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John Seelke

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PSEG Services Corporation

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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?

Yes

1) If not, please provide specific suggestions.

Yes, we agree that restricting the UFLS program parameters to ranges that are consistent with the RFC Legacy Region programs is an acceptable approach.  In addition, review of the three (3) RFC Legacy Region programs (ECAR, MAIN & MAAC) shows that this has been achieved and reflected in this draft.

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 current wording of the draft standard is may be consistent with current RFC practices; however the standard lacks the requirement for coordination between PCs who have a part of one PC’s island within another PC’s area (R5 in NERC PRC-006-1, even though the island spans Regions.  In addition, will PCs that span multiple regions (i.e., MISO & PJM) only have this RFC standard apply to load in the RFC region?  That seems very inefficient. 

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.

The requirements outlined in the first bullet under R8 are consistent with requirements currently in place and we find no issues or concerns with the current draft requirements.  Further, the draft requirements as they relate to the Generator Owners role in the UFLS program are consistent with the current draft of NERC PRC-024-1. 
The second bullet (no automatic underfrequency protection) in R8 is unclear – it states that “the Generatror (sic) Owner shall establish and follow procedures for underfrequency operation in accordance with PRC-006-RFC-01 Attachment 1.”   There is no reference to “procedures” in Attachment 1.  If the language is intended to have the GO develop procedures that meet (or exceed) the performance required on the curve in Attachment 1, it should be rewritten to state that
 
The requirements outlined in R8, bullets 2 & 3 raise significant concerns.  The current draft of PRC-006-RFC-01 R8, bullet 2 states that “[w]here a generator does not have automatic underfrequency protection installed … the Generator Owner shall establish and follow procedures for underfrequency operations in accordance with PRC-006-RFC-01 Attachment 1.”  Under the current practice, generators that do not have automatic underfrequency protection are operated such that they remain in-service during a frequency excursion with the expectation that the affected Transmission Owner and/or Distribution Provider will arrest the frequency event.  Requiring the Generator Owner to establish a procedure for such generating units would not benefit or increase the reliability of the Bulk Electric System. The current draft of PRC-006-RFC-01 R8, bullet 3 states that “[w]here a generator cannot meet the specifications in PRC-006-RFC-01 Attachment 1, the Generator Owner shall arrange for Load shedding, to be installed by mutual agreement with Distribution Providers….” We believe this is impractical.  Instead, we believe that the approach in NERC’s PRC-006-1(R4) is better, where by generators that trip above the curve are modeled by the PC, and to the extent that additional UFLS results, UFLS entities (TOs and DPs) are required to acquire that loads shedding per their implementation of  the PC’s UFLS program (R3).
 
Comment for R9 and R10
The current wording of the draft standard is consistent with current practices and is acceptable.  It is also agreed that this requirement should be removed once the NERC PRC-024-1 standard is completed and approved by FERC.
 

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?

Yes

4) If not, please provide specific suggestions.

The current wording of the draft standard is consistent with current practices and is acceptable. 

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.

Due to the significant issues raised in the response to items 2 and 3 and the comments listed under item 6, we DO NOT agree that the standard is ready for Category Ballot.
 
• In R1.1, the term “Peak Demand” is used.  This term is not defined by RFC nor NERC.  It is recommended that this term either be defined by RFC and/or NERC, or have the utilize the word in lower case format with a footnote describing the intended definition.
• The VSL for R4 has a significant error in the wording.  It is believed that the intent of the SDT was to use the term “calendar day” as opposed to “business day”.  As it reads now, there are overlaps between the durations between violation levels.
• Attachment 1 should have a note added that a generator’s underfrequency performance need not fall precisely on the curve, and that as long as the generator’s response is on or below the curve it has acceptable underfrequency performance.
• The drafting team should note that the operation of nuclear plants is subject to NRC and license requirements, and that if this standard requires a change in a nuclear plant’s performance, such changes may require NRC approval.  That should be addressed.

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