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Question: April 3, 2019 Per the Standards for COM-001 and COM-002, the retention period for written documentation is the most recent twelve calendar months and voice recordings for the most recent 90 calendar days unless directed by the CEA to retain specific evidence for a longer period of time as part of an investigation. Does SERC have a retention period for written documentation and call recordings that will require an entity to keep evidence longer than what is specified in the Standard? Response NERC Standard COM-001-3 requires the applicable entity to retain written documentation for the most recent twelve calendar months and voice recordings for the most recent 90 calendar days. NERC Standard COM-002-4 requires the applicable entity to retain data or evidence for each applicable Requirement for the current calendar year and one previous calendar year, with the exception of voice recordings which shall be retained for a minimum of 90 calendar days. SERC is obligated to request the data and evidence based on the retention periods that are stated in the NERC Standards and Requirements. SERC may request the applicable entity to retain specific evidence for a longer period of time as part of an investigation. Question: April 16, 2019 MOD-033 R1 requirement R1.2 has an exception that states “If no dynamic local event occurs within the 24 calendar months, use the next dynamic local event that occurs” Dynamic local event is not a defined term. Dynamic events happen often (e.g. breaker operations), but are not always measurable enough, or have sufficient data recorded to be used for comparison. Is it acceptable for an entity to define criteria for what is an acceptable local event, and can the exception be used if there is no acceptable event in 24 months? Example: For an event to be considered acceptable the following criteria must be met: • Sufficient EMS data is available, and • Event must result in a perturbation of a portion of the system, and • Sufficient event recorder data is available. Response Per MOD-033, for the dynamics validation, the target of validation is those events that the Planning Coordinator (PC) determines are dynamic local events. Adynamic local event could include such things as closing a transmission line near a generating plant. Adynamic local event is a disturbance on the power system that produces some measurable transient response, such as oscillations. It could involve one small area of the system or a generating plant oscillating against the rest of the grid. Therefore, it is the PC that has to identify the dynamic event. If something other than what the PC has identified is determined to be such an event, then the PC would still determine what is to be used. If no dynamic local event occurs within the 24 calendar months, use the next dynamic local event that occurs.
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