Can You Hear Me Now? COM-001-3 and How the New Version Affects You by Michael Tate — NERC Reliability Specialist, NAES Corporation

It wouldn’t be a day in the NERC compliance world without the seemingly most straightforward standard changing. With the implementation of COM-001-3, you may have questions about the applicability of new Requirement R12:

“Generator Operator (GOP) shall have internal interpersonal communication capabilities for the exchange of information necessary for the reliable operation of the BES. This includes communication capabilities between control centers within the same functional entity, and/or between a control center and field personnel.”

This sounds pretty straightforward except for the concept of ‘internal interpersonal communication.’ It was introduced by FERC a few years ago not only to ensure communication redundancies from one entity to another but also to ensure that such entities have redundancies within their own internal communication systems.

Implemented on October 1, 2017, COM-001-3 is largely unchanged as it applies to GOPs – i.e., Requirements R8 and R11. The changes in Version 3 worth noting are those that address the increasingly common situation of multiple control centers, contact with field personnel, and failure of these internal systems. Internal interpersonal communication is based on geography and applies to specific situations. The new Requirement R12 will require entities with control centers to back up communications within their own entity through the use of interpersonal communications. This means that GOPs that have geographically separated control centers or rooms will have a communications system for communicating directives from directing entities.

But what exactly constitutes ‘geographical separation of control rooms’? The wording of Requirement 12 may leave GOPs in the dark on this issue. A series of questions may help you sort this out.

Question 1: Does my Generation Operation depend on two or more DCS/SCADA terminals?

If yes: Go to Question 2.

If no: If the operation of your generator(s) depends solely on one DCS/SCADA Terminal, R12 is only partially applicable to your facility, in that contact with field personnel is still required but there is no need for any additional communication systems. Stating this within your compliance documentation for COM-001-3 with evidence proving that generation control depends on only one control terminal will provide proof of compliance.

Question 2: Does my facility have DCS/SCADA terminals in separate rooms and/or buildings?

If yes: If your generation DCS/SCADA terminals are separated among multiple control rooms, then Requirement 12 is fully applicable to you. Compliance can be demonstrated several ways: provide a drawing of your telecommunications from control room to control room that shows how the systems are linked; or provide proof that communications between control rooms are established through test records, recordings of internal interpersonal communication and/or email records.

If no: If your DCS/SCADA terminals are located in one control room in the generation facility, then this portion of Requirement 12 does NOT apply to your facility, in that contact with field personnel is still required but there is no need for any additional communication systems. These situations warrant only that GOPs show that DCS/ SCADA terminals are confined to one control room (via line diagrams, telecom drawings, etc.) and a statement in their compliance documentation.

Lastly, Requirement R12 requires field personnel to have communication between the control center and field personnel. Regardless of the facility layout, GOPs should have some form of communication from field personnel to their respective control room(s). This portion of R12 applies to all GOPs. In fact, in order to demonstrate compliance for Requirement R12, a GOP should have some form of communication – a simple two-way radio or company-issued cell phones – between those in the field and the control room. Luckily, proof of compliance may be fairly direct, as GOPs should have equipment specifications, test records of communication systems, or voice recordings.