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Andy Pusztai

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ATC

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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?

No

1) If not, please provide specific suggestions.

Please see responses to the questions in the survey.  In addition, below is our response to question 1:
1.  R1 and R2 add specificity to the NERC PRC-006-1 standard by limiting the Planning Coordinator’s UFLS Program to prescribed parameter ranges in order to promote consistency with the three Legacy Region UFLS programs.  Do you agree with the concept of restricting UFLS program parameters to ranges that are consistent with the RFC Legacy Region programs?  If not, please provide specific suggestions.
No, ATC does not agree with the concept of restricting UFLS program parameters to ranges that are consistent with the RFC Legacy Region programs. The NERC PRC-006-1 standard has sufficient specificity, permitting the Planning Coordinator to design and implement UFLS programs that maintain reliability. PRC-006-1 is an improvement over the legacy region programs and may require UFLS program parameters beyond the legacy values. In addition, some experience should be gained with the compliance to the PRC-006-1 standard to be able to assess whether the flexibility afforded by the NERC is more appropriate than the more prescriptive R1 and R2 requirements proposed in PRC-006-RFC-1 standard.

2) R3 through R7 add specificity and scope to the NERC PRC-006-1 standard requirements pertaining to identification and mitigation of islands as noted below.   


a. The Planning Coordinator needs to include additional items in their island identification criteria (R3).


b. The Planning Coordinator shall supply their island identification criteria (R4) and respond (R5) to any comments received on the island identification criteria from affected entities.


c. The Planning Coordinator shall identify and document islands by: applying the island identification criteria at least every 60 months (R6), supplying the results of applying the island identification criteria to affected entities (R6, Part 6.1), inviting, in writing, the participation of applicable entities, in the establishment of the mitigation plan (R6, Part 6.2) and establishing a mitigation plan to balance generation and Load and restore frequency in each area of islanding should the area of islanding become separated from the interconnection (R6, Part 6.3).


d. .Affected Distribution Providers, Transmission Owners and Generator Owners shall implement their portion of any mitigation plan (for the island(s)) as determined by the Planning Coordinator (R7).


Do you agree with the added specificity and scope pertaining to how islands are identified and addressed?

No

2) If not, please provide specific suggestions.

The Planning Coordinator needs to include additional items in their island identification criteria (R3).
No, ATC does not agree with the proposed language of R3. Some experience should be gained with island identification criteria under PRC-006-1 to be able to assess whether the more prescriptive R3 requirements are needed and appropriate. Additionally, the proposed language is ambiguous and, therefore, does not improve upon PRC-006-1 (e.g., there is insufficient direction given as to what constitutes an “island” consisting of 1000 MW since large systems can be broken into contiguous 1,000 MW lumps in hundreds of ways).
b. The Planning Coordinator shall supply their island identification criteria (R4) and respond (R5) to any comments received on the island identification criteria from affected entities.
R4 is a reasonable recommendation to ensure UFLS entities understand how the Planning Coordinator is identifying islands in accordance with PRC-006-1.
The proposed language for R5 refers to “a request for clarification” according to R4. R4 does not specify any requirements on the DP, TO or GO for making a request for clarification. Rather, R4 solely governs the timeframe for the PC to supply the island identification criteria. Therefore, the language stating “in accordance with Requirement R4” does not add clarity. Additionally, for Planning Coordinators spanning multiple UFLS entities, a 45 calendar day response requirement and the need to maintain auditable records for each request could be a significant burden since PRC-006-1 creates new requirements for PCs and island identification criteria will still need to be developed. It would be better to observe how the PCs implement the requirements of PRC-006-1 before moving ahead with a regional standard that prescribes these requirements.
c. The Planning Coordinator shall identify and document islands by: applying the island identification criteria at least every 60 months (R6), supplying the results of applying the island identification criteria to affected entities (R6, Part 6.1), inviting, in writing, the participation of applicable entities, in the establishment of the mitigation plan (R6, Part 6.2) and establishing a mitigation plan to balance generation and Load and restore frequency in each area of islanding should the area of islanding become separated from the interconnection (R6, Part 6.3).
No. It is not known what mitigation measures the standards drafting team has in mind and whether presently unknown mitigation measures can be identified, developed, approved, and implemented within 6 months. Therefore, no implementation time frame should be placed in the standard until there is more clarity and experience with the actual time it takes to establish a reasonable number and range of types of mitigation measures.
It is also unclear what the basis the standards drafting team assumes would be used to determine what the range of imbalance of Load and generation would be for the area of islanding. We would expect the imbalance basis to be the Load, generation and power transfer conditions (generation dispatch and firm transfers) of Year One Peak Demand base cases drawn from the applicable MMWG series base cases.
d. Affected Distribution Providers, Transmission Owners and Generator Owners shall implement their portion of any mitigation plan (for the island(s)) as determined by the Planning Coordinator (R7).
Yes except PRC-006-1 already contains this requirement (NERC PRC-006-1 R3 and R9). Additionally, the language should not specify a required timeframe for completion of the mitigation plan by these entities. The same requirements of PRC-006-1 gives the PCs the ability to establish the schedule for making corrections. This flexibility should be retained such that the PC, for example, can require an earlier date if the PC determines that this is appropriate and reasonable.

3) R8 and R9 extend the scope of the NERC PRC-006-1 standard to apply to Generator Owners’ underfrequency trip characteristics in planning UFLS programs as noted below. 

  
a. The premature tripping of a generating unit may have a very negative effect on the Bulk Electric System during a frequency excursion, and thus it is important to include a Generator Owner requirement within a standard dealing with UFLS. Generator Owners are required to either: 1) Set underfrequency protection in accordance with PRC-006-RFC-01 Attachment 1 (Time vs. Frequency curve) for generators that have automatic underfrequency protection installed, 2) establish and follow procedures for underfrequency operation in accordance with PRC-006-RFC-01 Attachment 1, for generators that do not have automatic underfrequency protection installed, or 3) arrange for Load shedding to be installed by mutual agreement with Distribution Providers, in addition to that required by the Planning Coordinator in Requirement R1 or Requirement R2, for generators that cannot meet the specifications in PRC-006-RFC-01 Attachment 1. (R8) (Note: the Time vs. Frequency curve in Attachment 1 is consistent with the curves in the NERC PRC-006-1 and draft PRC-024-1 standards (R11)).


b. Generator Owners (which are required to comply with R8) are required to supply underfrequency trip setting data to populate the Planning Coordinator’s UFLS data base (R9).  It is important for the Planning Coordinators to have such generator data in order to perform an accurate UFLS assessment (R10).  (This requirement may be removed once the NERC PRC-024-1 standard is completed and approved.)


Do you agree with the extended scope to include Generator Owners?

No

3) If not, please provide specific suggestions.

a. The premature tripping of a generating unit may have a very negative effect on the Bulk Electric System during a frequency excursion, and thus it is important to include a Generator Owner requirement within a standard dealing with UFLS. Generator Owners are required to either: 1) Set underfrequency protection in accordance with PRC-006-RFC-01 Attachment 1 (Time vs. Frequency curve) for generators that have automatic underfrequency protection installed, 2) establish and follow procedures for underfrequency operation in accordance with PRC-006-RFC-01 Attachment 1, for generators that do not have automatic underfrequency protection installed, or 3) arrange for Load shedding to be installed by mutual agreement with Distribution Providers, in addition to that required by the Planning Coordinator in Requirement R1 or Requirement R2, for generators that cannot meet the specifications in PRC-006-RFC-01 Attachment 1. (R8) (Note: the Time vs. Frequency curve in Attachment 1 is consistent with the curves in the NERC PRC-006-1 and draft PRC-024-1 standards (R11)).
ATC agrees that premature tripping of a generating unit can have a negative impact on frequency recovery. However, compensatory load tripping should only be established when it is needed to meet UFLS program requirements for the island as determined by the PC in lieu of changes by the GO. If compensatory load tripping is needed, the Planning Coordinator should determine the amount of compensatory load shedding as well as the location that would meet the performance requirements.
b. Generator Owners (which are required to comply with R8) are required to supply underfrequency trip setting data to populate the Planning Coordinator’s UFLS data base (R9).  It is important for the Planning Coordinators to have such generator data in order to perform an accurate UFLS assessment (R10).  (This requirement may be removed once the NERC PRC-024-1 standard is completed and approved.)
Yes, this would be an improvement to PRC-006-1.

4) R10 and R11 extend the scope of NERC PRC-006-1 standard by including requirements to assess UFLS program implementation (in addition to UFLS program design required in the NERC PRC-006-1 standard) as noted below. 

  
a. The Planning Coordinator is to perform, document and make available an assessment of the effectiveness of the “implementation” of the UFLS programs.  The NERC PRC-006-1 standard only requires an assessment of the “design” of the UFLS programs.  This assessment will assess the effectiveness of the implemented UFLS programs using the information contained in the Planning Coordinator’s database which, while satisfying the design requirements, may exceed the design specifications (R10).


b. Applicable Distribution Providers, Transmission Owners and Generator Owners are to complete any required changes to the implementation of the UFLS program based on any implementation deficiencies noted in the Planning Coordinator’s assessment.  The NERC PRC-006-1 standard only requires the applicable entities to provide automatic tripping of Load in accordance with the UFLS program design and does not account for any changes which may be found necessary based on the Planning Coordinator’s assessment of implementation.  Such changes may be necessary for the overall effectiveness of the UFLS program when arresting frequency excursions.  The three calendar year completion interval was chosen to give applicable entities a reasonable amount of time for making changes in the field (R11).


Do you agree with the need to assess UFLS program implementation as well as design?

No

4) If not, please provide specific suggestions.

a.  The Planning Coordinator is to perform, document and make available an assessment of the effectiveness of the “implementation” of the UFLS programs.  The NERC PRC-006-1 standard only requires an assessment of the “design” of the UFLS programs.  This assessment will assess the effectiveness of the implemented UFLS programs using the information contained in the Planning Coordinator’s database which, while satisfying the design requirements, may exceed the design specifications (R10).
No. It is not known what distinction the standards drafting team is making between the UFLS program “design” and “implementation”. This requirement is okay if the difference is understood to be that “design” refers to the load shedding that the Planning Coordinator determined was needed for acceptable UFLS program performance and required to be implemented (R11) and “implementation” refers to what the Distribution Provider, Transmission Owner, or Generation Owner reported was actually implemented (R7), which may be a little more than what was required.
b.  Applicable Distribution Providers, Transmission Owners and Generator Owners are to complete any required changes to the implementation of the UFLS program based on any implementation deficiencies noted in the Planning Coordinator’s assessment.  The NERC PRC-006-1 standard only requires the applicable entities to provide automatic tripping of Load in accordance with the UFLS program design and does not account for any changes which may be found necessary based on the Planning Coordinator’s assessment of implementation.  Such changes may be necessary for the overall effectiveness of the UFLS program when arresting frequency excursions.  The three calendar year completion interval was chosen to give applicable entities a reasonable amount of time for making changes in the field (R11).
Yes

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

No

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

No. Although we recognize the Draft 7 is a significant improvement over Draft 6, ATC recommends that the RFC defer establishing a RPC-006-RFC-1 standard until the industry gains enough experience with the PRC-006-1 standard to determine the limitations of that standard. In addition, we do not believe that the standard is ready for Category Ballot until the comments that we provided are adequately addressed.

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