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Howard Rulf

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We Energies

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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.

 

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.

With the current wording of Requirement R7, the Generator Owner (GO) may be required to implement underfrequency settings on generating units that could violate the manufacturers stated unit capability.  There needs to be an exclusion or “off-ramp” for the GO such that the GO shall not be required to implement any aspects of a mitigation plan which would violate equipment capability as documented in manufacturers operations and maintenance instructions, manuals, or other data

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 Attachment 1 frequency-time curve should include the equation which determines the allowable frequency between 2 seconds and 1800 seconds.  In addition, the word “Generator” should be inserted before the text “No Trip Zone” in the text box on the frequency-time curve. 
For some generation sites (such as windfarms) where automatic UF tripping is not installed, it may not be practical to have and implement a UF procedure.  At these sites, the GO may elect to install automatic UF protection in lieu of creating and implementing a UF procedure.  In the cases where the GO elects to install automatic UF tripping, there should be an implementation schedule allowing 48 months from the time that the standard is in effect for the GO to budget, plan, and install appropriate equipment.

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.

Similar to our comments regarding Requirement R7, in Requirement R11 there needs to be an exception for the GO such that the GO shall not be required to implement any aspects of a mitigation plan or changes to a UFLS program resulting from the assessment in Requirement R10 which would violate equipment capability as documented in manufacturers operations and maintenance instructions, manuals, or other data.

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.

Measures M7-M11 may need wording adjustments to align with the changes we propose for Requirements R7, R8, and R11.

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