UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Transcription

1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION WESTERN ELECTRICITY ) Docket Nos. RM COORDINATING COUNCIL ) RM ) COMPLIANCE FILING OF THE WESTERN ELECTRICITY COORDINATING COUNCIL IN RESPONSE TO ORDER NUMBERS 751 AND 752 ON VERSION ONE REGIONAL RELIABILITY STANDARDS I. INTRODUCTION The Western Electricity Coordinating Council (WECC) submits this filing in compliance with the directives of the Federal Energy Regulatory Commission (FERC or the Commission) contained in der Nos and in Docket Nos. RM and RM respectively, which approved certain Regional Reliability Standards developed by the WECC and submitted to the Commission for approval by the North American Electric Reliability Corporation (NERC). der No. 751 approved four revised WECC Regional Reliability Standards and five new regional definitions, and directed WECC to submit revisions to or explanations justifying certain violation risk factors (VRFs) and violation severity levels (VSLs) associated with the approved WECC Regional Reliability Standards, within sixty (60) days of the issuance of the Final Rule. der No. 751 also directed WECC to file, within sixty (60) days of the issuance of the Final Rule, WECC s criterion for identifying and modifying major transmission paths listed in the 1 Final Rule, Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance; Protection and Control; and Voltage and Reactive, (der 751), 135 FERC 61,061, 76 Fed. Reg. 23,690, (April 21, 2011). 2 Final Rule, Version One Regional Reliability Standard for Transmission Operations, (der 752), 135 FERC 61,062, 76 Fed. Reg. 23,470, (April 21, 2011).

2 Major WECC Transfer Paths in the Bulk Electric System Table (Transfer Path Table) and the Major WECC Remedial Action Schemes (RAS) Table (RAS Table). der No. 752 approved one WECC Regional Reliability Standard, directed WECC to modify certain VRFs and VSLs associated with the approved WECC Regional Reliability Standard, and directed WECC to file the modifications, within one-hundred twenty (120) days of the issuance of the Final Rule. der No. 752 also directed WECC to file, within sixty (60) days of the issuance of the Final Rule, WECC s criterion for identifying and modifying major transmission paths listed in the Transfer Path Table. Exhibit A to this filing includes clean and redline versions of FAC-501-WECC-1, PRC-004-WECC-1, VAR-002-WECC-1, and VAR-501- WECC-1 containing revisions to the associated VSLs as directed in der No. 751 and described herein. Exhibit B to this filing includes a clean and a redline version of TOP-007-WECC-1 including the revisions to the associated VRFs and VSLs as directed in der No. 752 and described herein. II. NOTICES AND COMMUNICATIONS following: Notices and communications with respect to this filing may be addressed to the Mark W. Maher Heather A. Ebert* Chief Executive Officer Senior Legal Counsel Steven F. Goodwill Western Electricity Coordinating Vice President and General Counsel Council Steven Rueckert* 7600 NE 41 st Street. Suite 150 Director of Standards Vancouver, WA Western Electricity Coordinating Telephone: (360) Council hebert@wecc.biz 155 North 400 West, Suite 200 Salt Lake City, UT Telephone: (801) steve@wecc.biz *Persons to be included on the Commission s official service list.

3 III. WECC TRANSFER PATH TABLE and WECC REMEDIAL ACTION SCHEMES TABLE der Nos. 751 and 752 direct WECC to file WECC s criteria for identifying and modifying major transmission paths listed in the Transfer Path Table. der No. 751 also directs WECC to file its criteria for identifying and modifying remedial action schemes (RAS) in the RAS Table. der Nos. 751 and 752 further accept WECC s commitment to publicly post any revisions to the Transfer Path Table and the RAS Table on the WECC website with concurrent notification to the Commission, NERC, and the industry. The Transfer Path Table and the RAS Table (jointly referred to herein as the Tables ) were originally developed as part of the Western Systems Coordinating Council (WSCC) 3 Reliability Management System (RMS) reliability criteria. 4 The WSCC Board of Trustees established a policy group and three task forces to develop the RMS reliability criteria. One of the WSCC task forces, comprised of experienced engineers and technical experts from WSCC members and non-members, including Security Coordinators, regulatory representatives, and WSCC Staff, determined the transfer paths and RAS to which certain RMS criteria would apply based on criticality to system reliability. During the course of developing the RMS criteria, the identified transfer paths and RAS were organized into the Tables by the WSCC task force. The Tables were posted for, and revised through, public comment. The Tables were also evaluated and revised through field tests during the RMS reliability criteria development process. The resulting tables, which were later named the Major WECC Transfer Paths in the Bulk Electric System Table and the Major WECC Remedial Action Schemes (RAS) Table, were thus 3 WSCC is one of the three predecessor entities to WECC. The Western Electricity Coordinating Council (WECC) was formed on April 18, 2002, by the merger of the WSCC, Southwest Regional Transmission Association (SWRTA), and Western Regional Transmission Association (WRTA). 4 The first WSCC RMS Reliability Criteria Agreement was accepted for filing by the Commission on July 29, 1999 in Docket No. ER and designated Western Systems Coordinating Council, FERC Electric Tariff, iginal Volume No. 1.

4 developed through an in-depth, broad and open process which included technical subject matter experts, public input, and lessons learned in field testing. The RMS reliability criteria, including the Tables, were then approved by the WSCC Board of Trustees and filed with FERC. 5 The WECC Regional Reliability Standards approved in der Nos. 751 and 752 arose initially from RMS reliability criteria, which were not addressed in the NERC continent-wide mandatory Reliability Standards. When these RMS reliability criteria were initially translated into WECC Regional Reliability Standards the Tables were included without revision. After approval by the WECC Board of Directors 6 and the NERC Board of Trustees, 7 NERC submitted eight proposed WECC Regional Reliability Standards for FERC approval. 8 On June 8, 2007, the Commission approved the proposed standards and directed WECC to develop specific modifications to some of the standards (2007 der). 9 During the subsequent standards development process at WECC, the Tables, which are now referenced in TOP-007-WECC-1, PRC-004-WECC-1, and FAC-501-WECC-1, were removed, without revision, from the WECC Regional Reliability Standards themselves. As approved by the Commission in der Nos. 751 and 752, the Tables are now posted on the WECC website. WECC has identified the need to develop current criteria for revising and updating the Tables because they have been removed from the associated WECC Regional Reliability Standards. As a result, WECC has begun the process of initiating formal development of current criteria for revising and updating the Tables. WECC is using an open, transparent, stakeholder process similar to the Process for Developing and Approving WECC Standards, to develop the 5 Id. 6 January 5, March 12, NERC submitted eight WECC Regional Reliability Standards to the Commission for approval on March 26, See Docket No. RR North American Electric Reliability Corp., 119 FERC 61,260 (June 8, 2007).

5 criteria. After approval by the WECC Board of Directors, WECC will post the criteria on its website and provide notice to FERC, NERC and the industry through a subsequent Compliance Filing in Docket Nos. RM and RM , unless otherwise directed by the Commission. WECC will not modify the Tables in the interim, unless directed by the Commission. IV. REVISIONS TO VIOLATION RISK FACTORS and VIOLATION SEVERITY LEVELS A. der No. 751 In der No the Commission directed WECC to consider modifications to certain VRFs and VSLs for FAC-501-WECC-1, PRC-004-WECC-1, VAR-002-WECC-1, and VAR- 501-WECC-1. The Commission then directed WECC to submit either revisions to such VRFs and VSLs or explanations justifying the current VRFs and VSLs, within 60 days of the issuance of der. 11 The following is a description of the changes to certain VSLs which WECC is submitting with this filing at Exhibit A, as well as justification for certain other current VRFs which WECC has not changed. 1. FAC-501-WECC-1 VSL Assignments The Commission noted that for FAC-501-WECC-1 the Lower VSL applies when the transmission maintenance and inspection plan does not include facilities for one of the paths in the Transfer Path Table, but the Transmission Owner (TO) is performing maintenance and inspection for those facilities. The Moderate VSL for FAC-501-WECC-1 applies when the transmission maintenance and inspection plan does not include facilities for two of the paths in the Transfer Path Table, and the TO is not performing maintenance and inspection for those 10 der No. 751 at P Id.

6 facilities. The Commission is concerned that it is ambiguous which VSL would apply if the transmission maintenance and inspection plan does not include facilities for one of the paths in the Transfer Path Table, and the TO is not performing maintenance and inspection for those facilities. 12 WECC addressed this concern by modifying the Lower and Moderate VSLs to include the scenario wherein the transmission maintenance and inspection plan does not include facilities for one or more of the paths in the WECC Transfer Path Table, but the TO is performing maintenance and inspection for those facilities (Lower), and to include the scenario where the transmission maintenance and inspection plan does not include associated facilities for one or two of the paths in the WECC Transfer Path Table, and the TO is not performing maintenance and inspection for those facilities (Moderate). 2. PRC-004-WECC-1 VSL and VRF Assignments The Commission notes that in PRC-004-WECC-1, the VSLs for Requirement R2.3 do not define a potential violation for the TO, even though both Requirement 2.3 and sub- Requirement apply to a TO. 13 WECC clarifies that, although the TO is not specifically identified in the language of the VSLs for Requirement 2.3 and sub-requirement 2.3.1, the failure to complete the actions required of the TO is identified in the language of the VSLs for Requirement 2.3 as previously filed with the Commission. Specifically, Requirement R2.3 requires the TO or the Generator Owner to repair and place back in service, within twenty-two (22) hours, any Protection System or RAS that incurred a Security-Based or Dependability- Based Misoperation where a Functionally Equivalent Protection System (FEPS) or Functionally 12 der No. 751 at P der No. 751 at P 130.

7 Equivalent Remedial Action Scheme (FERAS) is not in service to ensure the reliability of the Bulk Electric System. In addition, under Requirement R2.3.1, in instances where a FEPS is not available, the TO must remove the associated Element from service. The language of the VSLs identifies the failure to perform such requirements within 22 hours. However, WECC acknowledges the Commission s concern and has addressed it by including the term Transmission Owner, in the language of the VSLs for R2, and by rearranging the order of the applicable functions consistent with the required order of the actions in Requirement R2. The Commission also noted that VRFs have not been assigned to Requirements R2, R2.4, and R2.4.1 in PRC-004-WECC-1, 14 and directed WECC to submit an explanation if WECC believes it would be inappropriate to assign VRFs to these Requirements. WECC clarifies that the drafting of PRC-004-WECC-1 and drafting and assignment of VRFs for PRC-004-WECC-1 was completed in late 2007 and early 2008, and the formatting standard practices at that time differ from the current practices for formatting standards and the corollary formatting and assignment of VRFs. PRC-004-WECC-1 is drafted in a manner where the Requirements and sub-requirements are not individually one complete stand-alone action, but rather, point to the next level of sub-requirements for required actions or action options. At the time of drafting PRC-004-WECC-1, the drafting team assigned VRFs to the Requirement or sub-requirement where the complete action was identified. For example, the language contained in Requirement R2 requires the applicable entities to perform the actions of R2.1, R2.2, R2.3, or R2.4, depending on the type of Misoperation, rather than requiring a separate action in and of itself. As a result High VRFs are assigned to R2.1, R2.2 and R2.3. R2.4 is written similarly to R2 in that a certain action is acceptable if one of the sub-requirements of R2.4 is met. Specifically, R2.4 indicates 14 der No. 751 at P 130.

8 the Element or transmission path at issue may remain in service provided one of the actions of sub-requirements R2.4.1 or R2.4.2 is performed. As such, the VRF (Low) for R2.4 is identified at the end of sub-requirement R It was not possible to assign a High VRF to Requirement 2 because the last action identified in R2.4 is assigned a Low VRF. WECC understands that this multiple-layer standard formatting is no longer used, but also recognizes that a formal standards drafting effort would be required to revise the format of the standard. WECC has not revised the VRF assignments for PRC-004-WECC-1 at this time because, as discussed herein, the manner in which the standard is constructed does not lead to clear and enforceable VRF assignments for certain Requirements and sub-requirements. WECC agrees with the Commission that PRC-004-WECC-1 is enforceable as written, 15 and WECC agrees that when PRC-004-WECC-1 is next revised the PRC-004-WECC-1 Requirements and sub-requirements will be revised to ensure the formatting is consistent with any changes in NERC and Commission guidelines VAR-002-WECC-1 and VAR-501-WECC-1 VSL Assignments The Commission raised a concern that Requirement R1of VAR-002-WECC-1 requires the automatic voltage regulators to be in service and in automatic voltage control mode but the VSLs for Requirement R1 only specify that the automatic voltage regulator must be in service, and that this language could potentially be viewed as a violation of FERC guideline WECC addressed the Commission s concern by including the words and in automatic voltage control mode to the language of the VSLs for VAR-002-WECC-1, Requirement R1. 15 der No. 751 at P 51, der No. 751 at P der No. 751 at P 131.

9 The Commission also noted that in VAR-002-WECC-1, Requirement R1, and VAR-501- WECC-1, Requirement R1, the VSLs appear to lower the level of compliance from the levels of non-compliance associated with the currently-effective VAR-STD-002a-1 and VAR-STD- 002[b]-1, and that this change could potentially violate FERC violation severity level guideline WECC addressed this concern by modifying the percentage increments in the VSLs for VAR-002-WECC-1, Requirement R1 and VAR-501-WECC-1, Requirement 1 to five percent increments, consistent with NERC s guidance in the NERC reference document Violation Severity Level Guidelines 19, rather than to the two percent increments which would be indicated by FERC violation severity level guideline 1. The five percent increments are appropriate for two reasons. The two percent increments in the VAR-STD-002a-1 and VAR-STD-002b-1 were related to Levels of Non-Compliance and VSLs and Levels of Non-Compliance are not directly interchangeable. Levels of Non- Compliance took both the risk to the system, which is now addressed by VRFs, and the level to which a registered function failed to meet a requirement, which is now addressed by the VSL, into account. In current practice, VSLs are used solely for identifying the level to which the applicable entity failed to meet the requirement. As such, WECC does not believe that the two percent increments are appropriate or necessary to ensure reliability of the Bulk Electric System in this instance. In addition, WECC has identified no technical justification for the two percent increments included in VAR-STD-002a-1 and VAR-STD-002b-1. In the absence of a technical justification for the two percent increments, WECC adhered to NERC s guidance in the NERC reference document Violation Severity Level Guidelines and revised the VSLs associated with VAR-002-WECC-1 and VAR-501-WECC-1 to include five percent increments. 18 der No. 751 at P

10 The Commission also notes that, in VAR-002-WECC-1, Requirement R2, and VAR-501- WECC-1, Requirement R2, only Lower and Moderate VSLs are defined. 20 WECC addressed this concern by providing revised VSLs for VAR-002-WECC-1, Requirement R2, and VAR-501- WECC-1, Requirement R2, that are based on the failure of the applicable entity to have documentation identifying the number of hours excluded for increasing amounts of the requirements identified in VAR-002-WECC-1, Requirement R1.1 through R1.10 and VAR-501- WECC-1, Requirement R1.1 through R1.12. B. der No TOP-007-WECC-1 VRF and VSL Assignments In der No. 752, the Commission directed WECC to modify the VRF assignment for TOP-007-WECC-1, Requirement 1 from Medium to High 21 and to modify the VRF assignment for TOP-007-WECC-1, Requirement R2, from Lower to Medium, 22 and to submit a compliance filing reflecting these modifications within one hundred twenty (120) days from the date the Final Rule was issued. WECC hereby submits the modified VRFs, with this filing at Exhibit B, as directed. In der No. 752, the Commission also directed WECC to modify the VSL assignments for TOP-007-WECC-1, to reflect NERC s approved table format and include the revision as part of its compliance filing to be submitted within one hundred twenty (120) days from the date the Final Rule was issued. 23 WECC hereby submits the VSL assignments for TOP-007-WECC-1 in NERC s approved table format, with this filing at Exhibit B. 20 Id. 21 der No. 752 at P der No. 752 at P der No. 752 at P 53.

11 V. CONCLUSION WECC respectfully requests that the Commission accept this Compliance Filing in accordance with the Commission s directives in der Nos. 751 and 752, and approve the revised VSLs and VRFs described herein. Respectfully submitted this 20 th day of June, 2011, WESTERN ELECTRICITY COORDINATING COUNCIL /s/ Heather A. Ebert Heather A. Ebert Senior Legal Counsel Western Electricity Coordinating Council 7600 NE 41 st Street. Suite 150 Vancouver, WA Telephone: (360) hebert@wecc.biz

12 EXHIBIT A

13 WECC Standard FAC-501-WECC-1 Transmission Maintenance A. Introduction 1. Title: Transmission Maintenance 2. Number: FAC-501-WECC-1 3. Purpose: To ensure the Transmission Owner of a transmission path identified in the table titled Major WECC Transfer Paths in the Bulk Electric System including associated facilities has a Transmission Maintenance and Inspection Plan (TMIP); and performs and documents maintenance and inspection activities in accordance with the TMIP. 4. Applicability 4.1 Transmission Owners that maintain the transmission paths in the most current table titled Major WECC Transfer Paths in the Bulk Electric System provided at: 5. Effective Date: July 1, 2011 B. Requirements R.1. Transmission Owners shall have a TMIP detailing their inspection and maintenance requirements that apply to all transmission facilities necessary for System Operating Limits associated with each of the transmission paths identified in table titled Major WECC Transfer Paths in the Bulk Electric System. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning] R1.1. Transmission Owners shall annually review their TMIP and update as required. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning] R.2. Transmission Owners shall include the maintenance categories in Attachment 1-FAC-501- WECC-1 when developing their TMIP. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] R.3. Transmission Owners shall implement and follow their TMIP. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] C. Measures M1. Transmission Owners shall have a documented TMIP per R.1. M1.1 Transmission Owners shall have evidence they have annually reviewed their TMIP and updated as needed. M2. Transmission Owners shall have evidence that their TMIP addresses the required maintenance details of R.2. M3. Transmission Owners shall have records that they implemented and followed their TMIP as required in R.3. The records shall include: 1. The person or crew responsible for performing the work or inspection, 2. The date(s) the work or inspection was performed, 3. The transmission facility on which the work was performed, and 4. A description of the inspection or maintenance performed. Page 1 of 4

14 WECC Standard FAC-501-WECC-1 Transmission Maintenance D. Compliance 1. Compliance Monitoring Process 1.1 Compliance Monitoring Responsibility Compliance Enforcement Authority 1.2 Compliance Monitoring Period The Compliance Enforcement Authority may use one or more of the following methods to assess compliance: - Self-certification conducted annually - Spot check audits conducted anytime with 30 days notice given to prepare - Periodic audit as scheduled by the Compliance Enforcement Authority - Investigations - Other methods as provided for in the Compliance Monitoring Enforcement Program The Reset Time Frame shall be one year. 1.3 Data Retention The Transmission Owners shall keep evidence for Measure M1 through M3 for three years plus the current year, or since the last audit, whichever is longer. 1.4 Additional Compliance Information No additional compliance information. 2. Violation Severity Levels R# Lower VSL Moderate VSL High VSL Severe VSL R1 The TMIP does not include associated Facilities for one or more of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 but Transmission Owners are performing maintenance and inspection for the missing Facilities. The TMIP does not include associated Facilities for one or two of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the missing Facilities. The TMIP does not include associated Facilities for three of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the missing Facilities. The TMIP does not include associated Facilities for more than three of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the missing Facilities. or Page 2 of 4

15 WECC Standard FAC-501-WECC-1 Transmission Maintenance R2 R3 Transmission Owners did not review their TMIP annually as required by R.1.1. The TMIP does not include one maintenance category identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. Transmission Owners do not have maintenance and inspection records as required by R.3 but have evidence that they are implementing and following their TMIP. The TMIP does not include two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. Transmission Owners are not performing maintenance and inspection for one maintenance category identified in Attachment 1 FAC-501-WECC-1 as required in R3. The TMIP does not include three maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. Transmission Owners are not performing maintenance and inspection for two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in R3. The TMIP does not exist or does not include more than three maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. Transmission Owners are not performing maintenance and inspection for more than two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in R3. Version History Shows Approval History and Summary of Changes in the Action Field Version Date Action Change Tracking 1 April 16, 2008 Permanent Replacement Standard for PRC-STD October 29, 2008 NERC BOT conditional approval 1 April 21, 2011 FERC Approved in der 751 Page 3 of 4

16 WECC Standard FAC-501-WECC-1 Transmission Maintenance Attachment 1-FAC-501-WECC-1 Transmission Line and Station Maintenance Details The maintenance practices in the TMIP may be performance-based, time-based, conditional based, or a combination of all three. The TMIP shall include: 1. A list of Facilities and associated Elements necessary to maintain the SOL for the transfer paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System; 2. The scheduled interval for any time-based maintenance activities and/or a description supporting condition or performance-based maintenance activities including a description of the condition based trigger; 3. Transmission Line Maintenance Details: a. Patrol/Inspection b. Contamination Control c. Tower and wood pole structure management 4. Station Maintenance Details: a. Inspections b. Contamination Control c. Equipment Maintenance for the following: Circuit Breakers Power Transformers (including phase-shifting transformers) Regulators Reactive Devices (including, but not limited to, Shunt Capacitors, Series Capacitors, Synchronous Condensers, Shunt Reactors, and Tertiary Reactors) Page 4 of 4

17 WECC Standard FAC-501-WECC-1 Transmission Maintenance A. Introduction 1. Title: Transmission Maintenance 2. Number: FAC-501-WECC-1 3. Purpose: To ensure the Transmission Owner of a transmission path identified in the table titled Major WECC Transfer Paths in the Bulk Electric System including associated facilities has a Transmission Maintenance and Inspection Plan (TMIP); and performs and documents maintenance and inspection activities in accordance with the TMIP. 4. Applicability 4.1 Transmission Owners that maintain the transmission paths in the most current table titled Major WECC Transfer Paths in the Bulk Electric System provided at: 5. Effective Date: July 1, 2011 B. Requirements R.1. Transmission Owners shall have a TMIP detailing their inspection and maintenance requirements that apply to all transmission facilities necessary for System Operating Limits associated with each of the transmission paths identified in table titled Major WECC Transfer Paths in the Bulk Electric System. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning] R1.1. Transmission Owners shall annually review their TMIP and update as required. [Violation Risk Factor: Medium] [Time Horizon: Long-term Planning] R.2. Transmission Owners shall include the maintenance categories in Attachment 1-FAC-501- WECC-1 when developing their TMIP. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] R.3. Transmission Owners shall implement and follow their TMIP. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] C. Measures M1. Transmission Owners shall have a documented TMIP per R.1. M1.1 Transmission Owners shall have evidence they have annually reviewed their TMIP and updated as needed. M2. Transmission Owners shall have evidence that their TMIP addresses the required maintenance details of R.2. M3. Transmission Owners shall have records that they implemented and followed their TMIP as required in R.3. The records shall include: 1. The person or crew responsible for performing the work or inspection, 2. The date(s) the work or inspection was performed, 3. The transmission facility on which the work was performed, and 4. A description of the inspection or maintenance performed. Page 1 of 5

18 WECC Standard FAC-501-WECC-1 Transmission Maintenance D. Compliance 1. Compliance Monitoring Process 1.1 Compliance Monitoring Responsibility Compliance Enforcement Authority 1.2 Compliance Monitoring Period The Compliance Enforcement Authority may use one or more of the following methods to assess compliance: - Self-certification conducted annually - Spot check audits conducted anytime with 30 days notice given to prepare - Periodic audit as scheduled by the Compliance Enforcement Authority - Investigations - Other methods as provided for in the Compliance Monitoring Enforcement Program The Reset Time Frame shall be one year. 1.3 Data Retention The Transmission Owners shall keep evidence for Measure M1 through M3 for three years plus the current year, or since the last audit, whichever is longer. 1.4 Additional Compliance Information No additional compliance information. 2. Violation Severity Levels 2.1. Lower: There shall be a Lower Level of non-compliance if any of the following conditions exist: The TMIP does not include associated Facilities for one of the Paths identified in Attachment 1 FAC-501-WECC-1 as required by R.1 but Transmission Owners are performing maintenance and inspection for the missing Facilities Transmission Owners did not review their TMIP annually as required by R The TMIP does not include one maintenance category identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories Transmission Owners do not have maintenance and inspection records as required by R.3 but have evidence that they are implementing and following their TMIP Moderate: There shall be a Moderate Level of non-compliance if any of the following conditions exist: The TMIP does not include associated Facilities for two of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the missing Facilities The TMIP does not include two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. Page 2 of 5

19 WECC Standard FAC-501-WECC-1 Transmission Maintenance Transmission Owners are not performing maintenance and inspection for one maintenance category identified in Attachment 1 FAC-501-WECC-1 as required in R High: There shall be a High Level of non-compliance if any of the following condition exists: The TMIP does not include associated Facilities for three of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the missing Facilities The TMIP does not include three maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories Transmission Owners are not performing maintenance and inspection for two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in R Severe: There shall be a Severe Level of non-compliance if any of the following condition exists: The TMIP does not include associated Facilities for more than three of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the missing Facilities The TMIP does not exist or does not include more than three maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories Transmission Owners are not performing maintenance and inspection for more than two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in R3. R# Lower VSL Moderate VSL High VSL Severe VSL R1 The TMIP does not include associated Facilities for one or more of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System Attachment 1 FAC-501-WECC- 1 as required by R.1 but Transmission Owners are performing maintenance and The TMIP does not include associated Facilities for one or two of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the The TMIP does not include associated Facilities for three of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the The TMIP does not include associated Facilities for more than three of the Paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System as required by R.1 and Transmission Owners are not performing maintenance and inspection for the Page 3 of 5

20 WECC Standard FAC-501-WECC-1 Transmission Maintenance inspection for the missing Facilities. missing Facilities. missing Facilities. missing Facilities. or Transmission Owners did not review their TMIP annually as required by R.1.1. R2 The TMIP does not include one maintenance category identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. The TMIP does not include two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. The TMIP does not include three maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. The TMIP does not exist or does not include more than three maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required by R.2 but Transmission Owners are performing maintenance and inspection for the missing maintenance categories. R3 Transmission Owners do not have maintenance and inspection records as required by R.3 but have evidence that they are implementing and following their TMIP. Transmission Owners are not performing maintenance and inspection for one maintenance category identified in Attachment 1 FAC-501-WECC-1 as required in R3. Transmission Owners are not performing maintenance and inspection for two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in R3. Transmission Owners are not performing maintenance and inspection for more than two maintenance categories identified in Attachment 1 FAC-501-WECC-1 as required in R3. Version History Shows Approval History and Summary of Changes in the Action Field Version Date Action Change Tracking 1 April 16, 2008 Permanent Replacement Standard for PRC-STD October 29, 2008 NERC BOT conditional approval 1 April 21, 2011 FERC Approved in der 751 Page 4 of 5

21 WECC Standard FAC-501-WECC-1 Transmission Maintenance Attachment 1-FAC-501-WECC-1 Transmission Line and Station Maintenance Details The maintenance practices in the TMIP may be performance-based, time-based, conditional based, or a combination of all three. The TMIP shall include: 1. A list of Facilities and associated Elements necessary to maintain the SOL for the transfer paths identified in the most current Table titled Major WECC Transfer Paths in the Bulk Electric System; 2. The scheduled interval for any time-based maintenance activities and/or a description supporting condition or performance-based maintenance activities including a description of the condition based trigger; 3. Transmission Line Maintenance Details: a. Patrol/Inspection b. Contamination Control c. Tower and wood pole structure management 4. Station Maintenance Details: a. Inspections b. Contamination Control c. Equipment Maintenance for the following: Circuit Breakers Power Transformers (including phase-shifting transformers) Regulators Reactive Devices (including, but not limited to, Shunt Capacitors, Series Capacitors, Synchronous Condensers, Shunt Reactors, and Tertiary Reactors) Page 5 of 5

22 WECC Standard PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation A. Introduction 1. Title: Protection System and Remedial Action Scheme Misoperation 2. Number: PRC-004-WECC-1 3. Purpose: Regional Reliability Standard to ensure all transmission and generation Protection System and Remedial Action Scheme (RAS) Misoperations on Transmission Paths and RAS defined in section 4 are analyzed and/or mitigated. 4. Applicability 4.1. Transmission Owners of selected WECC major transmission path facilities and RAS listed in tables titled Major WECC Transfer Paths in the Bulk Electric System provided at and Major WECC Remedial Action Schemes (RAS) provided at Generator Owners that own RAS listed in the Table titled Major WECC Remedial Action Schemes (RAS) provided at Transmission Operators that operate major transmission path facilities and RAS listed in Tables titled Major WECC Transfer Paths in the Bulk Electric System provided at and Major WECC Remedial Action Schemes (RAS) provided at 5. Effective Date: October 1, 2011 B. Requirements The requirements below only apply to the major transmission paths facilities and RAS listed in the tables titled Major WECC Transfer Paths in the Bulk Electric System and Major WECC Remedial Action Schemes (RAS). R.1. System Operators and System Protection personnel of the Transmission Owners and Generator Owners shall analyze all Protection System and RAS operations. [Violation Risk Factor: Lower] [Time Horizon: Operations Assessment] R1.1. R1.2. System Operators shall review all tripping of transmission elements and RAS operations to identify apparent Misoperations within 24 hours. System Protection personnel shall analyze all operations of Protection Systems and RAS within 20 business days for correctness to characterize whether a Misoperation has occurred that may not have been identified by System Operators. R.2. Transmission Owners and Generator Owners shall perform the following actions for each Misoperation of the Protection System or RAS. It is not intended that Requirements R2.1 through R2.4 apply to Protection System and/or RAS actions that appear to be entirely reasonable and correct at the time of occurrence and associated system performance is fully compliant with NERC Reliability Standards. If the Transmission Owner or Generator Owner later finds the Protection System or RAS operation to be incorrect through System Protection personnel analysis, the requirements of R2.1 through R2.4 become applicable at the time the Transmission Owner or Generator Owner identifies the Misoperation: R2.1. If the Protection System or RAS has a Security-Based Misoperation and two or more Functionally Equivalent Protection Systems (FEPS) or Functionally Equivalent RAS (FERAS) remain in service to ensure Bulk Electric System (BES) reliability, the Transmission Owners or Generator Owners shall remove from service the Protection System or RAS that misoperated within 22 hours following identification of the Misoperation. Repair or replacement of the failed Protection System or RAS is at the Transmission Owners and Generator Owners discretion. [Violation Risk Factor: High] Page 1 of 6

23 WECC Standard PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation [Time Horizon: Same-day Operations] R2.2. If the Protection System or RAS has a Security-Based Misoperation and only one FEPS or FERAS remains in service to ensure BES reliability, the Transmission Owner or Generator Owner shall perform the following. [Violation Risk Factor: High] [Time Horizon: Same-day Operations] R R Following identification of the Protection System or RAS Misoperation, Transmission Owners and Generator Owners shall remove from service within 22 hours for repair or modification the Protection System or RAS that misoperated. The Transmission Owner or Generator Owner shall repair or replace any Protection System or RAS that misoperated with a FEPS or FERAS within 20 business days of the date of removal. The Transmission Owner or Generator Owner shall remove the Element from service or disable the RAS if repair or replacement is not completed within 20 business days. R2.3. If the Protection System or RAS has a Security-Based or Dependability-Based Misoperation and a FEPS and FERAS is not in service to ensure BES reliability, Transmission Owners or Generator Owners shall repair and place back in service within 22 hours the Protection System or RAS that misoperated. If this cannot be done, then Transmission Owners and Generator Owners shall perform the following. [Violation Risk Factor: High] [Time Horizon: Same-day Operations] R R When a FEPS is not available, the Transmission Owners shall remove the associated Element from service. When FERAS is not available, then The Generator Owners shall adjust generation to a reliable operating level, or Transmission Operators shall adjust the SOL and operate the facilities within established limits. R2.4. If the Protection System or RAS has a Dependability-Based Misoperation but has one or more FEPS or FERAS that operated correctly, the associated Element or transmission path may remain in service without removing from service the Protection System or RAS that failed, provided one of the following is performed. R R Transmission Owners or Generator Owners shall repair or replace any Protection System or RAS that misoperated with FEPS and FERAS within 20 business days of the date of the Misoperation identification, or Transmission Owners or Generator Owners shall remove from service the associated Element or RAS. [Violation Risk Factor: Lower] [Time Horizon: Operations Assessment] R.3. Transmission Owners and Generation Owners shall submit Misoperation incident reports to WECC within 10 business days for the following. [Violation Risk Factor: Lower] [Time Horizon: Operations Assessment] R3.1. R3.2. Identification of a Misoperation of a Protection System and/or RAS, Completion of repairs or the replacement of Protection System and/or RAS that misoperated. Page 2 of 6

24 WECC Standard PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation C. Measures Each measure below applies directly to the requirement by number. M1. Transmission Owners and Generation Owners shall have evidence that they reported and analyzed all Protection System and RAS operations. M1.1 Transmission Owners and Generation Owners shall have evidence that System Operating personnel reviewed all operations of Protection System and RAS within 24 hours. M1.2 Transmission Owners and Generation Owners shall have evidence that System Protection personnel analyzed all operations of Protection System and RAS for correctness within 20 business days. M2. Transmission Owners and Generation Owners shall have evidence for the following. M2.1 Transmission Owners and Generation Owners shall have evidence that they removed the Protection System or RAS that misoperated from service within 22 hours following identification of the Protection System or RAS Misoperation. M2.2 Transmission Owners and Generation Owners shall have evidence that they removed from service and repaired the Protection System or RAS that misoperated per measurements M2.2.1 through M M2.2.1 Transmission Owners and Generation Owners shall have evidence that they removed the Protection System or RAS that misoperated from service within 22 hours following identification of the Protection System or RAS Misoperation. M2.2.2 Transmission Owners and Generation Owners shall have evidence that they repaired or replaced the Protection System or RAS that misoperated within 20 business days or either removed the Element from service or disabled the RAS. M2.3 The Transmission Owners and Generation Owners shall have evidence that they repaired the Protection System or RAS that misoperated within 22 hours following identification of the Protection System or RAS Misoperation. M2.3.1 The Transmission Owner shall have evidence that it removed the associated Element from service. M2.3.2 The Generator Owners and Transmission Operators shall have documentation describing all actions taken that adjusted generation or SOLs and operated facilities within established limits. M2.4 Transmission Owners and Generation Owners shall have evidence that they repaired or replaced the Protection System or RAS that misoperated including documentation that describes the actions taken. M2.4.1 Transmission Owners and Generation Owners shall have evidence that they repaired or replaced the Protection System or RAS that misoperated within 20 business days of the misoperation identification. M2.4.2 Transmission Owners and Generation Owners shall have evidence that they removed the associated Element or RAS from service. M3. Transmission Owners and Generation Owners shall have evidence that they reported the following within 10 business days. Page 3 of 6

25 WECC Standard PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation M3.1 Identification of all Protection System and RAS Misoperations and corrective actions taken or planned. D. Compliance M3.2 Completion of repair or replacement of Protection System and/or RAS that misoperated. 1. Compliance Monitoring Process 1.1 Compliance Monitoring Responsibility Compliance Enforcement Authority 1.2 Compliance Monitoring Period Compliance Enforcement Authority may use one or more of the following methods to assess compliance: - Misoperation Reports - Reports submitted quarterly - Spot check audits conducted anytime with 30 days notice given to prepare - Periodic audit as scheduled by the Compliance Enforcement Authority - Investigations - Other methods as provided for in the Compliance Monitoring Enforcement Program The Performance-reset Period is one calendar month. 1.3 Data Retention Reliability Coordinators, Transmission Owners, and Generation Owners shall keep evidence for Measures M1 and M2 for five calendar years plus year to date Additional Compliance Information None. 2. Violation Severity Levels R# Lower VSL Moderate VSL High VSL Severe VSL R1 System Operating personnel of the Transmission Owner or Generator Owner did not review the Protection System Operation or RAS operation within 24 hours but did review the Protection System Operation or RAS operation within six business days. System Operating personnel of the Transmission Owner or Generator Owner did not review the Protection System operation or RAS operation within six business days. System Protection personnel of the Transmission Owner and Generator Owner did not analyze the Protection System operation or RAS operation within 20 business days but did analyze the Protection System operation or RAS operation within 25 business days. System Protection personnel of the Transmission Owner or Generator Owner did not analyze the Protection System operation or RAS operation within 25 business days. R2 The Transmission Owner not remove from service, repair, or implement other compliance measures for the Protection System or The Transmission Owner not remove from service, repair, or implement other compliance measures for the Protection System or Page 4 of 6 The Transmission Owner not perform the removal from service, repair, or implement other compliance measures for The Transmission Owner not perform the removal from service, repair, or implement other compliance measures for

26 WECC Standard PRC-004-WECC-1 Protection System and Remedial Action Scheme Misoperation RAS that misoperated as RAS that misoperated as the Protection System or the Protection System or required by R2.1 and required by R2.1 and RAS that misoperated as RAS that misoperated as R2.2.1 within 22 hours but R2.2.1 in less than 24 required by R2.1 and required by R2.1 and did perform the hours but did perform the R2.2.1 in less than 28 R2.2.1 within 32 hours requirements within 24 requirements within 28 hours but did perform the hours hours requirements within 32 hours R3 The Generator Owner, Transmission Operator, or Transmission Owner, did not adjust generation to a reliable operating level (R ), adjust the SOL and operate the facilities within established limits (R ) or implement other compliance measures for the Protection System or RAS that misoperated as required by R2.3 and R2.3.1within 22 hours but did perform the requirements within 24 hours The Transmission Owner not perform the required repairs, replacement, or system operation adjustments as required by R2.2.2 and R2.4 within 20 business days but did perform the required activities within 25 business days. The Transmission Owner not report the Misoperation and corrective actions taken or planned as required by R3.1 within 10 business days but did perform the required activities within 15 business days. The Generator Owner, Transmission Operator, or Transmission Owner, did not adjust generation to a reliable operating level (R ), adjust the SOL and operate the facilities within established limits (R ) or implement other compliance measures for the Protection System or RAS that misoperated as required by R2.3 and 2.3.1in less than 24 hours but did perform the requirements within 28 hours The Transmission Owner not perform the required repairs, replacement, or system operation adjustment as required by R2.2.2 and R2.4 within 25 business days but did perform the required activities within 28 business days. The Transmission Owner not report the Misoperation and corrective actions taken or planned as required by R3.1 within 15 business days but did perform the required activities within 20 business days. The Generator Owner, Transmission Operator, or Transmission Owner, did not adjust generation to a reliable operating level (R ), adjust the SOL and operate the facilities within established limits (R ) or implement other compliance measures for the Protection System or RAS that misoperated as required by R2.3 and R2.31 in less than 28 hours but did perform the requirements within 32 hours The Transmission Owner not perform the required repairs, replacement, or system operation adjustment as required by R2.2.2 and R2.4 within 28 business days but did perform the required activities within 30 business days The Transmission Owner not report the Misoperation and corrective actions taken or planned as required by R3.1 within 20 business days but did perform the required activities within 25 business days. The Generator Owner, Transmission Operator, or Transmission Owner, did not adjust generation to a reliable operating level (R ), adjust the SOL and operate the facilities within established limits (R ) or implement other compliance measures for the Protection System or RAS that misoperated as required by R2.3 and R2.3.1 within 32 hours The Transmission Owner not perform the required repairs, replacement, or system operation adjustments as required by R2.2.2 and R2.4 within 30 business days The Transmission Owner not report the Misoperation and corrective actions taken or planned as required by R3.1 within 25 business days. The Transmission Owner not report the completion of repair or replacement of The Transmission Owner not report the completion of repair or replacement of Page 5 of 6 The Transmission Owner not report the completion of repair or replacement of The Transmission Owner not report the completion of repair or replacement of Protection System and/or RAS that misoperated to