WECC-0119A RA Removal PRC-003-WECC-CRT-1.31

Completed Actions / Date
Standard Authorization Request (SAR) Submitted / January 12, 2016
SAR Deemed Complete / January 12, 2016
WECC Standards Committee (WSC) approved SAR / January 28, 2016
Drafting Team First Meeting / April 7, 2016
Drafting Team Meeting / April 14, 2016
Posting 1 Open / May 17, 2016
Posting 1 Close / July 1, 2016[1]
DT metto Respond to Comments (forward to WSC for ballot to retire) / July 7, 2016
WSC approved Ballot to Retire / September 6, 2016
Anticipated Actions / Date
Ballot Pool Open / September 28, 2016
Ballot Pool Close / October 19, 2016
Standards Briefing / October 20, 2016
Ballot Open / October 26, 2016
Ballot Close / November 16, 2016
WSC ballot Review for WECC Board of Directors (Board) Approval / December 6, 2016
Board reviews for Approval / March 2017

Recommendation / Request for Comment

The WECC-0119A Removal of Reliability Assurer Drafting Team (DT) is recommending retirement of WECC CRT in its entirety, coincident with the July 1, 2016 effective date of PRC-004-4(i), Protection System Misoperation Identification and Correction (NERC PRC) because eachRequirement (WR) is either resident in another document or the associated requirement to perform has been extinguished.[2]

Attachments A and B illustrate how the requirements will continue to be met if the specified language is retired. Attachment C is a list of the survey questions asked with this posting.

Implementation Plan

After the DT considers comments and makes any appropriate changes, the DT will create and post redline and clean versions of the affected documents for an iterative round of comments. If the final project is approved by a WECC Ballot Pool the DT is recommending implementation immediately following approval by the WECC Board of Directors, unless otherwise stated in the Recommendation section.

Remediation of Conflict of Interest

Retirement of the WRs will address the Standard Authorization Request (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.

Overview

The WECC CRT was drafted to meet the Fill-in-the-Blank (FITB) requirements of PRC-003-1 Regional Procedure for Analysis of Misoperations of Transmission and Generation Protection Systems, Requirement R1. Requirement R1 cross-references other NERC Standards that, in turn, cross-reference even more NERC Standards. This practice is known as incorporation by reference. As a result, a review of each of the affected documents was completed to ensure that retirement of the WECC CRT would not inadvertently expose WECC to compliance concerns, and also to ensure there is no longer a need for the WECC CRT.

Affected Documents

The documents impacted by the incorporation by reference include:

  • 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 Legacy Series

On the July 1, 2016 effective date of NERC Standard PRC-004-4(i), Protection System Misoperation Identification and Correction, WECC’s FITB obligations under the PRC-003 and PRC-004 legacy extinguish, to the extent that they ever existed.[3] That event triggers retirement ofRequirement (WR) 2, 3, 4, and 5.

In the PRC-004-4(i) Background section it 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. This is a potential reliability gap; consequently, 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 PRC-003/PRC-004 legacy series, WECC as the Regional Reliability Organization (AKA: RRO/Reliability Assurer (WECC)) no longer has a FITB Requirement obligation under that legacy series of NERC Standards once PRC-004-4(i) becomes effective. Neither PRC-004-4(i) or PRC-004-5(i) (that becomes effective April 2, 2017) have any specific obligations imputed to WECC in any of the requirements. As such, the need to retain WR2, 3, 4, and 5 are extinguished on July 1, 2016.

PRC-012 and PRC-016 – Attachment A

The secondpremise for drafting the WECC CRT was compliance with PRC-016. The PRC-016 series does not directly impose any requirements on the RRO; however, it does mandate compliance with PRC-012-0, Requirement R1 that requires the RRO to have a documented RAS review procedure to ensure RASscomply with WECC and NERC requirements, including PRC-012-0, Requirement R.1.1 through R1.1.9. Thus, any FITB obligation under PRC-016 is null if the mandates of PRC-012 are met.

As to PRC-012, WECC arguablyhas no direct FITB obligation under the standard because it was never approved or remanded.[4] That said, Attachment A, Table 1 proceeds on the premise that the FITB requirements do exist and illustrates how WECC currently meets the FITB Requirements of that standard. At Requirement R1 of both PRC-012-0 and its successor PRC-012-1, Remedial Action Scheme Procedure, the standard only requires that the RRO/WECC “have a documented…RAS review procedure.” Because the standard makes no further specification as to what constitutes a procedure so long as the required content is documented the summation of thedocuments illustrated in the following Attachments constitute the required procedure. Because the procedures are resident outside of the WECC CRT, the specified WRs are redundant and can be retired.

Finally, in considering whether retirement is warranted, on April 29, 2016, PRC-012-2, Remedial Action Schemes, was approved by a NERC Ballot Pool. If assigned an effective date by FERC, PRC-012-2 will retire the PRC-012 legacy and will not require any direct performance from the RRO/WECC. In other words, even if the WRs are not retired, if PRC-012-2 is assigned an effective date the WECC Standards Committee (WSC) could likely retire the WRs on its own initiative pursuant Step 13 of the Reliability Standards Development Procedures (Procures) without further due process.[5]

Retirement of the RA Requirements – Attachment B

Attachment B, Roles and Assignments, illustrates how the remaining FITB administrative functions are being met in other WECC documents. Specifically, the mandates are within the purview of the WECC Bylaws, Operating Committee Charter, the Relay Work Group Charter, and arguably the Remedial Action Scheme Reliability Subcommittee (RASRS)and the Joint Guidance Committee Charter because of the inter-committee activities of the RASRS. These administrative requirements need not be specifically restated in a WECC Criterion and are redundant if retained in both the WECC CRT and the peripheral document(s); therefore, the WRs can be retired.

Alternative Content Disposition

With WR 2, 3, 4, and 5 no longer needed, only WR1 would remain in the WECC CRT. Rather than retain a WECC Criterion to warehouse a single WR, the DT is recommending the content of WR1 be immediately retired and relocated to either the Procedure to Submit a RAS for Assessment Information Required to Assess the Reliability, or another RAS-related document, as deemed appropriate by the RASRS. In other words: 1) the language would be immediately removed from the WECC CRT because it is redundant, 2) the RASRS would take charge of the language, and 3) acting under its charter and the expertise of its subject matter experts (SME), would review the WR1 language and control final disposition of that language in a document that does not raise the same conflict of interest.

Although relocation of the language specifically falls within the scope of the SAR, this DT is suggesting that the expertise of the RASRS may best augment that effort.

Attachment A

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, 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 / Met in WECC Criterion / Met 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)
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, WRs2, 4, and 8 through 12 are not proposed for retirement.[7]
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 theinterconnected transmission system from meeting the performance requirementsdefined in Reliability Standards TPL-001-0, TPL-002-0, and TPL-003-0.[8] / 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…meet PRC-003-WECC-CRT-1, WR1.1 through WR1.4.” PRC-003-WECC-CRT-1.3
The above language from the WECC CRT is recommended for retirement. The content is duplicated in either the RAS Design and/or the RAS Procedure.
The DT is recommending the content of WECC CRT, 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.
Finally, WECC’s obligations under the NERC Standard TPL series are also not currently enforceable as that legacy series no longer exists. Those three standards have been addressed via updated NERC Standards rendering the reference back null.
The majority of that content has been updated in TPL-001-4, Transmission System Planning Performance Requirements. Enforceable 1/1/2015. / 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.[9] 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 thesame 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. / 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 protectionand control systems and applicable Regional Reliability Organization Emergencyprocedures. / 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 RASmisoperation. / PRC-004-WECC-1, Protection System and Remedial Action Scheme Misoperation. Addresses misoperation but only for Applicable to Major WECC Transfer Paths only.
RAS Procedure. See Periodic Assessments addressing Corrective Action Plans, page 9.
This is also addressed 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

Roles and Assignments

Roles of WECC as the RA – proposed for retirement.
These WECC CRT WRs are proposed for retirement because they are covered in the associated charters and are not required for inclusion in a WECC Criterion. By contrast, their inclusion in a WECC Criterion creates a conflict of interest to be remedial via retirement.
WR2.The Reliability Assurer (WECC) shall designate the Operating Committee to review…
WR3. The Reliability Assurer (WECC) shall designate the Relay Work Group, or any other group that the [OC] designates…developing and posting changes to this document.
WR4. The Reliability Assurer (WECC) shall designate the Relay Work Group…to review each five years.
WR5.The Reliability Assurer (WECC) shall distribute any changes… (emphasis added) / The roles and assignments of WECC, the OC, the RASRS, and the 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.
  • WR2 is addressed in the 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.
  • WR3 is addressed in the Relay Work Group Charter.
    “The RWG shall: develop principles…evaluate…recommend appropriate [changes] for…RAS. RWG Charter, Purposes/Responsibilities. Distribution of information is addressed in Purposes/Responsibilities at d. through g., with the ubiquitous “other duties from the OC…as assigned.”
  • WR4 is redundant to 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….”
  • WR4 is also redundant to 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.
  • WR5 is redundant to 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….” Further, WR5 is addressed in the Relay Work Group Charter. “The RWG shall: develop principles…evaluate…recommend appropriate [changes] for…RAS. RWG Charter, Purposes/Responsibilities. Distribution of information is addressed in Purposes / Responsibilities at d. through g., with the ubiquitous “other duties from the OC…as assigned.”
  • WR5 is also redundant to the Procedures in that the Procedures 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.

Attachment C