DECEMBER 2020
“Adopt the pace of nature: her secret is patience.”
- Ralph Waldo Emerson
MIDWEST RELIABILITY MATTERS Inside This Issue CEO MESSAGE
3 CEO Message
5 External Affairs
6 Compliance Monitoring and Enforcement Program
9 Registration, Certification and Standards
12 Bulk Power System Reliability
16 Volunteer Recognition Program
18 Security Corner
21 Operational Update
22 Industry News and Events Midwest Reliability Matters - December 2020
CEO MESSAGE
A Closing Letter Resiliency in the face of Adversity
As I write this end of year letter, I trust that you are healthy and safe wherever you are at the moment. This has been a challenging year for us all, both professionally and personally, and my thoughts and well wishes go out to anyone that has been affected by the COVID-19 pandemic.
This year has been one of continuing uncertainty as our Nation and communities grapple with the effects of a global health crisis. Added to the challenges presented by the pandemic were a number of severe weather events that tested the resiliency of the bulk power system and necessitated deployment of mutual assistance networks across North America. Amidst these challenges, and throughout mandatory government shutdowns, corporate safety restrictions, and a paramount shift to remote work, the critical functions of our industry continued with very little interruption. I am incredibly grateful for the hard work and efforts of our industry partners throughout this turbulent time!
Also in 2020, racial discrimination confronted us head on with the tragic death of George Floyd in Minneapolis. For MRO, this was in our neighborhood—at many of our doorsteps—adding to the stress and anxiety already experienced with the pandemic. This event called for us to condemn injustice and
3 CEO Message
discrimination and reaffirm our commitment to live by our values and continue to cultivate a workplace that makes equality, diversity, and openness priorities. MRO created a staff-led Diversity and Inclusion Committee to take an introspective look at the organization and identify areas of silent discrimination or intolerance. We remain deeply committed to this work.
At MRO, we kicked 2020 off with a renewed sense of optimism, having successfully integrated more than 100 registered entities into our regional work as a result of the dissolution of the SPP RE. In February, I spoke to staff about what our “new normal” might look like as we reached the end of this two-year journey. None of us could have imagined the remarkable events that would unfold. Instead of a new normal, we are now trying to assess and plan for the “novel normal” that will emerge post-pandemic.
Although the events of 2020 presented significant challenges, I am extremely proud of how MRO staff, the ERO Enterprise, our board and registered entities, and the entire reliability community have competently risen to the occasion with courage, curiosity, commitment…and resilience. Our ability to be flexible and adapt—to seamlessly shift course and chart new paths—has allowed us to thrive in the face of adversity.
Thank you again for your extraordinary efforts. We will continue to face challenges in the months ahead, but I’m confident that we will succeed, even under the most difficult circumstances. I look forward to a heathy 2021, and continuing to advance our mission and vision for the betterment of all those that depend on us.
Our future is bright!
- Sara Patrick, President and CEO
4 Midwest Reliability Matters - December 2020
EXTERNAL AFFAIRS
ERO Enterprise State Outreach Initiative
The ERO Enterprise operates in a complex and interconnected ecosystem, with regulatory oversight happening across North America at the provincial, federal, state and local levels. Developing relationships and sharing information on risks to reliability and security of the North American bulk power system across these regulatory agencies is critical to our success. Earlier this year, the ERO Enterprise began an initiative to increase awareness and share information with state regulators to inform these individuals of standards and publicly available reliability and security information, and enhance visibility within the states about ERO Enterprise work. A group was formed comprised of External Affairs staff from NERC and each of the six Regional Entities to coordinate a consistent approach and develop a strategy for executing this state outreach initiative.
Because MRO’s communication with state regulatory agencies has historically been limited to the annual meeting of the MidAmerican Regulatory Conference, which is comprised of most of the states in MRO’s footprint, we are taking a phased approach to implementing this initiative. As Director of External Affairs, I’ve been working over the past few months to compile contact information on each state regulatory agency in our region and develop materials introducing MRO and the ERO Enterprise. I’ve also been coordinating with bordering Regional Entities (ReliabilityFirst, SERC Reliability Corporation, and WECC) on communications with the states where our regional borders intersect.
In December, the ERO Enterprise External Affairs group will send a coordinated communication to all of the state regulatory agencies informing them of the release of NERC’s Long-Term Reliability Assessment (LTRA). The LTRA is a forward-looking annual assessment of the North American bulk power system that identifies trends, emerging issues, and potential risks over a ten-year horizon across North America. The purpose of sharing this information with state regulatory agencies is to provide details on how the electricity sector is undergoing significant change that is unprecedented in both its transformational nature and rapid pace, and how such an extraordinary evolution presents new challenges and opportunities for assuring reliability throughout this transition.
Although we do have existing relationships with some of the state commissioners in our footprint, I will be using the broader ERO Enterprise communication on the LTRA as a way of introducing MRO to the states where no relationship exists. The next phase of this initiative for MRO will be to follow up with each state regulatory agency in Q1 of 2021 to see what questions they might have on the information provided. Going forward, these relationships will be maintained through period outreach on important assessments and reports with the goal to become a trusted resource for information related bulk power system reliability and security.
This initiative is not a lobbying or advocacy effort and no confidential information will be shared with state regulatory agencies. If you have questions on this initiative, please feel free to reach out to me at tasha. [email protected].
- Tasha Ward, Senior Counsel and Director of External Affairs
5 Compliance monitoring and enforcement program
COMPLIANCE MONITORING AND ENFORCEMENT PROGRAM
Compliance Program Management Going above and beyond standard requirements
MRO is committed to providing non-binding guidance to industry stakeholders on important industry topics. Subject Matter Experts (SMEs) from MRO’s organizational groups authored this article, and the views expressed herein are the SMEs and do not represent the opinions and views of MRO.
Starting with FERC Order 693, FERC stated in part, in paragraph 253:
The most critical element of a Reliability Standard is the Requirements. As NERC explains, “the Requirements within a standard define what an entity must do to be compliant . . . [and] binds an entity to certain obligations of performance under section 215 of the FPA.”
This statement is the basis for all registered entities to follow and to reasonably assure that they remain compliant, thus supporting the reliability and security of the bulk power system.
Many Reliability Standards instruct entities to review or update information within a certain prescribed time frame. We are all familiar with words such as every 35 days, annual, every 15 calendar months, every 12 years, and so on. The evidence required for these types of standards is very straightforward to interpret and understand. In these cases, the nature of the requirements themselves create an environment where staff is kept current and practiced
6 Midwest Reliability Matters - December 2020
on processes.
However, there are some standards that do not have a reoccurring, prescribed timeframe within which to perform the prescribed action. For example, COM-002-4 - Operating Personnel Communications Protocols. Requirement 2 of this standard requires a Balancing Authority, Transmission Operator, and Reliability Coordinator to provide initial training for its operating personnel on documented communication protocols developed per Requirement 1. An entity will have to determine if this “initial” training is enough for their operating personnel for the course of their career. But what happens when the Operating Protocols don’t change for several years? Requirement 4 is an element of the standard where you assess the effectiveness of your communication protocols and modify, as necessary. Retraining and reiterating your initial training curriculum will remind the System Operators of their requirements to utilize three-part communications during daily operations.
Now the question will be, how often should you retrain? You will need to determine this based on the risks associated with having to use three-part communications for your System Operators. Some entities use three- part communication daily, where other smaller entities may infrequently use three-part communications. In either case, entities should consider staff’s typical participation in those protocols when determining at what interval retraining is required. Entities may want to train annually on their Operating Protocols to assure that three-part communication is used when needed. As an added incentive, if the entity is a Continuing Education Hour (CEH) provider, this could count towards a System Operators re-certification.
Entities are now being asked during audits and self-certifications to explain their internal controls to support the adherence to applicable standards. This is where you can “tell your story” that you are proactively reducing your future risk of noncompliance by going above the initial training requirement of COM-002-4. You and your System Operators can only benefit from this retraining.
This risk reduction can be applied to any standard where a periodicity of reoccurrence is not stated, or you want to reiterate to your staff their responsibilities. In PER-005-2, R3 requires training on company-specific tasks, at least once. PER-006-1, R1 states to provide training where you will need to determine if retraining is required to mitigate any risk. A reoccurring training program may be in your best interest for both standards to ensure that applicable staff remain proficient in their responsibilities.
In all cases where a standard lists a “one and done” action, you should be able to justify why you choose not to update a process within your compliance program. Yes, this is beyond the scope of what the requirement states, but it will allow you to have documentation for your justification on why or when you will review something after a certain period. This could be written within your program document or be part of a systematic review within your internal controls. Every entity can perform a systematic review of evidence to ensure that it is meeting the intended compliance objective, that it is effective, and that it is updated as required, based on current conditions.
- Joe DePoorter, Director of NERC Compliance and Generation Operations with Madison Gas and Electric and MRO CMEPAC Member
M R O ’ s A n n u a l S e l f - C e r t i fi c a t i o n S c h e d u l e N o w A v a i l a b l e The Q1 2021 through Q1 2022 Self-Certification schedule is now available on MRO’s website. Please note that MRO does not issue self-certifications based solely upon applicable reliability functions, but also based upon risk. If you believe your entity should have received a self-certification, but you did not receive a notification at the first of the quarter, please reach out to me directly [email protected].
7 Compliance monitoring and enforcement program
Align and SEL Update
The go live date for Release 1 of the Align project is March 31, 2021, for MRO and its registered entities! All training materials, including the training videos that were previewed during the regional adoption workshops and the registered entity testing exercise, are now available on the NERC Training Site.
The Regional Entities and NERC attended a Train the Trainer Session at the end of October. MRO will be releasing training dates for staff and registered entities in the near future. MRO’s Release 1 trainers will be Michael Spangenberg and Ryan McNamara.
For more information on the ERO Secure Evidence Lockers (SEL), visit the “Secure Evidence Locker Functionality” section on the Align FAQs page. The Regions and NERC will begin user acceptance testing for the SEL in December. The Align team recently hosted an ERO Enterprise stakeholder webinar on November 30, 2020. If you were not able to attend the webinar a recording of the webinar and the slide deck are available. Please inform an MRO Change Agent by January 1, 2021, if your entity plans to build its own SEL.
The build on Release 2 functionality has begun. As you may recall, Release 2 includes Periodic Data Submittals, Self-Certifications, and Technical Feasibility Exceptions. Release 2 is on schedule for user acceptance testing to begin in Quarter 1 of 2021.
- Desirée Sawyer and Marissa Falco, MRO Align Change Agents
8 Midwest Reliability Matters - December 2020
REGISTRATION, CERTIFICATION AND STANDARDS
Standards Alignment with Registration
On October 30, 2020, the Federal Energy Regulatory Commission (FERC) issued its Letter Order approving revisions to Reliability Standards associated with the Standards Alignment with Registration project. The focus of this project was to remove the references to Purchasing-Selling Entities and Interchange Authorities. References to Load-Serving Entity were also either removed or replaced by the appropriate NERC registered entity. The project included adding Underfrequency Load Shedding (UFLS)-only Distribution Providers to the Applicability Section of PRC-005 and PRC-006, per NERC registration criteria. In addition, revisions to the Reliability Standards replaced the term Planning Authority function with Planning Coordinator, for consistency across all of the Reliability Standards.
These changes were in response to FERC’s approval of NERC’s Risk based Registration Initiative on March 19, 2015. No substantive revisions were made to the proposed Reliability Standards’ underlying requirements.
The following NERC Reliability Standards were modified:
• FAC-002-3 (Facility Interconnection Studies) • IRO-010-3 (Reliability Coordinator Data Specification and Collection) • MOD-031-3 (Demand and Energy Data) • MOD-033-2 (Steady-State and Dynamic System Model Validation)
9 Registration, Certification and Standards
• NUC-001-4 (Nuclear Plant Interface Coordination) • PRC-006-4 (Automatic Underfrequency Load Shedding) • TOP-003-4 (Operational Reliability Data).
The effective date of the revised standards is April 1, 2021. Visit the NERC One-Stop-Shop for all FERC-approved Reliability Standards.
- Russ Mountjoy, Manager Registration, Certification and Standards
FERC Issues Order 873
On September 17, 2020, FERC approved via FERC Order 873, the retirement of 18 of 76 requirements identified during the Standards Efficiency Review (SER). FERC remanded one standard with two requirements back to NERC for future revisions to one of the requirements. FERC did not take a position on the remaining 56 requirements referred to as the MOD A requirements.
The overall SER project scope was to evaluate NERC Reliability Standards using a risk-based approach to identify potential efficiencies through retirement or modification of Reliability Standard Requirements. Considering that many Reliability Standards have been mandatory and enforceable for over 10 years in North America, this project sought to identify potential requirements that are not essential for reliability, could be simplified or consolidated, and could thereby reduce regulatory obligations or compliance burden.
Through Order 873, FERC approved the retirement of the following Reliability Standards in entirety: FAC-013- 2 (Assessment of Transfer Capability for the Near-term Transmission Planning Horizon); INT-004-3.1 (Dynamic Transfers); INT-010-2.1 (Interchange Initiation and Modification for Reliability); and MOD-020-0 (Providing Interruptible Demands and Direct Control Load Management Data to System Operations and Reliability Coordinators). The retirement date of these standards and requirements will be December 14, 2020. It is recommended that all prior evidence is archived and maintained per the data retention policies of each respective standard.
The following list of modified Reliability Standards was also approved as part of FERC Order 873: INT-006-5 (Evaluation of Interchange Transactions); INT-009-3 (Implementation of Interchange); PRC-004-6 (Protection System Misoperation Identification and Correction); IRO-002-7 (Reliability Coordination—Monitoring andAnalysis); and TOP-001-5 (Transmission Operations). The effective date of these modified standards is April, 1, 2021.
Although FERC supported the retirement of FAC-008-3 (Facility Ratings), requirement R7, FERC did not support the retirement of Requirement 8. FERC commented, “By retiring sub-requirements R8.1.2 and 8.2, transmission owners will no longer be required to communicate ratings information for solely owned limiting and next most limiting equipment present on jointly-owned facilities. Without ratings information on limiting and next most limiting equipment, transmission owners could lack the necessary information to correctly calculate the ratings for their jointly-owned facilities.” The entire standard is therefore remanded back to NERC for further consideration.
No action was taken by FERC regarding the 56 MOD A requirements due to concurrent activities to transfer the responsibility of these requirements to the North American Energy Standards Board (NAESB), which is underway. Comments to the Notice of Proposed Rule Making issued to NAESB were due November 3, 2020, after which FERC will determine the appropriate actions regarding the following MOD A Reliability Standards: MOD-001-1a (Available
10 Midwest Reliability Matters - December 2020
Transmission System Capability); MOD-004-1 (Capacity Benefit Margin); MOD-008-1 (Transmission Reliability Margin Calculation Methodology); MOD-028-2 (Area Interchange Methodology); MOD-029-2a (Rated System Path Methodology); and MOD-030-3 (Flowgate Methodology).
Phase II of the SER is currently underway with a focus on CIP Reliability Standards. The CIP Standards Efficiency Review Team is currently analyzing industry feedback to determine appropriate CIP Standard Requirements to be included in the efficiency review.
Visit the NERC One-Stop-Shop for all FERC-approved Reliability Standards.
- Russ Mountjoy, Manager Registration, Certification and Standards
Blackstart Resource Identification in EOP-005-3
A recent review of NERC Reliability Standard EOP-005-3 has led MRO to take a new approach to understanding the criteria that should be applied to the capabilities of Blackstart Resources.
EOP-005 first became effective in 2007 as version 1, requiring Transmission Operators to establish restoration plans and ensure that appropriate resources are available to carry out those plans. Subsequent versions of the standard have made refinements to the definitions of terms, including the introduction of the defined term “Blackstart Resources.” Throughout the history of EOP-005, however, utilities have adopted differing interpretations of the standard’s criteria for Blackstart Resource capability. Some entities have understood the criteria to be satisfied by a small diesel unit that is co-located with a larger combustion turbine generator and is able to energize station service loads necessary to start the larger unit without support from the grid. Historically, MRO has asserted that the diesel units do not meet the intent of EOP-005 and that the larger co-located generator is the appropriate unit to be identified as a Blackstart Resource.
EOP-005-3 R1.4 requires the identification of Blackstart Resources (the location, megawatt/var capacity, and type of unit). This is the requirement that MRO has considered to be at issue when small diesel units are identified as Blackstart Resources, however, neither this requirement nor the corresponding definition of Blackstart Resource include criteria for the capability of the identified units. Instead, this criteria is provided by EOP-005-3 R6.1, which states that the entity is expected to verify “The capability of Blackstart Resources to meet the Real and Reactive Power requirements of the Cranking Paths and the dynamic capability to supply initial Loads” every five years.The NERC definition of the term Load, “an end-use device or customer that receives power from the electric system,” does not support the identification of resources that are limited to energizing station service loads for adjacent generating units.
It is the entity’s obligation to provide reasonable assurance that the identified Blackstart Resources are able to meet the criteria in R6.1 and perform as required by the System Restoration Plan. Failure to provide this assurance is mitigated through a revision to the System Restoration Plan such that a different unit, which has the capabilities required by R6.1, is identified as the Blackstart Resource in accordance with EOP-005-3 R1.4.
- Adam Flink, PE, Sr. Risk Assessment and Mitigation Engineer, and Rumyana Kreidler, PE, PMP, Sr. Risk Assessment and Mitigation Engineer
11 Bulk Power System Reliability
BULK POWER SYSTEM RELIABILITY
Analyzing System Events Supporting a reliable bulk power system
Event analysis is a critical process for supporting the ERO’s goal of promoting the reliability of the bulk power system in North America. Analyzing bulk power system disturbances, determining the causes of those disturbances, and evaluating the potential for lessons learned to be shared with the industry are the primary goals for MRO in performing event analysis. Successful event analysis is, therefore, reliant on the willingness of MRO’s registered entities to share information regarding bulk power system disturbances that occur on their systems and to participate in the voluntary Event Analysis Process (EAP).
With the dissolution of the Southwest Power Pool Regional Entity (SPP RE) and the transfer of more than 100 of its registered entities to MRO in 2018, MRO inherited a number of open events waiting to go through the EAP. Coupled with MRO’s own significant number of open events, a backlog was created that at one point stretched back over two years and dozens of events! Reviewing events in a timely manner is critical to ensuring accurate analysis, as those with firsthand knowledge of the event may not remember crucial details the longer time goes by. Additionally, it is important to share any lessons learned that may come out of the EAP as quickly as possible to provide others the opportunity to learn from it and take action as necessary.
Recognizing these facts, MRO’s Reliability Assessment and Performance Analysis (RAPA) department focused its efforts on reducing the backlog of open events. While good progress was made in 2018 and 2019, a concerted effort was made this year to bring the average days of event analysis completion to within 4 to 6 months of an event
12 Midwest Reliability Matters - December 2020 occurrence. For example, if an event occurred in January of 2020 the analysis would be completed by June of 2020 at the latest. This allows adequate time for thorough analysis and follow up with any vendors if needed, and also is a reasonable window to develop a lessons learned.
Currently, MRO is on track to meet this goal. By the end of October, MRO had closed out a total of 58 events from 2020 alone! Of those events:
• 19 were Category 0 (events that do not meet the criteria of other categories) • 21 were Category 1a (an unexpected outage, that is contrary to design, of three or more BES Facilities caused by a common disturbance) • 15 were Category 1h (relating to the loss of monitoring or control at a control center such that it significantly affects the entity’s ability to make operating decisions for 30 continuous minutes or more) • 1 was a Category 2c (BES Emergency resulting in a voltage deviation of ≥ 10% difference of nominal voltage sustained for ≥ 15 continuous minutes) • 2 were Category 2f (Unintended loss of 300 MW or more of firm load for more than 15 minutes) • 4 events produced lessons learned, which can be found on NERC’s Lessons Learned webpage.
More information on all the categories and the steps involved in the ERO EA Process can be found in the ERO Event Analysis Process document.
As can be seen, MRO had an extremely productive year when it comes to analyzing system events. This work would not have been possible without the help and participation of our registered entities. The expertise MRO’s entities have provided when analyzing events has been invaluable, and their willingness to share information and contribute to lessons learned has been astounding. For that, on behalf of MRO’s RAPA department, I say thank you.
Tips and Suggestions
Below are list of tips and suggestions MRO recommends when submitting events for analysis through the EAP:
• Provide as much information as you can! The more information MRO has to analyze an event, the better we are able to determine accurate and appropriate cause codes. Also, the more information MRO has, the fewer follow-up questions we are likely to ask. • Try to determine the root cause of the event, which may be different from the apparent cause! For example, the apparent cause of an event may be that a breaker failed to operate because the breaker failure relay was left in test mode. The root cause of the event, however, may be determined to be that the relay was left in test mode because the technician who last maintained the relay failed to correct the relay settings because the new checklist his/her company had just rolled out omitted that step and that the checklist had not been vetted. MRO recommends to its entities that those involved in event analysis attend NERC’s period training on Root Cause Analysis. • Look for lessons learned! If there is something about an event that you feel would be good to share with the industry that could prevent a similar event from occurring, let MRO know. Keep in mind these can come from near miss events or category 0 events. • Reach out to MRO if you have questions! MRO is here to help and if you are having trouble determining the cause of an event, please don’t hesitate to reach out to us.
- Jake Bernhagen, PE, Senior System Protection Engineer
13 Bulk Power System Reliability
2020 Virtual ERAG Workshop
The Eastern Interconnection Reliability Assessment Group (ERAG) held its 2020 Workshop virtually on October 27, 2020. The theme of the workshop, which attracted approximately 205 participants, centered on risks associated with the protection and control systems that might impact the reliability and security of the bulk power system. ERAG Chairman Gaurav Karandikar opened the workshop with a welcome and overview of ERAG’s responsibilities to preserve and enhance bulk power system reliability in the Eastern Interconnection. ERAG is made of the following four Regional Entities within the Eastern Interconnection: ReliabilityFirst (RF), Midwest Reliability Organization (MRO), Northeast Power Coordinating Council (NPCC), and SERC Reliability Corporation (SERC).
Bryan Clark, Director Reliability Assessment and Performance Analysis for MRO, served as the conference emcee and introduced the first panelist speaker, Rich Bauer, Associate Director Reliability Risk Management/Event Analysis with NERC. Bauer’s presentation began by referencing multiple NERC disturbance reports, whitepapers, reliability guidelines and recommendations to improve modeling of inverter based resources. His presentation was followed by an introduction of the following panelist speakers: Sukumar Brahma (Dominion Energy Distinguished Professor, Clemson University), Ritwik Chowdhury (Engineer, R&D, Schweitzer Engineering Laboratories), and Manish Patel (Chief Engineer, Southern Company), who focused on risks and challenges associated with transmission planning and power system modeling with high penetration of inverter based resources. The discussion also highlighted some of the improvements to wind turbines for use in short circuit models in transmission planning with software such as CAPE, ASPEN, and ETAP, as well as updates to the IEEE P2800 standard.
Tony Solic (Manager, Reliability Compliance) and Matt Vacha (Manager, Transmission Protection) with FirstEnergy, presented the challenges of addressing misoperations and how FirstEnergy established a process to identify, resolve, and prevent misoperations that ultimately led to a successful reduction in misoperation rates in FirstEnergy’s system.
Bryan Gwyn, Senior Director of Solutions with Doble Engineering, reviewed the new technologies that are making an impact in protection and control systems. Gwyn focused on five areas where new technologies are having an affect on bulk power system reliability, which are advancements and new methodologies, renewables, communications and substation networks, testing, and cyber security, and highlighted some possible solutions.
Mark Kuras, Senior Lead Engineer with PJM, provided a review of the activities of PJM’s Relay Subcommittee related to NERC Reliability Standards PRC-001 and PRC-027. His presentation began by referencing PJM’s PRC-001 coordination requirements and expectation of its members. Kuras further discussed how PJM developed reliability guidelines for PRC-027 coordination and the processes for PJM members.
14 Midwest Reliability Matters - December 2020
Lee Underwood, Director of Practices with North American Transmission Forum (NATF), presented NATF’s role and responsibility related to system protection for its members. Underwood further described the system protection training, practices, tools and misoperation data collection that produce metrics for NATF and its members to use to assess specific causes of misoperations.
Jack Norris, Engineer II with NERC, gave an overview of NERC’s misoperation metrics and the importance of collecting misoperation information. Norris further highlighted the year over year changes and trends for each of the ERO Regional Entities, misoperation causes, and explained how misoperation metrics are calculated.
Mike Bocovich, Principal Systems Protection Engineer with MRO, reviewed the consistent reporting of misoperation data through a standardized template to assess protection system performance analysis, and how the consistent and accurate misoperation data can provide meaningful metrics to identify trends that negatively impact reliability.
Michael Lombardi, Director of Reliability Assessments, and Neeraj Lal, Senior Reliability Assessment and Performance Analysis Engineer with NPCC, closed out the conference with remarks about the workshop, ERAG’s role, and entertained possible topics of interest for next year’s workshop.
The conference received extremely high reviews from those who attended, and we hope you consider participating in next year’s event. Videos of the virtual ERAG Workshop presentations are available here. The individual presentations and full agenda packet are available on MRO’s website.
For more information or suggestions on future ERAG workshop topics, please contact Salva Andiappan, Principal Reliability Assessment Engineer.
- Salva Andiappan, Principal Reliability Assessment Engineer
Employee Spotlight
Please join us in weloming the following individuals to the MRO Team:
MIchelle Olsen joined MRO in 2019 as a temporary employee assisting the HR Department. In Novem- ber this year, Michelle accepted a position as Compliance Monitoring Administrator, supporting various aspects of MRO’s Compliance Monitoring work. We are excited to have Michelle as a full-time, perma- nent member of the MRO team!
Open Positions:
MRO is hiring! Watch our Why Work For MRO video to learn more about us.
• Senior Power System Engineer (Compliance Monitoring Department, O&P Auditor) • Risk Assessment and Mitigation Administrator
To apply, visit the Careers Page on our website or visit us on LinkedIn.
15 Volunteer Recognition Program
VOLUNTEER RECOGNITION PROGRAM
MRO’s SPS Working Group Retires A look at the work of these important volunteers
With the looming retirement of MRO’s Special Protection System Working Group (SPSWG), which is effective at the end of this year, MRO staff would like to take a moment to reflect back on the rich history of this group and the outstanding technical work it performed.
At the start of mandatory compliance in June of 2007, there were a handful of NERC Reliability Standards that were applicable to the Regional Entities (Regions) Regions. Although the Regions were regulators at that point, and not registered entities subject to mandatory compliance, they were identified as the responsible entity for certain standards that would help bridge the way and assure a smooth transition to the functional model. These were referred to as fill-in-the-blank standards, since they were temporary in nature and would ultimately be revised to be applicable to the registered entities. These fill-in-the-blank standards fell mainly into the planning, modeling, and system protection sets of standards.
Three of the fill-in-the-blank standards, PRC-012, PRC-013, and PRC-014, involved the review and coordination of special protection systems (SPSs) (referred to today as Remedial Action Schemes, or RAS). These three standards required the regional entity to review new and modified SPSs, review existing SPSs every five years to assure they were still effective and coordinated with any other SPSs in the area, and lastly to maintain an SPS database as a repository for SPSs for the whole region.
In 2007, MRO needed to formalize a policy and procedure and establish a working group for reviewing RASs to assure they met the requirements within these PRC standards. Because American Transmission Company (ATC) was registered in both the MRO and ReliabilityFirst regional footprints, its SPS reviews would be under
16 Midwest Reliability Matters - December 2020 the purview of either MRO or RF, depending on the location. ATC was one of the first multi-regional registered entities, which led MRO and RF to work together to form a common policy and procedure for SPS reviews that would be relatively seamless for ATC.
Both Regions quickly populated an SPS working group that would consist of highly experienced planners and system protection engineers. Both Regions created a procedure that laid out timing requirements and a checklist of materials that would be submitted to the working group to assure a thorough and efficient review, and to assure the SPS would meet the requirements of the PRC standards. This coordinated effort turned out to be very successful and served both Regions very well for the next 13 years.
At the time the MRO SPSWG was being formed, there were about 35 existing SPSs in the MRO footprint. At that time, the SPS count was growing because a number of wind plants were coming on line that would often install an SPS to help maximize energy output while still maintaining reliability. Several of these wind plant SPSs were temporary in nature and would eventually be retired once a transmission reinforcement was completed.
However, the MRO region also has several very sophisticated stability-related SPSs that are permanent in nature. These SPSs are reviewed on a five year cycle to assure effectiveness as the bulk power system evolves, and to assure they continue to coordinate with any other emerging SPSs. These five-year reviews were particularly important because the generation profile and system powerflows were rapidly changing. The RTO markets were now economically dispatching generation across their footprints, wind generation was being installed at the rate of 2,000 MW per year, and a transmission initiative called CAPX 2020 was launched, which resulted in 800 miles of EHV transmission being built at a cost of $2 billion.
Over the 13 years that the SPSWG existed, there were a number of system planners and system protection engineers that served on the group. This independent evaluation of SPSs helped the MRO region maintain a very high level of reliability as witnessed by the ERO Event Analysis Process : No Category 3, 4, or 5 events within the MRO region in the past 13 years.
We’ve come a long way together and MRO staff would like to sincerely thank each and every member of the SPSWG that has shared their expertise and time on this working group. The present members are:
• Dave Kempf, GRE (Chair) • Ding Lin, MHEB • John Grimm, XCEL • Gabriel Kainz, OTP • Wayne Guttormson, SPC • Andrew Berg, MRES
The above individuals were recognized with a plaque pursuant to MRO’s Volunteer Recognition Program. Dave Kempf, Ding Lin, and Wayne Guttormson also recieved awards given the length of time served. (Lin and Guttormson both served more than 12 years, receiving the highest honor!)
With the retirement of the fill-in the blank standards now complete, the SPS reviews will now be performed by the Planning Coordinators and Reliability Coordinators within MRO. These registered entities have adopted stakeholder-based working groups as well to perform the SPS reviews within their areas. MRO believes this will provide the Midwest region of North America with many more years of bulk power system reliability and security.
- John Seidel, Principal Technical Advisor
17 Security Corner
SECURITY CORNER
2020 MRO Security Conference - A Virtual Success!
The MRO Security Advisory Council (SAC) hosted a virtual 2020 Security Conference on October 7, 2020. The conference was designed to expand security awareness and strengthen cyber and physical security through information shared by experts within the security industry, as well as provide clarity on real world security lessons learned and best practices. This conference was the highest attended MRO Security Confer- ence to date, with a record number of over 400 participants.
Fourteen speakers provided attendees with information on topics that enable organizations to build and enhance effective security programs. Added for the first time this year were six SAC ‘Ask Me Anything’ ses- sions. These Ask Me Anything sessions allowed more in depth engagement between speakers and confer- ence attendees, and provided an additional forum for asking questions and having discussions that might not have been possible otherwise.
MRO Director of Security and SAC liaison Steen Fjalstad kicked off the conference with the MRO Welcome address and provided a brief review of the history and how the MRO Security Conference got its start. Then SAC Chair Jason Nations, Senior Manager of Enterprise Security at Oklahoma Gas and Electric, provided
18 Midwest Reliability Matters - December 2020 opening remarks and an update on MRO SAC activities. Nations also served as the conference emcee for the day.
Sara Patrick, MRO President and Chief Executive Officer, provided an executive perspective on security and how the five principles of High Reliability Organizations (HROs) support a strong security culture. She also discussed the four phases of the pandemic and what the future might look like for MRO and our industry. Patrick’s presentation was followed by Paul Calatayud, Chief Security Officer at Palo Alto Networks, who provided an exploration of the impact the COVID-19 pandemic has had within Palo Alto Networks and how it is seeing its customers adapt, along with lessons learned on how best to protect in this new normal.
Brett Lawler, Senior Threat Intelligence Analyst at Xcel Energy, covered the rising threat of extremist groups and the extremist group activity that is being seen today, and Scott Aaronson, Vice President, Security and Preparedness at Edison Electric Institute (EEI), provided information on threats to the nation’s most critical infrastructures from natural hazards and sophisticated adversaries. Aaronson discussed the pandemic and how the government and industry are working together to address related challenges.
Manny Cancel, NERC Senior Vice President and Chief Executive Officer at the Electricity Information Shar- ing and Analysis Center (E-ISAC), discussed the E-ISAC’s focus areas and objectives, as well as COVID-19 operations. The E-ISAC has actively been tracking COVID-19 since February of 2020, and recently has been providing daily COVID-19 awareness reporting and threat intelligence.
Andrew Bochman, Senior Grid Strategist with National and Homeland Security Idaho National Lab, discussed the origins of Consequence-driven Cyber informed Engineering (CCE) and provided a brief update on the four phases. He also provided his insights on compliance and cyber hygiene approaches for critical infra- structure.
Matt McQuin, Supervisor, physical Security at Evergy, provided a demonstration of his organization’s security video program. He discussed how his organization uses the data collected to support other business units within the organization and maintain security awareness.
Matt Wyckhouse, CEO of Finite State, provided insight into the conventional model for assessing product risk. He explained the roots of using third-party vendor risk assessments that assess product security and the challenges behind it. Lastly, he discussed detecting supply chain vulnerabilities and the threats that are within the ICS devices.
Timothy Langan, Special Agent in Charge of the Federal Bureau of Investigation’s Kansas City Field Office, reviewed the FBI’s approach to mitigating risks posed by trusted insiders of organizations. He also discussed the FBI’s insider threat program.
Kyle Gustofson, Transmission UAS Program Manager at Great River Energy, provided insight on the use of Unmanned Aircraft Systems (UAS) within his organization. He provided information on how UAS can improve safety, save money and capture data.
Adam Worrall, Security Manager, American Electric Power (AEP), discussed his organizations drone gover- nance group, lessons learned, accomplishments and AEP’s goals for the future use of UASs.
MRO SAC Vice Chair, John Breckenridge from Evergy, closed out the conference with a recap of the day, again promoting the work of the MRO SAC. The conference received very positive feedback from attendees and left people wanting “More Cowbell!” We look forward to providing another successful Security Confer- ence in 2021, which is planned to be held in October.
- Steen Fjalstad, Director of Security
19 Security Corner
2020 Virtual Regional Security Risk Assessment
MRO’s 2020 Security Conference was followed by the Regional Security Risk Assessment, which was held virtually for the first time. This meeting was attended by MRO SAC Members and regional security partners to discuss security risks within the region. This year’s assessment incorporated a series of pre-assessment surveys targeted at operational, physical, and cyber security subject matter experts from across the region.
The meeting began with an update from the E-ISAC on risks to registered entities. Meeting participants then broke out into small group sessions based on entity size to discuss cyber security, physical security, and operational security risks that were identified from the preassessment surveys as most prominent risks within the MRO footprint.
The risk findings from this meeting were used as input to the MRO Regional Risk Assessment and by the MRO SAC to identify topics for future outreach and training deliverables.
To participate in next year’s assessment, please reach out to MRO Director of Security Steen Fjalstad at [email protected].
- Joe Petaski, Manitoba Hydro, MRO SAC Member
20 Midwest Reliability Matters - December 2020
OPERATIONAL UPDATE
Assessing Bulk Power System Risk
MRO works closely with NERC to publish lessons learned from system events within our region, and in 2020 four such lessons learned from MRO were posted. These four lessons learned are the most that MRO has ever generated in a single year and provide great value to industry in order to avoid future impactful events. The fourth lesson learned related to cold weather operation of gas circuit breakers and can be found here.
Adding further value to industry related to reliability observations from the region and to provide a forward looking estimate of emerging regional reliability issues, MRO issued its first ever Regional Winter Assessment in the fourth quarter of 2020. The purpose of the MRO Regional Winter Assessment is to assess the region’s performance over the previous winter, and to provide a preview of expected challenges for the upcoming winter. MRO plans to also publish an annual Regional Summer Assessment next year, with both of these as- sessments being new annual deliverables for the region and key inputs into the MRO’s Regional Risk Assess- ment (RRA). The RRA is a document that MRO staff, with input from industry subject matter experts, prepares annually to identify risks to the reliable and secure operations of the bulk power system within MRO’s regional footprint.
Much work has gone into development of the 2021 RRA this quarter, which for the first time uses MRO’s new Risk Matrix. Originally developed by MRO’s Reliability Advisory Council (and further refined by the Security and CMEP advisory councils with input from the Organizational Group Oversight Committee), the Risk Matrix helps to identify and prioritize regional risks. The 2021 RRA is planned for release early next year.
Please reach out to me at [email protected] with any input you’d like to provide about MRO’s assess- ments or our work to address regional risk. Stay safe everyone and have a wonderful holiday!
-Richard Burt, Senior Vice President and Chief Operating Officer 21 Industry News and Events
INDUSTRY NEWS AND EVENTS
LATEST NEWS: ty, Security and Resilience Landscape, As- sessment Finds Clements Sworn in as New FERC Commis- sioner The 2020 Long-Term Reliability Assessment finds sufficient resource adequacy across most of North Allison Clements was sworn in on December 8, America and highlights reliability, security and 2020, as the newest member of the FERC. Read resilience risk associated with the changing gen- the full announcement. eration resource mix. In all but two areas, there is Senate Votes to Confirm Christie, Clements sufficient capacity to meet the electricity demand to Commission over the next 10 years. Read the full announce- ment. On November 30, 2020, the United States Senate confirmed the nominations of Mark Christie and Robb Named Chair of United Nations Cleaner Allison Clements to join the Federal Energy Regu- Electricity Systems’ Group of Experts latory Commission, bringing the Commission to its full, five-member complement of Commissioners Jim Robb has been named chair of the Group of for the first time in nearly two years. Read the full Experts on Cleaner Electricity Systems (CES), announcement. which is part of the United Nations Economic Commission for Europe (UNECE). Read the full FERC Staff Presentation on Managing Trans- announcement. mission LIne Ratings E-ISAC Expands Key Cybersecurity Program View the FERC staff presentation from November 19 on the draft notice of proposed rulemaking (or NERC’s Electricity Information Sharing and Anal- NOPR) that would reform both the pro forma Open ysis Center (E‑ISAC) recently partnered with the Department of Energy (DOE) on an expansion of Access Transmission Tariff (or OATT) and the the Cybersecurity Risk Information Sharing Pro- Commission’s regulations to improve the accura- gram (CRISP) to include operational technology. cy and transparency of transmission line ratings. The CRISP expansion, to include two operation- Read the full announcement. al technology pilots, marks a major milestone to improve E-ISAC capabilities that strengthen grid FERC Staff Presents the 2020 Annual Report security in North America. Read the full announce- on Enforcement ment. On November 19, 2020, the Office of Enforcement Capacity Supply Adequate for Winter De- (OE) is releasing its fourteenth annual Report on mand; Extreme Weather, Fuel and Energy Enforcement. As in previous years, OE staff pre- Risks in New England and California are Top pared this report to provide information about OE’s Reliability Concerns activities over the last fiscal year. The Report discusses the activities performed by OE’s Divi- In its 2020–2021 Winter Reliability Assessment, sions of Investigations (DOI), Audits and Account- NERC finds sufficient resource capacity is in place ing (DAA), and Analytics and Surveillance (DAS) across North America to meet winter demand. during the last fiscal year. Read it here. Noting how extreme weather can challenge grid reliability in specific areas, the assessment closely Evolving Resource Mix is Changing Reliabili- examines this reliability risk and identifies higher
22 Midwest Reliability Matters - December 2020 risk areas that are susceptible to emergency oper- REGIONAL AND MRO EVENTS: ating actions. Audit Experience in a Virtual Environment MRO Board Chair, President and CEO Sum- Webinar marize the Annual Meeting in the Fourth December 17, 2020 │1:00 p.m. Central Quarter Letter to Members MRO’s CMEP Advisory Council is hosting a webi- MRO held its Annual Member and Board of Direc- nar on audits in a virtual environment. Audits are tors Meeting on December 3, 2020, by WebEx. an important tool for verifying status of compliance Board Chair Thomas (Tom) Kent and President performance, adequacy of internal controls, and and CEO Sara Patrick provided a personal letter best practice. Additionally, MRO is responsible for to MRO members and stakeholders highlighting monitoring compliance of the registered entities important discussions from the meeting. Read the within its regional boundaries at regular intervals Fourth Quarter Letter to Members. based on reliability risk. Figuring out how to meet these audit requirements amid travel restrictions, MRO Announces Recipients of Inaugural company safety protocols, and government man- HERO Award dated restrictions related to the COVID-19 pandem- ic presents a significant new challenge. Register At MRO;s Annual Member and Board Meeting here. on December 3, 2020, the board recognized the recipients of MRO’s Annual HERO Award. This Ask CMEPAC Monthly Call prestigious award provides MRO the opportunity to January 12, 2021 │3:00 p.m. Central│WebEx recognize individuals for their exemplary initiative and commitment to advancing the concept and The next “Ask CMEPAC” call is scheduled for principles of Highly Effective Reliability Organiza- January 12, 2021, by WebEx. Entities from the tions (HEROs) throughout the MRO region and in region are encouraged to attend this call to ask support of MROs vision and mission. Read the full questions on topics such as on topics such as the announcement. development, retirement, and application of NERC Reliability Standards, risk assessment, compliance MRO Releases 2020 Regional Winter Assess- monitoring, and the enforcement of applicable stan- ment dards. To register, see MRO’s Meeting Calendar. On December 1, 2020, Midwest Reliability Orga- Weekly NSRF Call nization released its first 2020 Regional Winter Assessment. The assessment identifies challeng- Wednesdays │9:00 a.m. Central│WebEx es and potential reliability risks to the reliable and secure operations of the bulk power system within Join MRO’s NERC Standards Review Forum MRO’s regional footprint for the upcoming winter (NSRF) each Wednesday on its weekly call to hear season. I Read the full announcement. information about new and revised Reliability Stan- dards. To register, see MRO’s Meeting Calendar. INDUSTRY EVENTS:
SAVE THE DATE: GridEx VI In addition to the above events, MRO’s NERC November 16-18, 2021 Standards Review Forum and Security Advisory Council Threat Forum continue to meet weekly. NERC’s Electricity Information Sharing and Analy- sis Center (E-ISAC) is planning the sixth biennial To see more MRO meetings and events, visit our grid security exercise (GridEx VI) for November website calendar. 16–18, 2021. Stay tuned to NERC’s website for future information.
23 Published By: MIDWEST RELIABILITY ORGANIZATION 380 St. Peter Street, Suite 800 Saint Paul, MN 55102 651-855-1760 www.mro.net