WECC-0119 RA Removal PRC-(012 through 014)-WECC-CRT-2.1 1
Recommendation / Request for Comment
The WECC-0119 Removal of Reliability Assurer Drafting Team (DT) is recommending retirement of the WECC Requirements (WR) 1, 3, 5, 6, and 7 because the WRs are redundant to peripheral NERC and WECC documents.[1] The applicable entity of each of these requirements is the Reliability Assurer/WECC. WECC CRT WR 2, 4, 8 through 12 are not proposed for retirement.
1)Do you agree the specified WRs should be retired?
2)If you answered “no” to the first question please identify which WR(s) should not be retired and explain why it should not be retired.
3)If you answered “no” to the first question, please suggest the most appropriate alternate document into which the affected content should be relocated. Please explain your answer.
4)Will retirement of any of the specified WRs cause a reliability gap? If you answered “yes”, please explain your answer.
5)The DT welcomes comments on all other aspects of the proposed retirement.
Remediation of Conflict of Interest
Deletion of the WRs will address the SAR by eliminating the current conflict of interest whereby WECC serves both as the entity responsible to complete the assigned tasks as well as the entity responsible for monitoring the adherence to the assigned task. The DT concluded that retirement of the WRs will have no impact on the reliability of the Interconnection because the assigned tasks will continue to be performed in accordance with existing NERC Standards or peripheral WECC documents.
Overview
This memo is structured to illustrate how each of the underlying NERC requirements would continue to be met in the event the WRs were approved for retirement.
The WECC CRT was drafted to meet the “Fill-in-the-Blank” (FITB) requirements contained in three NERC Standards. Those three standards addressed in Attachments A through C require that WECC have specific regional procedures; but, they do not mandate any specific WECC document categorization, e.g. WECC Criteria. As long as WECC has the specified procedures, the assigned document categorization is irrelevant. As a result, if the procedures are contained (for example) in a WECC Guideline or other WECC document, WECC can remain compliant with the NERC Standards even if the specified WRs are retired.
As illustrated in the following Attachments, each mandated regional procedure is resident in a peripheral WECC Standard, WECC Criterion or other WECC document. If the identified WRs are retired, WECC can remain in compliance with the underlying NERC Standards.
The three standards are as follows:
- PRC-012-0 (PRC-012), Remedial Action Scheme Review (RAS) Procedure (Attachment A);
- PRC-013-0, Special Protection System Review Procedure (Attachment B);
- PRC-014-0, Special Protection System Assessment (Attachment C).
Because the reliability-related content of the underlying NERC Standards is addressed in peripheral WECC documents, retirement of the specified WRs will have no negative impact on reliability. The WRs are redundant and should be retired.
Western Electricity Coordinating Council
WECC-0119 RA Removal PRC-(012 through 014)-WECC-CRT-2.11
Attachment A[2]
PRC-012
Special Note: The Met in WECC Criterion column contains references to multiple WECC Criteria. Portions of PRC-(12 through 14)-WECC-CRT-2 are not proposed for retirement because they continue to support the NERC Standard. By contrast, portions of PRC-003-WECC-CRT-1.3 are proposed for retirement because they are redundant.
R1. Each Regional Reliability Organization with a Transmission Owner, Generator Owner, or Distribution Providers that uses or is planning to use a RAS shall have a documented Regional Reliability Organization RAS review procedure to ensure that RAS comply with Regional criteria and NERC Reliability Standards. The Regional RAS review procedure shall include: (emphasis added)NERC Requirement / Met in WECC Criterion / Meet in WECC Guideline
R1.1. Description of the process for submitting a proposed RAS for Regional Reliability
Organization review. / WR4. Each Reporting Party shall use the process as established by the RASRS to submit a RAS for review.PRC-(012 through 014)-WECC-CRT-2.1.[3] (PRC-12/14)
PRC-12/14, WR4 is not proposed for retirement.
Special note: The above WR4 comes from PRC-12/14, Remedial Action Scheme Review and Assessment Plan – not PRC-003-WECC-CRT-1.3. The inclusion here indicates how WECC will continue to meet the mandate if that document is retained.
PRC-12/14, WRs 2, 4, and 8 through 12 are not proposed for retirement.[4]
Although not proposed for retirement, PRC-12/14 WR4 could be retired without affecting WECC’s role assigned in the underlying FITB standard because the required procedure is also addressed in the RASRS Procedure. / Remedial Action Scheme Design Guide, June 2006. (RAS Design)
Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability of a RAS Guideline, October 28, 2013. (RASRS Procedure), Making a Submission to the RASRS for Scheme Review, page 10.
R1.2. Requirements to provide data that describes design, operation, and modeling of a
RAS. / WR2.Each Reporting Party shall complete and forward the data described in the WECC Remedial Action Scheme Information Sheet (Attachment A) to the Reliability Assurer (WECC) no later than 90 days after the Effective Date of this document. (PRC 12/14)
PRC-12/14, WR2 is not proposed for retirement; however, it could be because the content is contained in the Design document coupled with the RASRS Guideline.
PRC 12/14, Attachment A requires submittal of information regarding: 1) operating procedures, design objectives, operating, and modeling.
PRC-12/14, WR2 is itself partially redundant to PRC-004-WECC-1, Protection System and Remedial Action Scheme Misoperation; however, PRC-004 only applies to Major WECC transfer Paths in the Bulk-Electric System. / RAS Design
RAS Procedure, Sections A through H., pages 12-20. See also, WECC Remedial Action Scheme Database at pages, 9 and 20. See also Periodic Assessments addressing Corrective Action Plans, page 9.
R1.3. Requirements to demonstrate that the RAS shall be designed so that a single RAS
component failure, when the RAS was intended to operate, does not prevent the
interconnected transmission system from meeting the performance requirementsdefined in Reliability Standards TPL-001-0, TPL-002-0, and TPL-003-0.[5] / This Requirement is met in PRC-003-WECC-CRT-1, ARM RAS Misoperation Procedure WR1. Even if the WECC WR1 is retired, the NERC Requirement R1.3 is still met in the RAS Design and the RAS Procedure. The DT is recommending the content of that PRC-003-WECC-CRT-1, WR1 be retired and provided to the RASRS for final disposition. The scope of this SAR would allow the DT to take the additional step and relocate the language directly; however, the DT believes the RASRS is best suited to determine final disposition of the language. As such, if the DT’s recommendation is accepted, the WR would be retired under this SAR but any subsequent disposition of the affected content would be at the sole discretion of the RASRS. / Remedial Action Scheme Design Guide, June 2006.
Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability of a RAS Guideline, October 28, 2013. Tied to Local Area Protection Scheme (LAPS) and Wide Area Protection Scheme (WAPS) definitions as used throughout the RASRS Procedure.[6] See also: RASRS Procedure, Information Required to Assess the Reliability of A RAS, page 12. See also: PRC-(12 through 14)-WECC-CRT-2.1, Remedial Action Scheme Review and Assessment Plan, WR4.
R1.4. Requirements to demonstrate that the inadvertent operation of a RAS shall meet the
same performance requirement (TPL-001-0, TPL-002-0, and TPL-003-0) as that required of the contingency for which it was designed, and not exceed TPL-003-0. / RAS Deign
RAS Procedure. Tied to Local Area Protection Scheme (LAPS) and Wide Area Protection Scheme (WAPS) definitions as used throughout the RASRS Procedure.
The performance metrics specific to the TPLs (see LAPS/WAPS definition) will be resident in PRC-012-2. This requirement is being retained in the proposed new PRC-012-2 because that NERC drafting team is convinced that it is not covered by TPL-001-4, Transmission System Planning Performance Requirements. The definition of LAPS / WAPS is tied to the TPL legacy (retired) and is need of updating.
R1.5. Requirements to demonstrate the proposed RAS will coordinate with other protection
and control systems and applicable Regional Reliability Organization Emergency
procedures. / RAS Procedure. See Coordination with Protection and Control Systems, page 14, Bullet 8; RAS Classifications, p. 9; Information Required to Assess the Reliability of a RAS, page 12, at Bullet 11; RAS Purpose and Overview, page 13, Bullet 6; RAS Design, page 14, at Bullets 8 and 9.
R1.6. Regional Reliability Organization definition of misoperation. / WECC does not have a regional definition for Misoperation. PRC-04-4(i) creates a NERC-wide definition. Absent a regional definition, the NERC definition controls. After PRC-012 was drafted. FERC issued instructions that regional definitions should be avoided. PRC-012 is simply out of date with that mandate.
R1.7. Requirements for analysis and documentation of corrective action plans for all RAS
misoperation. / PRC-004-WECC-1, Protection System and Remedial Action Scheme Misoperation.
PRC-004-4(i), Requirement R5. Enforceable July 1, 2016.
RAS Procedure. See Periodic Assessments addressing Corrective Action Plans, page 9.
This is also covered in PRC-016-0.1, Special Protection System Misoperation, enforceable May 13, 2008 that becomes inactive on March 31, 2017 followed the April 1, 2017 enforcement date of PRC-016-1, Remedial Action Scheme Misoperation.
PRC-016, Version 0.1 requires compliance with a regional procedure but does not impose a burden on WECC to create it. WECC’s Section 1600 quarterly reporting for WECC of Protection System Misoperations also includes RAS but does not include Corrective Action Plans for both Protection System and RAS misoperation.
R1.8. Identification of the Regional Reliability Organization group responsible for the
Regional Reliability Organization’s review procedure and the process for Regional
Reliability Organization approval of the procedure. / RAS Procedure. See “Introduction: This document provides a framework for the submission of a [RAS], to the [RAS} Subcommittee…. for evaluation and operation within WECC.”
See also: “Purpose/Responsibilities:
The purpose of the RASRS is to review the reliability aspects of existing and planned Remedial Action Schemes (RAS) and to enhance grid performance within the Western Interconnection by providing a uniform review process.
R1.9. Determination, as appropriate, of maintenance and testing requirements. / RAS Procedure. See “B. RAS Design, 9.e) Describe how each multifunctional device is tested, both for commissioning and during maintenance testing, with regard to each function of the device.” See also: E. Commissioning, Maintenance and Testing.
Attachment B PRC-013
Unlike the PRC-012 legacy series, the PRC-013 series does not require a multi-faceted procedure nor does it require any documentation. It only requires that WECC create/maintain a RAS database with three specific attributes. WECC has the database. The database is populated with more than the minimum required data of PRC-013, R1 via WECC CRT WR2, Attachment A. The WECC CRT Attachment A is not proposed for retirement.
R1. The Regional Reliability Organization that has a Transmission Owner, Generator Owner, orDistribution Provider with a RAS installedshall maintain a RAS database. The database shallinclude the following types of information:NERC Requirement / Met in WECC Criterion / Met in WECC Guideline or Other Document
WR1. The Reliability Assurer (WECC) shall create and maintain a WECC Remedial ActionScheme Database containing, at a minimum, the information described on the WECC Remedial Action Scheme Information Sheet (Attachment A).
This language is proposed for retirement. / Retirement of WECC CRT WR1 would not eliminate WECC’s requirement to maintain the RAS Database. That mandate continues to reside in PRC-013-1, Remedial Action Scheme Database, at Requirement R1, even though the NERC Standard is not enforceable. Further, PRC-013-1, R1 is buttressed by NERC Standard PRC-015-1, Remedial Action Scheme Data and Documentation, Requirement R1 that requires the TO, GO, and DP to maintain and provide data in accordance with PRC-013-1, Requirement R1.
Retirement of WECC CRT WR1 does not eliminate the database mandate; rather, it eliminates the redundant WECC Requirement.
Even if the NERC PRC-013, R1 requirement were deleted, WECC would still maintain the RAS Database under peripheral, in-place practices. Specifically, the RAS Procedure recognizes that the “database has been created and is maintained by the RASRS in the form of an Excel spreadsheet…The owner (reporting party) for each new or modified RAS is required to fill in the database information in the template spreadsheet [AKA: Attachment A of PRC-(012 through 14)-WECC-CRR-2.1].” WECC Remedial Action Scheme Database.
WR2. Each Reporting Party shall complete and forward the data described in the WECC Remedial Action Scheme Information Sheet (Attachment A) to the Reliability Assurer (WECC) no later than 90 days after the Effective Date of this document. (PRC-012-0, R1.2.” PRC-(012 through 014)-WECC-CRT-2.1, Remedial Action Scheme Review and Assessment Plan, WECDC Requirement WR2.
This WR is not proposed for retirement. / WECCincludes more items in its database than the minimum NERC requirement. These “extras” include such items as the Scheme Owner (Reporting Party) and RAS name, plus other pertinent items.
R1.1. Design Objectives — Contingencies and system conditions for which the RAS wasdesigned, / WECC CRT Attachment A, WECC Remedial Action Scheme Information Sheet, Row 6, Design Objectives. That Attachment is not proposed for retirement.
“Data required to describe Design Objectives – contingencies and system conditions for which the scheme was designed.” / RASRS Procedure. Replicated in Attachment A, WECC RAS Database Information.[7]
R1.2. Operation —The actions taken by the RAS in response to Disturbance conditions,
and / WECC CRT Attachment A, WECC Remedial Action Scheme Information Sheet, Row7, Operation. Attachment A is not proposed for retirement.
“Data required describing Operation – The actions taken by the scheme in response to Disturbance conditions.” / RASRS Procedure. Replicated in Attachment A, WECC RAS Database Information.
R1.3. Modeling — Information on detection logic or relay settings that control operation of
the RAS. / WECC CRT Attachment A, WECC Remedial Action Scheme Information Sheet, Row8, Modeling. Attachment A is not proposed for retirement.
“Data required for adequate Modeling – Information on detection logic or relay settings that control operation of the scheme. / RASRS Procedure. Replicated in Attachment A, WECC RAS Database Information.
Attachment CPRC-014
This section describes which of the WRs Are to be kept and which are to be retained while also explaining why that action is recommended.
WECC CRT Requirements 1, 3, 5, 6, and 7 are proposed for retirement. WECC CRT Requirements 2, 4, and 8 through 12 are proposed to be kept. Those WRs retained are proposed for retention to support PRC-014.
R1. The Regional Reliability Organization shall assess the operation, coordination, andeffectiveness of all RAS installed in its Region at least once every five years for compliancewith NERC Reliability Standards and Regional criteria.Met in WECC Criterion / Met in WECC Guideline
WR10. Each Transmission Owner, each Generation Owner, and each Distribution Provider shall assess its RAS(s) for operation, coordination and effectiveness, at least once each five years.
This WR is not proposed for retirement. / RASRS Procedure. Periodic Assessment, page 9. See also: WECC CRT WR11 and Attachment B.
R3. The documentation of the Regional Reliability Organization’s RAS assessment shall include
the following elements:
R3.1. Identification of group conducting the assessment…. / WR3.The Reliability Assurer (WECC) shall designate the Remedial Action Scheme Reliability Subcommittee (RASRS)…
WR5. The Reliability Assurer (WECC) shall instruct the RASRS…
WR6. The Reliability Assurer (WECC) shall designate the Operating Committee (OC)…
WR7.The Reliability Assurer (WECC) shall instruct the RASRS… (emphasis added) / The roles and assignments of WECC, the Operating Committee (OC), the RASRS, and the Relay Work Group (RWG) are dictated by the WECC Bylaws and the associated charters. To the extent any subsequent changes were needed in the form of a WECC Criterion, development of WECC Standard Authorization Request would be required triggering due process in the Reliability Standards Development Procedures (Procedures).
Those roles and assignments need not be specifically re-stated in the WECC CRT.
•In the Operating Committee (OC) Charter as approved by the WECC Board of Directors, the OC shall “Coordinate protection schemes and associated equipment affecting interconnected system reliability.” OC Charter, Purpose/Responsibilities.
- The specific responsibilities of the WECC RASRS are also specified in the RASRS charter and need not be specifically restated in a WECC Criterion.
•See also the “all other clause” of the RWG Charter as well as the same clause for any other entity under the auspice of the OC since the WR allows the OC to assign “any other group that the WECC [OC] designates….”
•See also the Reliability Standards Development Procedures in that the Procedures mandate a five-year review of all documents created under the Procedures. Procedures, Maintenance of RRS and OPs Documents. The Procedures also require numerous types of notice (due process), comment / response posting, balloting, WSC and Board approval for any changes made under the Procedures. A major part of that process is announcement of all proposed and approved changes. Although the OC could also designate the group to assist in the development of changes to the WECC CRT, the OC cannot override the WECC/NERC/FERC approved Procedures that mandate how changes will be handled.
R3.1…and the date the assessment was performed.
R3.2. Study years, system conditions, and contingencies analyzed in the technical studies onwhich the assessment is based and when those technical studies were performed. / WR2. Each Reporting Party shall complete and forward the data described in the WECC Remedial Action Scheme Information Sheet (Attachment A) to the Reliability Assurer (WECC) no later than 90 days after the Effective Date of this document. (PRC-012-0, R1.1; See also PRC-012-0, R1.2)
Dates are established variously.
The Effective Date of the WECC CRT was January 1, 2014. In conjunction with WR2, that established the base line date. Thereafter, each time Attachment A/B is filed it includes the date. See also WR9/WM9, requiring dated correspondence; WR10, WR12, and each submittal of Attachment A/B, and WR12.
WR11. Each Reporting Party shall report the RAS assessment, required in WR10 above, by sending a completed Attachment B of this criterion to the Reliability Assurer (WECC) no later than December 31 of the calendar year in which the assessment was completed.
The substantive content for reporting (e.g., study years and system conditions) are addressed in WR10WR11, referencing Attachment B. Attachment B covers all of the PRC-014 data collection requirements. / The RASRS Procedure, Periodic Assessment states: “WECC recognizes that most, if not all members include RAS installed on their systems in System Operating Limits (SOL) studies daily outage planning, real time contingency analysis (RTCA) or similar studies, typical at least annually.” Page 9.
R3.2. Study years, system conditions, and contingencies analyzed in the technical studies on which the assessment is based and when those technical studies were performed. / WR4. Each Reporting Party shall use the process as established by the RASRS to submit a RAS for review.
The substantive content for reporting (e.g., study years and system conditions) are addressed in WR10/WR11, referencing Attachment B. Attachment B covers all of the PRC-014 data collection requirements.
These WRs are not proposed for retirement. / RASRS Procedure.
Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability of a RAS Guideline, October 28, 2013.
RAS Classification, page 6; Information Required to Assess the Reliability of a RAS, page 12
Attachment A, WECC RAS Database.
NERC Requirement / Met in WECC Criterion / Met in WECC Guideline
R3.3. Identification of RAS that were found not to comply with NERC standards andRegional Reliability Organization criteria. / WR8. Each Reporting Party shall review the WECC Remedial Action Scheme Database for accuracy and report any changes (or lack thereof), modifications, retirements or expansions of its RAS to the Reliability Assurer, no later than December 31 of each calendar year. (PRC-012-0, R1.2)
WR9. Each Reporting Party shall submit any additions, changes, modifications, retirements, or expansions of its RAS, to the RASRS or its successor, prior to placing the RAS or its changes into service.
These WRs are not proposed for retirement. / RASRS Procedure. Attachment A and database related section.
R3.4. Discussion of any coordination problems found between a RAS and other protectionand control systems. / WR10. Each Transmission Owner, each Generation Owner, and each Distribution Provider shall assess its RAS(s) for operation, coordination and effectiveness, at least once each five years.
See also: Attachment A that requires information on coordination and effectiveness of the RAS.
This WR is not proposed for retirement. / RASRS Procedure. Attachment A and database related section.
R3.5. Provide corrective action plans for non-compliant RAS. / Remedial Action Scheme Design Guide, June 2006. (Design)
RASRS Procedure. Information Required to Assess the Reliability of a RAS. Sections A through H., pages 12-20. See also, WECC Remedial Action Scheme Database at pages, 9 and 20.
Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability of a RAS Guideline, October 28, 2013.
See Periodic Assessments addressing Corrective Action Plans, page 9
Western Electricity Coordinating Council