Transmission Relay Loadability FERC Order 733 Project 2010-13

1. Transmission Relay Loadability FERC Order 733Project 2010-13 NERC Relay Loadability Standard Reliability Standards Webinar November 23, 2010

2. 2 Project Overview Standards Involved PRC-023-2 Transmission Relay Loadability Applicable Entities Affected Functional Entities with Load-Responsive Phase Protection Systems: Transmission Owners Generator Owners Distribution Providers Planning Coordinators

3. 3 Project Overview Applicable Facilities Affected Transmission lines operated at 200 kV and above Transmission lines operated at 100 kV to 200 kV as determined by the Planning Coordinator Transmission lines operated below 100 kV identified as critical facilities by the Regional Entity and as determined by the Planning Coordinator

4. 4 Project Overview Applicable Facilities Affected (cont’d) Transformers with low voltage terminals connected at 200 kV and above Transformers with low voltage terminals connected at 100 kV to 200 kV as determined by the Planning Coordinator Transformers with low voltage terminals identified as critical facilities by the Regional Entity and as determined by the Planning Coordinator

5. 5 Project Overview Scope On March 18, 2010, FERC issued Order No. 733 which approved Reliability Standard PRC-023-1 – Transmission Relay Loadability, and also directed NERC to develop certain modifications to the PRC-023-1 standard through its Reliability Standards development process. PRC-023-2 is the first step toward satisfying Order 733.

6. 6 Project Schedule to Completion Second draft of PRC-023-2 standard posted on November 1, 2010 for a 45-day formal comment period with concurrent ballot during the last 10 days of the comment period Comments and Ballot Results Close on December 16, 2010 Respond to Comments and Post Third Draft for Comment in January 2011 Conduct Recirculation Ballot in February 2011 Ballot Completion Anticipated in February 2011 Expected NERC Board of Trustees Approval in February 2011 Submit to FERC for Approval in March 2011

7. PRC-023-2 – Summary Key Changes to Requirements R1 – Modified criterion 10 (transformer loadability) to address paragraph 203 of Order 733 New R2 to address out-of-step blocking issues from paragraph 244 New R4 to require that entities provide a list of facilities using 15-minute ratings to PC, TOP, and RC per paragraph 186. New R5 to require that entities using criterion 12 (set relays to protect lines and determine loadability from settings) provide a list of such facilities to Regional Entity per paragraph 224. Modified old R3 (now R6) to use Attachment B criteria New R7 to provide for systemic implementation of standard for facilities determined per R6 7

8. PRC-023-2 – Change to R1, Criterion 10 Relay Loadability for Transformers Previously required load responsive relays to generally meet R1 Order 733, paragraph 203 directed modification to verify the equipment is capable of sustaining the overload Two components to transformer withstand capability (IEEE C37.91 and IEEE C57.102) Thermal – defined for currents over 2 x rating, times up to 30 minutes Mechanical – based only on impedance – times from 2 seconds to eight seconds Requirement modified to require that the transformer fault protection address the mechanical withstand characteristic 8

9. PRC-023-2 - R1 Criterion 10 Change Transformer withstand per IEEE C37.91 and C57.102 Thermal withstand curve Provide for operator response If protection is desired, apply devices designed for that purpose, with appropriate timing response Mechanical Withstand curve Addressed within standard 9

10. PRC-023-2 – New R2 (Out-of-Step Blocking - OSB) Attachment A previously specified that OSB needed to be considered If OSB is asserted by load conditions when a fault occurs, it will prevent fault protection from operating Order 733, paragraph 244 directed that OSB be added as an additional requirement “shall verify that its out-of-step blocking elements allow tripping … for faults that occur during the loading conditions used … per R1.” 10

11. PRC-023-2 – New R4 List of Facilities Using 15-Minute Rating R1, criterion 2 provides a smaller margin if entities are using a 15-minute rating Clarified in footnote 2 to address 15-minute ratings used for system operations Commits entities to 15-minute response to impending ratings violations Order 733, paragraph 186 directed that entities by required to provide a list of such facilities to TOPs. R4 requires that the list be provided annually to the TOPs, and adds Planning Coordinator and Reliability Coordinator to list 11

12. PRC-023-2 – New R5 List of Facilities using R1 Criterion 12 R1 criterion 12 provides that entities shall set their relays to protect their facilities and develop an associated rating if they are unable to apply any other criteria Order 733, paragraph 244 directs that the list of facilities using criterion 12 be available to users, owners, and operators of the BPS R5 requires that the list be provided annually to the Regional Entity 12

13. PRC-023-2 – R6 Use Attachment B Criteria Previous R3 required that Planning Coordinators have a process to determine facilities “critical to the reliability of BES”, maintain a list of such facilities, and provide the list Order 733 directs that NERC develop the criteria R6 now requires that the Planning Coordinators apply the criteria annually to 100-200 kV facilities and to sub-100 kV facilities identified as critical facilities in the Regional Entity Compliance Registry If Attachment B Criterion B4 is used, include the year studied Provide the list of identified facilities to all RE, RC, TO, GO, and DP within its Planning Coordinator area within 30 days 13

14. PRC-023-2 – New R7 – Systemic Implementation for sub-200 kV Facilities PRC-023-1 provided for ongoing implementation for sub-200 kV facilities (per old R3) within Implementation Plan Not an effective approach – Implementation Plan is only for initial implementation of new Standard, not for ongoing compliance New R7 to require that TO, GO, and DP implement R1, R2, R3, R4, and R5 for facilities identified per R6 within 24 months 14

15. 15 Modifications to Attachment A Order No. 733 ¶264 directed modifications to Attachment A to include supervising relay elements The Order specifically discussed concerns with pilot wire and current differential protection systems supervised by fault detector relays A new Section 1.6 in Appendix A was added to address this concern The proposed revision makes PRC-023-2 applicable to the following protective functions: Supervisory elements associated with current-based, communication-assisted schemes where the scheme is capable of tripping for loss of communications

16. 16 Addition of a New Attachment B Order No. 733 ¶69 directed inclusion of a test that Planning Coordinators must use to determine whether a sub-200 kV facility is critical to reliability of the Bulk-Power System The “Applicability Test” contained in Attachment B will be used by Planning Coordinators to determine which sub-200 kV transmission Elements must comply with this standard The test will be applied to: All facilities 100 kV to 200 kV Facilities below 100 kV identified by the Regional Entity as critical facilities for the purposes of the Compliance Registry

17. 17 Circuit must comply with the standardif any of the following criteria apply: Monitored Elements of: A flowgate in the Eastern Interconnection, A major transfer path within the Western Interconnection as defined by the Regional Entity, or A comparable monitored Element in the Texas Interconnection or Québec Interconnection, that have been included to address long-term reliability concerns, as confirmed by the applicable Planning Coordinator. Monitored Elements of an IROL where the IROL was determined in the long-term planning horizon Circuits that form a path (as agreed to by the plant owner and the Transmission Entity) to supply off-site power to nuclear plants

18. 18 Circuit must comply with the standardif any of the following criteria apply: (cont.) Circuits identified through defined power flow analysis: Simulation of double contingency combinations selected by engineering judgment in TPL-003 Category C3, but without manual system adjustments between contingencies Evaluation of the post-contingency loading of 100 kV to 200 kV circuits to identify circuits loaded greater than a specified percentage above the Facility Rating nearest a four-hour duration 115% of the Facility Rating, if based on a loading duration of up to and including four hours 120 % of the Facility Rating, if based on a loading duration greater than four and up to and including eight hours 130% of the Facility Rating, if based on a loading duration of greater than eight hours Radial circuits serving only load are excluded. Circuits that the Planning Coordinator may include based on other technical studies or assessments

19. 19 Implementation Plan The Implementation Plan for the revised standard provides varying amounts of time based on the nature of each Requirement Footnote 1 pertaining to Temporary Exceptions approved prior to approval of PRC-023-1 has been removed as directed in ¶284 This has no impact on applicable entities because the Temporary Exceptions have expired The latest due date for mitigation of temporary exceptions under the Beyond Zone 3 review was December 31, 2008

20. 20 Implementation Plan (cont.) Facility owners1 must comply with existing criteria in R1 upon approval,2 and Must comply with the addition to criterion 10 pertaining to transformer fault protection within 12 months,2 and Protective functions described in the new section 1.6 of Attachment A must comply with R1 within 24 months2 Facility owners1 must comply with R2 and R3 upon approval2 R2 already is enforceable as section 2 of Attachment A in PRC-023-1 R3 already is enforceable as R2 in PRC-023-1 1 Transmission Owners, Generator Owners, and Distribution Providers as described in the Applicability section of PRC-023 2 Measured from the first day of the first calendar quarter after applicable regulatory approvals or in those jurisdictions where regulatory approval is not required, the first day of the first calendar quarter after Board of Trustees adoption

21. 21 Implementation Plan (cont.) Facility owners1 must comply with R4 and R5 within 6 months2 Planning Coordinators comply with R6 (apply the criteria in Attachment B) within 18 months2 Requirement R7 is effective upon approval;2 however, R7 provides facility owners1 at least 24 months to meet R1 – R5 following notification by the Planning Coordinator that a sub-200 kV Facility must comply with this standard 1 Transmission Owners, Generator Owners, and Distribution Providers as described in the Applicability section of PRC-023 2 Measured from the first day of the first calendar quarter after applicable regulatory approvals or in those jurisdictions where regulatory approval is not required, the first day of the first calendar quarter after Board of Trustees adoption

22. 22 Summary Overview of Key Changes to PRC-023-2 to Satisfy Directives in FERC Order 733 PRC-023-2 Posted for Formal Comment with Concurrent Ballot Close on December 16, 2010 Webinar Provided as Outreach to Industry Target Submittal to NERC BOT in February 2011 Submit to FERC for Approval in March 2011 Implementation Plan provides varying amounts of time based on the nature of each Requirement

23. Information Link Transmission Relay Loadability, Project 2010-13 Information Link to NERC Website http://www.nerc.com/filez/standards/Project_2010-13_Summary_Table. Charles Rogers, SDT Chair, Affiliation cwrogers@cmsenergy.com Phil Tatro, SME & Advisor, NERC Staff phil.tatro@nerc.net Joe Bucciero, NERC Project Coordinator joe.bucciero@gmail.com 23

24.  ? Questions and Answers 24

25. Closing and Adjourn Register for the Ballot Pool Provide Constructive Comments Offer alternative language where possible Thank you. 25