Guidance on Requirements for PRC-005 Mitigation Plans

1. Guidance on Requirements for PRC-005 Mitigation Plans By: Texas RE Enforcement April 25, 2013 Talk with Texas RE April 25, 2013

2. PRC-005 Mitigation Plans • For the purposes of this presentation, hypothetical entity “ABC” is required to provide a Mitigation Plan. • Once ABC’s violation has been entered in webCDMS, ABC will be able to enter a Mitigation Plan. • ABC should make sure to address each step that is covered on the following slides. These slides refer to the “Plan Details” and “Activities and Timeline” fields in the Mitigation Plan. Talk with Texas RE April 25, 2013

3. Step 1: Identify the Issue and Mitigation • ABC should identify the issue. • Identify how ABC mitigated the issue. • Evidence is required. ABC should provide: • Maintenance Log • Testing Records • Upload the supporting evidence into the Entity Document section of the Mitigation Plan. Talk with Texas RE April 25, 2013

4. Step 2: Comprehensive Survey • Perform a comprehensive survey to ensure all the elements subject to PRC-005 are included and none are missing (generation and transmission, as applicable). • Evidence: • Provide a spreadsheet listing all elements’ maintenance and testing history. Include last two maintenance and testing dates. • For station batteries provide last two maintenance and testing dates of each type of testing. • Upload the supporting evidence into the Entity Document section of the Mitigation Plan. • Spreadsheet: • If the prior maintenance and testing dates are unknown, enter your registration date in the “Date: Maintenance and testing performed (prior to the possible violation period)” column. • Enter comments if necessary. • Note: Do not provide any supporting maintenance and testing records for this milestone. Provide the spreadsheet or screen display of the database containing devices and maintenance/test dates. Talk with Texas RE April 25, 2013

5. Step 3: Questionnaire • Complete the questionnaireand the embedded spreadsheet (available on Texas RE’s website). • This questionnaire determines the potential risk and severity due to the violation. • Upload the completed questionnaire and spreadsheet into the Entity Document Mitigation Plan section. • Complete the section of the questionnaire relevant to violation (i.e., do not complete PRC-008-0 R2). • Each piece of equipment subject to PRC-005-1 R2 that was missed must be listed. If you missed any equipment  multiple times, each instance of non-compliance should be listed separately. • For example, if battery testing was missed in 2nd quarter of 2010 and again in  3rd quarter of 2012, two line items should appear to address these issues. Talk with Texas RE April 25, 2013

6. Internal Control • Evidence is required. • ABC should describe its internal control process: • ABC’s monitoring process/plan to prevent or minimize the probability of further PRC-005-1 R2 violations. Talk with Texas RE April 25, 2013

7. Mitigation Plan Validation • Provide Data to Texas RE demonstrating completion of the mitigation plan • Transmission: Texas RE staff will make random equipment selections and request maintenance and testing records for such selections. All the issues need to be resolved before closing the mitigation plan. The proposed completion of this milestone must allow an additional 4 to 6 weeks. • Generation: Texas RE staff will select random generators and associated substations. Within that subset, Texas RE will again select random equipment for verification. Texas RE staff will then ask for maintenance and testing records of relays and associated equipment within the protection system. • Include evidence of continuous monitoring, if applicable. This would include items such as a screen display. Talk with Texas RE April 25, 2013