Order 754 is the Final Rule approving the interpretation of Interpretation TPL-002-0a PacifiCorp (Project 2009-14) regarding requirement R1.3.10. In addition to the approval, the Commission expressed a concern about single point of failure of protection systems and issued a directive for further investigation. From the Order, “…the Commission believes that there is an issue concerning the study of the non-operation of non-redundant primary protection systems; e.g., the study of a single point of failure on protection systems” (P19). In the first part of the directive (P20), the Commission directed FERC staff to meet with NERC and its appropriate subject matter experts to explore this reliability concern, including where it can best be addressed, and identify any additional actions necessary to address the matter. This portion of the directive was satisfied by the October 24-25, 2011 Technical Conference. In the second part (P20), NERC must complete an informational filing within six months of the Order (middle March 2012) explaining whether there is a further system protection issue that needs to be addressed and, if so, what forum and process should be used to address that issue and what priority it should be accorded relative to other reliability initiatives planned by NERC.

 

The participants in the technical conference perceived a reliability concern regarding the comprehensive assessment of potential protection system failures by registered entities.  The group agreed on the need to study if a gap exists regarding the study and resolution of a single point of failure on protection systems. Note: This is not a “redundancy of protection systems” issue. The issue is, do the requirements in the transmission planning reliability standards adequately address the analysis and discovery of a protection system failure in order develop plans to meet the performance requirements for the BES (i.e. TPL-001, 002, 003, and 004).

In response to the Order, a small group representing NERC staff and industry system protection and planning experts participated in a technical conference held on October 24-25, 2011 with FERC staff. The group concluded the technical conference with action items to develop a plan and other documents for industry consideration. A small industry focus group is developing an action plan and related documents for review by System Protection & Controls Subcommittee (SPCS) and Transmission Issues Subcommittee (TIS) in Fort Worth, Texas on December 6-7, 2011.