GDS NERC Compliance Bulletin

January 2014
FERC ORDER APPROVING NERC RELIABILITY STANDARD PRC-005-2 (HISTORY) On December 19, 2013, the FERC, in Docket RM13-7-000, approved the proposed NERC Reliability Standard PRC-005-2, six new definitions associated with the Standard, and an implementation plan petition of February 26, 2013. NERC proposed the new Reliability Standard in response to the FERC guidance provided in Orders 693 and 758. The FERC in approving Order 693 directed NERC to address two specific items: (1) develop a revision to PRC-005-1 incorporating a maximum time interval during which to conduct maintenance and testing of Protection Systems, and (2) to consider combining into one Standard the various maintenance and testing requirements for all of the maintenance and testing related Reliability Standards for Protection Systems, Special Protection Systems (SPS), underfrequency load shedding (UFLS) equipment, and undervoltage load shedding (UVLS) equipment. The FERC in approving Order 758 issued three additional directives addressing perceived deficiencies in the existing version of NERC Reliability Standard PRC-005-1. The three additional directives included (1) identifying and including the auxiliary relays and non-electrical sensing devices designed to sense or take action against any abnormal system condition that will affect reliable operation (such as sudden pressure relays); (2) include specific requirements for maintenance and testing of reclosing relays that affect the reliable operation of the bulk-power system; and, (3) include specific requirements for maintenance and testing of DC control circuitry. NERC Reliability Standard PRC-005-2 addresses a majority of the combined five directives issued by the FERC. The NERC Reliability Standard addresses: (1) maximum time intervals; (2) combining maintenance and testing Standards; and, (3) include specific requirements for maintenance and testing of DC control circuitry. NERC Reliability Standard PRC-005-2 did not address the following FERC directives (1) nonelectrical sensing devices and (2) maintenance and testing of reclosing relays. However, maintenance and testing of reclosing relays is being addressed in proposed NERC Reliability Standard PRC-005-3.

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NEW TERMS The development of PRC-005-2 saw the addition of six new terms. The terms are as follows:
Term Protection System Maintenance Program (PSMP) Definition An ongoing program by which Protection System components are kept in working order and proper operation of malfunctioning components is restored. A maintenance program for a specific component includes one or more of the following activities: Unresolved Maintenance Issue Segment Verify Determine that the component is functioning correctly. Monitor Observe the routine inservice operation of the component. Test Apply signals to a component to observe functional performance or output behavior, or to diagnose problems. Inspect Detect visible signs of component failure, reduced performance and degradation. Calibrate Adjust the operating threshold or measurement accuracy of a measuring element to meet the intended performance requirement.

A deficiency identified during a maintenance activity that causes the component not to meet the intended performance, cannot be corrected during the maintenance interval, and requires followup corrective action. Protection Systems or components of a consistent design standard, or a particular model or type from a single manufacturer that typically share other common elements. Consistent performance is expected across the entire population of a Segment. A Segment must contain at least sixty (60) individual components. Any one of the five specific elements of the Protection System definition. A Component is any individual discrete piece of equipment included in a Protection System, including but not limited to a protective relay or current sensing device. The designation of what constitutes a control circuit Component is dependent upon how an entity performs and tracks the testing of the control circuitry. Some entities test their control circuits on a breaker basis whereas others test their circuitry on a local zone of protection basis. Thus, entities are allowed the latitude to designate their own definitions of control circuit Components. Another example of where the entity has some discretion on determining what constitutes a single Component is the voltage and current sensing devices, where the entity may choose either to designate a full three phase set of such devices or a single device as a single Component. A failure of a Component requiring repair or replacement, any condition discovered during the maintenance activities in Tables 11 through 15 and Table 3 which requires corrective action or a Misoperation attributed to hardware failure or calibration failure. Misoperations due to product design errors, software errors, relay settings different from specified settings, Protection System Component configuration errors, or Protection System application errors are not included in Countable Events.

Component Type Component

Countable Event

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Of these newly defined terms, only the term Protection System Maintenance Program will be incorporated into NERCs Glossary of Terms, with the remainder applying only to Reliability Standard PRC-005-2. MAJOR DIFFERENCES BETWEEN STANDARDS The major differences between NERC Reliability Standard PRC-005-1b and PRC-005-2 are: Must develop a PSMP that includes: o Verification o Monitoring o Testing o Inspection o Calibration No longer able to set maximum intervals. Must perform a minimum amount of maintenance as defined by the Standard. Have a choice as to the maintenance method: o Time-Based o Performance-Based o Combination of the two UFLS, UVLS, and SPS relays now must be maintained with the same rigor as a Protection System (all Elements must be addressed). Utilization of performance-based maintenance methodology requires a Segment population greater than 60. o Can aggregate with other utilities if the entity cannot make the population by itself. o Cannot utilize relay manufacturers test data to make population. Required to demonstrate efforts to remediate Unresolved Maintenance Issues. Standard Breakout In accord with the FERC directive found in Order 693, NERC Reliability Standard PRC-005-2 incorporates multiple maintenance and testing Standards into one unified Standard.

PRC-008-0
UFLS Maintenance Programs

PRC-011-0
UVLS Maintenance/ Testing

PRC-005-1b
tPS & gPS Maintenance/ Testing

PRC-017-0
SPS Maintenance/ Testing

PRC-005-2

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NERC Reliability Standard PRC-005-2 requires Transmission Owners, Generation Owners, and Distribution Providers to document and implement programs for the maintenance of all Protection Systems through the implementation of a PSMP (Requirement 1). An entity is given a choice within the PSMP as to which maintenance method it utilizes to address each System Component Type. The maintenance methods are (1) time-based, (2) performance-based or (3) a combination of both methods (Requirement 1.1). A PSMP should contain the following specific components:

Verify
Determine if component is functioning correctly

Monitor
Observe the routine operation of the component

Test
Apply signals to a component to observe performance/ output behavior, or to diagnose problems

Inspect
Examine for signs of component failure, reduced performance or degradation

Calibrate
Adjust operating threshold or measurement accuracy to meet performance requirements

NERC Reliability Standard PRC-005-2 changes to a prescriptive Standard. The entity may continue to choose an interval as long as that interval does not exceed the maximum interval defined by the NERC Reliability Standard PRC-005-2 (Requirement 1.2). Also, NERC Reliability Standard PRC-005-2 sets forth minimum maintenance activities that must be performed for each Element of a Protection System. If an entity chooses to utilize the performance-based maintenance methodology, it must follow the procedure established in PRC-005 Attachment A Criteria for a Performance-Based Protection System Maintenance Program to establish and maintain its performance-based intervals (Requirement 2). CRITERIA FOR A PERFORMANCE-BASED PROTECTION SYSTEM MAINTENANCE PROGRAM An entity must develop a list with a description of components for each segment with a minimum Segment population of 60. If an entity would like to utilize the performance-based maintenance methodology, but does not meet the minimum population requirement of 60, the entity may choose to aggregate with other entities to make the minimum population. Relay manufacturer data cannot be utilized to meet the minimum population requirement. During the initial development of the performance-based program, the entity must maintain the timebased interval until such time that results of maintenance activities for 30 individual Components of the Segment has been obtained.

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Maintenance activities must be recorded for each Segment, especially Countable Events for each included Component. This will be used to analyze the overall performance and verify that Countable Events are within limits established in the Standard (no more than 4% of the Components within a given Segment). Then a maximum allowable maintenance interval can be determined and set. TO MAINTAIN THE TECHNICAL JUSTIFICATION FOR THE ON-GOING USE OF PERFORMANCEBASED PSMP At least annually, update the list of Protection System Components and Segments and/or description if any changes occur within the Segment. Perform maintenance on the greater of 5% of the Components (addressed in the performance based PSMP) in each Segment or three individual Components within the Segment in each year. For the prior year, analyze the maintenance program activities and results for each Segment to determine the overall performance of the Segment. Using the prior years data, determine the maximum allowable maintenance interval for each Segment such that the Segment experiences Countable Events on no more than 4% of the Components within the Segment, for the greater of either the last 30 Components maintained or all Components maintained in the previous year. If the Components in a Protection System Segment maintained through a performance-based PSMP experience 4% or more Countable Events, develop, document, and implement an action plan to reduce the Countable Events to less than 4% of the Segment population within three years. Entities that utilize a time-based maintenance methodology must maintain their Protection System Components as prescribed within the tables contained in the Standard: Tables 1-1 through 1-5 Component Type attributes, maximum maintenance intervals, and maintenance activities; Table 2 Alarming Paths and Monitoring, and Table 3 Maintenance Activities and Intervals for distributed UFLS and distributed UVLS Systems (Requirement 3). Entities can make their intervals stricter; however, they cannot make them less strict than the requirements of the tables. If an Unresolved Maintenance Issue is detected, efforts must be made to correct the issue (Requirement 5). In order to determine if an issue exists, an entity should have some type of process or procedure to define who determines the efficacy of the Protection System Element, what parameters are utilized to make that determination, and how the issue will be followed upon and ultimately remediated.

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IMPLEMENTATION

The implementation of PRC-005-2 is staggered with differing layers and levels of compliance interspersed throughout. The table below provides the event, implementation date, Requirement, and significance to the entity.
Event Regulatory Approval Beginning of first calendar quarter following Regulatory Approvals Beginning of first calendar quarter 12 months following Regulatory Approvals (1 year) Beginning of first calendar quarter 18 months following Regulatory Approvals (1-1/2 years) Beginning of first calendar quarter 24 months following Regulatory Approvals (2 years) Beginning of first calendar quarter 36 months following Regulatory Approvals (3 years) Date 2/24/2014 4/1/2014 Requirement(s) Significance Enforcement Date; 60 days after being filed in US Federal Register

4/1/2015

R1, R2, R5

100% Compliant

10/1/2015

R3, R4

100% Compliant for activities with maximum intervals less than 1 calendar year 30% Compliant for activities with maximum interval of 3 calendar years 100% Compliant for activities with maximum intervals 1 calendar year or more, but less than 2 calendar years 60% Compliant for activities with maximum intervals of 3 calendar years 30% Compliant for activities with maximum interval of 6 calendar years

4/1/2016

R3, R4

4/1/2017

R3, R4

Beginning of first calendar quarter 48 months following Regulatory Approvals (4 years) Beginning of first calendar quarter 60 months following Regulatory Approvals (5 years)

4/1/2018

R3, R4

100% Compliant for activities with maximum interval of 3 calendar years 60% Compliant for activities with maximum interval of 6 calendar years 30% Compliant for activities with maximum interval of 12 calendar years

4/1/2019

R3, R4

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Event Beginning of first calendar quarter 84 months following Regulatory Approvals (7 years) Beginning of first calendar quarter 108 months following Regulatory Approvals (9 years) Beginning of first calendar quarter 156 months following Regulatory Approvals (13 years)

Date 4/1/2021

Requirement(s) R3, R4

Significance 100% Compliant for activities with maximum interval of 6 calendar years 60% Compliant for activities with maximum interval of 12 calendar years 100% Compliant for activities with maximum interval of 12 calendar years

4/1/2023

R3, R4

4/1/2027

R3, R4

IMPACTS TO ENTITIES
The NERC Reliability Standard PRC-005-2 is an improvement over past PRC-005 Standards. Because PRC005-2 includes items not contemplated in prior versions, its implementation may have impacts to the entities. The addition of an Unresolved Maintenance Issue will require entities to contemplate a process for identifying and mitigating Protection System performance issues. Minimum levels of performance must be developed and maintenance activities compared to those performance levels. If a Protection System Component does not meet the minimum level of performance a mitigation effort will be required. The mitigation effort will need to be tracked until the Component is returned to normal. This documentation must be retained as evidence for Compliance Audits. The requirement (R1) to develop a PSMP may bring additional tasks as well. The PSMP requires (1) Verification, (2) Monitoring, (3) Testing, (4) Inspection, and (5) Calibration. While most of these items were performed in prior programs, all were not required. Entities may be faced with additional activities over previous programs. An entity no longer has the ability to set the maximum interval for each Component of the Protection System. The maximum intervals defined by NERC Reliability Standard PRC-005-2 may be shorter than previous programs. This may cause more frequent testing for entities which will need to be incorporated into work plans and budgets. The NERC Reliability Standard PRC-005-2 also defines minimum maintenance activities to be performed. Much like the interval, entities may find they must perform additional tasks and plan accordingly. While there appears to be many significant challenges for entities with the new Standard, overall the clarity provided will benefit entities, especially during Compliance Audits. Ultimately, the Standard provides more protection for the BES. If you have any questions regarding the PRC-005-2 Standard or other NERC compliance questions or concerns, please contact John Pasierb (john.pasierb@gdsassociates.com). GDS Associates, Inc. | PRC-005-2 7