Setting the Stage
Best practices and lessons learned are interesting topics, especially in the world of electric grid reliability. These approaches are closely tied to risk – the double-edged sword of risk to grid reliability – coupled with the risk of non-compliance with an approved NERC reliability standard. The Registered Entity or user of the Bulk Electric System is free to consider the application of the best practice or lessons learned and weigh the cost and time of implementation against the risk applicable to their situation. In some cases, the suggested best practice is not a heavy lift considering the attendant activity being addressed.
On November 2, FERC, NERC, and the Regional Entities issued a Joint Review of Protection System Commissioning Programs report. The key point of the report is a significant number of protection system misoperations are attributable to errors and lack of controls in the commissioning process. The recommended attributes of a successful process read like a who’s who of internal controls.
They include:
- Existence of a formal commissioning program
- Stated goals and objectives
- Well-defined plans to perform commissioning projects
- Clearly identified lines of responsibility and training
- Authority given to responsible parties
- Feedback methods to improve the plan
The report consists of these procedural, non-technical controls and quality assurance steps. The good news is these controls are easily developed steps that focus almost exclusively on communication. Easily demonstrated evidence of consideration and adoption of these best practices provides a simple plan defining the who, what, when, and where of the commissioning activity. Since the commissioning happens anyway, it’s easy to introduce these controls into the process.
The benefits of doing so are substantial:
- The details of the installation, setting, and testing of protection system components are well documented.
- The risk of errors is greatly reduced.
- By default, the process will produce elements of compliance with NERC standards PRC-005-6 Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance and FAC-008-5 Facility Ratings for both the beginning of testing intervals and required component lists. The higher the data quality, the less likely you have compliance issues with either of these frequently violated standards.
- Implementation of best practices highlights a superior culture of compliance. Auditors take this culture very seriously, and any steps taken to go above and beyond the absolute minimum to demonstrate compliance are well received.
- Finally, when easily implemented guidance that addresses one of the high-risk elements identified by the Compliance Monitoring and Enforcement Program Implementation Plan. (Protection System Coordination), it would be difficult to explain why the guidance was ignored.
Simple steps to address complex problems are not common. Implementation of best practices and lessons learned falls into that category and produces benefits far greater than the minimal cost of composing and adhering to a set of communication controls for a project you are going to do anyway.
The report also lists several IEEE procedures to help guide the technical implementation of the commissioning process.
