Project Single Points of Failure

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Project 2015-10 Single Points of Failure Bill Harm, NERC & Regional Coordination RSCS meeting September 15, 2017

Agenda Drafting Team Members Project 2015 10 Background Proposed Revisions Implementation Plan Next Steps 2

Standard Drafting Team (SDT) Members Name Jonathan Hayes (Chair) Delyn Kilpack (Vice Chair) Chris Colson Bill Harm Baj Agrawal Liqin Jiang Rich Kowalski Prabhu Gnanam Manuela Dobrescu Dobritoiu Ruth Kloecker Organization/ Company Southwest Power Pool Louisville Gas & Electric and Kentucky Utilities Western Area Power Administration PJM Arizona Public Service Company Duke Energy ISO New England ERCOT Hydro Quebec ITC Holdings 3

Background Addresses reliability issues concerning the study of single points of failure on Protection Systems from FERC Order No. 754 Addresses directives from FERC Order No. 786 Replaces references to the MOD 010 and MOD 012 standards with the MOD 032 Reliability Standard The threat to BES reliability from single point of failure (SPF) of a Protection System component established well before this draft standard 4

Background Project 2015 010 Single Points of Failure March 30, 2009: NERC issued a advisory report notifying the industry that a single point of failure issue had caused three significant system disturbances in five years. October 24 25, 2011: FERC technical conference titled Staff meeting on Single Points of Failure on Protection Systems concerning Commission s Order No. 754. December 6 8, 2011: NERC System Protection and Control Subcommittee (SPSC) agreed to sponsor a Request for Interpretation (RFI) which was accepted on February 3, 2012. September 2015 Report of Analysis on NERC Section 1600 Request for Data made a recommendation that TPL 001 4 Table 1 P5 event be revised to include protection system failure instead of a relay failure. 5

Summary of Revisions Project 2015 010 Single Points of Failure Requirement R1 Updated for MOD 032 1 standard. Requirement R1 Modified how known outages are selected for study. Requirement R2 Modified the P1 contingency events simulated (steady state) for known outages. Requirement R2 Added model conditions for stability analysis of P1 events for known outages. Requirement R2 Added stability analysis requirement for long lead time equipment unavailability. Requirement R4 Added documentation requirement if Cascading observed given 3 phase fault SPF. 6

Summary of Revisions Project 2015 010 Single Points of Failure Table 1 Modified Category P5 event to include SPF. Table 1 Modified Extreme Events, Stability column to differentiate SPF from stuck breaker. Table 1 Modified Footnote 13 to specify SPF. Implementation Plan (R1 & R2 36 months; R4 60 months). 7

Known Outages Key Concepts Addressing FERC Order No. 786 Planned outages are not hypothetical outages and should not be treated as multiple contingencies in the planning standard (should be addressed in N 0 base case) (P 42); Relying on Category P3 and P6 is not sufficient and does not cover maintenance outages (P 44); Near Term Transmission Planning Horizon requires annual assessments using Year One or year two, and year five, and known planned facility outages of less than six months should be addressed so long as their planned start times and durations may be anticipated as occurring for some period of time during the planning time horizon (P 45). 8

Known Outages Proposed Change to Requirement R1, Part 1.1.2 Study of Known Outages TPL 001 4 only requires study of outages lasting longer than six months. FERC Order No. 786 directed NERC to address outages that may be excluded. o Revised Requirement R2, Part 2.1.3 will reference Requirement R1, Part 1.1.2 (steady state Near Term). o New Requirement R2, Part 2.4.3 will reference Requirement R1, Part 1.1.2 (stability Near Term). Proposed coordination with Reliability Coordinator. o Pursuant to IRO 017 (Outage Coordination). o as selected in consultation with the RC for the Near Term Planning Horizon. 9

Known Outages Don t confuse duration of outage with when outage is planned Duration can be of any length of time. Outage must still fall within the Near Term Planning Horizon ( The transmission planning period that covers Year One through five. ). 10

Spare Equipment Proposed Change to Spare Equipment TPL 001 4 Requirement R2, Part 2.1.4 requires steady state study of removed long lead equipment from model if long lead equipment does not have a spare (example transformers). Proposed addition of Requirement R2, Part 2.4.5 requires stability study be performed for long lead equipment that does not have a spare. o Only have to study P1 and P2 events. 11

Single Point of Failure Events Proposed Change to P5 and Extreme Event Existing TPL 001 4 Table 1 P5 and extreme event (3 phase fault) refers to a fault and a failure of a non redundant relay. The proposal changes event to a fault and a failure of a non redundant component of a Protection System. For extreme event (Stability column), breaker failure and failure of a nonredundant component of a Protection System are differentiated. o Recognizes that sequence of Protection System action leading to Delayed Clearing may be quite different between two causalities. 12

Table 1 Footnote 13 Footnote 13 Expands Protection System components to be considered: o A single protective relay which responds to electrical quantities, without an alternative that provides comparable Normal Clearing times, e.g. sudden pressure relaying; o A single communications system, necessary for correct operation of a communication aided protection scheme required for Normal Clearing, which is not monitored or not reported; o A single dc supply associated with protective functions, and that single station dc supply is not monitored or not reported for both low voltage and open circuit; o A single control circuitry associated with protective functions including the trip coil(s) of the circuit breakers or other interrupting devices. Proposed TPL 001 5 clarifies subset of components of Protection System relevant to assessing Delayed Clearing. o PTs and CTs are excluded; single failed device unlikely to prevent tripping. o All other components addressed. 13

Single Point of Failure Event-driven Actions P5 Events Pursuant to Requirement R2, Part 2.7, failure to meet performance requires the development of a Corrective Action Plan Extreme Events 2e 2h Stability column Pursuant to Requirement R4, Part 4.2.2, if analysis concludes there is Cascading, an evaluation of possible actions designed to prevent the System from Cascading shall: o List System deficiencies, the associated actions needed to prevent the System from Cascading, and the associated timetable for implementation. o Be reviewed in subsequent annual Planning Assessments for continued validity and implementation status. 14

Implementation Plan The SDT recognizes the need to have a phased in approach to be able to study and develop a CAP for the failure of a Component of a Protection System In summary: R1 and R2 enforceable in 36 months after FERC approval (and alignment time). R4 enforceable in 60 months after FERC approval (and alignment time). CAPs addressing P5 changes enforceable in 60 months after FERC approval. Planning Assessments addressing all provisions of TPL 001 5 required by 36 months after FERC approval. 15

Technical Rationale Provides drafting teams a mechanism to: Explain the technical basis for Reliability Standard Provide technical guidance to help support effective application Moving forward a separate document to explain technical basis will be developed. Focus on understanding technology and the technical requirements No compliance approaches or compliance guidance Encourage use of NERC Compliance Guidance Policy Begin implementing for all projects going forward TPL 001 5 will not have rationale boxes in the standard Technical Rationale in Reliability Standards Compliance Guidance Policy 16

Next Steps At the September 2017 Standards Committee meeting, the SDT will seek authorization to post for a 45 day comment period and initial ballot An SDT meeting will be held to consider comments received Point of contact Latrice Harkness, Senior Standards Developer o Latrice.Harkness@nerc.net or call 404 446 9689 17

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