Ken Gartner, CMEP Process Principal November 28, 2017

Transcription

1 MIDWEST RELIABILITY ORGANIZATION 2018 MRO CMEP Implementation Plan Ken Gartner, CMEP Process Principal November 28, 2017 Improving RELIABILITY and mitigating RISKS to the Bulk Power System

2 2018 ERO CMEP Implementation Plan Single ERO-wide plan Uniform, region-specific appendices Format adopted in 2014, replaced individual plans Published in September, with Regional Appendices added in November Available on the NERC web site 2

3 2018 ERO CMEP Implementation Plan ERO-wide 2018 Implementation Plan Sections Significant CMEP Activities Program Alignment Process Compliance Guidance Process CIP focus on Remote Access Security Physical Security CIP Risk-Based Compliance Monitoring Coordinated Oversight of Multi-Region Registered Entities Compliance Assessments for Events and Disturbances 3

4 2018 ERO CMEP Implementation Plan ERO-wide 2018 Implementation Plan Sections Risk-Based Enforcement 2018 ERO Enterprise Risk Elements Regional Risk Assessments NERC Oversight of Regional Entity Compliance Monitoring Regional Appendices 4

5 2018 MRO Implementation Plan Appendix to the 2018 ERO CMEP Implementation Plan 2018 MRO Implementation Plan content within other Presentations today Compliance Oversight Plans (COPs) Regional Risk Assessment (RRA) 5

6 Compliance Audits 2018 Compliance Audit schedule Primarily based on COP results Addresses NERC Rules of Procedure (RoP) three-year RC, BA, TOP Compliance Audit requirement Can be found on MRO s website: MRO 2018 Compliance Audit Schedule.pdf 6

7 Spot Checks may be initiated at any time In response to an event As follow-up to a Self-Certification or a Periodic Data Submittal Based on commonly-identified issues at the regional or national level Spot Checks May be used instead of Compliance Audits, along with Self-Certifications, for entity-specific monitoring No planned Spot Checks in 2018 at this time 7

8 Periodic Data Submittals Based on schedule within the November posting of the ERO-wide 2018 Implementation Plan Standard Requirement(s) Submit To Submittal Frequency BAL R2 NERC Annually BAL R5 RE & NERC Per Std. Proposed Due Dates March 7 th of each year, per BAL Reliability Standard Attachment A's timeline 15 days after the end of the month (Report via the NERC Inadvertent Data Collection Monitoring Tool) EOP R2 NERC Per Std. Event Driven EOP R8 RE Per Std. Within six calendar months of the date when the functionality is lost FAC C.1.4 RE Quarterly 20 days after the end of the quarter PRC R12 RE Per Std. Within 90 calendar days of the discovery of a failure of the recording capability for the SER, FR or DDR data PRC R5 RE Annually At least once each calendar year, with no more than 15 months between reports PRC R6.2 RE Per Std. Within 30 calendar days of the establishment of the initial list and within 30 days of any changes to list 8

9 What to expect in 2018 Self-Certifications Guidance is given to registered entities as to the depth of scope, including whether the Self-Certification applies to the entire Standard, each Requirement, or each subrequirement. Sometimes this is referred to as a guided Self-Certification. Parameters are communicated to registered entities around the expected sufficiency of review performed on the items in scope. Specific evidence is identified that is required to be supplied to the Regional Entity to corroborate registered entity conclusions. 9

10 What to expect in 2018 Self-Certification scope based on results of COPs Self-Certification Process MRO reviews registered entity conclusions and provided supporting evidence MRO can rely upon the registered entity Self-Certification conclusions if able to obtain reasonable assurance that: The registered entity followed monitoring guidance supplied by MRO Evidence provided by the registered entity supports its Self-Certification conclusions 10

11 Self-Certification Frequency 2018 Quarterly Self-Certification Schedule Quarter Standard Requirement Q1 NUC R9 Q2 TOP R3, R6, R7 Q3 Q4 CIP MOD MOD MOD MOD MOD FAC FAC R1, R2, R3 R4 R1, R2, R3 R2 R2 R1, R2, R3, R4 R6, R7 R2 11

12 2018 Quarterly guided Self-Certification Schedule Self-Certification Frequency Three month notification period and three month response time for planned schedule Timeline October 1, 2017 January 1, 2018 April 1, 2018 July 1, 2018 October 1, 2018 January 1, 2019 Q1 Notification Response Q2 Notification Response Q3 Notification Response Q4 Notification Response 12

13 Questions? For questions, contact: 13