COM-002-4

Operating Instructions

and Operating

Personnel

May 16, 2019

William Fletcher

Senior Compliance Auditor

Agenda COM-002-4

▪ Time line / Review: FERC Order 808 Review of Standard’s

Purpose language

▪ Drafting Team Rationale

▪ NERC Glossary: Operating Instruction (OI)

▪ Audit Approach: operating personnel in context of NERC

Glossary usage within term for Operating Instruction

▪ Notes From the Field

▪ Violation History: COM-002-4

▪ Useful resources

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FERC Order 808

▪ April 15, 2015 / Enforceable: July 1, 20161

▪ Replaced COM-002-3

▪ Expanded, detailed Purpose vs COM-002-3:

“To improve communications for the issuance of

Operating Instructions with predefined

communications protocols to reduce the possibility of

miscommunication that could lead to action or

inaction harmful to the reliability of the Bulk Electric

System (BES).”1 Reference: FERC Order 808

FERC Order 808 – (2)

“… Reliability Standard COM-001-2 is intended to establish a clear set

of requirements for the communications capabilities that applicable

functional entities must have in place and maintain. Reliability

Standard COM-002-4 requires applicable entities to develop

communication protocols with certain minimum requirements,

including use of three-part communication when issuing Operating

Instructions.2 Reliability Standard COM-002-4 also sets out certain

communications training requirements for all issuers and recipients of

Operating Instructions, and establishes a flexible enforcement approach

for failure to use three-part communication during non-emergencies

and a “zero tolerance,” i.e., without exception, enforcement approach

for failure to use three-part communication during an emergency.”3

2 See Communications Reliability Standards, Order No. 808, 151 FERC ¶ 61,039, at P 23 Id. at 2 n.3

SDT Rationale COM-002-4

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Source: Project 2007-02 Rationale and Technical Justification

Operating Instruction

▪ NERC Glossary Term added Per Order 808

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Source: NERC Glossary

Operating Instruction

▪ COM-002-4: Discussion: Requirement phrase: “… oral two-

party, person-to-person Operating Instruction …”

• R2: Requirement does not contain the phrase “oral two-party, person to

person Operating Instruction,” but does reference R1 protocols.

• R3: Restricted to: “oral two-party, person to person Operating

instruction.”

• R5, R6: Restricted to issuers and receivers of “… oral two-party, person-to-

person Operating Instructions during an Emergency, excluding written or oral

single party to multiple-party burst Operating Instructions …”

• R7: Covers: issuers of oral and written burst Operating Instructions (not

common).

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Source: NERC Standard COM-002-4

NERC Glossary Terms

▪ Bulk Electric System: 07/01/2014

▪ Emergency or BES Emergency: 03/16/2007

▪ Element: 07/01/2016

▪ Facility: 3/16/2007

Element: “Any electrical device with terminals that may be connected to other electrical devices such as a generator, transformer, circuit breaker, bus section, or transmission line. An Element may be comprised of one or more components.”

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Source: NERC Glossary

Audit Approach: Operating Personnel

▪ Context—as used in Glossary term:

• Issuers and receivers of Operating Instruction(s)

• Referenced in FERC Order 808:

“… all issuers and recipients of Operating Instructions …”1

• Includes: System Operators in Control Centers

• Includes: (field) personnel acting upon:

“… a command involving the Real-time operation of the

interconnected Bulk Electric System to change or preserve the state,

status, output, or input of an Element of the Bulk Electric System or

Facility of the Bulk Electric System …” (Operating Instruction)

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1 See Communications Reliability Standards, Order No. 808, 151 FERC ¶ 61,039, at P 2

Audit Approach R1

✓ Are protocols included for issuers and receivers?

✓ System Operators (BA, TOP) receiving OIs? (yes)

• Think: Reliability Coordinator

✓ Does protocol document embrace the NERC Glossary

term for OI or make a different definition?

✓ Does the protocol document reflect operating

personnel, inclusive of workers outside Control

Centers, who can respond and act on an OI issued

from a System Operator?

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Audit Approach R2

✓ Training records for issuers of OI prior to

issuing an OI?

✓ Operators under supervision documented?

✓ Operators on shift schedules not otherwise

documented are presumed to be able to issue

OIs and receive OIs.

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Audit Approach R3

▪ R3: Training in protocols required prior to receiving an OI.

▪ If previous (prior to July 1, 2016) training for OI-designated

personnel relied-upon (three part communications, etc.), do the ILAs for

that training meet the content within the defined protocols or the

requirement language in R3?

• This has been an issue.

▪ Can training be delayed, and provided to personnel immediately

prior to issuing the OI? Yes, but …

▪ All personnel who can receive an Operating Instruction are required

to have training prior to receiving an Operating Instruction.

▪ A word on attestations, referencing NERC CAN-0030.

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Audit Approach R5, R6

▪ R5: BA, RC, TOP (issuers of OIs) in an

Emergency

▪ R6: BA, DP, GOP and TOP (receivers of OIs)

▪ These are so-called “zero tolerance”1 conditions

▪ Issuer and recipient have to get it right

▪ Yes, compliance risks for R5 and R6 on a “per

Operating Instruction” basis

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1 Ref: FERC Order 808

R5, R6: Emergency

▪ Emergency or BES Emergency:

“Any abnormal system condition that requires

automatic or immediate manual action to prevent

or limit the failure of transmission facilities or

generation supply that could adversely affect the

reliability of the Bulk Electric System.”

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Source: NERC Glossary

R5, R6: Observations

▪ R5, R6: Controls we’ve observed:

• Prompt (R4 type) assessment of Emergency OIs

after the fact (a sampling criterion)

• Issuer informs recipient of Emergency condition

• Additional documentation (logs, other notes)

• Prompt self-reporting for PNC associated with OIs

issued in an Emergency

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Notes From The Field

▪ Voluntary vs. involuntary compliance

▪ BES Emergency vs. non-BES Emergency

▪ COM-002-4 vs. TOP-001-4 R1

▪ COM-002-4 vs. IRO-001-4 R1

▪ COM-002-4 vs. IRO-001-4 R2

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COM-002-4 Violations

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Useful Resources

▪ NE Blackout Report (Rec. #26, p. 161)

▪ Order 693, paragraphs 531-540 (pp. 157–160)

▪ Project 2007-02 FAQ (COM-002-4)

▪ Peak RC Communication Protocol Procedure

• Public Document cited with permission

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Contact:

William “Bill” Fletcher

Sr. Compliance Auditor

bfletcher@wecc.org

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