SCE02V06

Application No.: A.
16-09-
Exhibit No.: SCE-02, Vol. 06
Witnesses: M. Flores
(U 338-E)
2018 General Rate Case
Transmission & Distribution (T&D)

Volume 06 – Substation Construction & Maintenance
Before the
Public Utilities Commission of the State of California
Rosemead, California
September 1, 2016
SUMMARY
This chapter describes SCE’s substation construction and maintenance activities, which include:
1. Inspection and maintenance of SCE’s substation equipment, including circuit breakers,
transformers, and relays;
2. Inspection and maintenance of miscellaneous substation equipment such as voltage
regulators, capacitors, disconnect switches, and other ancillary equipment;
3. Miscellaneous substation activities, such as substation drawing maintenance and updates;
4. Substation and Grid Control Center Operating activities such as outage maintenance and
grid monitoring; and,
5. Other substation activities, such as protection and control replacements, spare parts, tools
and work equipment, physical security and control room modernizations.
This exhibit presents SCE’s request for $78 million in O&M expenses for the 2018 Test Year
and $590 million in CPUC capital expenditures from 2016-2020 to effectively perform its functions.
Substation Construction & Maintenance O&M Expenses

2018 Forecast
(Total Company – Constant 2015 $Millions)
Substation Construction & Maintenance Capital Expenditure
2016-2020 Forecast
(CPUC-Jurisdictional Only – Nominal $Million)
SCE-02: Transmission & Distribution
Volume 06 - Substation Construction & Maintenance
Table Of Contents
Section Page Witness
I. SUBSTATION CONSTRUCTION, MAINTENANCE AND

OPERATIONS...................................................................................................1 M. Flores
A. Content and Organization ......................................................................1
B. Summary of O&M and Capital Request ................................................1
C. Regulatory Background/Policies driving SCE’s Request ......................3
D. 2015 Decision ........................................................................................4
1. Compliance Requirements .........................................................4
2. Comparison of Authorized 2015 to Recorded ...........................4
E. Substation Inspection and Maintenance Expenses ................................6
1. Circuit Breaker Inspection and Maintenance

(Portions of GRC Accounts 568.150 and 592.150) ...................6
a) Cost Forecast ..................................................................8
2. Transformer Inspection and Maintenance (Portions

of GRC Accounts 568.150 and 592.150) ...................................9
a) Cost Forecast ................................................................11
3. Relay Inspection and Maintenance (Portions of

GRC Accounts 568.150 and 592.150) .....................................12
a) Cost Forecast ................................................................13
4. Miscellaneous Equipment Inspection and

Maintenance (Portions of GRC Accounts 568.150
and 592.150) ............................................................................14
a) Cost Forecast ................................................................15
5. Miscellaneous Substation Expenses (Portions of

GRC Accounts 568.150 and 592.150) .....................................16
a) Cost Forecast ................................................................17
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Table Of Contents (Continued)
6. Substation Maintenance Crew Supervision (Portions

of GRC Accounts 568.150 and 592.150) .................................18
a) Cost Forecast ................................................................19
7. Substation Work Performed by Power Production

(GRC Accounts 562.150 and 582.150) ....................................19
a) Cost Forecast ................................................................20
F. Grid Operations O&M Expenses .........................................................21
1. Operating the Grid Control Center (GCC) (GRC

Account 561.170).....................................................................21
a) Monitoring and Operating SCE’s Bulk

Power System...............................................................21
b) Coordinating Planned Outages ....................................22
c) Developing and Maintaining Procedures .....................22
(1) Cost Forecast ....................................................23
2. Operating the Substation and Distribution System

(GRC Accounts 562.170 and 582.170) ....................................24
a) Cost Forecast ................................................................26
G. Substation Capital Expenditures ..........................................................27
1. Substation Capital Maintenance ..............................................27
a) Cost Forecast ................................................................29
2. Substation Protection and Control Replacements ....................30
a) Distribution & Transmission Protection and

Control System Replacement .......................................30
b) Digital Fault Recorder Replacement ............................30
c) Cost Forecast ................................................................31
3. Subtransmission Relay Upgrade Program ...............................32
-ii-
a) Overview ......................................................................32
b) Program Necessity .......................................................32
c) Program Description ....................................................33
d) Program Alternatives ...................................................34
e) Program Benefits .........................................................34
f) Cost Forecast ................................................................36
4. Substation Spare Parts..............................................................37
a) Cost Forecast ................................................................38
5. Substation Tools and Work Equipment ...................................40
a) Cost Forecasts ..............................................................41
6. Substation Physical Security ....................................................42
a) Copper Theft Program .................................................42
b) Tiered Physical Security Systems ................................43
(1) Tier 1 NERC CIP-014 Compliance

Program ............................................................43
(2) Tier 2-4 Physical Security Program .................44
c) Cost Forecast ................................................................45
7. Operational Facilities Maintenance .........................................46
a) Substation and Switching Center Facility

Maintenance .................................................................46
b) Control Building Modernization ..................................47
c) Cost Forecast ................................................................48
II. SUMMARY OF GRC ACCOUNTS ...............................................................50
A. GRC Account 561.170 .........................................................................50
-iii-
B. GRC Account 562.150 .........................................................................51
C. GRC Account 562.170 .........................................................................52
D. GRC Account 568.150 .........................................................................53
E. GRC Account 582.150 .........................................................................54
F. GRC Account 582.170 .........................................................................55
G. GRC Account 592.150 .........................................................................56
-iv-
1 I.
2 SUBSTATION CONSTRUCTION, MAINTENANCE AND OPERATIONS
3 A. Content and Organization
4 SCE’s transmission, sub-transmission, and distribution grid requires constant oversight and
5 control to provide safe, reliable, and continuous electrical service to its customers. Grid Operations, in
6 partnership with federal and state regulatory agencies, is responsible for monitoring and operating SCE’s
7 transmission and distribution system, which ranges from 120 volts to 500,000 volts and covers over
8 50,000 square miles of territory.
9 Operating the electrical system requires a staff of highly trained employees capable of
10 coordinating planned outages and responding to emergency situations, in stressful conditions.
11 Grid Operations personnel must monitor transmission equipment, sub-transmission equipment, and
12 distribution circuits and coordinate the actions of field personnel performing switching during planned
13 outages for construction or maintenance, or during unplanned outages for service restoration and
14 isolation of problems. System operators work closely with first responders in the field (i.e., troublemen
15 and substation operators) to restore service. Substation O&M activities include expenses to inspect and
16 maintain substation equipment such as circuit breakers, transformers, relays, and other equipment, and
17 the capital replacement of equipment that results from these inspections. This chapter also discusses
18 SCE’s systematic replacement of substation protection and control equipment, and substation claims and
19 spare parts.
20 This volume is structured as follows:
21 1. Overview of the substation maintenance, inspection and operations O&M and capital request;
22 2. Summary of regulatory background and policies that impact our substation operations;
23 3. Summary of the 2015 GRC Decision requirements including a comparison of authorized
24 versus recorded expenditures and expenses;
25 4. Substation O&M activities and our test-year request as summarized in Table I-1;
26 5. Substation Capital activities and our request as summarized in Table I-2 and Table I-3.
27 B. Summary of O&M and Capital Request
28 The tables below summarize the O&M and Capital activities discussed in this volume.
1
Table I-1
Substation Construction and Maintenance O&M Activities
(Total Company – Constant 2015 $000)
Activity 2018 Forecast
Circuit Breaker Inspection and Maintenance $5,652
Transformer Inspection and Maintenance $2,499
Relay Inspection and Maintenance $3,246
Miscellaneous Equipment Inspection and Maintenance $4,113
Miscellaneous Substation Expenses $2,980
Substation Maintenance Crew Supervision $4,344
Inspection and Maintenance of Substation Equipment (by Power Production) $1,908
Operating the Grid Control Center $9,813
Operating the Substation and Distribution System $43,594
Total $78,150
Table I-2
Substation Construction and Maintenance Capital Activities1
(Total Company – Nominal $000)
Description 2016 2017 2018 2019 2020
Substation Capital Maintenance 52,837 54,000 55,331 56,810 58,324
Substation Protection and Control Replacements 28,004 41,681 55,672 57,216 49,731
Subtransmission Relay Upgrade Program - - 41,589 42,893 44,257
Substation Spare Parts 17,184 4,549 4,664 2,123 2,161
Substation Tools and Work Equipment 5,400 5,477 5,580 5,682 5,785
Substation Physical Security 22,341 51,617 25,641 22,404 23,877
Operational Facility Maintenance 16,993 - - - -
LADWP-100% FERC in Workpapers Only 10,595 45,103 29,440 3,399 110
Total $153,354 $202,427 $217,917 $190,527 $184,246
Table I-3
Substation Construction and Maintenance Capital Activities
(CPUC-Jurisdictional – Nominal $000)
Description 2016 2017 2018 2019 2020
Substation Capital Maintenance 37,144 37,958 38,894 39,940 41,012
Substation Protection and Control Replacements 17,465 32,091 36,337 37,371 38,449
Subtransmission Relay Upgrade Program - - 41,589 42,893 44,257
Substation Spare Parts 5,284 4,549 4,664 2,123 2,161
Substation Tools and Work Equipment 5,400 5,477 5,580 5,682 5,785
Substation Physical Security 10,040 12,226 9,403 8,798 9,077
Operational Facility Maintenance 8,368 - - - -
LADWP-100% FERC in Workpapers Only - - - - -
Total $83,701 $92,302 $136,466 $136,806 $140,742
1 Los Angeles Department of Water and Power (LADWP) cost is for operation and maintenance of SCE’s
portion of Sylmar Converter Station and is 100% FERC jurisdictional.
2
1 C. Regulatory Background/Policies driving SCE’s Request
2 Certain SCE substations are California Independent System Operator (CAISO)-controlled
3 facilities under FERC jurisdiction. These include substations at 500 kV/220 kV and portions of
4 substations that transform power from 220 kV/115 kV and 220 kV/66 kV. All other substations are non-
5 CAISO controlled and are under the jurisdiction of the California Public Utilities Commission (CPUC).
6 SCE’s system includes 188 transmission substations and 677 distribution substations.
7 SCE’s substation construction and maintenance activities are regulated by several agencies that
8 implement standards, regulations, and/or perform audits that require SCE to perform asset management,
9 data tracking, reporting, and other compliance-related tasks. The Bulk Electric System (BES), which
10 primarily comprises transmission elements operated at 100 kilovolts (kV) or higher, is governed at the
11 national and regional level based on the design being an “interconnected group of lines and associated
12 equipment for the movement or transfer of electric energy between points of supply and points at which
13 it is transformed for delivery to customers or is delivered to other electric systems.”2 State level
14 organizations, such as the CPUC and the California Air Resources Board (CARB), provide regulatory
15 oversight over non-BES or distribution equipment responsible for delivering electricity to customers.
16 Since 2011, there has been an expansion in compliance activities that directly affect SCE work
17 practices. In 2011, California became the first state to enact mandatory sulfur hexafluoride (SF6)
18 emission reduction regulations through the California Air Resources Board (CARB).3 In the same year,
19 the North American Electric Reliability Corporation’s (NERC) approved both the Critical Infrastructure
20 Protection (CIP) Version 5 standards and the new versions of the Protection and Control (PRC)
21 standards.4 5 Additionally in 2012, the California Public Utilities Commission approved General Order
22 174 (GO 174) that requires SCE to inspect all of its substations on a routine basis and document any
23 anomalies found.6 NERC CIP compliance requires additional work for SCE due to the large scope of
2 “Glossary of Terms Used in NERC Reliability Standards” <http://www.nerc.com/files/glossary_of_terms.pdf/>.

3 “Final Regulation Order” <http://www.arb.ca.gov/cc/sf6elec/finalregulation.pdf>.
4 “Standard PRC-005-2(i) – Protection System Maintenance”
<http://www.nerc.com/pa/Stand/Reliability%20Standards/PRC-005-2(i).pdf>; “Standard PRC-005-6 –
Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance”
http://www.nerc.com/pa/Stand/Reliability%20Standards/PRC-005-6.pdf.
5 “Mandatory Standards Subject to Enforcement” http://www.nerc.net/standardsreports/standardssummary.aspx.
6 http://www.cpuc.ca.gov/gos/GO174/GO174_startup_page.html.
3
1 impact on personnel, processes, and procedures. Since SCE’s 2015 GRC, NERC revised the CIP and
2 PRC standards to expand the number of assets covered under these programs.7 Collectively, these
3 standards and regulations drive an increased scope of work that requires additional investment to
4 maintain SCE’s substations and grid operations. Rigid compliance deadlines require dedicated personnel
5 to perform activities: controlling change management, implementation of security patch releases,
6 protecting NERC CIP sensitive areas and information, and performing field assessments to ensure the
7 security posture of equipment in the substation and that the impact of all BES Cyber Systems have been
8 correctly evaluated. To meet these requirements, SCE has developed systems to streamline the process
9 and maintain compliance.
10 D. 2015 Decision
11 1. Compliance Requirements
12 The 2015 GRC Decision stated that “[i]n the next GRC, SCE should provide analysis of
13 the preemptive [circuit breaker] replacements in combination with other types of replacements.”8 SCE
14 substation circuit breakers are replaced through programs such as Infrastructure Replacement and
15 Substation Equipment Replacement Program (SERP, this program is focused on replacing over-duty
16 equipment) program. The 2015 GRC decision requires SCE to centralize discussion on breaker
17 replacement programs and summarize all programs. The description of all circuit breaker replacement
18 programs performed by T&D is included in SCE-02, Vol. 8. The reactive circuit breaker and transformer
19 replacements are detailed in Chapter G.1 of this volume.
20 2. Comparison of Authorized 2015 to Recorded
21 Figure I-1 summarizes our Test Year 2015 O&M request, the authorized amounts, and
22 our 2015 recorded costs compared to authorized amounts.
7 “V3-V5 Compatibility Tables” <http://www.nerc.com/pa/CI/Documents/V3-

V5%20Compatibility%20Tables.pdf>; “Implementation Plan”
<http://www.nerc.com/pa/Stand/CIP0036RD/CIP_Implementation_Plan_CLEAN_FERC_03112015.pdf>;
“CIP v5/v6 Implementation Plan” Tony Purgar
https://rfirst.org/compliance/Documents/RF%20CIPv5%20Workshop%20CIP%20v5v6_Implementation_Pla
n.pdf?Mobile=1.
8 See p. 80 of D.15-11-021.
4
Figure I-1
Substation Construction and Maintenance9
2015 GRC O&M Authorized Variance Summary
(Total Company – Constant 2015 $Millions)
1 The 2015 recorded O&M expenses for activities included in the volume was
2 approximately $7 million lower than authorized mainly due lower recorded costs in Substation
3 Inspection & Maintenance, which resulted from several factors including an accounting change in
4 division overheads implemented in 2014, a change in circuit breaker inspection cycles, and the re-
5 alignment of the Shop Services and Instrument Division (SSID).
6 Figure I-2 summarizes SCE’s Substation Construction and Maintenance Capital request
7 in the 2015 GRC, the 2015 GRC authorized amounts, and the variance between recorded and authorized
8 amounts.
9 Refer to WP SCE-02 Vol. 06, pp. 157-158 (O&M Authorized vs. Recorded).
5
Figure I-2
Substation Construction and Maintenance10
2015 GRC Authorized Variance Summary
2015 Capital
(CPUC-Jurisdictional – Nominal $Millions)
1 The 2015 recorded expenditures for substation construction and maintenance capital was
2 approximately $80 million over the amount authorized. The major cost increases were due to the
3 modernization of our operational facilities (substation control rooms) where our system operators are
4 located, compliance requirements for physical security, spare parts inventory replenishment, and
5 substation maintenance replacements including Coupling Capacitor Voltage Transformers (CCVT),
6 disconnect switches, power cable and ground grid upgrades.
7 E. Substation Inspection and Maintenance Expenses
8 1. Circuit Breaker Inspection and Maintenance (Portions of GRC Accounts 568.150
9 and 592.150)
10 The primary function of circuit breakers is to isolate problems on the electric system
11 before they can cascade into a complete system outage. Circuit breakers are the first line of defense in
10 Refer to WP SCE-02 Vol. 06, pp. 159-160 (Capital Authorized vs. Recorded).
6
1 the substation in protecting the system from an outside problem such as a surge in voltage due to a
2 lightning strike. Substation circuit breakers can be compared to circuit breakers in the average residence
3 from a basic functionality perspective. One of the primary differences is that in residences, the circuit
4 breaker performs the analysis and interruption functions. In a substation, the circuit breaker performs
5 only the interruption and relays perform the analysis. In addition, substation circuit breakers are larger
6 and more complex than a residential circuit breaker. A typical breaker in a residence may only be two
7 inches across and an inch thick, and must interrupt twenty amperes operating at 120 volts under normal
8 operations. A typical Distribution circuit breaker in a substation is approximately three feet square by
9 seven feet high, and can interrupt up to 3,500 amperes operating at 16,000 volts.
10 Due to their complexity, substation circuit breakers require routine maintenance. SCE’s
11 circuit breaker maintenance program involves calendar, use or condition-based maintenance. To help
12 maintain system reliability, SCE performs, at minimum, an annual inspection called a Circuit Breaker
13 Analysis (CBA). This is a process where a device is connected to a high voltage circuit breaker to
14 determine the circuit breaker’s health. The device interfaces with a computer that produces a graphical
15 representation of the mechanical operation of the breaker.
16 Further inspections, such as mechanism maintenance (MM) inspections, are performed
17 on set schedules or based on the number of operations a circuit breaker has performed. When used
18 together, these inspections increase the likelihood that the circuit breakers on SCE’s system are in good
19 condition and will provide safe and reliable service for customers.
20 MM inspections comprise a thorough cleaning and maintenance of the operating
21 mechanism of a circuit breaker. A substation circuit breaker comprises two main parts, the mechanism
22 cabinet and the main tank. The mechanism cabinet contains the controls, operating parts, and energy
23 storage device to move the main contacts. In a substation circuit breaker, there are different energy
24 devices to close and open the contacts. Some use compressed air. The MM inspection is performed
25 quadrennially on most circuit breakers, and in some of the extreme operating conditions is performed
26 more frequently and may be as often as an annual inspection. It includes changing the oil in the
27 compressor, cleaning the cabinet, taking measurements, and performing a CBA.
28 SCE performs an additional inspection called an Internal Inspection (II). This is a very
29 intrusive inspection and is performed on equipment selected based on equipment usage or condition of
30 the oil inside the main tank. This inspection requires removing the insulation medium (mineral oil or
31 sulfur hexafluoride gas (SF6)) and inspecting the main contacts. Other measurements and tests are
7
1 performed during this inspection and, depending on conditions, a capital replacement of the main
2 contacts or the entire breaker may be required.
3 The maintenance and repair activities mentioned above can vary widely in complexity,
4 costs, and resources required to perform them. Examples vary from a minor repair of replacing a control
5 switch, to an internal inspection of an oil-filled breaker.
6 a) Cost Forecast
Table I-4
Circuit Breaker Inspection and Maintenance11
Portions of GRC Account 568.150 and 592.150
Recorded and Adjusted 2011-2015/Forecast 2016-2018
(Constant 2015 $000)
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
568.150
Labor $1,737 $1,795 $1,867 $1,767 $1,550 $1,550 $1,550 $1,550
Non-Labor $708 $670 $699 $593 $625 $625 $625 $625
Subtotal 568.150 $2,445 $2,465 $2,567 $2,360 $2,175 $2,175 $2,175 $2,175
592.150
Labor $2,390 $2,578 $3,132 $2,565 $2,514 $2,514 $2,514 $2,514
Non-Labor $763 $568 $1,009 $589 $964 $964 $964 $964
Subtotal 592.150 $3,154 $3,146 $4,141 $3,154 $3,477 $3,477 $3,477 $3,477
Total $5,598 $5,612 $6,707 $5,514 $5,652 $5,652 $5,652 $5,652

Labor $4,127 $4,374 $4,999 $4,332 $4,064 $4,064 $4,064 $4,064
Non-Labor $1,471 $1,238 $1,708 $1,182 $1,588 $1,588 $1,588 $1,588
Ratio of Labor to Total 74% 78% 75% 79% 72% 72% 72% 72%
Basis of Forecast: Last Year Recorded

Basis of Labor/Non-Labor Split: Last Year Recorded Labor/Non-Labor Ratio
7 Transmission substation circuit breaker inspection and maintenance expenses are

8 recorded in GRC Account 568.150, while those for distribution substation circuit breaker inspection and
9 maintenance are recorded in GRC Account 592.150. Circuit breakers require annual inspection and
10 analysis to determine the health of the equipment. The results determine the maintenance activities
11 Refer to WP SCE-02 Vol. 06, pp. 1-113.
8
1 required for each circuit breaker, which vary from year-to-year, as described previously. Labor expenses
2 in this activity are for substation crews performing the work. Non-labor expenses are primarily for
3 materials such as replacement parts. Due to an accounting change in division overheads implemented in
4 2014,12 2011 – 2013 non-labor costs do not accurately reflect costs under current accounting practices.
5 As shown in Table I-4, SCE used last year (2015) recorded to forecast 2016 – 2018 as it best represents
6 a typical year for the combined inspection and repair costs, and is most reflective of the costs SCE will
7 incur for those activities under the updated accounting practices.
8 2. Transformer Inspection and Maintenance (Portions of GRC Accounts 568.150 and
9 592.150)
10 Transformers are one of the most important and expensive assets on the SCE electrical
11 grid and are essential to reliable power delivery. Their failure can pose unsafe conditions, lead to
12 extended outages for customers, and impose extraordinarily high costs on the utility. Therefore, routine
13 maintenance, diagnostic testing, and proper operation of transformers are of paramount importance in
14 maintaining service life and public and employee safety.
15 Substation transformers are composed of three main parts: main tank, bushings, and in
16 approximately twenty percent of transformers, a Load Tap Changer (LTC). Maintenance of these
17 transformers comprises a Dissolved Gas Analysis (DGA) and a detailed visual inspection of the
18 transformer and ancillary equipment. Each transformer equipped with an LTC will have the mechanism
19 serviced during the visual inspection. The LTC receives a DGA or an Oil Tap Changer Analysis (OTA)
20 depending on its configuration. Some LTC configurations do not facilitate a DGA or an OTA test. In
21 such configurations, an internal inspection of the device is performed on a periodic basis.
22 High-grade mineral oil is used in transformers to perform two functions: cooling and
23 insulation. Heat and moisture can degrade the transformer and the oil, and the DGA test is performed to
24 monitor this degradation. The OTA test performed on the LTC comprises a DGA and additional tests to
25 determine the health of the LTC oil, contacts, and associated parts immersed in the oil. These additional
26 tests include particulate analysis of metals and other materials found in the oil.
27 Based on the results of the DGA or OTA tests and inspections, further inspections
28 (including internal inspections) and diagnostic testing might be necessary to assess and repair the
12 See SCE-08 Vol. 03 and the response to Master Data Request Question I.A.12.
9
1 transformer and its ancillary devices, such as bushings, radiators, conservator tanks, and associated
2 components. Repairs can range from minor to major, costing a few hundred dollars to a few hundred
3 thousand dollars or more. An example of a minor repair would be replacing a cooling fan, while a major
4 repair would be an active leak on a transformer, which requires the transformer oil to be drained and
5 processed, and all gaskets replaced and the transformer refilled. These repairs may include replacement
6 of parts and ancillary equipment, or even the transformer itself. Diagnostic tests are also conducted after
7 routine or emergency field repairs to determine whether the transformer can be placed back in service.
8 LTC Internal Inspections involves very rigorous and detailed inspections of the tap
9 changer parts and mechanisms. These are typically performed if the results of the load tap changer
10 mechanism maintenance or OTA warrant further investigation.
10
1 a) Cost Forecast
Table I-5
Transformer Inspection and Maintenance13
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
568.150
Labor $797 $531 $829 $562 $534 $534 $534 $534
Non-Labor $672 $422 $568 $448 $445 $445 $445 $445
Subtotal 568.150 $1,469 $953 $1,397 $1,010 $979 $979 $979 $979
592.150
Labor $547 $586 $764 $809 $923 $923 $923 $923
Non-Labor $414 $640 $891 $606 $597 $597 $597 $597
Subtotal 592.150 $961 $1,227 $1,655 $1,415 $1,520 $1,520 $1,520 $1,520
Total $2,430 $2,179 $3,052 $2,425 $2,499 $2,499 $2,499 $2,499

Labor $1,344 $1,117 $1,593 $1,371 $1,457 $1,457 $1,457 $1,457
Non-Labor $1,086 $1,062 $1,459 $1,053 $1,043 $1,043 $1,043 $1,043

2 Transmission substation transformer inspection and maintenance expenses are

3 recorded in GRC Account 568.150, while those for distribution substation transformers are recorded in
4 GRC Account 592.150. As described previously, transformers are inspected and an oil analysis is
5 performed to determine the health of the equipment. The results determine the maintenance activities
6 required, which vary from year-to-year. Costs for these maintenance activities can also vary depending
7 on the repair needed. Labor expenses in this activity are for the substation crews performing the work.
8 Non-labor expenses are primarily for materials such as replacement parts.
11
1 Repairs to transformers can vary from year-to-year based on the severity and
2 quantity of those repairs. Due to an accounting change in division overheads implemented in 2014,14
3 2011 – 2013 non-labor costs do not accurately reflect costs under current accounting practices.
4 Accordingly, SCE used last year (2015) recorded to forecast 2016 – 2018 as it best represents a typical
5 year for the combined inspection and repair costs, and is most reflective of the costs we will incur for
6 those activities under the updated accounting practices. SCE used 2015 recorded costs to forecast 2016-
7 2018 expenditures.
8 3. Relay Inspection and Maintenance (Portions of GRC Accounts 568.150 and 592.150)
9 Protective relays work with circuit breakers to monitor the operating conditions of the
10 entire electrical grid and play a critical role in protecting the system during abnormal conditions. The
11 malfunction or failure of a protection system to operate as designed can cause hazards to the public,
12 equipment damage, or wide area disturbances. Therefore, periodic maintenance and system testing of
13 protective relays is of paramount importance in maintaining a safe and reliable electrical grid.
14 The purpose of SCE’s relay inspection and maintenance program is to determine the
15 performance, functionality, and availability of the protection systems. This process comprises a visual
16 inspection, calibration, verification of proper electrical signals, secondary cable insulation testing,
17 control and trip circuitry, and an overall system communications test. Based on these inspections,
18 protection system components might require repairs or replacement of electrical components such as
19 power supplies, input/output modules, Current Transformer/Potential Transformer (CT/PT) modules,
20 user interface modules, or communication cards. Obsolescence of electrical components may require the
21 replacement of the protective relay.
22 In 2014, SCE implemented additional documentation requirements to address new
23 requirements associated with Critical Infrastructure Protection (CIP) Version 5.15 Some are one-time
24 activities and others will be ongoing. The one-time activities were initial data gathering efforts that
25 included password validation, baseline configuration, and ports and services. These one-time costs are
26 included in Section 5, Miscellaneous Substation Expenses (Portion of GRC Account 592.150). The
15 See SCE witness John Pespisa’s testimony in SCE-08 Vol. 01.
12
1 ongoing activities in this account include ports and services validation, compliance logging, installing
2 cyber security patches, and maintaining the electronic and physical security perimeters.
3 a) Cost Forecast
Table I-6
Relay Inspection and Maintenance16
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
568.150
Labor $1,436 $1,507 $1,412 $1,093 $1,024 $1,024 $1,024 $1,024
Non-Labor $516 $296 $301 $181 $214 $214 $214 $214
Subtotal 568.150 $1,952 $1,803 $1,713 $1,274 $1,238 $1,238 $1,238 $1,238
592.150
Labor $2,374 $1,266 $1,295 $1,632 $1,596 $1,596 $1,596 $1,596
Non-Labor $718 $410 $427 $266 $411 $411 $411 $411
Subtotal 592.150 $3,092 $1,676 $1,722 $1,898 $2,008 $2,008 $2,008 $2,008
Total $5,044 $3,480 $3,435 $3,172 $3,246 $3,246 $3,246 $3,246

Labor $3,810 $2,774 $2,707 $2,725 $2,621 $2,621 $2,621 $2,621
Non-Labor $1,235 $706 $728 $446 $625 $625 $625 $625

4 Relays require periodic maintenance and system testing to determine the health of
5 the equipment. In 2011, SCE implemented a new maintenance program that addresses the five
6 protection system components: relays, direct current (DC) supply, current and voltage sensing devices,
7 DC control circuitry, and associated communication circuits. These five components make up a
8 protection system under the recently approved regulatory standard PRC-005-2 by the North American
9 Electric Reliability Corporation (NERC) board of trustees. Because of this new maintenance program
10 that extended the time between inspections, SCE decided to levelize the number of inspections to
13
1 balance workload. As can be seen in Table I-6, SCE accomplished most of this levelization effort in
2 2011 to minimize work load impacts in future years.
3 In addition to the new testing requirements implemented in 2011, SCE added
4 more documentation requirements in 2014 to address the new requirements associated with Critical
5 Infrastructure Protection (CIP) Version 5. These additional activities include ports and services
6 validation, compliance logging, installing cyber security patches, and maintaining the electronic and
7 physical security perimeters.
8 Since the additional testing and documentation were both fully implemented in
9 2015, the costs recorded in these year are the best representation of level of activity and expenses we
10 expect to incur in the future. SCE utilized the last year (2015) recorded costs as the basis for our 2016 –
11 2018 forecasts, as shown in Table I-6.
12 4. Miscellaneous Equipment Inspection and Maintenance (Portions of GRC Accounts
13 568.150 and 592.150)
14 Apart from the major equipment classes detailed above, substations house a wide variety
15 of electrical equipment and structures that are integral to the controlled flow of electricity and equipment
16 protection. The equipment and structures receive periodic inspections. Some of the equipment detailed
17 below receive scheduled maintenance that includes testing, lubrication and/or a thorough cleaning, while
18 others are visually inspected by crews for corrosion, leakage, and degradation.
19 Detailed inspections and tests are conducted if anomalies are noted during scheduled
20 maintenance. If severe enough, equipment could be tagged for replacement. Routine maintenance at
21 substations also includes regularly scheduled equipment washing to remove dirt and pollutants from the
22 equipment exterior and structures. The miscellaneous equipment and structures can be divided into three
23 main categories.
24 • Voltage regulation includes equipment used for maintaining a constant voltage level
25 for the electricity being distributed to customers from the substations. Equipment in
26 this category includes voltage regulators and capacitors.
27 • Disconnect Switches are devices installed to allow substation equipment, such as
28 circuit breakers and power transformers, to be isolated from service for maintenance
29 and to redirect power flow.
30 • Support Equipment is the ancillary equipment needed to support the operation of
31 primary equipment such as circuit breakers, power transformers, and protective
14
1 relays. Equipment in this category include power cables used to interconnect high
2 voltage equipment, battery systems installed to provide power for protective relays,
3 apparatus controls, communications, emergency lighting, remote terminal units,
4 System Control and Data Acquisition (SCADA) equipment used to convey
5 information to Grid Operations, and trench covers essential to protect control and
6 power cables from weather and other external factors and allow easy and safe access
7 by personnel.
8 a) Cost Forecast
Table I-7
Miscellaneous Equipment Inspection and Maintenance17
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
568.150
Labor $1,079 $1,247 $1,142 $1,406 $1,347 $1,347 $1,347 $1,347
Non-Labor $655 $674 $496 $265 $355 $355 $355 $355
Subtotal 568.150 $1,733 $1,921 $1,638 $1,670 $1,702 $1,702 $1,702 $1,702
592.150
Labor $1,802 $1,429 $1,407 $1,723 $1,523 $1,523 $1,523 $1,523
Non-Labor $715 $558 $678 $400 $889 $889 $889 $889
Subtotal 592.150 $2,517 $1,987 $2,085 $2,123 $2,411 $2,411 $2,411 $2,411
Total $4,250 $3,908 $3,723 $3,793 $4,113 $4,113 $4,113 $4,113

Labor $2,881 $2,676 $2,549 $3,129 $2,870 $2,870 $2,870 $2,870
Non-Labor $1,369 $1,232 $1,174 $664 $1,244 $1,244 $1,244 $1,244

9 Miscellaneous equipment represents all other equipment and structures inside a

10 substation, excluding transformers, circuit breakers, and relays. Each asset group within this category
15
1 has different periodic inspection and maintenance requirements. The results determine the maintenance
2 activities required, which vary from year-to-year. Due to an accounting change in division overheads
3 implemented in 2014,18 2011 – 2013 non-labor costs do not accurately reflect costs under current
4 accounting practices. Accordingly, SCE used last year (2015) recorded to forecast 2016 – 2018 as it best
5 represents a typical year for the combined inspection, maintenance, and repair costs for miscellaneous
6 equipment, and is most reflective of the costs SCE will incur for those activities under the updated
7 accounting practices. These forecasts are reflected in Table I-7 above.
8 5. Miscellaneous Substation Expenses (Portions of GRC Accounts 568.150 and
9 592.150)
10 Miscellaneous substation expenses include costs to operate and maintain substations not
11 directly related to inspection and maintenance programs or first line supervision. As part of regular
12 operational transactions, substation personnel rely on a variety of services like document handling,
13 copying, and printing. This includes updating and maintaining wiring diagrams and equipment
14 schematics for technical support personnel and crews. The costs also include the services to update and
15 disseminate the documents developed.
16
1 a) Cost Forecast
Table I-8
Miscellaneous Substation Expenses19
Portions of GRC Accounts 568.150 and 592.150
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
568.150
Labor $1,436 $1,390 $1,545 $809 $838 $838 $838 $838
Non-Labor $1,249 $1,163 $1,296 $743 $651 $651 $651 $651
Subtotal 568.150 $2,685 $2,553 $2,841 $1,552 $1,489 $1,489 $1,489 $1,489
592.150
Labor $608 $753 $830 $830 $1,003 $1,003 $1,003 $1,003
Non-Labor $702 $936 $746 $1,864 $488 $488 $488 $488
Subtotal 592.150 $1,310 $1,689 $1,576 $2,694 $1,491 $1,491 $1,491 $1,491
Total $3,995 $4,242 $4,417 $4,246 $2,980 $2,980 $2,980 $2,980

Labor $2,044 $2,143 $2,376 $1,639 $1,841 $1,841 $1,841 $1,841
Non-Labor $1,951 $2,099 $2,041 $2,607 $1,139 $1,139 $1,139 $1,139

2 Additional activities covered in this account include equipment calibration and

3 testing and personnel relocations. In 2013 SCE shut down San Onofre Nuclear Generating Station
4 (SONGS). As a result, SCE’s Shop Services and Instrument Division (SSID), which serviced many of
5 the needs of SONGS, was discontinued. Due to the reduced scope of SSID’s function, there is a
6 corresponding reduction in 2014 and 2015 in this account as shown in Table I-8.
7 To retain the skilled workers from SSID and SONGS, SCE filled vacancies with
8 a number of these employees requiring some to re-locate to other areas of the company, sometimes over
9 a 100 miles away from their previous position’s work location. In 2014 SCE incurred costs of
10 approximately $700,000 to relocate these employees. These expenses are reflected in the non-labor cost
17
1 increase in 2014 in GRC Account 592.150. As a result of the reduced scope of work related to the
2 SONGS shutdown, and the cost incurred to relocate employees in 2014, recorded 2015 costs best
3 represents SCE’s base miscellaneous substation expenses going forward. Therefore, SCE used 2015
4 recorded costs to forecast expenditures in 2016 – 2018.
5 6. Substation Maintenance Crew Supervision (Portions of GRC Accounts 568.150 and
6 592.150)
7 The first-line supervisors of substation maintenance crews work closely with the crews to
8 make sure they are working safely, provide on the job training, schedule work assignments and tasks,
9 provide oversight and quality assurance. Since the crews perform many activities throughout the day, we
10 do not track precisely how much time they spend on transmission versus distribution substation work.
11 The supervisor charges are split approximately evenly between Transmission and Distribution accounts
12 because the split reflects that supervisors typically split their time overseeing and addressing
13 transmission related and distribution related activities, evenly. The non-labor costs in these sub-accounts
14 are composed of general expenses incurred by employees while working and related vehicle charges.
18
1 a) Cost Forecast
Table I-9
Substation Maintenance Crew Supervision20
Portion of GRC Account 568.150 and 592.150
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
568.150
Labor $1,954 $1,934 $2,172 $2,000 $1,863 $1,863 $1,863 $1,863
Non-Labor $464 $469 $514 $147 $148 $148 $148 $148
Subtotal 568.150 $2,418 $2,404 $2,686 $2,147 $2,011 $2,011 $2,011 $2,011
592.150
Labor $2,291 $2,247 $2,451 $2,233 $2,168 $2,168 $2,168 $2,168
Non-Labor $515 $528 $559 $187 $165 $165 $165 $165
Subtotal 592.150 $2,806 $2,775 $3,010 $2,420 $2,333 $2,333 $2,333 $2,333
Total $5,224 $5,178 $5,696 $4,567 $4,344 $4,344 $4,344 $4,344

Labor $4,246 $4,181 $4,623 $4,233 $4,031 $4,031 $4,031 $4,031
Non-Labor $978 $997 $1,072 $334 $313 $313 $313 $313

2 SCE used 2015 recorded costs to forecast 2016 – 2018 expenditures-.

3 Maintenance crew supervision varies only slightly from year-to-year and 2015 represents a typical year.
4 The total forecasts were allocated between labor and non-labor expenses based on the 2015 ratios. The
5 forecasts for maintenance crew supervision expenses are shown in Table I-9.
6 7. Substation Work Performed by Power Production (GRC Accounts 562.150 and
7 582.150)
8 SCE owns several substations in remote parts of SCE’s service territory, primarily in the
9 Big Creek and Bishop areas. Since many are within SCE hydroelectric or other facilities operated by
10 SCE’s Power Production Division (PPD), those crews are responsible for substation operations and
19
1 maintenance. These PPD managed substations include nine transmissions substations (GRC Account
2 562.150) and 48 distribution substations (GRC Account 582.150), many of which also serve as backup
3 power to SCE hydroelectric powerhouses.
4 a) Cost Forecast
Table I-10
Inspection and Maintenance of Substation Equipment21
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
562.150
Labor $587 $317 $638 $859 $1,119 $1,119 $1,119 $1,119
Non-Labor $712 $414 $434 $351 $456 $456 $456 $456
Subtotal 562.150 $1,299 $731 $1,072 $1,210 $1,575 $1,575 $1,575 $1,575
582.150
Labor $93 $90 $128 $158 $300 $300 $300 $300
Non-Labor $3 $14 $43 $28 $33 $33 $33 $33
Subtotal 582.150 $96 $103 $171 $186 $333 $333 $333 $333
Total $1,395 $835 $1,243 $1,396 $1,908 $1,908 $1,908 $1,908

Labor $680 $407 $766 $1,017 $1,419 $1,419 $1,419 $1,419
Non-Labor $715 $428 $477 $379 $489 $489 $489 $489

5 As shown in Table I-10, the recorded costs have increased for both the
6 transmission and distribution substation work from 2013 through 2015. 2012 recorded expenses are
7 lower than other years due to the higher mix of capital work performed in 2012.
8 The increase in costs in 2013 – 2015 is due to the higher number of O&M repairs
9 conducted. This effort to identify repairs began in 2013 to evaluate equipment and prioritize work
20
1 required to maintain equipment for safe and reliable operations. SCE anticipates the same level of
2 activity in 2016-2018.
3 As shown in Table I-10, SCE utilized last year recorded cost in 2015 as the basis
4 for forecast expenditures in 2016-2018. SCE used the last year recorded to forecast 2016 – 2018 as it
5 represents a typical year for the combined inspection, maintenance and repair costs for this account. This
6 is also consistent with Commission guidance to use the last recorded year’s expenses as a base to
7 forecast test year levels, if the past three recorded years show a trend in a certain direction.
8 F. Grid Operations O&M Expenses
9 1. Operating the Grid Control Center (GCC) (GRC Account 561.170)
10 The Grid Control Center (GCC) is responsible for the overall monitoring and control of
11 SCE’s transmission system. The GCC acts as the primary point of contact for the California Independent
12 System Operator (CAISO) and has the authority and obligation to direct SCE’s transmission grid
13 operations during normal and emergent conditions. These activities are critical for maintaining system
14 reliability and meeting regulatory compliance requirements. The GCC staff comprises 44 employees,
15 including power system operators, operating engineers, and managers.22 GCC activities can be
16 categorized into three main responsibilities: monitoring and operating SCE’s bulk power system,
17 coordinating planned outages, and developing and maintaining operating procedures.
18 a) Monitoring and Operating SCE’s Bulk Power System
19 GCC personnel monitor the bulk power system around the clock from a single
20 control room using SCE’s Energy Management System (EMS) and a dynamic dispatch via electronic
21 maps that graphically depicts the status of SCE’s and adjacent utilities’ bulk power systems. GCC
22 personnel use these tools to monitor operating parameters such as voltage, frequency, power flow, and
23 equipment status. When system conditions change, the power system operators and engineers access the
24 information in real time, determine if corrective action is necessary, and instruct SCE’s switching
25 centers to execute the actions. To comply with regulatory requirements, Grid Operations also maintains
26 a separate Alternate Grid Control Center (AGCC) as a backup to its primary control room. If the GCC
27 becomes inoperable, the AGCC will allow SCE to meet regulatory requirements to operate and monitor
28 its bulk power system with minimal interruption.
22 See WP SCE-02 Vol. 06, pp. 161-162 (GCC Org Chart 2016).
21
1 b) Coordinating Planned Outages
2 The GCC manages the outage coordination activity for SCE with the CAISO and
3 external parties, such as neighboring utilities. Outages are planned to allow crews to install, remove, or
4 repair equipment on the bulk power system. The GCC also coordinates outage parameters, i.e., location,
5 schedule and duration, with the CAISO and any adjacent utilities to optimize work and reliability.
6 Similarly, when external parties, such as neighboring utilities, schedule outages or need to work on their
7 equipment, the GCC manages the communications and coordination for SCE to maintain system
8 reliability and minimize risk of service impacts to customers.
9 GCC personnel play a key governance and control role during planned outages to
10 facilitate reliability of the bulk-power grid and safety of the personnel working on it. They study and
11 review outage requests for operational feasibility, adherence to established operational procedures, and
12 impact on power flow. Detailed technical analyses are conducted to identify and address any operational
13 concerns or constraints and to establish necessary outage parameters. As maintenance work requests
14 come to the GCC, power flow, dynamic stability, and post-transient voltage stability analyses are
15 performed to evaluate and plan for the safe and reliable operation of the bulk power system during the
16 outage. These studies help identify any load or generation limits that may need to be imposed before an
17 outage can proceed.
18 When an outage has ended, power flow is being restored, or new equipment is
19 placed in service on the bulk power system, the GCC determines the proper procedure to safely energize
20 the equipment and place it in service.
21 c) Developing and Maintaining Procedures
22 The GCC also develops, implements, and maintains procedures for power system
23 operators and switching center operators to use when performing real-time operational activities, which
24 helps maintain reliability during both normal and emergency operating conditions. Procedures
25 developed by the GCC that involve lines and equipment under the CAISO’s purview is submitted to the
26 CAISO for review. This process enables proper coordination and continuity with any CAISO operating
27 procedures.
28 GCC personnel are responsible for compliance with several NERC reliability
29 standards: Transmission Operations and Monitoring, Emergency Preparedness and Operations,
30 Interconnection Reliability Operation and Coordination, and Voltage and Reactive (VAR) control.
22
1 When these NERC standards change, GCC personnel must develop new procedures and participate in
2 any additional training required to meet the new standards.
3 (1) Cost Forecast
Table I-11
Grid Control Center23
GRC Account 561.170
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Labor $5,292 $5,312 $5,664 $6,150 $7,297 $7,297 $7,297 $7,297
Non-Labor $2,861 $3,075 $3,050 $3,073 $2,517 $2,517 $2,517 $2,517
Total $8,154 $8,387 $8,713 $9,224 $9,813 $9,813 $9,813 $9,813

4 Table I-11 above shows the recorded and forecast costs for this activity.
5 The labor costs in this activity are driven by the number of GCC personnel. As projected in the 2015
6 GRC, SCE achieved the staffing level of 41 for GCC and AGCC.24 In addition, we have identified the
7 need for better coordination with SCE’s generator interconnection customers due to the growing
8 penetration and complexity of renewable energy connections to the transmission and the distribution
9 systems. To address the need for better coordination, SCE formed a specialized group in 2014
10 comprising three employees with the express purpose of coordinating grid outages with the generator
11 interconnection customers. The group conducts periodic town hall meetings for improved
12 communications and coordination, develops policies regarding outage impacts and notifications,
13 interfaces with internal project management and craft personnel on outages, and acts as the single point
14 of contact to manage customers’ questions and complaints.

24 See WP SCE-02 Vol. 06, pp. 163-164 (GCC Headcount 2011-2018).
23
1 Due to division overhead accounting change starting 2014,25 2015
2 recorded costs are most representative of the expense level required for the future operation of the GCC
3 and AGCC. This level of expenses includes the three new positions added in 2014 for the generator
4 interconnection customer coordination group. Additionally, we anticipate the amount and scope of work
5 to continue at 2015 levels going forward, and therefore expect to maintain 2015 staffing levels through
6 the test year. Accordingly, SCE used the last year (2015) recorded to forecast 2016 – 2018 as it is our
7 best representation of what we expect to incur in 2018 to safely and reliably operate the GCC and
8 AGCC. These costs and forecasts are shown in Table I-11.
9 2. Operating the Substation and Distribution System (GRC Accounts 562.170 and
10 582.170)
11 While the GCC is responsible for monitoring and controlling the bulk power system, the
12 day-to-day operation of the sub-transmission and distribution system is carried out by 14 switching
13 centers geographically dispersed throughout the system. The operation of these switching centers relies
14 primarily on two types of employees: system operators and substation operators.
15 System operators are stationed within the switching centers and are responsible for
16 remotely operating the portion of the transmission, sub-transmission and distribution system within their
17 geographic control area. This requires that each switching center comply with published system
18 operating bulletins that set operating parameters for electrical control equipment on the system. In
19 addition, 865 manned and unmanned substations are on the system.
20 Besides monitoring and operating the portion of the grid they are responsible for, system
21 operators also write switching programs used to electrically isolate, de-energize, or test equipment in the
22 field to support maintenance or capital work. The increasing number of switching procedures is based on
23 the work performed by transmission, substation, and distribution construction and maintenance
24 organizations.
25 Substation operators perform routine and emergency switching and visually inspect
26 substation equipment. Substation operators travel to various substations within their assigned
27 geographical areas to perform their work.
24
1 The information gathered from the visual inspections performed by substation operators
2 and the detailed inspections performed as part of the substation maintenance and inspection program are
3 both used for planning substation maintenance work. Substation operators also inspect the physical
4 facilities and perimeter of substations for damages to structures (including vandalism), and
5 encroachments by vegetation or wildlife. These inspections are required by regulatory agencies,
6 including CAISO, CPUC and WECC, and are critical to the safety of both SCE crews and the public. In
7 2013, the CPUC adopted General Order 174, which requires documented inspections of all substations.
8 Besides mandated inspections, substation operators investigate reports of unusual events at SCE’s
9 substations, such as alarms generated by equipment within the substation or reports from the public, an
10 animal inside a substation, intrusion by unidentified parties into the substation, or a change in equipment
11 status due to an earthquake or storm.
12 Substation operators also perform routine switching to support planned work that requires
13 an outage, and emergency switching to respond to any unplanned events that affect the grid. Routine
14 switching involves de-energizing and isolating equipment that requires maintenance or capital work. All
15 switching done by substation operators is performed at the substations, as opposed to remote switching
16 performed by system operators from switching centers. To perform this work, substation operators
17 follow detailed switching procedures written by system operators. Substation operators perform
18 switching procedures several times per day to support construction, maintenance, and routine or
19 emergency troubleshooting activities.
20 Emergency switching is done in response to any unplanned event that interrupts the flow
21 of power on the grid. Substation operators are the first responders to inspect and assess damage caused
22 by an unplanned event within a substation. Switching for emergencies differs from routine switching for
23 maintenance because it is reactive and performed specifically to isolate damaged equipment and safely
24 restore the flow of electricity to customers. With emergency switching, a substation operator assesses
25 the status of the damaged equipment and reports it to a system operator. Based on this assessment, the
26 substation operator prepares a draft emergency switching procedure and submits it to the system
27 operator for review and approval. Once approved, a system operator directs a substation operator to
28 perform the switching.
25
1 a) Cost Forecast
Table I-12
Substation Operations26
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
562.170
Labor $14,492 $13,497 $14,178 $14,325 $16,037 $16,037 $16,037 $14,387
Non-Labor $5,242 $5,652 $5,670 $4,015 $3,943 $3,943 $3,943 $3,537
Subtotal 562.170 $19,734 $19,149 $19,848 $18,340 $19,980 $19,980 $19,980 $17,924
582.170
Labor $17,455 $19,075 $20,183 $20,690 $22,913 $22,913 $22,913 $20,556
Non-Labor $6,253 $7,829 $7,802 $6,003 $5,701 $5,701 $5,701 $5,114
Subtotal 582.170 $23,709 $26,904 $27,984 $26,693 $28,614 $28,614 $28,614 $25,670
Total $43,442 $46,053 $47,833 $45,033 $48,594 $48,594 $48,594 $43,594

Labor $31,948 $32,572 $34,361 $35,015 $38,950 $38,950 $38,950 $34,943
Non-Labor $11,495 $13,482 $13,472 $10,018 $9,644 $9,644 $9,644 $8,651
Basis of Forecast: Itemized Forecast (Last Year Recorded Less 2018 Savings)
2 Substation operation expenses are recorded to either a transmission or a

3 distribution account, depending on the work being performed. As SCE’s grid continues to expand and
4 age, substation and system operators are facing more regulatory inspection requirements and increased
5 switching complexity. To maintain system reliability, SCE added critical workforce, the Reliability
6 Investment Incentive Mechanism (RIIM) positions, to support these new requirements. This addition of
7 resources corresponds to the steady labor cost increase as shown in Table I-13.27 Due to an accounting
8 change in division overheads starting in 2014,28 2011 – 2013 non-labor costs do not reflect current
9 practices.

27 See 2015 GRC Decision D.15-11-021, p. 23 and WP SCE-02 Vol. 06, pp. 165-166 (Grid Operation RIIM
Headcounts 2011-2015).
28 See SCE-08 Vol. 03 and Master Data Request 1.A.12.
26
1 Given the trend in labor and non-labor shown in Table I-13 above, SCE forecast
2 costs for these activities using adjusted last year recorded forecast methodology. The 2015 recorded cost
3 represents the forecast for 2016-2018 as it reflects the expected necessary staffing and non-labor
4 expenses. This also follows Commission guidance to use the last recorded year’s expenses as a base to
5 forecast test year levels, if the past three recorded years show a trend in a certain direction. However,
6 from this forecast base of last recorded year, we adjusted our 2018 forecast down by $5.0 million to
7 account for a change in accounting treatment that will record system operator switching done to support
8 capital projects, to the capital work order.29
9 G. Substation Capital Expenditures
10 1. Substation Capital Maintenance
11 Substation Capital Maintenance captures the labor and equipment costs to remove and
12 replace assets on a reactive or programmatic basis. It does not include the costs for preemptive
13 replacement of circuit breakers and substation transformers, which are discussed in SCE-02, Vol. 8. It
14 also does not include preemptive replacement of substation protection and control systems, which is
15 discussed later in this volume.
16 Reactive replacements are initiated when substation equipment fails in-service, or when
17 Substation Inspection and Maintenance programs indicate imminent equipment failure or possible safety
18 issues. For example, in 2015, 17 circuit breakers were replaced under the Substation Capital
19 Maintenance program. All equipment classes, including the major equipment categories (circuit
20 breakers, transformers and relays) can be replaced for reactive reasons. These replacements are
21 predominantly like-for-like replacements requiring minimal engineering. Reactive equipment
22 replacements must be completed in a timely manner because substation equipment failures may lead to
23 prolonged outages, unsafe operating conditions, or more expensive reactive solutions.
24 Drivers for such emergency events can be due to external events like weather conditions
25 or internal component failure. For example, in 2015, we had one event where a distribution transformer
26 bank in the Nugget substation automatically disconnected from the grid during a lightning storm.
27 Further investigation revealed that the bushing had failed catastrophically. SCE determined that due to
29 See WP SCE-02 Vol. 06, pp. 167-169 (System Operator Proposal Estimate).
27
1 the age and condition of the transformer it would need to be replaced. The associated replacement costs
2 were recorded in this category.
3 Some equipment SCE identifies for replacement may not have to be replaced
4 immediately. In these cases, the equipment is left in service and monitored until a replacement can be
5 planned, which reduces costs associated with forced outages.
6 Besides breakdown and inspection-driven capital maintenance, SCE has created
7 programs targeting replacements of equipment reaching its end of service life or installations of new
8 technology that can monitor equipment health.30 This programmatic approach allows SCE to proactively
9 plan work over longer periods, perform necessary engineering design, and allocate resources to
10 effectively staff all required work. Examples of equipment being addressed under the programmatic
11 approach are current transformers (CT), potential transformers (PT), Coupling Capacitor Voltage
12 Transformers (CCVT), transformer bushings, load tap changers (LTC), line regulators, disconnect
13 switches, power cables, and DC (Direct Current) systems. Online transformer monitoring is an example
14 of new technology SCE is adding to assess and track the health of its A and AA transformers.
30 The equipment replaced in this account are not part of any other Infrastructure Replacement programs.
28
1 a) Cost Forecast
Figure I-3
Substation Capital Maintenance31
Multiple WBS Elements32
Recorded 2011-2015/Forecast 2016-2020
(Total Company – Constant 2015 and Nominal $000)
2 As shown in Figure I-3, the increased expenditures in 2014-2015 resulted from

3 two factors: (1) an increased focus on programmatic substation maintenance work that targets specific
4 asset classes for replacement; and (2) an increase in reactive replacements due to aging infrastructure.
5 The cost of programmatic maintenance work will level out in 2016 as SCE shifts
6 its programmatic replacement focus to different asset classes, which includes programs such as battery,
7 power cable, and disconnect replacements and LTC contact upgrades. In addition, SCE expects to
8 continue reactive replacements, due to their variability from year-to-year, SCE based its 2016 – 2020
9 capital expenditure forecast on a five-year average of 2011-2015 expenditures. This also follows
10 Commission guidance to use an averaging methodology to forecast future costs, when recorded costs
11 fluctuate significantly.

32 WBS Elements CET-PD-BM-SU, CET-PD-IR-SP (portion), CET-ET-IR-ME (portion), CET-PD-OT-OC.
29
1 2. Substation Protection and Control Replacements
2 The Substation Protection and Control System Replacement program identifies and
3 replaces protection and control equipment approaching the end of its service life, that contain
4 components known to be problematic or no longer available, or that can no longer be cost-effectively
5 maintained. The work performed in this category can be broadly classified into three activities, as
6 described in the following sub-sections.
7 The Substation Protection and Control System Replacements and Subtransmission Relay
8 Upgrades may occur at the same substations under the Grid Modernization Substation Automation
9 program as discussed in SCE-02, Vol. 10. In these instances the SA-3 (Substation Automation) and CSP
10 (Common Substation Platform) systems will utilize the equipment installed under replacement programs
11 covered in this volume.
12 a) Distribution & Transmission Protection and Control System Replacement
13 Approximately half of SCE’s substations are automated. At one time, virtually all
14 substations were operated by field personnel, many around the clock. To improve efficiency, reliability,
15 and safety, SCE’s goal is to eventually automate all of its substations. Beginning in the 1980s, SCE
16 installed control/automation systems as technology evolved, providing greater capabilities for remote
17 control, data acquisition, and automatic response. In 1997, SCE installed its first control/automation
18 system, which integrated the protective relays and controls unlike earlier versions that kept them
19 separate. Although these systems are much more technologically advanced than earlier versions, the
20 computer-based components require more frequent upgrade or replacement. Today, almost half of the
21 existing protection and control systems on SCE’s system are no longer supported by the manufacturer,
22 and most have no cost-effective hardware/software upgrade solution.
23 SCE divides relay replacements into four categories: (1) Replacement of obsolete
24 protection and/or control system; (2) Replacement of first generation integrated system (relays and
25 control computer); (3) Replacement of first generation integrated system (control computer only); and,
26 (4) Replacement of obsolete Process Logic Controller (PLC) only.
27 b) Digital Fault Recorder Replacement
28 Digital Fault Recorders (DFR) are installed at each of SCE’s 500kV and 220kV
29 substations. These recorders capture data regarding circuit disturbances. The first generation of Digital
30 Fault Recorders installed have limited measurement capabilities. Specifically, they do not measure all
31 four currents (three phase and one ground current). The ability to measure all four currents is required by
30
1 the Western Electric Coordinating Council (WECC).33 WECC also requires the visibility of streaming
2 phasor measurement data to coordinate and monitor Western utility electric grids. When the devices fail,
3 maintenance takes more time and effort, since replacement parts are harder to procure. SCE is replacing
4 these outdated DFRs with systems that can provide both digital fault recording and phasor measurement
5 data (DFR/PMU) to meet this WECC requirement and to track system stability and overall system
6 health. This program will also update the DFRs identified to support NERC PRC002-2 Requirements.
7 PRC002-2 identified that SCE needed to provide the level of monitoring at substations that included
8 Sequence of Events Recording (SER) and Fault Record (FR) data.
9 c) Cost Forecast
Figure I-4
Substation Protection and Control Replacements34
Various WBS Element35
10 SCE plans to replace both its distribution protection and control equipment and its
11 500 kV and 220 kV relays. SCE finalized the design to replace the obsolete relay protection and control
12 systems, first-generation integrated systems (relays and control computers), and Programmable Logic
33 “Standard PRC-002-1 – Define Regional Disturbance Monitoring and Reporting Requirements”

http://www.nerc.com/files/prc-002-1.pdf.
35 WBS Elements CET-ET-IR-RP, CET-ET-GA-EM, CIT-00-OP-NS.
31
1 Controllers (PLC). The cost forecast in 2017-2020 reflects the engineering and construction phase of the
2 replacement program. The forecast also includes replacement of Remote Terminal Unit (RTU’s),
3 replacement of Digital Fault Recorders/Phasor Measurement Units (DFR/PMU), and replacement of
4 500kV and 220kV relays.36 SCE developed the program forecasts based on historical average costs for
5 the identified scope items and spread these costs over a two or three-year project span for each site.37
6 Table I-13 shows the average cost per location by program.
Table I-13
Substation Protection & Control Relay Replacement Programs
Average Cost per Location
(Nominal $000)
AverageCostperSite TotalNumberofLocation(2016Ͳ2018)
ReplaceNonͲBulkRelaysͲ115kV&Below $558 61
ReplaceBulkRelaysͲ220kV&500kV $1,728 34
ReplaceSASInfrastructure $827 65
ReplaceDigitalFaultRecorders(DFRs) $458 40
7 3. Subtransmission Relay Upgrade Program

8 a) Overview
9 The Subtransmission Relay Upgrade Program will replace those 66kV and 115
10 kV line protection relay devices identified as potentially unreliable under the condition of load
11 encroachment caused by additional Distributed Energy Resources (DER) generation.38
12 b) Program Necessity
13 Most legacy protective relaying devices are set to monitor one system condition
14 (e.g., current, voltage, frequency, etc.). The majority of substations channel one-way power flow from
15 utility to the customer. When the direction of the current changes due to DER generation, more sensitive
16 and secure types of protective relaying are required to maintain system reliability. These substations
17 were not developed with DER generation in mind and were not equipped with the associated protective
18 relaying equipment required for the correct sensing of two-way power flows.
36 See WP SCE-02 Vol. 06, pp. 170-177 (Substation Protection and Control Forecast).
37 Project span includes one to two years for design and engineering and one year for construction based on site-
specific scope of work.
38 See WP SCE-02 Vol. 06, pp. 178-188 (Integrated Distributed Energy Resources & Protection System
Upgrades).
32
1 As the number of generating DER installations continue to increase at the
2 distribution level, two-way power flows also increase. The legacy protective relay devices at the
3 substation cannot accurately react to system conditions in the presence of load encroachment and reverse
4 power.
5 Due to load encroachment because of reverse power flow, SCE expects an
6 increase in equipment outages due to protective relay misoperations. Modifying existing legacy
7 protective relays is not possible due to limitations of the equipment; most provided a single function.
8 Adjusting existing protective relay settings introduces potential safety concerns as legacy relays cannot
9 simultaneously provide sensitive ground fault protection and account for reverse power flows. This is
10 unacceptable due to reliability impacts and can result in serious safety hazards for workers and the
11 public.
12 To provide safe and reliable integration of DERs on the SCE system, the
13 protective relaying scheme and related infrastructure will need to be improved. One option is to upgrade
14 legacy protection relays with new ones. The new microprocessor protection relays are equipped with the
15 capability to provide load encroachment, voltage polarized directional sensing, and ground overcurrent
16 protection. These capabilities can accommodate reverse power flow created by DERs and protect the
17 downstream circuits.
18 c) Program Description
19 SCE developed a system-level forecast of DER installations through 2020, and
20 allocated these installations, and their associated capacities, across SCE’s distribution circuits for each
21 of the years 2015 - 2024. This forecast is discussed in detail in SCE-09, Vol. 1.
22 In parallel with this effort, SCE reviewed all subtransmission circuit relays and
23 identified the relays not designed for, or expected to operate under, the conditions of load encroachment.
24 Combining these studies, SCE then identified which of those vulnerable relays were forecast to
25 experience reversed power flow prior to the end of 2020 based on the latest circuit DER Forecast. Those
26 vulnerable relays are the relays SCE intends to replace with relays capable of operating dependably
27 under the conditions of load encroachment. Relay replacement will be prioritized based on when each
28 relay is expected to encounter load encroachment. However, SCE will also levelize the workload over
29 the three year period to minimize disruptive and cost-inefficient cycling of workforce resources.
30 Subtransmission line protective relays are routinely replaced under the
31 infrastructure replacement work sponsored by Substation Construction and Maintenance (SC&M) as
33
1 discussed above in the Substation Protection and Control Relay Replacements activity. Overlaps
2 between this Subtransmission DER-driven relay upgrade program and SC&M’s Substation Protection
3 and Control relay replacement program have been removed from this activity’s forecast.
4 d) Program Alternatives
5 Other options in protecting the equipment and the public from circuit faults under
6 load encroachment conditions include: (1) rejecting DER interconnection requests wherever the
7 attachment might cause the relay protection to become vulnerable; (2) delaying investment in relay
8 replacement until we have received that DER interconnection application which would cause the relay
9 protection to become vulnerable; and (3) compelling the applicant requesting DER connection to pay for
10 the required relay replacement, as necessary. None of these options were viewed as following the vision
11 of the future grid held by the CPUC, the State Legislature, or SCE. Additionally these options would not
12 encourage the installation and operation of DERs.
13 Given the consequences described in the Program Necessity section above, taking
14 no action, would be untenable. Continuing to operate a grid without dependable protection would put the
15 safety and reliability of the grid at risk as more customers install DERs.
16 e) Program Benefits
17 Currently there are approximately 880 115 kV relays and 5,274 66 kV line
18 protection relays in SCE’s Subtransmission system. These are summarized by type and voltage in Table
19 I-14.
Table I-14
Subtransmission Relays Currently in System
SubtransmissionLine
Voltage ProtectionRelayType Population
66kV ElectroͲmechanical 3,548

SolidState 259
Microprocessor 1,467
Total 5,274
115kV ElectroͲmechanical 344

SolidState 84
Microprocessor 452
Total 880
34
1 Virtually all of the electro-mechanical relays and solid state relays will be
2 rendered undependable under the conditions of reverse power flow. Most of our installed
3 microprocessor relays can operate dependably with reverse power flow.
4 Of the 3,892 electro-mechanical and 343 solid state relays in our subtransmission
5 system, 918 electro-mechanical, 82 solid state, and 129 micro-processer relays installed in substations
6 are expected to see reverse power flow conditions by the end of 2020.
7 When compared against the option of doing nothing, the Subtransmission Relay
8 Replacement program will reduce the likelihood of spurious operations of 1,129 subtransmission relays.
9 115 kV and 66 kV circuit breakers operate to clear a fault at an average rate of approximately once
10 every 15 months.39 Circuit breakers controlled by relays incapable of responding to a fault under load
11 encroachment will not operate in time to prevent significant equipment damage.
12 The relays to be replaced under the Subtransmission Relay Upgrade program are
13 among the oldest in the SCE system, some installed over forty years ago. Over the last five years, these
14 legacy relays that have reached the end of their useful life have experienced dramatic increases in failure
15 rates (approximately 180 failed per year),40 depleting spare replacement caches with no replacements
16 available from manufacturers. Repair or replacement of these relays with identical units as they fail is
17 not feasible. Replacing these antiquated relays with modern supported relays will lower the risk of
18 outages by reducing the time needed to repair relays found inoperable during routine testing or when
19 they fail.
20 As electromechanical relays age the moving mechanical components in these
21 devices will wear and “drift” from the original settings, introducing a small amount of error into the
22 operation of the relay. While manageable usually, this amount of error introduces faulty relay operation
23 and can slow the device response time to protect the system from failing equipment.
24 An additional benefit of using new microprocessor protective relays is the ability
25 to monitor, communicate, and record system events, a feature that is not available in legacy
26 electromechanical relays. The benefit of recording system disturbances allows engineers to determine
27 the problem and quickly develop a plan to restore service or prevent similar issues. Furthermore, legacy
39 See WP SCE-02 Vol. 06, pp. 189-191 (Estimation of Substation Circuit Breaker Kick-Out).
40 See WP SCE-02 Vol. 06, pp. 192-193 (2010-2015 TPU/DPU Relay Failure Rate).
35
1 relays typically use proprietary and/or obsolete communication protocol which are not compatible or
2 able to communicate with modern technology. Microprocessor relays will allow for use of industry
3 standard communication protocols, increase the ability to gather data remotely and improve situational
4 awareness.
5 f) Cost Forecast
Figure I-5
Subtransmission Relay Upgrade41
WBS Element CET-ET-GM-SA
(CPUC-Jurisdictional – Constant 2015 and Nominal $000)
36
Table I-15
Forecast Subtransmission Relay Upgrade
NumberofSubtransmission
(66kVor115kv)Line
ProtectionRelaystobe ForecastUnitCost*(Nominal$ TotalRecorded/ForecastCost
Year Replaced x1,000) (Nominal$x1,000)
2016 0 $202.759 $0
2017 0 $206.975 $0
2018 196 $212.187 $41,589
2019 196 $218.844 $42,893
2020 196 $225.802 $44,257
Total 588 $128,739
* Unitcostis$199kin2015constant;2016Ͳ2020unitcostshownwithescalation
1 The Subtransmission Relay Upgrade program will begin in 2018. The forecast
2 spending of the program is shown in Figure I-5.42 SCE uses the total recorded costs from the
3 subtransmission relay replacement projects between 2010 and 2016, divides it by the total number of
4 relays replaced in these programs to obtain a unit cost of $199k per relay replacement. Based on the total
5 1,129 line protection relays SCE identified to experience load encroachment by year 2020, SCE
6 determines 588 new microprocessor relays to be installed over the three year period from 2018-2020,
7 yielding 196 relay installation per year. SCE forecasts the annual expenditure by multiplying the unit
8 cost (in $2015 constant) by the forecast number of units to be installed per year as shown in Table I-15.
9 4. Substation Spare Parts
10 Substation equipment controls the flow of electricity to customers. When equipment and
11 parts must be replaced, delays must be minimized. SCE must maintain an inventory of equipment that
12 requires a long lead-time for ordering, especially as the infrastructure ages faster than it can be
13 proactively replaced. This inventory enables SCE to reduce outage time at the substation and minimize
42 See WP SCE-02 Vol. 06, pp. 194-205 (Subtrans Relay Upgrade Forecast).
37
1 the customer minutes of interruption caused by an unplanned major equipment failure. Examples of the
2 equipment maintained in inventory at substations are transformers, circuit breakers, disconnects, and
3 other similar equipment. Spare transformers are also used temporarily to address unforeseen increased
4 load requirements at various substations during the peak summer months.
5 a) Cost Forecast
Figure I-6
Substation Spare Parts43
6 As shown in Figure I-6, SCE made significant investments in 2014 – 2015 to

7 replenish its inventory of critical substation spare parts. These investments were driven by the need to
8 add one AA and several A and B Bank transformers to its spare inventory due to a variety of reliability
9 and operational issues described below. Because of the investments made in these years, SCE’s forecast
10 for 2017 – 2020 is significantly lower than what was recorded in 2014-2015 and forecast for 2016.
11 A Bank transformers (230kV/66kV or 230kV/115kV) typically have delivery lead
12 times of over one year. An A Bank failure results in a significant reduction of system reliability. Over
13 the 2013 to 2015 rate case cycle SCE experienced two failures of A bank transformers. Rapid

44 WBS Elements CET-PD-OT-SP and CET-PD-CI-CI.
38
1 replacement of failed transformers is essential to grid safety, efficiency, and reliability. Therefore an
2 adequate number of readily available spare transformers is required. In light of the age of many existing
3 SCE A Banks, increased and dynamic system loading patterns, and increasing awareness of potential
4 terrorism risks, SCE reviewed 220kV transformers and identified the need to add spare A Banks to the
5 SCE system in 2013-2014.45 Five new spare A Banks were placed in the SCE system at strategically
6 appropriate locations. SCE purchased one AA spare (500kV to 115kV) transformer to ensure system
7 reliability of the Valley 115kV system.
8 B Bank (115KV or 66KV to 16KV, 12KV, or 4 KV) transformers connect SCE’s
9 transmission system to distribution circuits. B Banks, or distribution class transformers, have a typical
10 lead time of nine to twelve months. Similar to A Bank transformers, an engineering review was
11 performed on the need for distribution class transformers. SCE has over 2,100 distribution class
12 transformers currently in service. Over the 2013 to 2015 rate case cycle SCE experienced six failures of
13 B bank transformers. Many are beyond their designed life of 30 years, and some of SCE’s transformers
14 are over 60 years old. Increasing system load requires that SCE operate some at the extreme limits of
15 their designed capacity during high load (typically summer) episodes. In response to the engineering
16 review to ensure grid reliability, beginning in 2014 SCE increased its inventory levels for these
17 transformers and began to purchase of new equipment to meet the goals identified.
Table I-16
Spare Part Expenditures 2010-2013
($000 Nominal)
Year 2010 2011 2012 2013

SparePartsCosts $5,977 $(871) $3,030 $(384)
Averagecost/year $1,938
Baselinecost/year $2,000
18 Due to the unique size of our spare parts investments made in 2014 – 2015, SCE
19 used an average of nominal expenditures from 2010 – 2013, as shown in Table I-16, to forecast its
20 baseline costs for the 2016 – 2020 period. SCE used an averaging methodology to estimate these costs
45 See WP SCE-02 Vol. 06, pp. 206-212 (Substation A Bank Required Spares).
39
1 as spending on substation spare parts fluctuates greatly from year-to-year depending on the usage of the
2 spare parts and the long lead times to replenish the used inventory. The costs in this time frame best
3 represents typical activity in this account with no additions to the spare inventory. These baseline costs
4 represent the incremental and other costs associated with replacing used inventory. This incremental cost
5 can be thought of through an example: A transformer is replaced from a unit issued from the spare
6 inventory purchased in 2011, at a cost of $425,000. To replenish the inventory, a new transformer is
7 purchased that costs $475,000. The difference in cost between the two transformers of $50,000 is
8 reflected in this account. As reflected in Table I-16, the average nominal expenditures from 2010 – 2013
9 is $2.0 million, and we use this amount as our baseline annual costs in our 2016 – 2020 forecast.
10 To this baseline, SCE adds amounts needed in 2016-2018 to purchase additional
11 equipment to reach target inventory levels based on SCE’s engineering study.46 The combination of the
12 costs required to maintain inventory levels identified by this engineering study, and the baseline costs
13 discussed above and in Table I-16, comprise SCE’s substation spare parts capital forecast for 2016 –
14 2020, as shown in Figure I-6.
15 5. Substation Tools and Work Equipment
16 Specialized tools used by substation crews go through normal wear and tear so must
17 eventually be replaced. New tools must be purchased in response to new types of electrical equipment
18 being installed, and new inspection and maintenance procedures being implemented. The crews must be
19 outfitted with adequate tools for safety and productivity purposes. Technology advancements require
20 purchasing new testing equipment to support SCE’s power grid as it evolves.
21 As an example, in order to communicate with new microprocessor relays, SCE has been
22 purchasing new relay tests sets from Doble engineering (model 6150sv). Additional costs include
23 replacement of obsolete (no longer supported by manufacturer) equipment. The tool expenditures
24 include the costs for acquiring and retiring portable tools and work equipment that cost more than
25 $1,000. Portable tools are moderately priced and have relatively long lives. Examples include electric,
26 pneumatic, and hydraulic power tools, generators, meters, electronic test equipment, gas monitors, and
27 compression tools for making high voltage electrical connections.
46 See WP SCE-02 Vol. 06, pp. 213-215 (Substation B Bank Required Spares).
40
1 a) Cost Forecasts
Figure I-7
Substation Tools and Work Equipment47
(CPUC-Jurisdictional – Constant 2015 and Nominal $000)
2 SCE is performing more capital work than it has in the past, leading to a
3 corresponding increase in the quantity of capital tools needed to support this work and to help field
4 crews have the appropriate technology to install and test modern equipment The increased spend in 2013
5 and 2014 as shown in Figure I-7 is directly related to both new technology and increased need for tools
6 and test equipment. With this increased work, the tools are being used more, reducing the life
7 expectancy. Finally, the technology needed to install and test new equipment requires crews to have the
8 tool for the work being performed.
9 To support the new technology mentioned above, SCE has been purchasing new
10 test equipment and tools.49 The cost of these tools is shown in the expenditures in Figure I-7 for years
11 2013 to 2015. In addition, in the beginning of 2015, SCE purchased tools to comply with federal

48 WBS Elements CET-PD-OT-ST, CET-PD-OT-SE.
49 See WP SCE-02 Vol. 06, pp. 216-220 entitled “Doble EOL Letter”, “Doble EOL Letter 2.”
41
1 regulations to mitigate employee arc flash exposure.50 SCE anticipates these expenditures will continue
2 over the 2016 – 2020 period. Due to the unpredictability of technological advances, SCE utilized the
3 recorded 2011-2015 average as the basis for its 2016-2020 forecast.
4 6. Substation Physical Security
5 SCE substations are situated to best serve customer loads and are often visible within
6 public domains. This renders our substation equipment vulnerable to terrorism, theft, and vandalism.
7 The associated safety and liability concerns beyond potential disruption of electrical services require
8 measures to fortify critical assets against physical attacks. Some examples are block walls to prevent
9 access and conceal visibility of substation assets, alarms, improved gates and walls to deter break-ins,
10 and threat detection systems. SCE has several substation physical security programs in place to prevent
11 theft, address compliance requirements, and protect SCE’s critical assets.
12 a) Copper Theft Program
13 SCE has experienced substations being vandalized and looted for copper over the
14 past few years. From 2013 to 2014 there were, on average, over 13 break-ins to SCE substations per
15 month51 that resulted in losses due to copper theft, customer outages, and/or serious injury to the thieves.
16 The stolen copper is critical to the safe and reliable operation of the substation, as it provides the return
17 path of electricity under normal operating conditions.
18 Copper theft presents a significant safety risk to SCE employees and contractors,
19 who can be injured while working on electrical equipment that has had its copper grounding wires
20 removed by thieves who are also at risk while performing these illegal activities. The customer impact
21 of copper theft is also significant. Affected customers experience an average of 11 hours of outage each
22 time power is shut off either due to the impact of the theft itself, or due to the repair work required to
23 replace copper parts.
24 Because of these safety and reliability risks, SCE has developed a program to
25 reduce copper theft at its substations. We have identified which facilities require physical security
26 enhancements to minimize the possibility of future copper thefts based on factors such as safety
27 (customer and employee) risks and the history of theft at stations. The prioritized substations receive
50 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=24422.
51 See WP SCE-02 Vol. 06, pp. 221-231 (Copper Theft Record).
42
1 high security fencing and improved lighting to deter theft and reduce the risk of injuries or customer
2 outages. Initial results of this program are proving to be highly effective. Substations given these
3 enhancements have seen a reduction in the number of thefts.
4 b) Tiered Physical Security Systems
5 Recognizing the increasing physical security threats to our substation equipment
6 and facilities, SCE developed a tiered approach to enhance physical security which includes the
7 protection of assets identified by NERC CIP-014-2, and beyond. The substation tiers are determined
8 based on the number of network connections, voltage class, and load, as shown in Figure I-8.
Figure I-8
Substation Physical Security
Tiered Program
9 (1) Tier 1 NERC CIP-014 Compliance Program

10 In 2013, a PG&E substation was attacked, resulting in substantial
11 reduction in transmission capability and over $15 million in damages. This was the first significant
12 attack on a substation in the United States. In 2014, NERC developed physical security regulations to
13 require utilities to protect critical substations from attack that could cause widespread outages in the
14 bulk electrical system. This program was identified as Tier 1-NERC CIP-014. This program is discussed
15 in more detail in SCE-07 Operational Services-Vol. 5. CIP-014 requires utilities to assess, review, and
16 identify critical facilities that are vulnerable to physical attack risks, and furthermore, develop and
17 implement a plan to enhance protection for these assets.
43
1 After the 2013 attack at the PG&E substation, SCE evaluated its
2 substations to identify areas where the company should bolster its security to prevent a similar
3 occurrence on SCE assets. Because of this, and prior to the development of the NERC CIP-014 program,
4 SCE identified seven substations in 2014 for physical security enhancements. These substations were
5 critical to the reliable operation of our grid. In addition, SCE considered these substations to be probable
6 candidates for future NERC CIP-014 requirements due to their criticality. Therefore, SCE initiated pilot
7 physical security enhancements to four out of the seven substations in 2014, in anticipation of the
8 release of CIP-014. These enhancements included improvements to walls, reinforcement of gates,
9 concealment of key assets, and improvements to technical security to detect threats and improve
10 response, including improved cameras, alarms, and lighting.
11 CIP-014 does not define the specific mitigation tools and methods for
12 identified critical facilities but requires utilities to develop and implement a security risk mitigation plan.
13 To prepare and help inform the development of our security mitigation plan, this pre-CIP-014 pilot
14 program was created not only for SCE to get ahead of the anticipated compliance requirements but also
15 to pilot and test security technology options to determine the best practices to be later incorporated into
16 the remaining CIP-014 qualified sites. Examples of piloting scope include testing long range video or
17 gunshot detection technology to increase situational awareness, building high-security physical
18 perimeter walls, improving security lighting and audible alarms to deter attacks.52 In 2015, CIP-014 was
19 released, and the final version of the regulation included criteria that two of the four pilot sites met.
20 Together with the remaining three CIP-014 qualified sites, SCE has seven substations that require
21 physical security enhancements under Tier 1 Physical Security Program.
22 (2) Tier 2-4 Physical Security Program
23 Besides the Tier 1-NERC CIP 014 substations and facilities described
24 above, SCE also plans to deploy security enhancements to other critical substations under business
25 resiliency planning to protect our assets that are critical to safe and reliable power delivery . These
26 critical substations are categorized into Tiers 2 to 4 based on their impact on the electrical systems if a
27 breach or physical attack occurs. This program identifies security deficiencies at these prioritized sites
52 The fundamental implementation approaches for physical security enhancement are Increase Situational
Awareness (Detect), Harden/Enhance Perimeter (Deter), Deny Access to Critical Assets (Delay), Cover and
Concealment, Response.
44
1 and develops and implements corrective plans accordingly. The scope varies based on site factors, but
2 the general goal of the program is to develop a standardized deployment to improve SCE’s facility
3 security maintenance and management.
4 c) Cost Forecast
Figure I-9
Substation Physical Security53
Multiple WBS Elements54 CET-ET-IR-ME (Portion)
5 The WBS element CET-ET-IR-ME (portion) captures these programs’

6 expenditures in the Transmission Substation portion of the projects. Broadly, these expenditures are
7 required to fund physical security enhancements such as: providing AC/DC power feeds to security
8 equipment and lighting, providing ballistic barriers around critical equipment, installing concealment,
9 and replacing or modifying substation fences and gates. The breakdown of the forecast cost per program
10 described above can be found in Table I-17.

54 WBS CET-ET-IR-ME (portion), CET-PD-OT-FO (portion), CET-PD-IR-SP (portion).
45
Table I-17
Substation Physical Security Enhancement Programs
Recorded 2014-2015/Forecast 2016-2020 (Nominal $000)
Numberof
Substations 2014 2015 2016 2017 2018 2019 2020
8/yearfrom
CopperTheft 2016andon $Ͳ $3,330 $8,151 $8,321 $8,530 $8,798 $9,077
Tier1:PreͲCIPͲ
014&CIPͲ014 7 $10,861 $14,344 $14,190 $42,550 $9,052 $Ͳ $Ͳ
Tier2Ͳ4 29 $Ͳ $Ͳ $Ͳ $746 $8,059 $13,606 $14,800
Total $10,861 $17,673 $22,341 $51,618 $25,640 $22,404 $23,877
1 SCE plans to implement eight substation projects per year from 2016-2020 to
2 enhance fencing, gate, and lighting under the Copper Theft Mitigation program. These costs are
3 determined by the number of feet of new fencing and the lighting needed to deter further copper theft.
4 For Tiered Substation Physical Security programs, SCE will focus on completing the pre-CIP-014 pilot
5 site enhancements in 2016. In 2017, SCE will complete the majority of Tier 1 (CIP-14) site
6 enhancements, with completion of all remaining work in 2018. From 2018 – 2020, SCE will complete
7 enhancements for Tier 2-4 sites. SCE used historical average costs from substation projects containing
8 similar scope items as well as pilot site vendor quotes to develop the Tiered program forecast,
9 inconsideration of each site’s specific requirements.55
10 7. Operational Facilities Maintenance
11 This work category includes two distinct activities as described below.
12 a) Substation and Switching Center Facility Maintenance
13 The portfolio of SCE substations and switching centers were built between the
14 1940s and the 1990s. These substation facilities have aged and many require increased maintenance.
15 Periodically, we must replace or rebuild failed or failing equipment at these substation facilities, such as
16 heating, ventilating, and air conditioning (HVAC) systems, plumbing, electrical, roof replacements,
17 fencing, motorized gates, fuel tanks, carpet, flooring, and asphalt or concrete driveways which undergo
18 regular wear and tear. The historical and 2016 forecast cost are allocated within this WBS account CET-
19 PD-OT-FO. Starting in 2017, facility maintenance costs will be recorded in the WBS account COS-00-
55 See WP SCE-02 Vol. 06, pp. 232-242 (Substation Tiered Physical Security Forecast) / WP SCE-02 Vol. 06C
pp. 1-11 (Substation Tiered Physical Security Forecast – Confidential).
46
1 RE-MA-NE7637 in accordance with internal budget decisions. This substation facilities maintenance
2 activity is important to maintaining a safe working environment for employees and to protect the
3 sensitive electronic equipment that monitors and controls the power grid. More details are discussed in
4 SCE-07 Operational Services-Vol. 3.
5 b) Control Building Modernization
6 The other portion of this account records the cost for SCE’s Control Building
7 Modernization projects. Many switching centers have been enhanced with automation and relay scheme
8 installations that have led to encroachment in Grid Operations’ personnel space. Load growth increases
9 combined with reductions of switching centers in SCE service territory over time created a consolidation
10 of personnel without adequately addressing the remaining facilities’ space requirements. The result has
11 hampered the switching center’s ability to monitor and control the power grid with adequate situational
12 awareness due to aging control consoles and technology. There is also a need to comply with the
13 standards associated with Americans with Disability Act (ADA). In addition, none of these facilities
14 accommodated NERC CIP Physical Security Perimeter compliance requirements.
15 To meet NERC CIP56 physical security standard requirements, control building
16 layout arrangements were modified and redesigned to consolidate all operational activities within the
17 same room, to avoid security breaches. Besides operational duties, new control room configurations
18 contain personnel facilities such as restrooms and break rooms. These additional facilities are within the
19 physical security boundary to reduce false NERC CIP reporting alarms caused by frequent traffic into
20 and out of the control room area. Work station layout changes were also included with the consideration
21 of operator ergonomics, work interference minimization from radio transmission and cross talk, and
22 requirements from the Americans with Disability Act (ADA). Besides console upgrades, display wall
23 and telecommunication system were included in the design to improve operators’ situational awareness
24 and response to significant electrical events as SCE’s bulk electric system continues to expand and
25 become more complex.
56 “Standard CIP-006-03c – Cyber Security – Physical Security” <http://www.nerc.com/files/CIP-006-3c.pdf>;

“CIP-006-5 – Cyber Security – Physical Security of BES Cyber Systems” <http://www.nerc.com/files/CIP-
006-5.pdf>.
47
1 c) Cost Forecast
Figure I-10
Operational Facilities57
WBS Element CET-PD-OT-FO (portion)
2 In 2013, SCE launched a program to renovate the aging facilities. SCE evaluated
3 the project scope and included additional substations and grid control centers to maintain control model
4 consistency and address immediate space needs for new relay and control schemes and impending
5 NERC CIP compliance. SCE concluded the evaluation in 2013 and identified various control building
6 modification or replacement projects, which drove the increase in capital costs in 2014 and 2015. New
7 control buildings were constructed at Devers, Lugo, Valley, and Vista substations, and expansions of
8 existing control buildings were initiated at El Nido and Rector Substations. Modernization of control
9 rooms and Distribution Operations Centers (DOC) at Mira Loma, Santa Ana, Lighthipe and Ventura,
10 Eldorado, Mesa, and Vincent substations, as well as SCE’s Grid Control Center and Alternate Grid
11 Control Center, were also included for system consistency to allow seamless transfer of operational
12 jurisdictions and reduce operator error.
13 The control room and building designs incorporate NERC CIP version 5
14 standards and SCE Corporate Security policies to address physical access controls, meet ADA
57 Refer to WP SCE-02, Vol. 06, pp. 114-156.
48
1 accessibility requirements, and provide space for an IT room, security room, break room and lockers.
2 The control room includes the system operator ergonomic consoles and a display wall system that
3 allows all operators to project the Outage Management System, Energy Management System and
4 Distribution Management System (OMS/EMS/DMS) for situational awareness during routine and
5 emergency operating situations. An updated phone system that can transfer operational jurisdiction
6 including telephone communications during system emergencies to other switching centers or DOCs
7 was also installed to replace to existing system that had reached the end of its useful life. As shown in
8 Table I-18, which is a subset of the costs represented in Figure I-10, SCE expects to complete these
9 Control Room Modernization upgrades by the end of 2016 with forecasted spend of $10.9 million.58
Table I-18
Control Room Modernization
2011-2015 Recorded/2016 Forecast
(Total Company – Nominal $000)
(Nominal$000) Recorded Forecast
Control Room Modernization 2011 2012 2013 2014 2015 2016
Total $30 $20 $4,340 $72,729 $44,611 $10,905
58 See WP SCE-02 Vol. 06, pp. 243-249 (Control Room Modernization Cost Breakdown & Control Building
Scope of Work).
49
1 II.
2 SUMMARY OF GRC ACCOUNTS
3 A. GRC Account 561.170
Figure II-11
Summary of GRC Account 561.17059
$12,000
$10,000
$8,000
$6,000
$4,000
$2,000
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Grid Control Center
Labor $5,292 $5,312 $5,664 $6,150 $7,297 $7,297 $7,297 $7,297
Non-Labor $2,861 $3,075 $3,050 $3,073 $2,517 $2,517 $2,517 $2,517
Sub- Total $8,154 $8,387 $8,713 $9,224 $9,813 $9,813 $9,813 $9,813
Total 561.170
Labor $5,292 $5,312 $5,664 $6,150 $7,297 $7,297 $7,297 $7,297
Non-Labor $2,861 $3,075 $3,050 $3,073 $2,517 $2,517 $2,517 $2,517
Total Expenses $8,154 $8,387 $8,713 $9,224 $9,813 $9,813 $9,813 $9,813
50
1 B. GRC Account 562.150
Figure II-12
$1,800
$1,600
$1,400
$1,200
$1,000
$800
$600
$400
$200
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Inspection and Maintenance of Transmission Substation Equipment
Labor $587 $317 $638 $859 $1,119 $1,119 $1,119 $1,119
Non-Labor $712 $414 $434 $351 $456 $456 $456 $456
Sub- Total $1,299 $731 $1,072 $1,210 $1,575 $1,575 $1,575 $1,575
Total 562.150
Labor $587 $317 $638 $859 $1,119 $1,119 $1,119 $1,119
Non-Labor $712 $414 $434 $351 $456 $456 $456 $456
Total Expenses $1,299 $731 $1,072 $1,210 $1,575 $1,575 $1,575 $1,575
51
1 C. GRC Account 562.170
Figure II-13
$25,000
$20,000
$15,000
$10,000
$5,000
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Operating Transmission Substations
Labor $14,492 $13,497 $14,178 $14,325 $16,037 $16,037 $16,037 $14,387
Non-Labor $5,242 $5,652 $5,670 $4,015 $3,943 $3,943 $3,943 $3,537
Sub- Total $19,734 $19,149 $19,848 $18,340 $19,980 $19,980 $19,980 $17,924
Total 562.170
Labor $14,492 $13,497 $14,178 $14,325 $16,037 $16,037 $16,037 $14,387
Non-Labor $5,242 $5,652 $5,670 $4,015 $3,943 $3,943 $3,943 $3,537
Total Expenses $19,734 $19,149 $19,848 $18,340 $19,980 $19,980 $19,980 $17,924
52
1 D. GRC Account 568.150
Figure II-14
$14,000
$12,000
$10,000
$8,000
$6,000
$4,000
$2,000
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Miscellaneous Transmission Substation Expense
Labor $1,436 $1,390 $1,545 $809 $838 $838 $838 $838
Non-Labor $1,249 $1,163 $1,296 $743 $651 $651 $651 $651
Sub- Total $2,685 $2,553 $2,841 $1,552 $1,489 $1,489 $1,489 $1,489
Transmission Circuit Breaker Inspection and Maintenance

Labor $1,737 $1,795 $1,867 $1,767 $1,550 $1,550 $1,550 $1,550
Non-Labor $708 $670 $699 $593 $625 $625 $625 $625
Sub- Total $2,445 $2,465 $2,567 $2,360 $2,175 $2,175 $2,175 $2,175
Transmission Maintenance Crew Supervision

Labor $1,954 $1,934 $2,172 $2,000 $1,863 $1,863 $1,863 $1,863
Non-Labor $464 $469 $514 $147 $148 $148 $148 $148
Sub- Total $2,418 $2,404 $2,686 $2,147 $2,011 $2,011 $2,011 $2,011
Transmission Miscellaneous Equipment Inspection and Maintenance

Labor $1,079 $1,247 $1,142 $1,406 $1,347 $1,347 $1,347 $1,347
Non-Labor $655 $674 $496 $265 $355 $355 $355 $355
Sub- Total $1,733 $1,921 $1,638 $1,670 $1,702 $1,702 $1,702 $1,702
Transmission Relay Inspection and Maintenance

Labor $1,436 $1,507 $1,412 $1,093 $1,024 $1,024 $1,024 $1,024
Non-Labor $516 $296 $301 $181 $214 $214 $214 $214
Sub- Total $1,952 $1,803 $1,713 $1,274 $1,238 $1,238 $1,238 $1,238
Transmission Transformer Inspection and Maintenance

Labor $797 $531 $829 $562 $534 $534 $534 $534
Non-Labor $672 $422 $568 $448 $445 $445 $445 $445
Sub- Total $1,469 $953 $1,397 $1,010 $979 $979 $979 $979
Total 568.150
Labor $8,439 $8,404 $8,967 $7,637 $7,156 $7,156 $7,156 $7,156
Non-Labor $4,264 $3,694 $3,874 $2,376 $2,439 $2,439 $2,439 $2,439
Total Expenses $12,703 $12,099 $12,842 $10,013 $9,595 $9,595 $9,595 $9,595
53
1 E. GRC Account 582.150
Figure II-15
$350
$300
$250
$200
$150
$100
$50
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Inspection and Maintenance of Distribution Substation Equipment
Labor $93 $90 $128 $158 $300 $300 $300 $300
Non-Labor $3 $14 $43 $28 $33 $33 $33 $33
Sub- Total $96 $103 $171 $186 $333 $333 $333 $333
Total 582.150
Labor $93 $90 $128 $158 $300 $300 $300 $300
Non-Labor $3 $14 $43 $28 $33 $33 $33 $33
Total Expenses $96 $103 $171 $186 $333 $333 $333 $333
54
1 F. GRC Account 582.170
Figure II-16
$35,000
$30,000
$25,000
$20,000
$15,000
$10,000
$5,000
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Operating Distribution Substations
Labor $17,455 $19,075 $20,183 $20,690 $22,913 $22,913 $22,913 $20,556
Non-Labor $6,253 $7,829 $7,802 $6,003 $5,701 $5,701 $5,701 $5,114
Sub- Total $23,709 $26,904 $27,984 $26,693 $28,614 $28,614 $28,614 $25,670
Total 582.170
Labor $17,455 $19,075 $20,183 $20,690 $22,913 $22,913 $22,913 $20,556
Non-Labor $6,253 $7,829 $7,802 $6,003 $5,701 $5,701 $5,701 $5,114
Total Expenses $23,709 $26,904 $27,984 $26,693 $28,614 $28,614 $28,614 $25,670
55
1 G. GRC Account 592.150
Figure II-17
$16,000
$14,000
$12,000
$10,000
$8,000
$6,000
$4,000
$2,000
Recorded Forecast
2011 2012 2013 2014 2015 2016 2017 2018
Miscellaneous Distribution Substation Expense
Labor $608 $753 $830 $830 $1,003 $1,003 $1,003 $1,003
Non-Labor $702 $936 $746 $1,864 $488 $488 $488 $488
Sub- Total $1,310 $1,689 $1,576 $2,694 $1,491 $1,491 $1,491 $1,491
Distribution Circuit Breaker Inspection and Maintenance

Labor $2,390 $2,578 $3,132 $2,565 $2,514 $2,514 $2,514 $2,514
Non-Labor $763 $568 $1,009 $589 $964 $964 $964 $964
Sub- Total $3,154 $3,146 $4,141 $3,154 $3,477 $3,477 $3,477 $3,477
Distribution Maintenance Crew Supervision

Labor $2,291 $2,247 $2,451 $2,233 $2,168 $2,168 $2,168 $2,168
Non-Labor $515 $528 $559 $187 $165 $165 $165 $165
Sub- Total $2,806 $2,775 $3,010 $2,420 $2,333 $2,333 $2,333 $2,333
Distribution Miscellaneous Equipment Inspection and Maintenance

Labor $1,802 $1,429 $1,407 $1,723 $1,523 $1,523 $1,523 $1,523
Non-Labor $715 $558 $678 $400 $889 $889 $889 $889
Sub- Total $2,517 $1,987 $2,085 $2,123 $2,411 $2,411 $2,411 $2,411
Distribution Relay Inspection and Maintenance

Labor $2,374 $1,266 $1,295 $1,632 $1,596 $1,596 $1,596 $1,596
Non-Labor $718 $410 $427 $266 $411 $411 $411 $411
Sub- Total $3,092 $1,676 $1,722 $1,898 $2,008 $2,008 $2,008 $2,008
Distribution Transformer Inspection and Maintenance

Labor $547 $586 $764 $809 $923 $923 $923 $923
Non-Labor $414 $640 $891 $606 $597 $597 $597 $597
Sub- Total $961 $1,227 $1,655 $1,415 $1,520 $1,520 $1,520 $1,520
Total 592.150
Labor $10,013 $8,860 $9,880 $9,793 $9,727 $9,727 $9,727 $9,727
Non-Labor $3,827 $3,640 $4,309 $3,911 $3,514 $3,514 $3,514 $3,514
Total Expenses $13,839 $12,500 $14,189 $13,703 $13,241 $13,241 $13,241 $13,241
56
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Application No.: A.

2018 General Rate Case

Transmission & Distribution (T&D)

Public Utilities Commission of the State of California

Substation Construction & Maintenance O&M Expenses

I. SUBSTATION CONSTRUCTION, MAINTENANCE AND

A. Content and Organization ......................................................................1

B. Summary of O&M and Capital Request ................................................1

C. Regulatory Background/Policies driving SCE’s Request ......................3

D. 2015 Decision ........................................................................................4

1. Compliance Requirements .........................................................4

2. Comparison of Authorized 2015 to Recorded ...........................4

E. Substation Inspection and Maintenance Expenses ................................6

1. Circuit Breaker Inspection and Maintenance

a) Cost Forecast ..................................................................8

2. Transformer Inspection and Maintenance (Portions

a) Cost Forecast ................................................................11

3. Relay Inspection and Maintenance (Portions of

a) Cost Forecast ................................................................13

4. Miscellaneous Equipment Inspection and

a) Cost Forecast ................................................................15

5. Miscellaneous Substation Expenses (Portions of

a) Cost Forecast ................................................................17

6. Substation Maintenance Crew Supervision (Portions

a) Cost Forecast ................................................................19

7. Substation Work Performed by Power Production

a) Cost Forecast ................................................................20

F. Grid Operations O&M Expenses .........................................................21

1. Operating the Grid Control Center (GCC) (GRC

a) Monitoring and Operating SCE’s Bulk

b) Coordinating Planned Outages ....................................22

c) Developing and Maintaining Procedures .....................22

(1) Cost Forecast ....................................................23

2. Operating the Substation and Distribution System

a) Cost Forecast ................................................................26

G. Substation Capital Expenditures ..........................................................27

1. Substation Capital Maintenance ..............................................27

a) Cost Forecast ................................................................29

2. Substation Protection and Control Replacements ....................30

a) Distribution & Transmission Protection and

b) Digital Fault Recorder Replacement ............................30

c) Cost Forecast ................................................................31

3. Subtransmission Relay Upgrade Program ...............................32

a) Overview ......................................................................32

b) Program Necessity .......................................................32

c) Program Description ....................................................33

d) Program Alternatives ...................................................34

e) Program Benefits .........................................................34

f) Cost Forecast ................................................................36

4. Substation Spare Parts..............................................................37

a) Cost Forecast ................................................................38

5. Substation Tools and Work Equipment ...................................40

a) Cost Forecasts ..............................................................41

6. Substation Physical Security ....................................................42

a) Copper Theft Program .................................................42

b) Tiered Physical Security Systems ................................43

(1) Tier 1 NERC CIP-014 Compliance

(2) Tier 2-4 Physical Security Program .................44

c) Cost Forecast ................................................................45

7. Operational Facilities Maintenance .........................................46

a) Substation and Switching Center Facility

b) Control Building Modernization ..................................47

c) Cost Forecast ................................................................48

II. SUMMARY OF GRC ACCOUNTS ...............................................................50