Key Reliability
Standard Spot Check
Frank Vick
Compliance Team Lead
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
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Talk with Texas RE
March 28, 2013
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 PRC005-1.
 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.
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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.




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Protective relays.
Associated communication systems.
Voltage and current sensing devices.
Station batteries and battery chargers.
DC control circuitry.
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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).
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
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
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Talk with Texas RE
March 28, 2013
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.
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Talk with Texas RE
March 28, 2013
Contact Information
Frank.Vick@texasre.org
(512) 583-4949