UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION ) )

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1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION North American Electric Reliability Corporation ) ) Docket No. JOINT PETITION FOR APPROVAL OF PROPOSED REGIONAL RELIABILITY STANDARDS VAR-002-WECC-2 AND VAR-501-WECC-2 Gerald W. Cauley President and Chief Executive Officer North American Electric Reliability Corporation 3353 Peachtree Road, N.E. Suite 600, North Tower Atlanta, GA (404) (404) facsimile Charles A. Berardesco Senior Vice President and General Counsel Holly A. Hawkins Associate General Counsel Sean Bodkin Associate Counsel North American Electric Reliability Corporation 1325 G Street, N.W., Suite 600 Washington, D.C (202) (202) facsimile charles.berardesco@nerc.net holly.hawkins@nerc.net sean.bodkin@nerc.net Sandy Mooy Associate General Counsel Chris Albrecht Legal Counsel Western Electricity Coordinating Council 155 North 400 West, Suite 200 Salt Lake City, UT (801) calbrecht@wecc.biz smooy@wecc.biz Counsel for the Western Electricity Coordinating Council Counsel for the North American Electric Reliability Corporation December 15, 2014

2 TABLE OF CONTENTS I. Executive Summary... 2 II. Notices and Communications... 2 III. Background... 3 A. Regulatory Framework... 3 B. History of VAR-002-WECC-2 and VAR-501-WECC C. Project Paragraph IV. Justification for Approval... 7 A. Basis and Purpose of Proposed VAR-002-WECC-2 and VAR-501-WECC B. Enforceability of Proposed VAR-002-WECC-2 and VAR-501-WECC V. CONCLUSION... 9 Exhibit A Exhibit B Exhibit C Exhibit D Exhibit E VAR-002-WECC-2 Automatic Voltage Regulators VAR-501-WECC-2 Power System Stabilizers Implementation Plan Order No. 672 Criteria Complete Development Record of Proposed VAR-002-WECC-2 and VAR-501- WECC-2 Standard Drafting Team Roster ii

3 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION North American Electric Reliability Corporation ) ) Docket No. JOINT PETITION FOR APPROVAL OF PROPOSED REGIONAL RELIABILITY STANDARDS VAR-002-WECC-2 AND VAR-501-WECC-2 The North American Electric Reliability Corporation ( NERC ) 1 hereby requests Federal Energy Regulatory Commission ( Commission ) approval, in accordance with Section 215(d)(1) of the Federal Power Act ( FPA ) 2 and Section 39.5 of the Commission s regulations, 3 of proposed regional Reliability Standards VAR-002-WECC-2 (Automatic Voltage Regulators) and VAR-501-WECC-2 (Power System Stabilizer) developed by NERC and the Western Electricity Coordinating Council ( WECC ). 4 NERC requests that the Commission approve proposed regional Reliability Standards VAR-002-WECC-2 and VAR-501-WECC-2 (Exhibit A) and find that the proposed regional Reliability Standards are just, reasonable, not unduly discriminatory or preferential, and in the public interest. 5 NERC also requests approval of the associated Implementation Plan (Exhibit B). Proposed regional Reliability Standards VAR-002-WECC-2 and VAR-501-WECC-2 were adopted by the NERC Board of Trustees on November 13, NERC has been certified by the Commission as the electric reliability organization ( ERO ) in accordance with Section 215 of the FPA. See N. Am. Elec. Reliability Corp., 116 FERC 61,062 (2006) U.S.C. 824o (2012) C.F.R (2014). 4 As the Regional Entity who developed proposed regional Reliability Standards VAR-002-WECC-2 and VAR-501-WECC-2, WECC joins and supports NERC s petition, thereby making WECC a party in this proceeding. 5 Unless otherwise designated, capitalized terms shall have the meaning set forth in the Glossary of Terms Used in NERC Reliability Standards ( NERC Glossary of Terms ), available at 1

4 As required by Section 39.5(a) 6 of the Commission s regulations, this petition presents the technical basis and purpose of the proposed Reliability Standards, a summary of the development proceedings conducted by NERC and WECC for proposed VAR-002-WECC-2 and VAR-501-WECC-2 (Exhibit D), and a demonstration that the proposed regional Reliability Standards meet the criteria identified by the Commission in Order No (Exhibit C). I. Executive Summary Consistent with the Commission s order 8 approving NERC s Compliance Enforcement Initiative ( CEI ), including the Find, Fix, Track and Report ( FFT ) program, NERC is requesting retirement of two requirements within two regional Reliability Standards, VAR-002- WECC-1 Requirement R2 and VAR-501-WECC-1 Requirement R2, that are unnecessary, and where violation of the requirements pose a lesser risk to the reliability of the Bulk-Power System. The proposed regional Reliability Standards continue to achieve the same reliability purpose of the prior versions. The purpose of proposed VAR-002-WECC-2 is to ensure that automatic voltage regulators on synchronous generators and condensers are kept in service and controlling voltage. The purpose of proposed VAR-501-WECC-2 is to ensure that power system stabilizers on synchronous generators are kept in service. II. Notices and Communications 6 18 C.F.R. 39.5(a) (2012). 7 The Commission specified in Order No. 672 certain general factors it would consider when assessing whether a particular Reliability Standard is just and reasonable. See Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. 31,204, at P 262, , order on reh g, Order No. 672-A, FERC Stats. & Regs. 31,212 (2006). 8 North American Electric Reliability Corporation, 138 FERC 61,193 at P 81 (2012) ( FFT Order ). 2

5 following: 9 Notices and communications with respect to this filing may be addressed to the Gerald W. Cauley President and Chief Executive Officer North American Electric Reliability Corporation 3353 Peachtree Road, N.E. Suite 600, North Tower Atlanta, GA (404) (404) facsimile Sandy Mooy* Associate General Counsel Chris Albrecht* Legal Counsel Western Electricity Coordinating Council 155 North 400 West, Suite 200 Salt Lake City, UT (801) calbrecht@wecc.biz smooy@wecc.biz Charles A. Berardesco* Senior Vice President and General Counsel Holly A. Hawkins* Associate General Counsel Sean Bodkin* Associate Counsel North American Electric Reliability Corporation 1325 G Street, N.W., Suite 600 Washington, D.C (202) (202) facsimile charles.berardesco@nerc.net holly.hawkins@nerc.net sean.bodkin@nerc.net III. Background A. Regulatory Framework By enacting the Energy Policy Act of 2005, which amended the Federal Power Act ( FPA ), 10 Congress entrusted the Commission with the duties of approving and enforcing rules to ensure the reliability of the Nation s Bulk-Power System, and with the duties of certifying an ERO that would be charged with developing and enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1) 11 of the FPA states that all users, owners, and operators of the Bulk-Power System in the United States will be subject to Commission- 9 Persons to be included on the Commission s service list are identified by an asterisk. NERC respectfully requests a waiver of Rule 203 of the Commission s regulations, 18 C.F.R (2014), to allow the inclusion of more than two persons on the service list in this proceeding U.S.C. 824o (2012). 11 Id. 824(b)(1). 3

6 approved Reliability Standards. Section 215(d)(5) 12 of the FPA authorizes the Commission to order the ERO to submit a new or modified Reliability Standard. Section 39.5(a) 13 of the Commission s regulations requires the ERO to file with the Commission for its approval each Reliability Standard that the ERO proposes should become mandatory and enforceable in the United States, and each modification to a Reliability Standard that the ERO proposes should be made effective. The Commission has the regulatory responsibility to approve standards that protect the reliability of the Bulk-Power System and to ensure that such standards are just, reasonable, not unduly discriminatory or preferential, and in the public interest. A Reliability Standard proposed by a Regional Entity must meet the same standard that NERC s Reliability Standards must meet, i.e., the regional Reliability Standard must be shown to be just, reasonable, not unduly discriminatory or preferential, and in the public interest. 14 If the regional Reliability Standard is proposed by a Regional Entity organized on an Interconnection-wide basis, to be applicable on an Interconnection-wide basis, then NERC must rebuttably presume that the standard is just, reasonable, not unduly discriminatory or preferential, and in the public interest. 15 Pursuant to Section 215(d)(2) of the FPA 16 and Section 39.5(c)(1)-(2) 17 of the Commission s regulations, the Commission will give due weight to the technical expertise of the ERO with respect to the content of a Reliability Standard and to the technical expertise of a Regional Entity organized on an Interconnection-wide basis with respect to a Reliability 12 Id. 824o(d)(5) C.F.R. 39.5(a) (2014) U.S.C. 824o(d)(2); 18 C.F.R. 39.5(a) U.S.C. 824o(d)(3); 18 C.F.R. 39.5(b) U.S.C. 824o(d)(2) C.F.R. 39.5(c)(1)(2). 4

7 Standard to be applicable within that Interconnection. In Order No. 672, the Commission noted that: As a general matter, we will accept the following two types of regional differences, provided they are otherwise just, reasonable, not unduly discriminatory or preferential and in the public interest, as required under the statute: (1) a regional difference that is more stringent than the continent-wide Reliability Standard, including a regional difference that addresses matters that the continent-wide Reliability Standard does not; and (2) a regional Reliability Standard that is necessitated by a physical difference in the Bulk- Power System. 18 A regional difference generally takes one of two forms: (1) a regional variance may be included in a continent-wide Reliability Standard, which achieves the reliability objective of the continent-wide standard s requirement(s) in an alternate way than specified in a given Requirement in the continent-wide standard or (2) a separate regional Reliability Standard may be developed, which adds one or more Requirements without altering any continent-wide Requirements that are applicable to entities in the region. 19 As discussed in the Western Electricity Coordinating Council Reliability Standards Development Procedures, the regional Reliability Standards for WECC are developed in a transparent, inclusive, open, and balanced process with reasonable notice and opportunity for public comment Order No. 672 at P See NERC, Whitepaper to Provide Guidance on Regional Standards and Variances, May 17, 2012, available at f. 20 The Western Electricity Coordinating Council Reliability Standards Development Procedures are available at Development%20Procedures.pdf&action=default&DefaultItemOpen=1 5

8 B. History of VAR-002-WECC-2 and VAR-501-WECC-2 On March 16, 2007, the Commission issued Order No. 693, approving Reliability Standard VAR Reliability Standard VAR requires Generator Operators to operate in automatic voltage control mode, to maintain generator voltage or reactive power output as directed by the Transmission Operator, and to notify the Transmission Operator of a change in status or capability of any generator reactive power resource. On June 8, 2007, the Commission approved eight WECC regional Reliability Standards that apply in the Western Interconnection, including WECC-VAR-STD-002a-1 (Automatic Voltage Regulators) and WECC-VAR-STD-002b-1 (Power System Stabilizer). 22 The Commission subsequently approved revisions to both WECC-VAR-STD-002a-1 and WECC- VAR-STD-002b-1, which were re-designated VAR-002-WECC-1 and VAR-501-WECC-1 respectively, in Order No C. Project Paragraph 81 On March 15, 2012, the Commission issued an order 24 approving NERC s CEI, including the FFT program. Paragraph 81 ( P 81 ) of the FFT Order reads: The Commission notes that NERC s FFT initiative is predicated on the view that many violations of requirements currently included in Reliability Standards pose lesser risk to the Bulk-Power System. If so, some current requirements likely provide little protection for Bulk-Power System reliability or may be redundant. The Commission is interested in obtaining views on whether such requirements could be removed from the Reliability Standards with little effect on reliability and an increase in efficiency of the ERO compliance program. If NERC believes that specific Reliability Standards or specific requirements within certain Standards should be revised or removed, we invite NERC to make specific proposals 21 Id. P N. Am. Elec.Reliability Corp., 119 FERC 61,260 (2007). 23 Version One Regional Reliability Standards for Facilities Design, Connections, and Maintenance; Protection and Control; and Voltage and Reactive, 135 FERC 61,061 (2011). 24 FFT Order at P 81 (emphasis added). 6

9 to the Commission identifying the Standards or requirements and setting forth in detail the technical basis for its belief. In addition, or in the alternative, we invite NERC, the Regional Entities and other interested entities to propose appropriate mechanisms to identify and remove from the Commission approved Reliability Standards unnecessary or redundant requirements. We will not impose a deadline on when these comments should be submitted, but ask that to the extent such comments are submitted NERC, the Regional Entities, and interested entities coordinate to submit their respective comments concurrently. In response, NERC initiated a review, referred to as the P 81 project, to identify requirements that could be removed from Reliability Standards without impacting the reliability of the Bulk-Power System. This project identified Requirement R2 in both regional Reliability Standards VAR-002-WECC-1 and VAR-005-WECC-1 as candidates for retirement. However, because these Reliability Standards are maintained by WECC, the retirements were deferred in that project for later consideration by WECC through its standard development process. 25 IV. Justification for Approval This section explains the proposed Requirement R2 retirement in each proposed regional Reliability Standard and how each continues to meet its respective reliability purpose. NERC and WECC request Commission approval of proposed regional Reliability Standards VAR-002- WECC-2 and VAR-501-WECC-2 (Exhibit A) and the Implementation Plan (Exhibit B). As discussed in Exhibit C, proposed regional Reliability Standards VAR-002-WECC-2 and VAR- 501-WCC-2 satisfy the Commission s criteria in Order No. 672 and are just, reasonable, not unduly discriminatory or preferential, and in the public interest. The complete development record for the proposed Regional Reliability Standard is provided in Exhibit D. 25 See Complete Set of Standards with Proposed Retirements for Phase 1 available on the P 81 project page at 7

10 A. Basis and Purpose of Proposed VAR-002-WECC-2 and VAR-501-WECC-2 Proposed VAR-002-WECC-2 and proposed VAR-501-WECC-2 revise currentlyeffective version 1 standards to remove an administrative Requirement R2 in each, which require documentation of R1. The documentation language has been added to the Measure in Requirement R1 in each. VAR-002-WECC-1, Requirement R2 states: R2. Generator Operators and Transmission Operators shall have documentation identifying the number of hours excluded for each requirement in R1.1 through R1.10. [Violation Risk Factor: Low] [Time Horizon: Operations Assessment] VAR-501-WECC-2, Requirement R2 states: R2. Generator Operators shall have documentation identifying the number of hours excluded for each requirement in R1.1 through R1.12. [Violation Risk Factor: Low] [Time Horizon: Operations Assessment] The proposed modifications in both VAR-002-WECC-1 and VAR-501-WECC-2 include: deletion of Requirement R2, which requires documentation of Requirement R1; the addition of Measure M1.4.3 requiring the date of the outage be provided with the currently required quarterly reports; and non-substantive formatting changes have been made throughout the document to conform to NERC drafting conventions. The substantive Requirements in both regional Reliability Standards have not changed and remain more stringent than the continent-wide Reliability Standard VAR Proposed VAR-002-WECC-2 continues to set only very limited circumstances for when a generator s automatic voltage regulator should be operated in a mode other than voltage control mode and continues to further limit the cumulative timeframe for doing so. Proposed VAR-501-WECC-2 continues to require that Generator Operators have a power system stabilizer in service. 8

11 B. Enforceability of Proposed VAR-002-WECC-2 and VAR-501-WECC-2 Proposed VAR-002-WECC-2 and VAR-501-WECC-2 contain Measures that support each Requirement by clearly identifying what is required and how the Requirement will be enforced. The Measures have not substantively changed from the prior Commission approved versions of the Standards except for the addition of reporting the date of an outage related to an exclusion for each Standard. The Measures continue to provide clarity regarding how the Requirements will be enforced, and ensure that the Requirements will be enforced in a clear, consistent, and non-preferential manner and without prejudice to any party. 26 The proposed regional Reliability Standards continue to contain both a VRF and VSL for the remaining Requirement R1. V. CONCLUSION For the reasons stated above, NERC and WECC respectfully request that the Commission approve the proposed VAR-002-WECC-2 and VAR-501-WECC-2 regional Reliability Standards and the Implementation Plan. Respectfully submitted, /s/ Sean Bodkin Charles A. Berardesco Senior Vice President and General Counsel Holly A. Hawkins Associate General Counsel Sean Bodkin North American Electric Reliability Corporation 26 Order No. 672 at P 327 ( There should be a clear criterion or measure of whether an entity is in compliance with a proposed Reliability Standard. It should contain or be accompanied by an objective measure of compliance so that it can be enforced and so that enforcement can be applied in a consistent and non-preferential manner. ). 9

12 1325 G Street, N.W., Suite 600 Washington, D.C (202) (202) facsimile charlie.berardesco@nerc.net holly.hawkins@nerc.net sean.bodkin@nerc.net Counsel for the North American Electric Reliability Corporation December 15,

13 Exhibit A VAR-002-WECC-2 Automatic Voltage Regulators And VAR-501-WECC-2 Power System Stabilizer

14 VAR-002-WECC-2 Automatic Voltage Regulators (Clean)

15 WECC Standard VAR-002-WECC-2 Automatic Voltage Regulators A. Introduction 1. Title: Automatic Voltage Regulators (AVR) 2. Number: VAR-002-WECC-2 3. Purpose: To ensure that Automatic Voltage Regulators on synchronous generators and condensers shall be kept in service and controlling voltage. 4. Applicability: 4.1. Functional Entities: Generator Operators Transmission Operators that operate synchronous condensers This VAR-002-WECC-2 Standard applies to synchronous generators and synchronous condensers that are connected to the Bulk Electric System 5. Effective Date: On the first day of the first quarter, after applicable regulatory approval. B. Requirements and Measures R1. Generator Operators and Transmission Operators shall have AVR in service and in automatic voltage control mode 98% of all operating hours for synchronous generators or synchronous condensers. Generator Operators and Transmission Operators may exclude hours for R1.1 through R1.10 to achieve the 98% requirement. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] R1.1. The synchronous generator or synchronous condenser operates for less than five percent of all hours during any calendar quarter. R1.2. Performing maintenance and testing up to a maximum of seven calendar days per calendar quarter. R1.3. AVR exhibits instability due to abnormal system configuration. R1.4. Due to component failure, the AVR may be out of service up to 60 consecutive days for repair per incident. R1.5. Due to a component failure, the AVR may be out of service up to one year provided the Generator Operator or Transmission Operator submits documentation identifying the need for time to obtain replacement parts and if required to schedule an outage. R1.6. Due to a component failure, the AVR may be out of service up to 24 months provided the Generator Operator or Transmission Operator submits documentation identifying the need for time for excitation system replacement (replace the AVR, limiters, and controls but not necessarily the power source and power bridge) and to schedule an outage. WECC-0105 P81 Final Page 1 of 4

16 WECC Standard VAR-002-WECC-2 Automatic Voltage Regulators R1.7. The synchronous generator or synchronous condenser has not achieved Commercial Operation. R1.8. The Transmission Operator directs the Generator Operator to operate the synchronous generator, and the AVR is unavailable for service. R1.9. The Reliability Coordinator directs Transmission Operator to operate the synchronous condenser, and the AVR is unavailable for service. R1.10. If AVR exhibits instability due to operation of a Load Tap Changer (LTC) transformer in the area, the Transmission Operator may authorize the Generator Operator to operate the excitation system in modes other than automatic voltage control until the system configuration changes. M1. Generator Operators and Transmission Operators shall provide quarterly reports to the compliance monitor and have evidence for each synchronous generator and synchronous condenser of the following: C. Compliance M1.1 The actual number of hours the synchronous generator or synchronous condenser was on line. M1.2 The actual number of hours the AVR was out of service. M1.3 The AVR in service percentage. M1.4 If excluding AVR out of service hours as allowed in R1.1 through R1.10, provide: M1.4.1 M1.4.2 M1.4.3 The number of hours excluded, The adjusted AVR in-service percentage, The date of the outage. 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: - Reports submitted quarterly - Spot check audits conducted anytime with 30 days notice - 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 a calendar quarter. WECC-0105 P81 Final Page 2 of 4

17 WECC Standard VAR-002-WECC-2 Automatic Voltage Regulators 1.3 Data Retention The Generator Operators and Transmission Operators shall keep evidence for Measures M1 for three years plus current year, or since the last audit, whichever is longer. 1.4 Additional Compliance Information E. Regional Differences None F. Interpretations None G. Associated Documents None The sanctions shall be assessed on a calendar quarter basis If any of R1.2 through R1.9 continues from one quarter to another, the number of days accumulated will be the contiguous calendar days from the beginning of the incident to the end of the incident. For example, in R1.4 if the 60 day repair period goes beyond the end of a quarter, the repair period does not reset at the beginning of the next quarter When calculating the in-service percentages, do not include the time the AVR is out of service due to R1.1 through R The standard shall be applied on a machine-by-machine basis (a Generator Operator or Transmission Operator can be subject to a separate sanction for each non-compliant synchronous generator and synchronous condenser). WECC-0105 P81 Final Page 3 of 4

18 WECC Standard VAR-002-WECC-2 Automatic Voltage Regulators R R1 Table of Compliance Elements Time Horizon Operational Assessment VRF Medium Violation Severity Levels Lower VSL Moderate VSL High VSL Severe VSL There shall be a There shall be a There shall be a There shall be a Lower Level of Moderate Level of High Level of Severe Level of non-compliance non-compliance if non-compliance if non-compliance if AVR is in AVR is in service AVR is in service if AVR is in service less than less than 90% but at less than 80% but service less than 98% but at least least 80% or more at least 70% or 70% of all hours 90% or more of of all hours during more of all hours during which the all hours during which the during which the synchronous which the synchronous synchronous generating unit or synchronous generating unit or generating unit or synchronous generating unit synchronous synchronous condenser is on or synchronous condenser is on line condenser is on line for each condenser is on for each calendar line for each calendar quarter. line for each quarter. calendar quarter. calendar quarter. WECC-0101 P81 Final Page 4 of 4

19 VAR-002-WECC-2-Automatic Voltage Regulators (Redline)

20 WECC WECC Standard Standard VAR-002-WECC-2 VAR-002-WECC-1 Automatic Automatic Voltage Voltage Regulators Regulators A. Introduction 1. Title: Automatic Voltage Regulators (AVR) 2. Number: VAR-002-WECC Purpose: To ensure that Automatic Voltage Regulators on synchronous generators and condensers shall be kept in service and controlling voltage. 4. Applicability: 4.1. Functional Entities: Generator Operators Transmission Operators that operate synchronous condensers This VAR-002-WECC-12 Standard only applies to synchronous generators and synchronous condensers that are connected to the Bulk Electric System. 5. Effective Date: 5. Effective Date: On the first day of the first quarter, after applicable regulatory approval. B. Requirements and Measures R1. Generator Operators and Transmission Operators shall have AVR in service and in automatic voltage control mode 98% of all operating hours for synchronous generators or synchronous condensers. Generator Operators and Transmission Operators may exclude hours for R1.1 through R1.10 to achieve the 98% requirement. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] R1.1. The synchronous generator or synchronous condenser operates for less than five percent of all hours during any calendar quarter. R1.2. Performing maintenance and testing up to a maximum of seven calendar days per calendar quarter. R1.3. R1.4. R1.5. R1.6. AVR exhibits instability due to abnormal system configuration. Due to component failure, the AVR may be out of service up to 60 consecutive days for repair per incident. Due to a component failure, the AVR may be out of service up to one year provided the Generator Operator or Transmission Operator submits documentation identifying the need for time to obtain replacement parts and if required to schedule an outage. Due to a component failure, the AVR may be out of service up to 24 months provided the Generator Operator or Transmission Operator submits documentation identifying the need for time for excitation system replacement (replace the AVR, limiters, and controls but not necessarily the power source and power bridge) and to schedule an outage. WECC-0105 AdoptedbyBoard P81 Final oftrustees: October29, 2008 Page 1 1 of 6

21 WECC WECC Standard Standard VAR-002-WECC-2 VAR-002-WECC-1 Automatic Automatic Voltage Voltage Regulators Regulators R1.7. R1.8. R1.9. The synchronous generator or synchronous condenser has not achieved Commercial Operation. The Transmission Operator directs the Generator Operator to operate the synchronous generator, and the AVR is unavailable for service. The Reliability Coordinator directs Transmission Operator to operate the synchronous condenser, and the AVR is unavailable for service. R1.10. If AVR exhibits instability due to operation of a Load Tap Changer (LTC) transformer in the area, the Transmission Operator may authorize the Generator Operator to operate the excitation system in modes other than automatic voltage control until the system configuration changes. R2. Generator Operators and Transmission Operators shall have documentation identifying the number of hours excluded for each requirement in R1.1 through R1.10. [Violation Risk Factor: Low] [Time Horizon: Operations Assessment] C. Measures M1. Generator Operators and Transmission Operators shall provide quarterly reports to the compliance monitor and have evidence for each synchronous generator and synchronous condenser of the following: D. C. Compliance M1.1 The actual number of hours the synchronous generator or synchronous condenser was on line. M1.2 The actual number of hours the AVR was out of service. M1.3 The AVR in service percentage. M1.4 If excluding AVR out of service hours as allowed in R1.1 through R1.10, provide: M1.4.1 M1.4.2 The number of hours excluded, and The adjusted AVR in-service percentage., M2. If excluding hours for R1.1 through R1.10, provide the1.4.3 The date of the outage, the number of hours out of service, andsupporting documentation for each requirement that applies Compliance Monitoring Process Compliance Monitoring Responsibility Compliance Enforcement Authority Compliance Monitoring Period Compliance Enforcement Authority may use one or more of the following methods to assess compliance: - Reports submitted quarterly WECC-0105 AdoptedbyBoard P81 Final oftrustees: October29, 2008 Page 2 2 of 6

22 WECC WECC Standard Standard VAR-002-WECC-2 VAR-002-WECC-1 Automatic Automatic Voltage Voltage Regulators Regulators - Spot check audits conducted anytime with 30 days notice - 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 a calendar quarter Data Retention the The Generator Operators and Transmission Operators shall keep evidence for Measures M1 and M2 for three years plus current year, or since last audit, whichever is longer Additional Compliance Information The sanctions shall be assessed on a calendar quarter basis If any of R1.2 through R1.9 continues from one quarter to another, the number of days accumulated will be the contiguous calendar days from the beginning of the incident to the end of the incident. For example, in R1.4 if the 60 day repair period goes beyond the end of a quarter, the repair period does not reset at the beginning of the next quarter When calculating the in-service percentages, do not include the time the AVR is out of service due to R1.1 through R The standard shall be applied on a machine-by-machine basis (a Generator Operator or Transmission Operator can be subject to a separate sanction for each non-compliant synchronous generator and synchronous condenser). 2. Violation Severity Levels for R Lower: There shall be a Lower Level of non-compliance if the following condition exists: AVR is in service less than 98% but at least 90% or more of all hours during which the synchronous generating unit or synchronous condenser is on line for each calendar quarter Moderate: There shall be a Moderate Level of non-compliance if the following condition exists: AVR is in service less than 90% but at least 80% or more of all hours during which the synchronous generating unit or synchronous condenser is on line for each calendar quarter High: There shall be a High Level of non-compliance if the following condition exists: AVR is in service less than 80% but at least 70% or more of all hours during which the synchronous generating unit or synchronous condenser is on line for each calendar quarter. WECC-0105 AdoptedbyBoard P81 Final oftrustees: October29, 2008 Page 3 3 of 6

23 WECC WECC Standard Standard VAR-002-WECC-2 VAR-002-WECC-1 Automatic Automatic Voltage Voltage Regulators Regulators 2.4. Severe: There shall be a Severe Level of non-compliance if the following condition exists: AVR is in service less than 70% of all hours during which the synchronous generating unit or synchronous condenser is on line for each calendar quarter. 3. Violation Severity Levels for R Lower: There shall be a Lower Level of non-compliance if documentation is incomplete with any requirement R1.1 through R Moderate: There shall be a Moderate Level of non-compliance if the Generator Operator does not have documentation to demonstrate compliance with any requirement R1.1 through R High: Not Applicable 3.4. Severe: Not Applicable E. Regional Differences 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 VAR-STD-002a-1 1 April 21, 2011 FERC Order issued approving VAR- 002-WECC-1 (approval effective June 27, 2011) * FOR INFORMATIONAL PURPOSES ONLY * Enforcement Dates: Standard VAR-002-WECC-1 Automatic Voltage Regulators (AVR) (WECC) United States Standard Requirement Enforcement Date Inactive Date VAR-002-WECC-1 All 07/01/2011 None F. Interpretations None G. Associated Documents None WECC-0105 AdoptedbyBoard P81 Final oftrustees: October29, 2008 Page 4 4 of 6

24 WECC Standard VAR-002-WECC-2 Automatic Voltage Regulators R R1 Table of Compliance Elements Time Horizon Operational Assessment VRF Medium Violation Severity Levels Lower VSL Moderate VSL High VSL Severe VSL There shall be a There shall be a There shall be a There shall be a Lower Level of Moderate Level of High Level of Severe Level of non-compliance non-compliance if non-compliance if non-compliance if AVR is in AVR is in service AVR is in service if AVR is in service less than less than 90% but at less than 80% but service less than 98% but at least least 80% or more at least 70% or 70% of all hours 90% or more of of all hours during more of all hours during which the all hours during which the during which the synchronous which the synchronous synchronous generating unit or synchronous generating unit or generating unit or synchronous generating unit synchronous synchronous condenser is on or synchronous condenser is on line condenser is on line for each condenser is on for each calendar line for each calendar quarter. line for each quarter. calendar quarter. calendar quarter. WECC-0101 P81 Final Page 5 of 6

25 VAR-501-WECC-2 Power System Stabilizer (Clean)

26 WECC Standard VAR-501-WECC-2 Power System Stabilizer A. Introduction 1. Title: Power System Stabilizer (PSS) 2. Number: VAR-501-WECC-2 3. Purpose: To ensure that Power System Stabilizers (PSS) on synchronous generators shall be kept in service. 4. Applicability: 4.1. Functional Entities: Generator Operators 5. Effective Date: On the first day of the first quarter after applicable regulatory approval. B. Requirements and Measures R1. Generator Operators shall have PSS in service 98% of all operating hours for synchronous generators equipped with PSS. Generator Operators may exclude hours for R1.1 through R1.12 to achieve the 98% requirement. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] R1.1. R1.2. R1.3. R1.4. R1.5. R1.6. R1.7. The synchronous generator operates for less than five percent of all hours during any calendar quarter. Performing maintenance and testing up to a maximum of seven calendar days per calendar quarter. PSS exhibits instability due to abnormal system configuration. Unit is operating in the synchronous condenser mode (very near zero real power level). Unit is generating less power than its design limit for effective PSS operation. Unit is passing through a range of output that is a known rough zone (range in which a hydro unit is experiencing excessive vibration). The generator AVR is not in service. R1.8. Due to component failure, the PSS may be out of service up to 60 consecutive days for repair per incident. R1.9. Due to a component failure, the PSS may be out of service up to one year provided the Generator Operator submits documentation identifying the need for time to obtain replacement parts and if required to schedule an outage. WECC-0105 P81 VAR-501-WECC-2 Final Page 1 of 5

27 WECC Standard VAR-501-WECC-2 Power System Stabilizer R1.10. Due to a component failure, the PSS may be out of service up to 24 months provided the Generator Operator submits documentation identifying the need for time for PSS replacement and to schedule an outage. R1.11. R1.12. The synchronous generator has not achieved Commercial Operation. The Transmission Operator directs the Generator Operator to operate the synchronous generator, and the PSS is unavailable for service. M1. Generators Operators shall provide quarterly reports to the compliance monitor and have evidence for each synchronous generator of the following: M1.1 The number of hours the synchronous generator was on line. M1.2 The number of hours the PSS was out of service with generator on line. M1.3 The PSS in service percentage M1.4 If excluding PSS out of service hours as allowed in R1.1 through R1.12, provide: M1.4.1 M1.4.2 M1.4.3 The number of hours excluded, The adjusted PSS in-service percentage, Date of the outage. C. Compliance 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: - Reports submitted quarterly - Spot check audits conducted anytime with 30 days notice - Periodic audit as scheduled by the Compliance Enforcement Authority - Investigations - Other methods as provided for in the Compliance Monitoring Enforcement Program WECC-0105 P81 VAR-501-WECC-2 Final Page 2 of 5

28 WECC Standard VAR-501-WECC-2 Power System Stabilizer The Reset Time Frame shall be a calendar quarter. 1.3 Data Retention The Generator Operators shall keep evidence for Measures M1 and M2 for three years plus current year, or since the last audit, whichever is longer. 1.4 Additional Compliance Information C. Regional Variances None. D. Interpretations None. E. Associated Documents None The sanctions shall be assessed on a calendar quarter basis If any of R1.2 through R1.12 continues from one quarter to another, the number of days accumulated will be the contiguous calendar days from the beginning of the incident to the end of the incident. For example, in R1.8 if the 60 day repair period goes beyond the end of a quarter, the repair period does not reset at the beginning of the next quarter When calculating the adjusted in-service percentage, the PSS out of service hours do not include the time associated with R1.1 through R The standard shall be applied on a generating unit by generating unit basis (a Generator Operator can be subject to a separate sanction for each non- compliant synchronous generating unit or to a single sanction for multiple machines that operate as one unit). WECC-0105 P81 VAR-501-WECC-2 Final Page 3 of 5

29 WECC Standard VAR-501-WECC-2 Power System Stabilizer R R1 Table of Compliance Elements Time Horizon Operational Assessment VRF Medium Violation Severity Levels Lower VSL Moderate VSL High VSL Severe VSL There shall be a There shall be a There shall be a There shall Lower Level of Moderate Level of High Level of be a Severe non-compliance non-compliance if non-compliance if Level of if PSS is in PSS is in service is in service less noncompliance service less than less than 90% but at than 80% but at 98% but at least least 80% or more least 70% or more if PSS is in 90% or more of of all hours during of all hours during service less all hours during which the which the than 70% which the synchronous synchronous of all hours synchronous generating unit is generating unit is during generating unit is on line for each on line for each which the on line for each calendar quarter. calendar quarter. synchronous calendar quarter. generating unit is on line for each calendar quarter. WECC-0105 P81 VAR-502-WECC-2 Final Page 4 of 5

30 WECC Standard VAR-501-WECC-2 Power System Stabilizer Version History Version Date Action Change Tracking 1 April 16, 2008 Permanent Replacement Standard for VAR-STD-002b-1 1 April 21, 2011 FERC Order issued approving VAR- 501-WECC-1 (approval effective June 27, 2011) 2 NERC Board of Trustees Approval Removed documentation requirement from Requirement R2; placed the mandate into the Measures. Deleted Requirement R2. WECC-0105 P81 VAR-502-WECC-2 Final Page 5 of 5

31 VAR-501-WECC-2 Power System Stabilizer (Redline)

32 WECC WECC Standard VAR-501-WECC-2 VAR-501-WECC-1 Power System Stabilizer A. Introduction 1. Title: Power System Stabilizer (PSS) 2. Number: VAR-501-WECC Purpose: To ensure that Power System Stabilizers (PSS) on synchronous generators shall be kept in service. 4. Applicability: 4.1. Functional Entities: Generator Operators 5. Effective Date: On the first day of the first quarter, after applicable regulatory approval. B. Requirements and Measures R1. Generator Operators shall have PSS in service 98% of all operating hours for synchronous generators equipped with PSS. Generator Operators may exclude hours for R1.1 through R1.12 to achieve the 98% requirement. [Violation Risk Factor: Medium] [Time Horizon: Operations Assessment] R1.1. R1.2. R1.3. R1.4. R1.5. R1.6. R1.7. The synchronous generator operates for less than five percent of all hours during any calendar quarter. Performing maintenance and testing up to a maximum of seven calendar days per calendar quarter. PSS exhibits instability due to abnormal system configuration. Unit is operating in the synchronous condenser mode (very near zero real power level). Unit is generating less power than its design limit for effective PSS operation. Unit is passing through a range of output that is a known rough zone (range in which a hydro unit is experiencing excessive vibration). The generator AVR is not in service. R1.8. Due to component failure, the PSS may be out of service up to 60 consecutive days for repair per incident. R1.9. Due to a component failure, the PSS may be out of service up to one year provided the Generator Operator submits documentation identifying the need for time to obtain replacement parts and if WECC-0105 AdoptedbyBoard P81 VAR-501-WECC-2 oftrustees: Final October29, 2008 Page 1 1 of 7

33 WECC WECC Standard VAR-501-WECC-2 VAR-501-WECC-1 Power System Stabilizer required to schedule an outage. R1.10. Due to a component failure, the PSS may be out of service up to 24 months provided the Generator Operator submits documentation identifying the need for time for PSS replacement and to schedule an outage. R1.11. The synchronous generator has not achieved Commercial Operation. R1.12. The Transmission Operator directs the Generator Operator to operate the synchronous generator, and the PSS is unavailable for service. R2. Generator Operators shall have documentation identifying the number of hours excluded for each requirement in R1.1 through R1.12. [Violation Risk Factor: Low] [Time Horizon: Operations Assessment] C. Measures M1. Generators Operators shall provide quarterly reports to the compliance monitor and have evidence for each synchronous generator of the following: M1.1 The number of hours the synchronous generator was on line. M1.2 The number of hours the PSS was out of service with generator on line. M1.3 The PSS in service percentage M1.4 If excluding PSS out of service hours as allowed in R1.1 through R1.12, provide: M1.4.1 The number of hours excluded, and M1.4.2 The adjusted PSS in-service percentage., M2. If excluding hours for R1.1 through R1.12, provide: M2.1 The date M1.4.3 Date of the outage. M2.2 Supporting documentation for each requirement that applies WECC-0105 AdoptedbyBoard P81 VAR-501-WECC-2 oftrustees: Final October29, 2008 Page 2 2 of 7

34 WECC WECC Standard VAR-501-WECC-2 VAR-501-WECC-1 Power System Stabilizer C. D. Compliance 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: - Reports submitted quarterly - Spot check audits conducted anytime with 30 days notice - 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 a calendar quarter. 1.3 Data Retention The Generator Operators shall keep evidence for Measures M1 and M2 for three years plus current year, or since the last audit, whichever is longer. 1.4 Additional Compliance Information The sanctions shall be assessed on a calendar quarter basis If any of R1.2 through R1.12 continues from one quarter to another, the number of days accumulated will be the contiguous calendar days from the beginning of the incident to the end of the incident. For example, in R1.8 if the 60 day repair period goes beyond the end of a quarter, the repair period does not reset at the beginning of the next quarter When calculating the adjusted in-service percentage, the PSS out of service hours do not include the time associated with R1.1 through R1.12. The standard shall be applied on a generating unit by generating unit basis (a Generator Operator can be subject to a separate sanction for each non- compliant synchronous generating unit or to a single sanction for multiple machines that operate as one unit). 2. Violation Severity Levels 2.1. Lower: There shall be a Lower Level of non-compliance if the following condition exists: PSS is in service less than 98% but at least 90% or more of all hours during which the synchronous generating unit is on line for each calendar quarter Moderate: There shall be a Moderate Level of non-compliance if the following condition exists: PSS is in service less than 90% but at least 80% or more of all hours during which WECC-0105 AdoptedbyBoard P81 VAR-501-WECC-2 oftrustees: Final October29, 2008 Page 3 3 of 7

35 WECC WECC Standard VAR-501-WECC-2 VAR-501-WECC-1 Power System Stabilizer the synchronous generating unit is on line for each calendar quarter High: There shall be a High Level of non-compliance if the following condition exists: PSS is in service less than 80% but at least 70% or more of all hours during which the synchronous generating unit is on line for each calendar quarter Severe: There shall be a Severe Level of non-compliance if the following condition exists: PSS is in service less than 70% of all hours during which the synchronous generating unit is on line for each calendar quarter. 3. Violation Severity Levels for R Lower: There shall be a Lower Level of non-compliance if documentation is incomplete with any requirement R1.1 through R Moderate: There shall be a Moderate Level of non-compliance if the Generator Operator does not have documentation to demonstrate compliance with any requirement R1.1 through R High: Not Applicable 3.4. Severe: Not Applicable C. E. Regional DifferencesVariances None. D. Interpretations None. E. Associated Documents None. WECC-0105 AdoptedbyBoard P81 VAR-501-WECC-2 oftrustees: Final October29, 2008 Page 4 4 of 7

36 WECC Standard VAR-501-WECC-2 Power System Stabilizer R R1 Table of Compliance Elements Time Horizon Operational Assessment VRF Medium Violation Severity Levels Lower VSL Moderate VSL High VSL Severe VSL There shall be a There shall be a There shall be a There shall Lower Level of Moderate Level of High Level of be a Severe non-compliance non-compliance if non-compliance if Level of if PSS is in PSS is in service is in service less non-complia service less than less than 90% but at than 80% but at nce if PSS 98% but at least least 80% or more least 70% or more is in service 90% or more of of all hours during of all hours during less than all hours during which the which the 70% of all which the synchronous synchronous hours synchronous generating unit is on generating unit is during generating unit is line for each on line for each which the on line for each calendar quarter. calendar quarter. synchronous calendar quarter. generating unit is on line for each calendar quarter. WECC-0105 P81 VAR-502-WECC-2 Final Page 5 of 7

37 WECC Standard VAR-501-WECC-2 Power System Stabilizer 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 VAR-STD-002b-1 1 April 21, 2011 FERC Order issued approving VAR- 501-WECC-1 (approval effective June 27, 2011) 2 NERC Board of Trustees Approval Removed documentation requirement from Requirement R2; placed the mandate into the Measures. Deleted Requirement R2. * FOR INFORMATIONAL PURPOSES ONLY * Enforcement Dates: Standard VAR-501-WECC-1 Power System Stabilizer (PSS) (WECC) United States Standard Requirement Enforcement Date Inactive Date VAR-501-WECC-1 All 07/01/2011 WECC-0105 P81 VAR-502-WECC-2 Final Page 6 of 7

38 Exhibit B Implementation Plan

39 Implementation Plan WECC-0105 P81 Changes VAR-002-WECC-2 Automatic Voltage Regulator VAR-501-WECC-2 Power System Stabilizer Approvals Required VAR-002 WECC-2 Automatic Voltage Regulator VAR-501-WECC-2 Power System Stabilizer Project WECC-0105 implements P81 changes. According to its Implementation Plan, the documentation requirements resident in Requirement R2 of both VAR-002-WECC-1 and VAR-501-WECC-1 have been removed from the Requirements section and made part of the Measures for Requirement R1 in the new documents. Other than various formatting changes, no other substantive changes were made. Prerequisite Approvals None Revisions to Glossary Terms None Applicable Entities VAR-002 WECC-2 Automatic Voltage Regulator Generator Operator Transmission Operator VAR-501-WECC-2 Power System Stabilizer Generator Operator Conforming Changes to Other Standards None Effective Dates On the first day of the first quarter, after applicable regulatory approval. Retirements None Justification of Phasing None WECC-0105 P81 Project Implementation Plan October 7, 2014 VAR-002-WECC-2 Automatic Voltage Regulators / VAR-501- WECC-2 Power System Stabilizers 1

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