UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) ) ) ) ) COMMENTS OF THE EDISON ELECTRIC INSTITUTE

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1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Coordination of Protection Systems for Performance During Faults and Specific Training for Personnel Reliability Standard ) ) ) ) ) Docket No. RM COMMENTS OF THE EDISON ELECTRIC INSTITUTE I. INTRODUCTION The Edison Electric Institute ( EEI ), on behalf of our member companies, hereby respectfully submits comments in response to the Notice of Proposed Rulemaking ( NOPR ) issued by the Federal Energy Regulatory Commission ( the Commission or FERC ) on November 16, 2017, in the above-referenced docket. 1 EEI is the association that represents all U.S. investor-owned electric companies. Our members provide electricity for about 220 million Americans, and operate in all 50 states and the District of Columbia. As a whole, the electric power industry supports more than 7 million jobs in communities across the United States. In addition to our U.S. members, EEI has more than 60 international electric companies, with operations in more than 90 countries, as International Members, and hundreds of industry suppliers and related organizations as Associate Members. Organized in 1933, EEI provides public policy leadership, strategic business intelligence, and 1 Coordination of Protection Systems for Performance During Faults and Specific Training for Personnel Reliability Standard, 161 FERC 61,159 (2017) ( NOPR ).

2 essential conferences and forums. EEI s U.S. members include Generator Owners and Operators, Transmission Owners and Operators, Load-Serving Entities, and other entities that are subject to the mandatory Reliability Standards developed by the North American Electric Reliability Corporation ( NERC ) and enforced by NERC and the Commission. Accordingly, EEI members are directly affected by the NOPR. EEI supports the Commission s proposal to approve PRC (Coordination of Protection Systems for Performance during Faults) and PER (Specific Training for Personnel) as well as their proposal to retire PRC-001-1(ii) System Protection Coordination). EEI also supports the Commission s proposal to approve the VRSs, VSLs and implementation plans and effective dates proposed by NERC. We also support the Commission s proposal to approve the new and revised definitions contained in the associated NERC filing (i.e., Protection System Coordination Study, Operational Planning Analysis, and Real-time Assessment). However, EEI does not support the Commission s proposal to direct NERC to modify proposed Reliability Standard PRC to require an initial protection system coordination study to ensure that applicable entities perform, as a baseline, a study demonstrating proper coordination of protection systems. II. COMMENTS The proposed Reliability Standards PRC and PER are just, reasonable and not unduly discriminatory or preferential, and in the public interest and improve upon the currently-effective Reliability Standard PRC (ii). 2 EEI supports the Commission s proposal to approve these standards and the associated definitions, VRSs, VSLs and 2 NOPR at P 6. 2

3 implementation plans submitted by NERC. However, EEI does not share the Commission s concern or support the proposal to direct NERC to modify Reliability Standard PRC-027-1, Requirement R2, Option 2 ( Proposed Modification ). EEI does not support the Proposed Modification because it will require responsible entities to conduct Protection System coordination studies well beyond the level of risk necessary to ensure an adequate level of reliability and negate the benefits provided by Requirement R2, Option 2, which creates unreasonable burdens on large entities. Furthermore, the Commission has not sufficiently justified the necessity of the Proposed Modification based on industry data. If the Commission can provide such a justification, then NERC and the Standards Drafting Team (SDT) should be given the ability to consider alternative approaches that might be less burdensome but equally effective. A. The Proposed Modification creates an unnecessary and unreasonable burden on larger entities. Requirement R2 provides entities with an alternative approach for determining the Protection System settings that need to be reevaluated for adjustment by assessing Fault current values against an established Fault current baseline. Should the Fault current values exceed 15%, then the Protection Systems associated with the affected BES Element are evaluated through a Protection System coordination study. While Option 2 does not require entities to perform initial Protection System coordination studies on all BES Elements, it is an equally effective approach since entities already conduct such studies when initially developing Protection System settings for their BES Elements. Moreover, allowing responsible entities to evaluate changes in Fault current values against an established baseline provides needed efficiencies that will allow responsible entities to better focus limited resources where they can 3

4 be most effectively applied. A Protection System coordination study (Requirement R1) is the process that is followed to determine whether Protection System settings are set in a manner that ensures Protection Systems operate in the intended sequence during Faults. These studies are routinely conducted whenever new BES Elements are installed, for system reconfigurations, and for modernization projects, such as replacing electromechanical relays with microprocessor based relays. Equally important is that such changes are assessed through evaluating changes in Fault current. Also, Requirement R1 already requires that changes to the BES resulting in new relaying or settings will result in reexamination of coordination of associated protection systems. The 15% threshold adequately accounts for the need to recoordinate Protection Systems due to slowly changing levels of available short circuit currents resulting from aggregated system changes. The 15% threshold is technically justified by the fact that a minimum margin of 20% is typically used in the industry for impedance type elements, with even greater margins typically used for overcurrent type elements. Allowing a maximum of 15% deviation from the previous baseline fault duty will provide ample notice to an entity that new coordination studies are necessary, especially as proposed in PRC-027. Should the Commission proceed with the Proposed Modification requiring all entities to conduct new Protection System coordination studies outside of the efficiencies provided under Option 2 of Requirement R2 then responsible entities will be faced with conducting large numbers of compliance related studies that are unlikely to improve BES reliability while creating unnecessary and unreasonable burdens that would especially impact larger entities. Protection System coordination may need to be reevaluated over time to ensure proper 4

5 operation of Protection Systems is maintained over time. While conducting periodic Protection System coordination studies is one method of assessing existing coordination, it is inefficient for entities which have large numbers of Protection Systems. Another method, such as provided under Option 2, yields equally effective results through simply tracking changes in Fault current, which allows entities to avoid needless studies that are unlikely to yield any actionable results. Under Option 2, if this change is greater than 15%, then a Protection System Coordination Study (Requirement R1) is needed to determine if the current settings need to be adjusted and coordinated. If the Fault current is not changing, the settings do not need to be adjusted, i.e., a Protection System coordination study is unnecessary. In addition to being unnecessary, requiring an initial Protection System coordination study for each BES Element (i.e., the Proposed Modification) will require a significant amount of work by responsible entities to reevaluate Protection Systems associated with BES Elements. This level of rework under the implementation timeframe will create an unreasonable burden, especially in light of the limited protection engineering resources (including contractors) available. Such a burden may also increase the likelihood of human error as these resources are stretched to complete these studies for each BES Element. PRC as proposed by NERC enables responsible entities to focus only on the BES Elements that have experienced Fault current changes of 15% or greater deviation, i.e., ensuring that the Elements that are most likely to need adjustment and recoordination are addressed. During the standards development process, NERC evaluated the prevalence of misoperations associated with relay settings and found that between 2012 and 2015 only 11% of misoperation events (17 events out of 151) and only 2.9% of total events (17 out of 574) 5

6 involved System Protection Coordination issues. 3 Importantly, these errors were not a result of a lack of BES Element coordination, but a result of human error, which will continue to be a factor as long as humans preform this complex work. Directing responsible entities to conduct more Protection System coordination studies can result in introducing new miscoordination due to human errors. While Requirement R2, Option 2 allows entities to reduce the frequency of Protection System coordination studies of BES Elements, this option provides large entities with extremely large numbers of BES Elements an opportunity to better manage their studies in ways that provide risk-based efficiency in maintaining Protection System performance. Option 2 ensures that BES Elements that most likely need Protection System settings adjustments will be further studied to ensure optimal performance. In contrast, the Proposed Modification does not prioritize at risk BES Elements. Accordingly, Option 2 provides two important benefits to companies with very large systems: 1) BES Elements that represent the greatest risk are studied first and 2) scarce protection engineer resources are leveraged to the greatest possible benefit to BES reliability. If the Commission remains unconvinced that Option 2 provides sufficient safeguards against Protection System coordination errors, we recommend directing NERC to assess the effectiveness of Option 2 after the implementation of the proposed Reliability Standard and if necessary make technical recommendations to improve the efficiency and effectiveness as appropriate. 3 Petition of the North American Electric Reliability Corporation for Approval of Proposed Reliability Standards PRC and PER and Retirement of PRC , 41 (Sept 2, 2016) ( Petition ). 6

7 B. The Commission has not sufficiently justified the need for the Proposed Modification. In the NOPR, the Commission identified reports to justify the need for the Proposed Modification based on past misoperation and outage events related to miscoordination. EEI disagrees with the Commissions conclusions, which are addressed in chronological order below. First, regarding the 2006 NERC System Protection Control Task Force assessment of Reliability Standard PRC-001 and the 2009 NERC letter, it is unclear why the Commission finds these compelling after years. Second, although the 2011 report on the Arizona-Southern California Outage report identified that Protection System coordination studies were not performed or otherwise reevaluated after system changes, the Commission attributed the outage to a lack of Remedial Action Scheme coordination, which is addressed by the new Reliability Standard PRC (Remedial Action Schemes). As a result, it is unclear how the Proposed Modification would improve entity obligations to coordinate these systems or otherwise prevent similar outages in the future. Third, the 2013 Misoperations Report prepared by the Protection System Misoperations Task Force identified a number of methods that would be useful to reducing misoperations (i.e., peer reviews, increased training, more extensive fault studies, standard templates for setting standard schemes using complex relays, and periodic review of existing settings when there is a change in system topography ), 4 which do not suggest that entities are not conducting coordination studies or that a lack of coordination is a contributing factor in misoperations. A 4 NERC, Misoperations Report Prepared by Protection Systems Misoperations Task Force, 35 (April 1, 2013). 7

8 more accurate description of the issue would be misoperations due to human error. Fourth, in the 2014 NERC Lessons Learned Report, errors in coordination were identified; however, the primary factor in this misoperation was due to the unnecessary (i.e., incorrect) installation of frequency relays on auxiliary equipment within a generating facility. The responsible entity addressed this concern by removing the frequency relay installation as a corrective action. Fifth, the Analysis of System Protection Misoperations section in the 2015 NERC State of Reliability Report does not indicate a lack of Protection System coordination was a contributing factor in Misoperations. Instead, the earlier findings from the 2013 Misoperation Report again identified human error and a need for training as the largest contributing factors. And relative to the 2016 NERC State of Reliability Report, which stated that 40% of incorrect setting/logic/design misoperations in the Texas Reliability Entity ( TRE ) were due to the miscoordination of ground overcurrent settings. While this is an accurate statement, it can also yield an impression that is far different from what occurred in the TRE region from the 4 th quarter of 2012 to the 3 rd quarter of 2015, where TRE logged a misoperation rate of 7.9%. Of those misoperations, 41% were in the category of incorrect settings/logic errors/design errors, which would mean that 3.2% of the misoperations fell in this category. And when analyzing these operations further, it was determined that 41% of those misoperations were a result of miscoordination of ground overcurrent settings, which yield a final value of 1.3%. While this number is small, ERCOT was concerned enough that they evaluated these errors and issued recommendations that were contained in a report to assist entities to better coordinate these 8

9 relays. 5 It should be noted that there was no indication that the relays were not coordinated, simply errors were being made. C. The Commission should allow NERC to explore alternatives to address a specific concern rather than prescribe a specific modification to PRC EEI supports NERC s assessment that Option 2 provides entities the flexibility to determine whether there were any changes in Fault current at the BES Element that could affect Protection System coordination. 6 We believe that such an approach will, if allowed by the Commission to prove its worth, prove to be an economically sound solution while requiring entities to conduct new coordination studies on BES Elements that have seen a 15% or greater deviation in fault current, which aligns with generally accepted engineering practices. These margins are based on measurement errors, possible errors in fault studies, or unknown system configuration changes that can occur during system disturbances or short term operating conditions. 7 Configuration changes may include the impacts of BES aggregation for dispersed power producing resources, which over time will have greater impacts on Protection System coordination. Accordingly, the Commission should not impose prescriptive changes that would limit the ability of NERC to develop changes to Requirement 2, Option 2 that might better address the Commission s concerns while providing solutions with a lessor impact on entity resources. NERC should be afforded the flexibility to consider options other than the proposed directive contained in the NOPR. The Proposed Modification would constrain NERC from developing a solution that satisfies the Commission s concerns, balances reliability risks, and minimizes 5 ERCOT, A Review of Ground Fault Protection Methods for Transmission Lines (March 2, 2017). 6 Petition, Option 2 Comparison of Fault Current Values at 36 7 Id. at 37. 9

10 resources as well as regulatory burdens. III. CONCLUSION EEI appreciates the opportunity to submit comments in response to the NOPR. EEI supports the proposal to approve the proposed standards, but we do not support the Proposed Modification. To address Commission concerns, we recommend directing NERC to assess the effectiveness of Option 2 after the implementation of the proposed Reliability Standard and, if necessary, make technical recommendations to improve the effectiveness of the Requirement. If the Commission determines modifications are necessary now, then the Commission should clarify the need for the modification and limit the scope of their directive to allow NERC sufficient latitude to find a solution that addresses the Commission s concerns while limiting unnecessary burdens that are unlikely to effectively and efficiently address the risk to BES reliability. Respectfully submitted, EDISON ELECTRIC INSTITUTE /s/ Scott I. Aaronson Vice President, Security & Preparedness Mark Gray Senior Manager, Transmission Operations mgray@eei.org Melanie Seader Associate General Counsel, Reliability and Security mseader@eei.org Edison Electric Institute Washington, D.C (202) Dated: January 29,