Please enter your first and last name.

Thad Ness

Please enter your company name.

American Electric Power (AEP)

If this is from a group, please enter all additional members.

 

1) Subsequent to a review performed by NERC staff, the SDT has reformatted and modified certain requirements of the draft PRC-006-RFC-01 standard. Do you agree with the reformatted structure and modified requirements of the standard?

Yes

1) If not, please provide specific suggestions.

 

2) Time Horizons have been added to the Requirements. Do you agree that the Time Horizons are appropriate for the requirements?

Yes

2) If not, please provide specific suggestions.

However, our comment regarding R3 has language that could read contrary to the stated Time Horizon. We recommend removing the words “…as a result of an UFLS event.” From R3.

3) The Measures have been modified to include more examples on how to assess performance and outcomes for the purpose of determining compliance with the requirements.  Do you agree that the Measures are appropriate?

No

3) If not, please provide specific suggestions.

AEP agrees with additional information, but M3. needs to be adjusted, as it is not entirely consistent with Requirement 3. M3 is event driven, while R3 is driven by PC assessment.

4) The Violation Severity Levels (VSLs) have been modified to be consistent with the modified requirements and based on NERC and the FERC guidelines.  Do you agree that the VSLs are appropriate?

No

4) If not, please provide specific suggestions.

 For R1, Severe VSL the last condition needs to be reconsidered as it could be read to infer that participation to collectively implement by mutual agreement is required.
R3 – What is meant by the “percentage of automatic switching?” Percentage of number of banks, percentage of MVARs or something else?  This needs to be clarified to remove ambiguity.
R12 – The VSLs for this requirement would need to be revisited by the SDT based on the comments that we provide regarding R12 in question 6.
R12 - We did notice an error the last condition should state, “The Generator Owner that owns a unit(s) withOUT…”
The word “with” needs to be replaced with “without”

5) The Violation Risk Factors (VRFs) have been modified to be consistent with the modified requirements and based on NERC and the FERC guidelines.  Do you agree that the VRFs are appropriate?

Yes

5) If not, please provide specific suggestions.

 

6) The Standard Drafting Team believes the standard is ready for Category Ballot.  Do you agree?

No

6) If not, please provide specific suggestions that would make it acceptable to you.

AEP offers the following input to the Standards Drafting Team.  While this project has been under development, there has also been significant progress on NERC related standards.  There are a number of overlapping and possibly conflicting requirements with the now NERC Board approved PRC-006-1, and also with the coordination of generator off-nominal frequency curves between NERC Standards PRC-006-1 and draft PRC-024-1.  AEP believes that more work should be done to remove similar requirements and overlapping elements, and resolve inconsistencies between this draft Regional standard and the NERC standard(s).
AEP also offers these specific comments:
R1.7 & R2.2 – “For installations where motor loads or distributed generation may be isolated, additional supervision (e.g. undercurrent) shall be used to avoid false operation during Fault isolation.”  The wording needs to have the word “should” in place of “shall”.  This would be addressed in the misoperation process.  It is often not practical to determine how long a disconnected distribution feeder will remain energized due to an induction machine on the load.
R3 – It is not clear if this requirement is event driven or a long-term planning based requirement.  Our assumption is it long-term planning and not event driven. The words “as a result of an UFLS event” need to be removed. Also, AEP questions M3., and believes it needs to be reworded as it is not entirely consistent with Requirement 3. M3 is event driven, while R3 is driven by PC assessment.
R12 – With respect to Table 1 of Requirement 12 of this draft, the frequency and minimum time delays of the standard should be evaluated for consistency with the proposed generator off-nominal frequency capability curves in NERC Standard PRC-006-1 “Development and Documentation of Regional UFLS Programs” Attachment 1 and draft NERC Standard PRC-024-1 “Generator Performance During Frequency and Voltage Excursions” Attachment 1.  The frequency and time values currently proposed by RFC would permit a generating unit’s underfrequency trip point to be set in compliance with RFC Standard PRC-006-RFC-1 but the setting would not be in compliance with NERC Standard PRC-024-1.  This inconsistency can only lead to future compliance confusion.
With respect to Requirement 12.1 of this draft we find it acceptable to require the Generator Owner, where technically feasible, to set their automatic underfrequency protection, and where not automatic, their underfrequency tripping procedures to conform to a Table 1 modified to be consistent with PRC-024-1 Attachment 1, as described above.  We also find it acceptable to require the Generator Owner to supply the data listed in Requirements 15 to the Planning Coordinator, Transmission Owner and/or Distribution Provider. 
AEP recognizes the need to coordinate the underfrequency tripping of generators with automatic underfrequency load shedding programs.  Furthermore, we recognize the need to evaluate the impact that the premature tripping of a generating unit may have on the Bulk Electric System during a frequency excursion and the potential need to install additional load shedding to compensate for the loss of such a generator.
However, we strongly feel that the requirement of the Generator Owner to arrange for load shedding to be installed should be removed from the standard.  We believe that the requirement of the Generator Owner to arrange for load shedding is inconsistent with the resolution between NERC Standard PRC-006-1 “Development and Documentation of Regional UFLS Programs” and draft NERC standard PRC-024-1 “Generator Performance During Frequency and Voltage Excursions.”  These standards only require that Generator Owners document relay settings or equipment limitations that prevent conformance to the off-nominal frequency curves of those standards and that Planning Coordinators develop and document underfrequency load shedding programs that account for generators whose trip characteristics do not conform to the off-nominal frequency curves of those standards.  Neither NERC standard requires the shedding of load by Generation Owners.
As written, the RFC standard does not contain any mechanism by which a Generator Owner can require a Transmission Owner or Distribution Provider to install load shedding on the Generator Owner’s behalf.  A Generator Owner who owns no transmission or distribution, may be forced into non-compliance with the standard if they cannot reach an agreement with a Transmission Owner or Distribution Owner to shed load.  The requirement (R12) causes one entity’s compliance to be dependent on the cooperation of another entity and such dependence has been problematic in certain instances where it has been proposed in other draft standards.
It is for the reasons documented above that AEP strongly believes that Requirement 12 and its associated measures and violation severity levels should be revised by removing the requirement for Generator Owners to arrange for load shedding.
Other - There should be a requirement in-between R16 and R17 for a peer review process to develop an implementation plan based on the results of the Planning Coordinator’s assessment.  Then the proposed R17 could be the requirement to implement the action plan.
Each Distribution Provider, Transmission Owner or Generator Owner for which UFLS or other protection system changes are recommended by the peer review and remediation process, (see newly proposed requirement above) shall complete the changes within three years of the completion of the finalization of the action plan to remediate deficiencies resulting from the Planning Coordinators assessment (as determined in Requirement R16)

Created at 9/7/2012 10:09 AM by System Account
Last modified at 9/7/2012 10:09 AM by System Account