Chapter # — Chapter Title


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Table of Contents

Table of Contents

Purpose

Continuity Plan

Accountabilities/Responsibilities

NERC

Regional Entity (RE)

Certification Process

Certification Review Process

Related Documentation

Appendix I: Terms and Definitions

Rev 0 – TOP Certification of ITC Great Plains1

Purpose / Continuity Plan

Purpose

This ERO Certification Process Document serves two purposes.

First, it provides consistency in the implementation of an ERO-wide Certification process that will meet the requirements of the NERC Rules of Procedure (ROP) Section 500 and Appendix 5A.

Second, it provides transparency in the implementation of the Certification process in order that entities applying or registered for the Reliability Coordinator (RC), Balancing Authority (BA) and/or Transmission Operator (TOP) functions will gain a better understanding of what to expect as the process is executed.

Continuity Plan

The North American Electric Reliability Corporation’s (NERC) mission is to ensure the reliability of the North American bulk power system. NERC is the electric reliability organization (ERO) certified by the Federal Energy Regulatory Commission to establish and enforce reliability standards for the bulk power system. NERC develops and enforces reliability standards; assesses adequacy annually via a 10-year forecast, and summer and winter forecasts; monitors the bulk power system; and educates, trains and certifies industry personnel. ERO activities in Canada related to the reliability of the bulk power system are recognized and overseen by the appropriate governmental authorities in that country.

NERC has delegated to Regional Entities (RE)s, via regional delegation agreements (RDA)s[1], certain responsibilities for the conduct of ERO statutory functions.

In accordance with the NERC Rules of Procedure Section 500, subsection 3 Delegation and Oversight, NERC shall develop and maintain a plan to ensure the continuity of an Organization Registration and Certification Program within the geographic or electrical boundaries of a Regional Entity in the event that no entity is certified as a Regional Entity for that Region, or the Regional Entity withdraws as a Regional Entity or does not operate its Organization Registration and Certification Program in accordance with delegation agreements and other requirements. To conduct this plan, NERC would follow and adhere to the Registration and Certification procedural documents in order to successfully fulfill the day to day activities surrounding Entity Registration and Certification.

1ERO Certification Process Manual

Accountabilities / Responsibilities

Accountabilities/Responsibilities

NERC

President and Chief Executive Officer (CEO), or Designee

  • Responsible for overall execution of the Continuity Plan as described on Page 3.

Director of Compliance Operations or Designee

  • Provides overall oversight of the ERO Certification process and maintains responsibility for effective and consistent implementation of the Certification process throughout the eight REs.

Manager Organization Registration & Certification

  • Provides direct oversight of the ERO Certification process and maintains contact with REs for effective implementation of the Certification process.
  • Confirms that the composition of each Certification Team (CT) complies with ROP requirements.
  • Assigns NERC member(s) to CT.
  • Establishes training requirements and facilitates training for CT members.
  • Maintains registry of CT member training.
  • Plans and organizes Certification workshops for REs and stakeholders.
  • Facilitates NERC approval of RE recommendation of entity certifications.
  • Proposes and maintains revisions to Certification process documents as required.

Regional Entity (RE)

President and Chief Executive Officer (CEO), or Designee

  • Responsible for overall execution of the Certification Process.
  • Acts upon the CT recommendation for certification.
  • Notifies the entity and NERC of the Certification decision.

Manager (or Designee) responsible for Certification

  • Ensures Regional execution of the ERO Certification process.
  • Identifies Certification Team Leader (CTL) and determines members of the CT in coordination with the CTL, confirms completion of required training, and execution of appropriate CT member documentation.
  • Approves and ensures the adequate implementation of subsequent action plans from completed ERO Certifications.
  • Responsible for facilitating final RE approval of entity Certification.
  • Confirms all evidence and Certification documentation is kept in accordance with the RE document retention procedures per ROP Section 502.2.

Certification Team Leader (CTL)

  • Must be a trained Team Leader.
  • Completed NERC online Auditor training.
  • AttendedNERC’s Lead Auditor Training workshop.
  • Completed required reading package.
  • Participated as a Team Member on at least two (2) certifications
  • Coordinates Certification activities in accordance with ROP Section 500, Appendix 5A, and the Certification Process Manual to achieve stated objectives of the ERO Certification process.
  • Establishes and maintains contact with entity applicant throughout the Certification process.
  • Performs and oversees fact finding, interviews and data collection.
  • Prepares Opening and Closing Presentations.
  • Analyzes on-site interviews, observations, feedback, etc to complete the ERO Certification.
  • Develops draft Final Report including coordination with CT members of wording regarding positive observations and closed bucket 2 items.
  • Supports REManager, or designee, responsible for Certification in facilitating REapproval of entity Certification.

Certification Team Member (Duties as assigned by the CTL)

  • Completes required training per ROP and executes Confidentiality agreements and Conflict of Interest forms.
  • Reviews evidence presented by applicant, documents questions for entity SMEs, submits requests for information to CTL.
  • Interviews subject entity management, SMEs, and system operators.
  • Acts as Scribe if assigned.
  • Contributes comments on Final Report

1ERO Certification Process Manual

Certification Process

Certification Process

The certification[2] of an entity requires a well-planned, in depth review and well documented assessment of an entity’s capability to perform the tasks of the certifiable function for which it has applied or has been registered. This document provides a summary of the steps required to conduct the certification process. The following procedure is written generally in chronological order and may be changed at the discretion of the CTL to meet schedules, differences in Certification scope, management direction, differences in RE needs, etc. Further, it is written on the basis that an entity has requested Certification. If an entity has received a registration initiated by either the Regional Entity or NERC as allowed in ROP Appendix 5A, or if the entity is already registered[3]the procedure will be adjusted as appropriate.

If there are any discrepancies between the NERC ROP and this document, the NERC ROP shall take precedence. All discrepancies must be brought to the attention of NERC or the appropriate RE for further actions, as needed.

The Regional Entity shall assign a Certification Team Lead (CTL) once an application has been received and accepted or an entity has been registered by the Regional Entity or NERC on behalf of the entity[4]. The CTL should be a trained team leader[5] as this will provide a solid foundation for the Certification Team (CT). The CTL is responsible to develop a CT in compliance with the NERC Rules of Procedure (ROP) Appendix 5A. All CT members must have completed the requirements as described in the appropriate Member Training Form, prior to participation in the certification process andadhere to ERO’s confidentiality agreements for any data or information made available to the CT member through the certification process.

The following is a summary of steps to be followed during a certification:

Planning

  1. As required by the ROP, the CT members:
  2. Shall consist of:
  3. For Balancing Authority, the CT shall have representation from the following:
  4. An existing BA, the entity’s proposed RC, TOP, each affected Regional Entity, and NERC.
  5. For Reliability Coordinator, the CT shall have representation from the following:
  6. An existing RC, a BA and a TOP in the proposed RC area, each affected Regional Entity, and NERC.
  7. For Transmission Operator, the CT shall have representation from the following:
  8. An existing TOP, the entity’s proposed RC, each affected Regional Entity, and NERC.
  9. Additional CT members with expertise in any of the NERC registry functional areas may be added as necessary (i.e. NERC, Regional Entity staff).
  10. Entities such as government representatives or other stakeholders may be observers in the certification process.
  11. The CTL shall ensure all CT members have completed the following:
  12. Certification Team Member Training Record form.
  13. An ERO Conflict of Interest and business Ethics for Certification Team Members form.
  14. An ERO Confidentiality Agreement for NERC Certification Team form.
  15. The Certification Scope:
  16. The CT shall review the application for certification to determine the scope of the assessment. Using the NERC Reliability Standards VRF Matrix, the team shall develop a Master Matrix to identify which Reliability Standards shall be assessed based upon the function(s) for which the entity is to be certified.
  17. The CTL shall develop anonline portal to store all documentation. The CTL shall set up a secured server to house all relevant Certification Process documents, including but not limited to:
  18. The application
  19. All relevant correspondence between the CTL and the applicant, including the Certification Packet described in 4 below
  20. All relevant correspondence between the CTL and the CT members
  21. Instructions for the entity to access the server in order for the entity to submit their responses and allow for CT members to access the documentation supplied
  22. The agreed applicable Master Matrix to be evaluated during the process
  23. The overall process schedule
  24. The agenda for the on-site visit if required
  25. The Final Report
  26. The RE approval/rejection of application for certification
  27. A Certification Packet shall be developed and sent to the entity 90 days prior to the on-site visit[6] and shall consist of:
  28. Notification of the certification process
  29. The tentative overall process schedule and on-site agenda for the certification process
  30. The appropriate questionnaires[7]
  31. The Master Matrix
  32. The CT Roster and CT member biographies requesting no-objections to CT members
  33. Pre-Certification survey which is to be returned to the CTL days within 15 days
  34. Any specific requests for information (RFI) known
  35. CTL should contact the entity within one week of submitting the packet to:
  36. Confirm receipt of the package
  37. Discuss any concerns the entity may have
  38. The entity shall complete and return to the CTL the questionnaires, master matrix and supporting documentation no later than four weeks prior to the on site visit.
  39. The CTL shall schedule a document review to take place prior to the on-site visit, preferably the document review should take place face to face with the CT members, however a teleconference is acceptable.
  40. The CTL and CT shall review the Pre-certification survey, in order to:
  41. Develop an understanding of the entity being certified
  42. Make all travel arrangements
  43. The CTL shall assign a scribe(s) to document the assessment and identify teams if the CT is to be broken into smaller groups:
  44. For complex certifications of new facilities, the CTL may assign members of the CT into different focus areas such as:
  45. Facilities – examples of items that could be included (but are not limited to the following) are: the physical cyber assets against the CIP standards, the cyber training, the maintenance contracts and records for the facilities, the electrical system and UPS, the cyber security of servers, passwords, etc. per the CIP standards, and the physical installation of data and voice equipment.
  46. EMS/SCADA – Interview the EMS/SCADA subject matter experts (SMEs) to ensure that the tools will provide adequate situational awareness against the NERC Standards. Ensure adequate change control of the EMS/SCADA. Review the data transfer, server, applications, and redundancy configuration of the core tools including: EMS, OSI-PI, ICCP, outage scheduling, scheduling, map board displays, communication systems, etc.
  47. Operator Preparedness – Interview the operators at their workstations and ask them to present the tools, procedures, CIP readiness, and their procedure use for normal day-to-day and emergency operations. Interview the training staff regarding initial, training needed to support the transition to the new responsibilities and continuing training against the NERC Standards. Interview the planning staff to ensure adequate contingency planning and proper interaction with the real time operators.
  48. The CT shall conduct a document review of the documentation provided prior to the on-site visit and shalldocument all:
  49. Questions for the entity’s management, SMEs and system operators based upon the review of the supporting documentation
  50. Additional RFIs and submit to the entity prior to the on-site visit
  51. document all comments which support of the entity’s abilities to perform the function for which the entity applied during the document review and close out those items which do not need further review
  52. Issues which need to be addressed prior to certification being granted

12. The CTL shall provide the entity a final schedule and agenda for the on-site visit based upon the results of the document review.

Fieldwork

  1. Opening Presentation
  2. The CTL shall provide an opening presentation the first day on site.
  3. The entity shall provide an opening presentation, briefly describing the entity, the location, evacuation and other safety issues, restrooms and other housekeeping information.
  4. The CT shall interview entity personnel to provide clarification to responses provided and reviewed during the document review.
  5. The CT shall request electronic copies of documents provided.
  6. Security sensitive materials shall be documented, however, they shall remain at the entity’s facility.
  7. The CT shall tour the facilities observing and noting the required physical assets. The CT may request a demonstration of the tools used to support the function.
  8. At the end of each day, the CT will caucus in preparation for the daily debriefing.Subsequently, the CTL shall lead a daily debriefing with the entity in order to:
  9. Identify the status of the assessment.
  10. Identify any items of concern which need to be addressed, identify which bucket each item is in.
  11. Provide an update to the schedule.
  12. Identify any possible violations of applicable standards in order for the entity to self-report to its respective region.
  13. The CTL shall provide an exit briefing at the end of the on site visit in order to:
  14. Identify any items of concern which need to be addressed, identify which bucket each item is in.
  15. Discuss the reporting process.
  16. Discuss the next steps in the certification process, including the post on site visit anticipated schedule, including closing bucket 2 items.
  17. Confirm that Entity Feedback Forms will be forwarded to the entity with a sincere request for candid feedback.

Reporting

  1. The CTL will provide the CT with the Feedback Form-CT Member and request that they be returned within 5 calendar days with a copy to the NERC Certification email .
  2. After completion of the on-site visit the CTL should develop:
  3. a spread sheet listing all Bucket 2 items which are to be tracked and closed prior to requesting RE management approve certification; and
  4. the draft Final Report, in coordination with input from the CT, which presupposes bucket 2 items are closed,.
  5. Upon completion of the draft Final Report, the CTL should transmit the draft Final Report to the CT requesting return with final comments within 2 calendar days.
  6. Upon completion, the CTL should transmit the draft Final Report to the entity requesting return with comments within 14 calendar days.
  7. The comments received from the entity will be given due consideration and incorporated in the Final Report at the discretion of the CTL, in consultation with the CT.
  8. The CTL will review the completed Final Report one last time with the CT and when all Bucket 2 items are closed to the satisfaction of the CT, submit to the appropriate RE management[8] the CT recommendation and Final Report for consideration and approval.
  9. If rejected by RE management, the CTL will work with the CT and the entity to resolve any issues.
  10. If approved by RE management, the RE CEO[9] (or a designee) will transmit to the entity, with a copy to NERC, the formal RE approval and RE recommendation for NERC approval using as a template, the “Region Certification Approval Recommendation Letter” available on NERC’s website.
  11. If approved by NERC, NERC shall transmit via email to the applicant, confirmation of Certification of the application function, noting that the applicant will receive via post, a hard copy of:
  12. The Certification Letter
  13. Certificate of functional Certification
  14. After the applicant is certified, the RE will register the applicant; the applicant will be registered for the new function on the confirmed date that operationswill begin[10].
  15. After the applicant is certified, the applicant must commence operations for the application function within 12 months after being notified of approval by NERC. If the applicant fails to commence operation within 12 months, the certification process must be repeated.

1ERO Certification Process Manual

Related Documentation

Certification Review Process