On September 20, 2017, the Federal Energy Regulatory Commission (FERC) approved NERC’s PRC 012-2 standard governing protection and controls for remedial action schemes (RAS). It replaces previously effective and pending PRC standards.
PRC-012-2 aims to ensure that RAS do not introduce unintentional or unacceptable reliability risks to the Bulk Electric System. Transmission owners, generation owners, or distribution providers that own all or part of any RAS are required to address issues related to the:
PRC-012-2 provides clear and unambiguous responsibilities for utilities that own all or part of a RAS, including:
PRC-012-2 establishes a new working framework between RAS owners, the Planning Coordinators, and Reliability Coordinators, which will involve a considerable start-up and review effort. As a result, standard implementation will occur over a 36 month period.
The standard also includes two new feature concepts: Limited Impact and Functional Modification/Functional Testing. Please download our Regulatory Update for the full details.
PRC-005 v. PRC-012
A key industry concern during the development of PRC-012-2 had been the boundary between the maintenance requirements of PRC-005 and PRC-012. The PRC-012-2 standard is not intended to “double dip” requirements relative to PRC-005. It stands alone and includes all the necessary obligations, including the reporting of RAS misoperations. It is important to note that in PRC-012-2 functional testing is not equivalent to component testing. Segments may be logical functions, not necessarily components.
Engineering review and planning analysis of existing SPS and RAS designs will be critical for compliance. In particular the relationship between limited impact RAS and NERC’s TPL-001-4 standard will require careful assessment. It must be shown that that limited impact RAS are not being used to meet the TPL-001-4 requirements. Design and implementation of new RAS may be necessary. Extensive independent review by both a Planning Coordinator and Reliability Coordinator in addition to the Transmission Planner and Generator Owners that own all or parts of any RAS scheme will also be required.
To learn more, please read our full Regulatory Update on PRC-012-2.