1. Key Reliability Standard Spot Check Frank Vick Compliance Team Lead

2. 2 KRSSC Program ●Key Reliability Standard Spot Check (KRSSC) was designed to improve consistency of compliance auditing. ●Eight Regional Entities involved. ●Captures a snapshot of the procedures and processes. ●Reliability Standards that have the potential for having a major impact on the Bulk Electric System (BES).  2010 = PRC-005-1  2011 = EOP-005-1 Talk with Texas RE March 28, 2013

3. 3 KRSSC SCOPE & Objectives ●NERC selected an audit from each region that included PRC-005.  Time span from October 2009 through May 2010.  Similar sized registered entities. ●This snapshot provided insight into the issues facing compliance auditors in auditing PRC- 005-1.  Identified issues regional audit teams experience when evaluating compliance with the selected Reliability Standard.  Identified areas in Regional Entity audit evaluations in which additional guidance may be needed to improve evaluation processes or to promote consistency in evaluations. Talk with Texas RE March 28, 2013

4. 4 Methodology ●NERC selected an audit recently performed by each Regional Entity. ●Audit reports, Reliability Standards Audit Worksheet (RSAWs), and evidence files supplied by the Registered Entities were provided to NERC.  With the same information, could NERC come to the same conclusion as the audit team? ●Follow-up questions were asked and answered. ●Teleconferences were held with each Region. ●A report was generated.  Addressed areas needing improvement as the ERO and individually.  Enhanced consistency across all Regions. Talk with Texas RE March 28, 2013

5. 5 KRSSC Program Results ●The outcome identified six main areas of inconsistencies in the compliance audit application across the Eight Regional Entities.  Evidence of testing when test dates prior to 6/18/2007 are required to be provided. Compliance Application Notice (CAN-008-PRC-005-1).  Selecting or expanding sample sets to include all device types.  Evidence of continuous monitoring of protection system elements. Could be a substitute if stated in the registered entity’s program. Require evidence of alarming and continuous monitoring by an operator that can initiate corrective actions. Talk with Texas RE March 28, 2013

6. 6 KRSSC Program Results Cont’d  Accepting computerized summary files of test dates as evidence of testing. The audit sample is verified against actual test records to determine compliance.  When historical experience (good utility practice) is used as a basis for testing and maintenance intervals, entity must provide some historical records to support the basis.  Testing and maintenance plans with some flexibility for interval. The basis for any flexibility must be separately stated and evidence provided for the basis, or the flexibility has to be included in the basis presented for the maintenance and testing intervals. Talk with Texas RE March 28, 2013

7. 7 Miscellaneous Issues ●Test records, whether performed by registered entity personnel or contractors are not uniform and are often difficult to interpret.  Provide a sample annotated test record for each type of test record provided, with an explanation of what the test indicated and a definition of each relevant heading. ●Verifying whether DC control circuitry and/or associated communications are being tested as a part of functional testing of relays continues to be an area that requires the registered entities to provide additional information.  Provide detailed relay diagrams, functional test procedures, etc. ●PRC-005-1 R1.2 requires a “Summary of maintenance and testing procedures,”  Include a short, concise statement covering the important aspects of the maintenance and testing procedures, such as the system protection elements tested, elements continuously monitored, functional test performed, testing intervals and basis. Talk with Texas RE March 28, 2013

8. 8 Conclusion ●Results were provided to each Regional Entity individually. ●Results were reviewed with Regional Entity at the ERO Auditor Workshop and reinforced NERC’s expectation in auditing practices going forward. ●KRSSC is a tool for assessing and identifying consistency issues in the application of standards across the Regional Entities. ●Allows NERC to provide guidance to the Regional Entities and registered entities to improve the compliance monitoring process. ●Allows NERC to further its goal of being a learning organization and maintaining transparency. Talk with Texas RE March 28, 2013

9. 9 PRC-005-1 R1 Expectations – Texas RE ●Provide a “Program” document (or documents) that fully describes what the Registered Entity does to ensure all transmission and generation Protection Systems affecting the reliability of the Bulk Electric System (BES) are maintained and tested. ●The Program must include maintenance and testing intervals for each device/equipment type.  Protective relays.  Associated communication systems.  Voltage and current sensing devices.  Station batteries and battery chargers.  DC control circuitry. Talk with Texas RE March 28, 2013

10. 10 PRC-005-1 R1 Expectations – Texas RE Cont’d ●The Program must include/identify a basis for the maintenance and testing intervals for each device/equipment type.  Protective relays.  Associated communication systems.  Voltage and current sensing devices.  Station batteries and battery chargers.  DC control circuitry. ●NERC’s “Protection System Maintenance (A Technical Reference)” document, prepared by the System Protection and Controls Task Force (Sept. 13, 2007), could be used to provide a basis. Talk with Texas RE March 28, 2013

11. 11 PRC-005-1 R1 Expectations – Texas RE Cont’d ●The Program must include a summary of the maintenance and testing procedures by device/equipment type.  Protective relays.  Associated communication systems.  Voltage and current sensing devices.  Station batteries and battery chargers.  DC control circuitry. ●Include a detailed narrative describing the entity’s program and how the program is implemented with clear references to the Program document(s). Talk with Texas RE March 28, 2013

12. 12 PRC-005-1 R2 Expectations – Texas RE ●Include a detailed narrative describing how the entity implemented its Program with clear references to the Program document(s) and associated records. ●Provide a complete listing of all the equipment in the Entity’s Protection System by type (Excel). ●Equipment name, type, location, interval, last 2 test dates, next test date. ●Include all the equipment types (not just the relays).  Protective relays.  Associated communication systems.  Voltage and current sensing devices.  Station batteries and battery chargers.  DC control circuitry. Talk with Texas RE March 28, 2013

13. 13 PRC-005-1 R2 Expectations – Texas RE Cont’d ●Provide the actual maintenance and test records.  For smaller entities initial submission could include all the records.  For larger entities provide sample records of each type of inspection, maintenance or test record (for last 2 dates). ●For each type of test record, provide narrative describing what is being done with references in the record identified. ●If all records are not provided in the initial submission, Texas RE will provide a sampling list by equipment type that the Entity will be expected to provide detailed evidence in the form of inspection, maintenance and test records. Talk with Texas RE March 28, 2013

14. 14 PRC-005-1 R2 Expectations – Texas RE Cont’d ●The Entity will provide the inspection, maintenance and test records requested in the sampling list. ●Additional records may be requested during the audit. ●Note:  Relays may have different maintenance and test intervals based upon relay type and monitoring.  Batteries may have different intervals for: Inspection Test Maintenance Talk with Texas RE March 28, 2013

15. 15 PRC-005-2 Update ●This standard merges previous standards PRC-005-1, PRC-008-0, PRC-011-0, and PRC-017-0. ●NERC has provided a companion document to PRC-005-2, PRC-005-2 Protection — System Maintenance Supplementary Reference. ●PRC-005-2 was adopted by the BOT on November 7, 2012. ●PRC-005-2 has been filed with FERC. Talk with Texas RE March 28, 2013

16. Contact Information Frank.Vick@texasre.org (512) 583-4949