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THE LINE BETWEEN

PRC-023/PRC-025

What generator
Owners need to
know!

Daniel J Hansen
NRG Energy, Inc.
3/31/2015

Compliance Executed by Region

NERC Regions are separate Compliance


Organizations.

WHY RELAY LOADABILITY STANDARDS ARE IMPORTANT


2003 BLACKOUT
Transmission Lines Tripped for reasons other
than clearing a fault. Cascading separation and
outages are caused by load responsive relays.
290 Generating Units Tripped (approximately
52,745 MW). The Primary Reason: the
operation of protection relays for units connected
to a system in distressed condition. As
generating units trip prematurely, the cascading
impact is accelerated.

Clearly Needed are corrective actions to


lessen the reliability impact of load responsive
relays: avoid unnecessary cascading outages.

TIMELINE of APPROVAL for RELAY LOADABILITY STANDARDS

PRC-023-1 FERC ORDER 733

3/18/2010

PRC-023-2 FERC ORDER 759

3/15/2012

PRC-023-3 FERC ORDER 799


PRC-025-1

7/17/2014

FERC ORDER 733

Applicability of PRC-023 as directed by FERC in Order


No. 733, provides very explicit wording for application.
Protection of specific Transmission is included; Generator
Owner Facilities are excluded.

HV GENERATION
INTERCONNECTION

PRC023

Compliance Scope
Growth Reaching
Into GO Facilities

Generator Owners
contributed to the overreach
either by ignorance or
passive submission.
GENERATION
FACILITIES

PRC-023 APPLICABILITY
TRANSMISSION OWNERS
OWNERS

GENERATOR

PRC-023
Requirements

Generator Owners are included in the


applicability section of the PRC-023
standard, even though protection of
Generator Owner Facilities are
excluded.

WHAT SHOULD HAVE BEEN CLEAR TO SEE, BECAME BLURRED

FERC ORDER 733: WHERE DOES THE CONFUSION START?


Generator Owners are included in the applicability
section of PRC-023-1
FERC recognized that Generator Relay Loadability
is a complex issue; it presents distinctly different
challenges
PRC-023 applies to the Protection of Transmission
Elements, regardless if primary or backup protection
and regardless of physical location of the relay.
FERC identified that Distance Back-up Protection
located at Generating Units can be applied in two ways
o Transmission Elements (as defined by
applicability)
o Generator and GSU
Therefore, Relays for Transmission Protection
located at a generating unit are within PRC-023
applicability.

Further Complications - Incorrect Interpretation

Progression of False
Logic
Generator Owners are in
applicability Section
Transmission Lines over
200kV are included in
scope of PRC-023
High Voltage Overhead
Conductors are
Transmission lines
Generator Owners high
voltage overhead
conductors are
Transmission lines
Relays on those lines are
in the scope of PRC-023

CRUCIAL ISSUE - WHAT IS PROTECTED & BY WHOM

One Utility with GO & TO


Registrations. Distance
elements on generating units
are integrated into backup
transmission protection
schemes.
Generator
Owner

Transmission
Owner

PRC-023-1 applies: protection for transmission elements,


regardless of physical location of relay, includes within scope.

CRUCIAL ISSUE - WHAT IS PROTECTED & BY WHOM


The GO & TO are independent. PRC023 DOES NOT APPLY for GO distance
elements, regardless of the reach into
the transmission system.
PRC-025-1 will apply to GO protection.

Generator
Owner

Transmission
Owner

Generator Owner & Transmission Owner have an obligation


to coordinate, but no obligation to protect each others facilities.

GENERATOR OWNERS HV FACILITIES

Generator
Owner

Transmis
sion
Owner

PRC-023 does not apply to Generator Owner, if GO high


voltage facilities existing exist only for generation interconnection.

FERC ORDER 733 ESTABLISHES A BRIGHT LINE


There was never an intentional blurring of the
lines
FERC is abundantly clear, with no ambiguity, there
is to be a separation of transmission and
generation loadable relays into different standards.
PRC-023-1 excludes Generator relays susceptible
to load; Generator step-up transformer relay
loadability is intentionally omitted
Generator, step-up and auxiliary transformer
loadability will get address by NERC in a future
reliability standard.
FERC acknowledges generator step-up and
auxiliary transformer loadability and generator
relay loadability all to refer to the same thing.

A DEFINITIVE, BRIGHT LINE OF SEPARATION


FERC Order No. 733
Therefore, no generator owner that
is not also a
transmission owner and/or a
distribution
provider will be subject to PRC-0231.

NERC COMPLIANCE PROCESS BULLETIN #2012-001

(PRC-023-1) applies to facilities 100 kV above and to transformers with


low-voltage terminals 200 kV and above. Because there are no
commercial generators with a terminal voltage as high as 100 kV and all
generator step-up and auxiliary power transformers have low-voltage
windings well below 200 kV, PRC-023-1 excludes generators and all
generator step-up and auxiliary transformers. Therefore, no generator
owner that is not also a transmission owner and/or a distribution
provider will be subject to PRC-023-1.

PRC-023-3 & PRC-025-1 DEVELOPMENT


Clarifies the Separation between the Two
Standards
PRC-023-3 Applicability:
Transmission lines operated at 200 kV and above,
except Elements that connect the GSU transformer(s)
to the
Transmission system that are used exclusively to
export energy directly from a BES generating unit or
generating
plant.
PRC-025-1 Applicability:
The converse of PRC-023-3 applicability is applied.
FERC Order No. 799:
There is no compliance overlap between PRC-023-3
and PRC-025-1, i.e. the same relay element does not
come under the requirements of both standards.

SUMMARY
1. All Versions of PRC-023 apply to protection of the
networked Transmission Owners BES Facilities defined
within applicability section , not Generator Owners
equipment and circuits.
2. From the beginning, the application of PRC-023 to a
Generator Owner was intentionally limited, restricted
to relays protecting Transmission Owner Facilities.
3. FERC Order Nos. 733 and 733A each state in clear,
unambiguous terms no generator owner that is not
also a transmission owner and/or a distribution provider
will be subject to PRC-023-1.
4. There is No Applicability Overlap between PRC-023 &
PRC-025. A single relay is limited to the scope of one
standard, but not both. Protection of Generator
Interconnection Facilities was never intended to first
comply with PRC-023, then later transition to PRC-025.

THE END