• FERC Approves Revised Reliability Standard for Protection System Maintenance
  • January 10, 2014 | Authors: Peter S. Glaser; Kevin C. Greene; Daniel L. Larcamp; Clifford S. Sikora; Lara L. Skidmore
  • Law Firms: Troutman Sanders LLP - Washington Office ; Troutman Sanders LLP - Atlanta Office ; Troutman Sanders LLP - Washington Office ; Troutman Sanders LLP - Portland Office
  • On December 19, 2013, FERC issued a final rule approving a revised Reliability Standard for Protection System Maintenance. The revised standard PRC-005-2, which consolidates the four current Reliability Standards into a single standard, will incorporate new requirements for minimum maintenance activities and maximum time intervals between maintenance activities for individual components of the bulk electric system. The North American Electric Reliability Corporation (“NERC”) revised the standard in response to directives issued in FERC’s Order No. 693.

    Under the revised standard, entities have the option of developing their own performance-based maintenance programs; however, these programs must result in a minimum level of performance and be revised if those levels are not met. Under Requirement R1 of the standard, these programs can either be time-based or performance-based, and must identify certain monitored component attributes where monitoring is used as a basis for extending maintenance intervals. Under Requirement R2, any entity that uses performance-based maintenance intervals must also meet certain additional requirements, which are detailed in Attachment A of the Reliability Standard. Requirement R3 requires that activities for time-based maintenance be performed in accordance with corresponding tables in the standard, while Requirement R4 states that all activities for performance-based intervals must follow the requirements of Attachment A. Last, Requirement R5 requires that an entity demonstrate its efforts toward resolving any maintenance issues discovered during their maintenance activities.

    In addition to approving PRC-005-2 and its requirements, FERC approved most of the violation severity levels associated with each of the standard’s five requirements, but directed NERC to revise the violation severity level for Requirement R1. FERC also approved the six definitions - Component, Component Type, Countable Event, Protection System Maintenance Program, and Unresolved Maintenance Issue - NERC proposed, but noted that only the term Protection System Maintenance Program will be included in NERC’s Glossary of Terms, while the other five will only apply to PRC-005-2.

    Overall, FERC concluded that PRC-005-2 will enhance reliability by establishing condition-based and performance-based maintenance programs, and promote efficiency by consolidating all protection system maintenance requirements into a single standard. However, FERC directed NERC to submit an informational filing, within one year of the issuance of the rule, apprising FERC of its ongoing efforts to analyze failures of protection systems, and the status of NERC’s guidance report on the commissioning of power system protection systems.

    The rule will become effective February 24, 2014.