Comment Report Form for WECC-0119B

Posting 1

The WECC-0119B PRC-(012 through 014)-WECC-CRT-2.1, Remedial Action Scheme Review and Assessment Plan (WECC PRC) Drafting Team (DT) thanks everyone who submitted comments on the proposed documents.

Posting

This document was last posted for a 30-day public comment period fromJuly 11 through August 11, 2016.

On July 8, 2016, WECC distributed notice of the posting via the Standards Email List.

The DT asked stakeholders to provide feedback on the proposed document through a standardized electronic template. WECC received comments from four entities as shown in the following table.

Location of Comments

All comments received on the document can be viewed in their original format on the WECC-0119Bproject page under the “Submit and Review Comments – RA Removal PRC-(012 through 014)-WECC-CRT-2.1” accordion.

Changes in Response to Comment

TEXT

Effective Date and Implementation Plan

The proposed effective date is immediately on approval by the WECC Board of Directors (Board). For clarification, if an entity is already up to date on requirements in the existing version, the new effective date does not reset the associated calendar requirements.

Justification

The WECC PRC and all of the supporting documents are currently in effect. There should be no change in operations or business practices as a result of the proposed changes.

Action Plan

A redlined version and a proposed clean version of the document will be provided for Posting 3. Posting 3 is targeted for August 22 through September 22, 2016. The DT will meet to address comments September 29 and again on October 6, 2016, as needed. If Posting 3 raises no new substantive issues, the DT will request that the WSC approve the document for ballot with subsequent disposition by the WSC and the WECC Board of Directors.

Contacts and Appeals

If you feel your comment has been omitted or overlooked, please contact W. Shannon Black, WECC Consultant, at . In addition, there is a WECC Reliability Standards Appeals Process that can be found in the Reliability Standards Development Procedures.

Commenter / Organization
1 / W. Shannon Black on behalf of Gene Henneberg and the Remedial Action Scheme Reliability Subcommittee (RASRS) / Western Electricity Coordinating Council (WECC), on behalf of the RASRS
2 / Jeri Freimuth / Arizona Public Service (APS)
3 / Patricia Robertson / British Columbia Hydro (BC Hydro)
4 / Johnny Anderson / Idaho Power
5 / Steven Rueckert / WECC[1]

Index to Questions, Comments, and Responses

Question

The Drafting Team welcomes comments on all aspects of the document.

  1. Response Summary

Summary Consideration: / See summary in the preamble of this document.
Commenter / Comment / Response
WECC – Black on behalf of Gene Henneberg and the RASRS / The following comments were ratified by the RASRS during the July 20, 2016, RASRS meeting.
The RASRS appreciates the opportunity to comment on the update of the PRC. For the following reasons, the RASRS is requesting that three terms used in the PRC be deleted from the WECC Glossary. The three terms contained in Attachment A, Row 4, Classifications, include: 1) the Local Area Protection Scheme (LAPS), 2) the Safety Net, and 3) Wide Area Protection Scheme (WAPS). Although these three terms are contained in the WECC Glossary of Terms, their content comes from the Procedure to Submit a RAS for Assessment / Information Required to Assess the Reliability of a RAS Guideline (Guideline). The Guideline is administered by the RASRS under the auspice of the Operating Committee (OC).
As used in the Attachment these capitalized listings are proper nouns and are not defined terms. Their definitional content comes directly from the Guideline, pages 5 and 6, and is a near-verbatim duplication of text between the WECC Glossary and the Guideline. This duplication creates redundancy and uncertainty in the administration of RASs, creates a potential negative impact on reliability, and should therefore be deleted from the WECC Glossary in favor of retention in the Guideline. Unlike the WECC Glossary, the Guideline at pages 5 and 6 contains an elaborate narrative supporting the terms; this narrative is lacking in the WECC Glossary which further clouds implementation of the terms. Finally, the WECC Glossary is administered by the WECC Standards Committee (WSC); the Guideline is administered by the OC. Deleting the terms from the WECC Glossary would eliminate the conflict of oversight.
In addition to deleting the terms from the WECC Glossary, the RASRS would request the following language be added to the Guidance Section of the PRC to ensure clarity.
Guidance Section
The capitalized terms used in Attachment A, Row 4, "Classifications" are used as proper nouns and not as defined terms. WAPS, LAPS, and Safety Nets are currently addressed by the Remedial Action Scheme Reliability Subcommittee, under the auspice of the Operating Committee. Additional information on WAPS, LAPS, and Safety Nets can be found in the Procedure to Submit a RAS for Assessment Information required to Assess the Reliability of a RAS Guideline, as updated from time-to-time.
The DT concurs that the following three terms should be eliminated from the WECC Glossary: 1) Local Area Protection Scheme (LAPS),2) the Safety Net, and 3) Wide Area Protection Scheme (WAPS). Definitions for the terms would be maintained by the RASRS in documents owned by that group or the associated Standing Committee.
The Guidance Section will be updated accordingly.
APS / AZPS supports the balance of the updates to this criterion; however, we suggest an area for clarification exists with regard to WR5. We recommend that the language of WR5 be revised to make clear that a staggered review of each RAS is permissible, if desired, rather than a single review of all RAS(s) at the same time. This would offer additional flexibility while still achieving reliability outcome of ensuring assessments occur on a periodic basis.
Clarification of WR5
The existing language was included in the criterion at APS’ earlier request. See WECC-0055, RAS Criterion PRC-012 – 014-WECC-CRT-1, Responses to Posting 1, Posted June 8 through July 26, 2010, Baj Agrawal, APS.
A clarification for WR5 has been added to the Guidance Section.
Guidance Section for WR5
WR5 should not be interpreted to mean that all of an entity’s RASs must be reviewed at once, unless they all are due for review at the same time. Reviews may be staggered.
BC Hydro / BC Hydro has the following comments:
1. WR1. BC Hydro assumes that if the data per Attachment A was provided under the previous version, there is no need to re-submit the data within 90 days after the Effective Date of the new version. DT can you please confirm?
2. WR3. In the previous version, the RA (WECC) was designated to maintain the WECC RAS Database. With the new version, there is no one assigned responsibility to maintain the database, however a Reporting Party needs to review the database for accuracy and report discrepancies. How will the Reporting Party know who's maintaining the database (if anyone is) and where the current database is posted? Will an entity be found in non-compliance if they've reviewed the wrong version of the database? What is the purpose of reporting discrepancies if no one is maintaining the database?
Deletion of WR1
WR1 will be deleted.
WR1 was initially included in order to create the WECC RAS database. The database has now been created and is being maintained by the RASRS; therefore, the need for the requirement no longer exists. Because the WR1 was specific to the needs of start-up, and because the content is duplicated in the Procedure, all of WR1 has been deleted.
Impact to Attachment A and Attachment B
All but the Reporting Party row of Attachment A will be deleted.
With the database up and running, and with the described content being near-fully replicated in the Procedure to Submit a RAS for Assessment, Information Required to Assess the Reliability of a RAS Guideline, Revised: October 28, 2013 (Procedure) (compare Attachment A of the Procedure with Attachment A of the WECC Criterion), the full content of Attachment A in the criterion is no longer needed. As a result, all rows of Attachment A in the criterion – except the Reporting Party – will be deleted. Although identification of the Reporting Party is near-replicated in the Procedure’s Attachment A, the language is not a precise carryover. Further, the Reporting Party row of the criterion’s Attachmentidentifies the applicable entity for many of the criterion’s requirements rendering retention of that row essential.
To retain the background of the original version the following narrative will be added to the Guidance Section:
The explanatory narrative in the criterion’s Attachment A has been deleted and updated into the criterion’s Guidance Section as follows. This should address BC Hydro’s concerns.
WECC Remedy Action Scheme (RAS) Database
When the first draft of this criterion was approved it met the NERC fill-in-the-blank (FITB) requirement to establish a WECC RAS database. The initial version required completion and submittal of a data set regarding RAS from which the WECC Remedial Action Scheme Reliability Subcommittee (RASRS) created the WECC RAS database. It is the WECC RASRS that maintains that database. The FITB standards described a discrete minimum data set for inclusion in the WECC RAS database but were silent on WECC’s ability to expand on that minimum.
Since the RASRS maintains the database, the RASRS also maintains the procedure whereby the database is populated. Instructions and explanations regarding the database are currently found in the Procedure to Submit a RAS for Assessment, Information Required to Assess the Reliability of a RAS Guideline, Revised: October 28, 2013, see pages 9 and 10 (Procedure). Because the Procedure is owned by the RASRS under the auspice of the Operating Committee (OC), its contents may change from time-to-time under the due process rules of the OC.
In light of the changes made to Attachment A, the following language will be deleted from Attachment B.
“Although the content of Attachment A and Attachment B are both provided to WECC, it is only the content of Attachment A that constitutes the minimum data to be contained in the WECC RAS database. This document shall not be interpreted as prohibiting the expansion of the WECC RAS database to include information beyond that contained in Attachment A.”
WR3 Maintenance of the RASRS
The underlying NERC fill-in-the-blank standards only require that WECC have a procedure for addressing the database. That procedure need not be resident in a WECC Criterion. The procedure addressing the database is contained in the Procedure to Submit a RAS for Assessment, Information required to Assess the reliability of a RAS Guideline, Revised: October 28, 2013, see pages 9 and 10 (Procedure). That document is best suited as the location for the mandated procedure because the RASRS represents the most qualified set of subject-matter experts and the Procedure is maintained by the RASRS under the auspice of the Operating Committee.
Specifically, that procedure states:
“The [RAS] database has been created and is maintained by the RASRS in the form of an Excel spreadsheet.” (emphasis added)
From a practical standpoint, all RAS activity gets channeled through the RASRS. “When a scheme has been reviewed and achieved either full or conditional acceptance by the RASRS….the scheme data is incorporated in the WECC RAS database.” (Loc. Cit. page 10) As such, the Reporting Party should have minimal difficulty locating the RAS database as well as accessing any RAS-related support.
As to BC’s compliance question, at the threshold there is no mandated compliance with a WECC Criterion – only adherence. Determining whether an entity is in adherence to a WECC Criterion falls outside of the purview of the drafting team. That said, the Procedure specifies that the RAS database is maintained by the RASRS; therefore, there is only one specified database. It is “the [RAS] database…maintained by the RASRS.”
Idaho Power / PRC Attachment A is similar to Attachment A of the "Procedure to Submit a RAS Assessment/Information Required" document, but the RASRS document provides better guidance.
Remove PRC Attachment B and utilize RASRS "Procedure to Submit a RAS Assessment/Information Required" document. RASRS, as Subject Matter Experts, already does scheme reviews and Attachment B is redundant.
Deletion of Attachment B
The DT declined to delete Attachment B as it is directly needed to support the additional features of WR6 and WR7, and peripherally for WR5.
WR2 requires that “Each Reporting Party shall use the process as established by the Remedial Action Scheme (RAS) Reliability Subcommittee (RASRS) when submitting a RAS for review.” “The information that should be included in the assessment is based on the requirements of PRC-014-0, R3.1-5 and outlined in Attachment B.” Procedure, Periodic Assessments, page 9.
The content of the Procedure Attachment B and the WECC Criterion Attachment B are identical. Since the underlying FITB standard does not mandate the type of document in which the procedure reside, it can be in either the WECC Criterion or the Procedure, but retention in both is redundant.
Attachment B is implicated in WR5, WR6, and WR7. Although a minor rewrite of WR5 could negate any need for reference to Attachment B, WR6 and WR7 require submittal of Attachment B and retention of that data, respectively. Although these features are included in the Procedure,WR6 adds the December 31 feature and WR7 adds the document retention feature – neither of which is directly included in the Procedure. This renders the WECC Criterion more specific than the Procedures.
The DT believes this is also in keeping with the Procedures in that “The RAS Criterion…requires annual reporting…intended to keep the RAS database up to date.” Procedures, page 10. As such, Attachment B should be retained for purposes of WR6 and WR7 (WR5 peripherally).
If the RASRS were to include these added features in the Procedure, both Attachment B and the added features would be clearly redundant. Without that clarity, Attachment B should be retained.
WECC - Rueckert /
  1. Old requirement 12, new requirement 7, seems to be a documentation issue rather than an actual requirement that promotes reliability. The DT should consider retiring the requirement.
  1. In the crosswalk of requirements from PRC-012 to where they are found in various WECC documents, I don’t think I understand the second column information for R1.3. It says it is met in PRC-003-WECC-CRT-1, WR1. PRC-012, R1.3 requires RAS be designed so that a single RAS component failure doesn’t prevent the interconnected system form [sic] meeting certain performance levels. This is a design and performance issue. PRC-003-WECC-CRT-1, WR1 requires analysis, documentation, and reporting of misoperations as well as the development of a corrective action plan so that misoperations do not occur again. This is an after the fact activity that doesn’t have anything to do with the initial design or system performance. The proposed justification should be amended to reflect this.
  1. In the same document, for R1.7, PRC-012, R1.7 requires documentation of Corrective Action Plans for mitigating future misoperations. The reference to the RAS Procedure, Corrective Action Plans, page 9 addresses the requirement for five-year RAS assessments for operation, coordination, and effectiveness. During these assessments, if a RAS is found to no longer be effective in ensuring acceptable performance for an event, the RAS must be redesigned so that it is still effective for the event it is designed. It doesn’t seem to me that these are the same things. I do agree that PRC-016 requires analysis and a CAP for RAS misoperations. Can the DT clarify or, in the alternative, amend the original justification?
  1. What WECC 1600 quarterly reporting of WECC Protection System Misoperations are you referring to that also includes RAS Misoperations? WECC doesn’t have any 1600 requests. NERC does have one for reporting Misoperations of Protection Systems, but it doesn’t include RAS at this time. Could the DT please clarify the 1600 issue or amend the justification document?

Retirement of WR7
WR7 will be deleted.
The DT concurs that WR7 is purely an administrative task and should be deleted. The deletion is in keeping with the spirit of NERC’s Find, Fix, Track, “P81” project targeted to eliminate requirements not specific to reliability.
The Crosswalk
At the threshold, the DT notes that the crosswalk was posted for comment from May 17 through July 1, 2016. WECC’s comments were received out of time on August 5, 2016.
The PRC-003-WECC-CRT-1 does not support the references NERC PRC-012, R1.3 requirement.
The DT agrees and will delete the reference. The premise of the crosswalk is to show redundancy. The column 2 reference will be deleted and buttressed in column 3 as follows:
See Procedure, Information Required to Assess the Reliability of a RAS, page 12. “Specifically, the scheme must still satisfy…single point of failure” requirements.
PRC-012, R1.7 cross reference to PRC-004-WECC-1 / 1600 Reference
The DT appreciates WECC’s insights. The reference will be deleted in favor of the PRC-016 reference that immediately follows it. The reference to WECC’s 1600 reporting will also be deleted. Although WECC has delegated authority to request such data, WECC has not issued any 1600 data requests.

[1] WECC’s Comment/Response software allows only one entry per person. Mr. Rueckert’s comments were received via email by Mr. Black on August 5, 2016 at 9:22 a.m. (MT). Due to software limitations Mr. Rueckert’s comments were added to those provided on July 20, 2016 by Mr. Black.