WECC-0119 PRC-003-WECC-CRT-1.3 Removal of Reliability Assurer1

MEMO

Date:June 1, 2016

To:WECC Standards Committee (WSC)

Subject:WECC-0119, Removal of Reliability Assurer (SAR)

PRC-003-WECC-CRT-1.3 (WECC CRT), ARM Procedure[1]

The memo requests retirement of the following WECC Requirements(WR) included in the WECC CRT because the WRs are either duplicated in a peripheral NERC Standard or WECC document, or are no longer required. Retirement would be effective as of July 1, 2016 coincide with the effective date of PRC-004-4(i), Protection System Misoperation Identification and Correction. Because the WRs are redundant, retirement will have no impact on reliability.[2] The entire WECC CRT is proposed for retirement because WR1 is addressed in PRC-004-4(i). The balance of the WRs (2-5) are either no longer required or are addressed in peripheral WECC documents.

DEPENDING ON THE REASON FOR RETIREMENT THE WSC MAY HAVE THE AUTHORITY TO RETIRE THIS WITHOUT FURTHER DUE PROCESS. IF RETIRED BECAUSE OF REDUNDANCY TO NERC STANDARDS – NO FURTHER DUE PROCESS. SLAM DUNK ON WR1 (PRC-004)….IFFY AS TO THE REST.

Deletion of the WRs will address the goals of 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 FOLLOWING 2 OPTIONS ARE OFFERED AND PERMISSIBLE UNDER THE SAR BUT NOT REQUIRED UNDER THE SAR.

OPTION 1: MOVEWR1 TO THE RAS PROCEDURE NOW AND DELETETHE ENTIRE CRITERION.

OPTION 2: RETIRE WR1 COINCIDENT WITH THE EFFECTIVE DATE OF PRC-012-2, JULY 1, 2017(?).

THE FOLLOWING WOULD BE REWORDED ACCORDINGLY.

OPTION 1

This memo also requests relocation of WECC CRT, WR1, into a WECC Regional Guideline, such as the Remedial Action Scheme Design Guide, June 2006 or the Procedure to Submit a RAS for AssessmentInformation Required to Assess the Reliability of a RAS Guideline, October 28, 2013 (RAS Procedure). Relocation would be effective July 1, 2016. Relocation is allowed under the scope of the SAR.

OPTION 2

This memo also requests retirement of WECC CRT, WR1, coincident with the effective date of PRC-012-2, Remedial Action Schemes, because that standard “corrects the applicability of the fill-in-the-blank standards [PRC-012-1, inter alia)] by assigning the requirement responsibilities to the specific users, owners, and operators of the Bulk-Power System, and incorporates the reliability objectives of all the [Remedial Action Scheme]-related standards.”[3] ….MAY BE THE BETTER REFERENCE IS PRC-004-4…..

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. It also illustrates why WRs 2 through 5 should be retired.

The WECC CRT was drafted to meet the “Fill-in-the-Blank” (FITB) requirements contained in four NERC Standards. Those four standards 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 in a WECC Guideline or other WECC document, WECC can remain compliant with the NERC Standards. As illustrated in the following Attachment, 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 WECC CRT was drafted to meet the “Fill-in-the-Blank” (FITB) requirements from four documents:

  • PRC-003-1 (PRC-003), Regional Procedure for Analysis of Misoperation of Transmission and generation Protection Systems, specifically Requirement R1;
  • PRC-004-1 (PRC-004), Analysis and Mitigation of Transmission and Generation Protection System Misoperations, specifically Requirements R1, R2, and R3, addressing regional procedures for Corrective Action Plans wherein all three requirements refer back to PRC-003-1, R1;
  • PRC-016-0.1 (PRC-016), Special Protection System Misoperations, specifically Requirement R1 that requires recordation of misoperations in accordance with a regional Special Protection Schemes (SPS/AKA: Remedial Action Schemes (RAS) review procedure required in PRC-012-0, Remedial Action Scheme Review Procedure, Requirement R1; and,
  • PRC-012-0 (PRC-012), Remedial Action Scheme Review Procedure.

PRC-003 and PRC-004

On May 29, 2015, in a letter order from the Federal Energy Regulatory Commission (FERC), FERC approved NERC Standard PRC-004-4(i), Protection System Misoperation Identification and Correction. That standard is subject to United Stated enforcement as of July 1, 2016. This is the triggering event for retirement of WRs 2, 3, 4, and 5.

Section 5 Background of PRC-004-4(i) states:

In the FERC Order No. 693, the Commission identified PRC-003-0 as a “fill-in-the-blank” standard. The Order stated that because the regional procedures had not been submitted, the Commission proposed not to approve or remand PRC-003-0. Because PRC-003-0 (now PRC-003-1) is not enforceable, there is not a mandatory requirement for Regional Entity procedures to support the Requirements of PRC-004-2.1a… PRC-004-3 combines the reliability intent of the two legacy standards PRC-003-1 and PRC-004-2.1a.”

Because the FERC-approved PRC-004-4(i) combines the reliability intent of the legacy PRC-003 and PRC-004 series, WECC as the Regional Reliability Organization (AKA: RRO/Reliability Assurer (WECC)) no longer has a regulatory obligation under that legacy series of NERC Standards.

PRC-012 and PRC-016

The secondpremise for drafting the WECC CRT was compliance with PRC-016. The PRC-016 series does not directly add any additional requirements to the RRO; however, it does mandate compliance with PRC-012-0, Requirement R1 that requires WECC to “have a documented [regional Special Protection System] review procedure to ensure that [RASs] comply with Regionalcriteria and NERC Reliability Standards” to include nine specified criteria contained in R.1.1 through R1.1.9.[4]

Attachment A illustrates how WECC currently complies with the PRC-012 FITB legacy. Noting PRC-012-1 only requires that WECC have “procedures” (not a document categorized as a WECC Criterion), each element of the PRC-012 legacy is captured in other WECC documents. This means that any WECC obligation under that PRC-012/PRC-016 legacy has been met and the content of WR1 is not required to be retained in the WECC CRT for purposes of WECC’s compliance with the FITB standards. It could either be kept with no further action, retired immediately as redundant to the RASRS Procedure,or in the alternative, the language could migrate into the RASRS Procedure is additional detail was desired for that document.

Retirement of the RA Requirements

As for the remaining WRs, these are administrative in nature, addressed in the WECC Bylaws, Operating Committee Charter, and the RWG Charter. These requirements need not be specifically restated in a WECC Criterion and should be retired. (Attachment A, Table 2.)

Conclusion

All regulatory requirements for WECC as the RRO that are included in each of the four foundational NERC FITB Standards are either no longer required or are met in peripheral WECC documents. As such, WRs 2, 3, 4, and 5 should be retired as of July 1, 2016. The remaining WR1 could also be retired thereby retiring the entire WECC CRT.

Western Electricity Coordinating Council

WECC-0119 PRC-003-WECC-CRT-1.3 Removal of Reliability Assurer1

Attachment ATable 1 addressing PRC-012[5]

R1. Each Regional Reliability Organization with a Transmission Owner, Generator Owner, orDistribution Providers that uses or is planning to use a RAS shall have a documented RegionalReliability 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 / Meet 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[6] (PRC 12-14)
Special note: This WR2 is from PRC-(12 through 14)-WECC-CRT-2.1, Remedial Action Scheme Review and Assessment Plan – not PRC-003-WECC-CRT-1.3 (PRC 12-14). The inclusion here is to show how WECC would continue to meet the underlying FITB requirement if the identified WRs were retired. WR of PRC-(012 through 014)-WECC-CRT-2.1 is not proposed for retirement. See also PRC-012-0, R1.1; See also PRC-012-0, R1.2.
Although not proposed for retirement, this WR 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.
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, Attachment A requires submittal of information regarding: 1) operating procedures, design objectives, operating, and modeling.
This WECC Requirement is also 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.
This WR is not proposed for retirement. / Remedial Action Scheme Design Guide, June 2006. (Design)1
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.
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 requirements
defined in Reliability Standards TPL-001-0, TPL-002-0, and TPL-003-0.[7] / WR1. For each Misoperation of a Protection System or RAS that it owns and is applied to an Element described in Section A4.2 “Facilities,” each Transmission Owner and each Distributer Provider that owns one or more transmission Protection Systems, and each Generator Owner shall: (WR1.1 through WR1.4.) WECC CRT. / 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.[8] 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.
Once effective, 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.
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 thatrequired of the contingency for which it was designed, and not exceed TPL-003-0. / 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.
Once effective, 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.
R1.5. Requirements to demonstrate the proposed RAS will coordinate with other protection
and control systems and applicable Regional Reliability Organization Emergency
procedures. / Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability of a RAS Guideline, October 28, 2013.
Coordination with Protection and Control Systems, page 14, Bullet 8.
See also: 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.
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.
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.
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. 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. / Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability of a RAS Guideline, October 28, 2013.
“Introduction: This document provides a framework for the submission of a [RAS], to the [RAS} Subcommittee…. for evaluation and operation within WECC.”
R1.9. Determination, as appropriate, of maintenance and testing requirements. / Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability of a RAS Guideline, October 28, 2013.
“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 A, Table 2 Addressing Roles and Assignments

WR2.The Reliability Assurer (WECC) shall designate the Operating Committee to review…
WR3. The Reliability Assurer (WECC) shall designate the Relay Work group…
WR4. The Reliability Assurer (WECC) shall designate the Relay Work Group…
WR5.The Reliability Assurer (WECC) shall distribute any changes…(emphasis added)
All from the WECC CRT / The roles and assignments of WECC, the Operating Committee, and the Relay Work Group are dictated by the WECC Bylaws, the Operating Committee Charter, and the RWG Charter. Those roles and assignments need not be specifically re-stated in the WECC CRT. The RWG Charter specifies that it will receive its instructions from the Operating Committee. One primary role of the RWG is to provide technical support for Remedial Action Schemes.

Western Electricity Coordinating Council

[1] PRC-003-WECC-CRT-1.3, Analysis, Reporting, and Mitigation of Transmission and Generation Protection System and Remedial Action Scheme Misoperation Procedure

[2] Pursuant the Reliability Standards Development Procedures, Step 13 – Retire [a WECC Criterion], “Upon determining that the subject manner of [a WECC Criterion] is duplicate in a NERC Reliability Standard, and that retirement of the [WECC Criterion] will not cause a reliability gap after the effective date of the associated NERC Reliability Standard, the WSC may retire [a WECC Criterion] on its own initiative without further dueprocess.”

[3] NERC Implementation Plan for PRC-012-2, Remedial Action Schemes, Description of Current Draft.

A formal comment period and additional ballot for PRC-012-2 – Remedial Action Schemes, as well as a non-binding poll of the associated Violation Risk Factors and Violation Severity Levels concluded 8 p.m. Eastern, Friday, March 18, 2016 receiving the required affirmative vote. An effective date has not been established.

[4]The PRC-012-0/1 has an April 1, 2017 enforcement date. PRC-012-2 has passed a NERC ballot, and if approved by FERC, would eliminate the FITB requirements of its predecessors rendering moot any RRO/WECC requirement for compliance with the PRC-012 legacy.

[5] PRC-012-1 has an April 1, 2017 enforcement date. PRC-012-2 has passed a NERC ballot, and if approved by FERC, would eliminate the FITB requirements of its predecessors rendering moot any Regional Reliability Organization (RRO)/WECC requirement for compliance with the PRC-012 legacy.

[6] Because the RASRS documents refer back to the WECC CRT, the associated language in those documents would need to be updated in the event of retirement, e.g. RASRS Procedure: Attachment A, WECC RAS Database Information, page 2, para. 2. “In accordance with the Requirements of PRC-012 through 14 WECC CRT-1”.

[7] Arguably, the TPL-001, 2 Version Zeros no longer exists; therefore, the mandate no longer exists.

[8] These definitions will need to be updated because they incorporate by reference” TPL-(001 through 004)-WECC-1-CRT, System Performance Criteria”. That WECC Criterion no longer exists. All but the content of WR3 was retired via WECC Ballot Pool. WR3 is not addressed in TPL-001-WECC-CRT-3, System Performance.