RASRS Report to the OC5

Remedial Action Scheme Reliability Subcommittee Report to the Operating Committee

March 21, 2017

Western Electricity Coordinating Council

RASRS Report to the OC5

1  Meetings

The Remedial Action Scheme Reliability Subcommittee (RSSRS) met November 14-16, 2016 in San Diego, CA. RASRS also held webinars on December 6th and 19th to review and update several documents

The next RASRS meeting is scheduled in Salt Lake City on April 10-12, 2017.

2  Remedial Action Scheme Reviews

The RASRS reviewed the following schemes during the meeting in November 2016:

PG&E

·  Sobrante-Standard Oil SPS – classification change from LAPS to Safety Net approved

·  Carrizo RAS – modification due to new switching station. Still classified as LAPS

LADWP

·  Owens Valley RAS – modifications related to voltage collapse mitigation were approved

·  Scattergood RAS – generation removal and logic modification were approved

·  Harbor RAS – removal due to system upgrades approved

·  Hollywood RAS (Safety Net) – was approved

BPA

·  Paul Substation LLL modification to the AC RAS – was approved

·  McNary transformer LL modification – was approved

·  BPA information discussion on RAS Automatic Arming - Changes in the grid such as sub-hourly energy markets, e.g. EIM, require faster dispatcher reaction to changing loads and put a greater burden on RAS dispatchers to make necessary adjustments if manual-only arming were maintained.

BC Hydro

·  Peace Area Wind RAS – information update with scheme now in service

·  Peace Area Load Shed RAS – was approved

·  Saltery Bay (SAY) RAS – removal due to system improvements approved

·  Bridge River Area RAS – RASRS conclusion that the scheme is a WAPS due to level of potential generation shedding and will require further review.

·  North Coast RAS – modifications to this RAS resulting from an earlier misoperation were approved

SDG&E

·  TL50001, TL50003, TL50004, TL50005 – originally approved as SPS but modified to WAPS due to involvement of CENACE

TEP

·  Tie Open Load Shed RAS (TOLS) – five-year review, approved the scheme as WAPS with one action item on communication documentation

PAC

·  Goshen RAS Action Items – RASRS accepted completion of two of three action items from July 2016 meeting

SCE

·  High Desert Power Project RAS (HDDPPRAS) – modifications accepted as still a LAPS

·  Mojave Desert RAS (MDRAS) – modifications due to retirement of Cool Water generation and system upgrades, was approved

·  Whirlwind AA-Bank RAS – adding third transformer bank and additional arming points. Modifications were approved.

3  RASRS Reviews

3.1 RASRS Charter

RASRS performed the annual review of the RASRS Charter and concluded that no modifications were needed at this time.

3.2 RAS Design Guide Revision

The Relay Work Group reviewed and revised this 2006 document at its September 2016 meeting. RASRS reviewed those revisions and also added revisions. Approval of the revised document will be handled through the RWG.

3.3 RASRS Revision of WECC-1 RAS Operating Procedure

The RASRS reviewed and revised this 2015 document. Significant changes included removal of Mid-Columbia Wanapum (Grant) and Rocky Reach (Chelan) generation from the generation available for shedding via BPA’s High Gen Drop algorithm and changes related to rebuilding WAPA’s Waterflow substation. These changes did not affect COI Path rating.

3.4 NERC PRC-012-2 RAS Standard Development

The approved new NERC RAS definition will go into effect April 1, 2017 (no fooling!). There is a two-year implementation period to identify any existing schemes that were not previously classified as RAS but are RAS under the new definition. New RAS will be regulated under the new definition without the two-year implementation period. Any schemes presently classified as RAS that may not be RAS under the new definition should be reviewed by RASRS to confirm the owner’s conclusion.

The proposed PRC-012-2 was filed with FERC in August. The proposed standard consolidates all existing RAS-related requirements from the present versions of PRC-012, PRC-013, PRC-014, PRC-015, PRC-016, and PRC-017. The drafting team’s object was to keep all appropriate “old” requirements with minimal modifications to actual expectations, but has re-assigned compliance responsibilities and clarified language as judged to be appropriate.

·  Requirements R1, R2, and R3 are assigned to RAS owners and the Reliability Coordinator for review of new and modified RAS. The RC may also request other Entities to participate in the scheme reviews.

·  Requirement R4 is assigned to Planning Coordinators to periodically evaluate existing RAS.

·  Requirement R5 assigns RAS Owners to evaluate actual RAS operations.

·  If any scheme deficiencies are identified in R4, R5, or R8, then Requirements R6 and R7 assign the RAS Owners to produce a Corrective Action Plan (CAP) and to complete that CAP (as modified, if necessary).

·  Requirement R8 assigns RAS Owners to perform functional testing of RAS for those RAS components that are not already covered by PRC-005.

·  Requirement R9 assigns the RC to compile and update a RAS database.

FERC issued a Notice of Proposed Rule Making (NOPR) in January. The NOPR proposed to approve the new PRC-012-2, but sought additional information to:

·  Clarify that proposed PRC-012-2 will not modify or supersede any system performance obligations under Reliability Standard TPL-001-4, e.g. non-consequential load loss always <= 75 MW for P1, P2, and P3 events.

·  Seek comment on the processes used to ensure the WECC LAPS or NPCC Type III RAS will be compliant with Reliability Standard TPL-001-4 prior to the effective date of Reliability Standard PRC-012-2, including the load considerations above.

·  Seek comment on whether the term “limited impact RAS” should be defined in the Glossary of Terms Used in NERC Reliability Standards.

The NERC legal counsel is preparing a response to this information request. Other Entities are also welcome (and encouraged!) to respond to the FERC NOPR. Closing date is April 10, 2017.

3.5 Procedure and Information Required for RAS Assessment

RASRS is seeking OC approval of proposed revisions to the document which will

·  Include specific recognition of the new NERC RAS definition

·  Update LAPS, WAPS, and SN definitions referring to revised WECC Criteria and updated NERC standards

·  Modify related flow chart figures that illustrate the WECC review process

·  Update references and links

·  Actual data collected to enable scheme reviews is not changing

These changes will better align the “Procedure” document with current NERC requirements and will (hopefully) enable a smoother transition to implementing the new PRC-012-2.

4  The Future of RASRS

The new PRC-012-2 standard assigns most of the present reliability responsibilities of the RASRS under WECC to the Reliability Coordinator (Peak Reliability and AESO for Alberta within WECC). This would remove WECC’s approval and specific record keeping responsibilities for remedial action schemes when the standard goes into effect.

The Organizational Structure Review Task Force is aware of this situation. No immediate structural changes are proposed for the OC or RASRS. Preliminary discussions indicate that Peak would like to retain an organization that looks similar to the RASRS. However, WECC and Peak Reliability (and AESO for Alberta) will have adequate time to develop a specific transition plan to transfer appropriate RASRS functions when the final PRC-012-2 standard goes into effect.

Western Electricity Coordinating Council