Compliance Open Webinar Wildfire Edition August 20, 2020 Travis - PowerPoint PPT Presentation

Compliance Open Webinar Wildfire Edition August 20, 2020 Travis English Training & Outreach Specialist

Pre-Meeting Statements ▪ All WECC meetings are conducted in accordance with the WECC Antitrust Policy and the NERC Antitrust Compliance Guidelines ▪ All participants must comply with the policy and guidelines ▪ This meeting is public — confidential or proprietary information should not be discussed in open session 3

Pre-Meeting Statements ▪ This webinar is being recorded and will be posted publicly ▪ By participating, you give your consent for your name, voice, image and likeness to be included in that recording ▪ WECC strives to ensure the information presented today is accurate and reflects the views of WECC ▪ However, all interpretations and positions are subject to change ▪ If you have any questions, please contact WECC’s legal counsel 4

Webinar Use ▪ You have been automatically muted on entry ▪ Questions will be answered at the end of the presentation. • Speak and raise your hand! • Use the Q&A feature 5

Agenda Reliability & Security Workshop and Internal Controls Practices Group ▪ • Steve Goodwill — Senior Vice President of Reliability and Security Oversight, General Counsel and Secretary The Align Project Transition Report ▪ • Michael Dalebout — Manager of Enforcement Operations Wildfire Risks and Internal Controls ▪ • Ari Barusch — Associate Enforcement Attorney • Sherri Palmer — Senior Internal Controls Specialist Vegetation Program Management o Equipment Inspection Program Management o Equipment Inventory Program Management o Alerts and Early Warnings Program Management o 6

Reliability & Security Workshop and Internal Controls Practices Group August 20, 2020 Steve Goodwill Senior Vice President of Reliability and Security Oversight, General Counsel and Secretary

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Reliability & Security Webinar — Tuesday, October 27 ▪ Digital learning opportunity ▪ Free registration for all stakeholders • Available at wecc.org ▪ Split into two sections: • Operations and Planning — morning sessions • Critical Infrastructure Protection — afternoon sessions 9

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Contact: Steve Goodwill Senior Vice President of Reliability and Security Oversight, General Counsel and Secretary sgoodwill@wecc.org 12

The Align Project: Transition Report August 20, 2020 Michael Dalebout Manager of Enforcement Operations

The Align Project 14

Contact: Michael Dalebout Manager of Enforcement Operations mdalebout@wecc.org 15

Wildfire Risks, and Internal Controls August 20, 2020 Ari Barusch Associate Enforcement Attorney Sherri Palmer Senior Internal Controls Specialist

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Welcome ▪ WECC encourages entities to take proactive wildfire risk mitigation actions ▪ WECC believes that effective development and execution of internal controls lowers the risk of wildfires ▪ WECC would like to work with you today and going forward on your internal controls journey 18

Forces Driving Change Why are internal Internal Emerging Inefficiencies Risks & controls important? & Increasing Delayed Compliance Compliance Violations Requirements Legacy Need For Equipment, Organizational Internal Lost Structure & Controls Expertise, & Behavior SME Turnover Third-Party NERC Contractor Maturing to Training & Risk-Based Monitoring Awareness Approach Needs 19

Risk & Internal Controls Relationship Identify Risk Control Assess 20

Managing Your Vegetation Management Program FAC-003-4 21

Understanding Risks — FAC-003-4 Using Potential Failure Points and Guidance Questions ▪ During your last vegetation inspection, did you consider encroachments from trees/plants beyond your right of way ? ▪ Do you have accurate and current records identifying where all your hazard trees are? ▪ Have you been working with federal agencies to ensure all shared responsibilities have been identified and you clearly understand your responsibilities? ▪ How do you ensure that vegetation management programs adapt to changing conditions (climate changes, wildfire historical data, use of new technology, etc.)? 22

Additional Risks Considerations Cooperating With Federal Agencies ▪ Do you have transmission lines or other equipment on federal land? ▪ Do you know what agency oversees that land? ▪ Are you checking in with the closest field office? ▪ Instructional Memorandum 2018-070 (Bureau of Land Management) ▪ Do you have transmission lines or other equipment on private land? 23

FAC-003-4 R1: Each applicable Transmission Owner and applicable Generator Owner shall manage vegetation to prevent encroachments into the Minimum Vegetation Clearance Distance (MVCD) of its applicable line(s), which are either an element of an IROL, or an element of a Major WECC Transfer Path; operating within their Rating and all Rated Electrical Operating Conditions of the types shown below: 24

Internal Control Recommendations Internal Controls — People, Process, and Technology Mitigation Strategies Climate Specialized Models Skills Internal Systems & Threshold Controls Controls Conditions Risk ROW Legal Forecasting Rights 25

Public Lands: 43 USC S. 1772 1. The term "hazard tree" means any tree or part 3. If vegetation or hazard trees have contacted or present an imminent danger of contacting an thereof (whether located inside or outside a right- electric transmission or distribution line from of-way) that has been designated, prior to tree within or adjacent to an electric transmission or failure, by a certified or licensed arborist or forester distribution right-of-way, the owner or operator of (A) dead, likely to die within the routine vegetation the electric transmission or distribution lines- management cycle, or likely to fail within the (1) may prune or remove the vegetation or hazard routine vegetation management cycle; and tree- (A) to avoid the disruption of electric service; (B) if the tree or part of the tree failed, likely to- and ▪ (i) cause substantial damage or disruption (B) to eliminate immediate fire and safety to a transmission or distribution facility; hazards; and or (2) shall notify the appropriate local agent of the Secretary concerned not later than 1 day after the ▪ (ii) come within 10 feet of an electric date of the response to emergency conditions. power line 26

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Managing Your Equipment Inspection Program FAC-501-WECC-2 28

Understanding Risks — FAC-501-WECC-2 Using Potential Failure Points and Guidance Questions ▪ How do you detect and remedy an incomplete inspection ? ▪ How do you ensure that all inspection test results requiring actions have been addressed? ▪ If an SME is not available for the scheduled inspection, how do you become aware of the potential constraints, and how do you plan for other SMEs with the required specialization to meet the needs of the inspection? 29

Understanding Risks — FAC-501-WECC-2, cont. Using Potential Failure Points and Guidance Questions ▪ Did you consider all upstream and downstream equipment , including monitoring equipment, within the Equipment Inspection Program? ▪ How do you ensure that ALL wildfire hazard equipment has been identified and formally documented? ▪ How do you ensure you have identified and included all equipment that could be at risk for overload and spark in your Equipment Inspection Program? 30

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FAC-501-WECC-2 ▪ R1: Each Transmission Owner shall have a Transmission Line Maintenance and Inspection Plan (TMIP) that includes, at a minimum, each of the items listed in Attachment A, Transmission Maintenance and Inspection Plan Content ▪ R2: Each Transmission Owner shall annually update its TMIP to reflect all changes to its TMIP ▪ R3: Each Transmission Owner shall adhere to its TMIP 32

Internal Control Recommendations Internal Controls — People, Process, and Technology Mitigation Strategies Proactive Specialized Hardening Skills the Grid Inspection QA Internal Tracking Checkpoints Systems & Controls in Process Controls Effective Cross Methods Training 33

Build an Equipment Baseline What to include in Equipment Baseline Documentation: • One-line diagrams • FAC-003-4 data • Base case data • SOL information • Physical inspection validation • Previous internal audits list of facilities • Attachment 2 of MOD-025 (generator testing) results 34

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Managing Your Equipment Inventory Program FAC-008-3 36