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Louis Slade

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Dominion

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Michael Gildea
Lou Oberski
Mike Garton
Chip Humphrey
Connie Lowe

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?

Abstain

1) If not, please provide specific suggestions.

Dominion has no comment

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.

Dominion is opposed to the establishment of a definitive time to implement the mitigation plan as it does not know what the plan might entail (R7).
Dominion could support if the requirement read ‘…….Each Distribution Provider, Transmission Owner and Generator Owner shall implement its portion of any mitigation plan developed in accordance with Requirement R6 within 36 months of the date that the mitigation plan was established, or as mutually agreed upon by the entity and the Planning Coordinator.
 

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.

Dominion continues to oppose the requirement to procure load shed service for the reasons we have stated previously ( 3rd bullet in R8). As we have stated in previous comments on this regional standard, we do not agree, because it still requires a Generator Owner to procure a service (load shed) for which we have found no willing provider. It is Dominion’s position therefore that this portion of the proposed requirement (3rd bullet in R8) is not feasible, given no entity will provide the service the Generator is obligated to procure, which  essentially guarantees that a Generator Owner of a non-conforming generator will not be able to comply with this requirement.
The SDT stated that “This practice of procuring additional load shedding is also consistent with a number of Legacy RFC UFLS programs.”
Dominion has been unable to substantiate the SDT’s response that procuring additional load shedding is also consistent with a number of Legacy RFC UFLS programs. Our review of the RFC website indicates that the legacy ECAR UFLS documents (12 and 12A) were retired on 3-6-2008. And our review of the MAAC document did not contain an explicit obligation related to the provision of load shed service. We did note however this paragraph ““It must be recognized that generating units may also trip during underfrequency conditions due to loss of plant auxiliary equipment. For example, underfrequency relays are often used at nuclear plants on electrical systems that are used to monitor or supply critical reactor systems. These set points must be considered when evaluating the performance of the underfrequency load shedding program. The amount of load to be shed at each step of the load shedding program should take into account any known generator MW that will trip at that frequency level or higher due to underfrequency relay protection or loss of auxiliary equipment.”

Also, very importantly, Dominion believes that the addition of this requirement will reduce reliability in order to provide the ‘fairness’ the SDT desires.  For example, if the service is to be provided only when the non-conforming generator actually trips due to a frequency event, then the non-conforming generator would have to contact the seller and the seller would have to shed equivalent load (all within the 0-2 second time allowance contained in this proposed standard. Dominion does not believe deployment of the service can be done this quickly, and therefore the adverse impact to reliability will be greater than if the non-conforming generator was included in the UFLS plan.
 Equally concerning, if the service is to be provided whenever the frequency reaches the set point of the non-conforming generator (regardless of the output of the generator, including 0, if off line at onset of event), Dominion believes that deployment (if not equal to the output of the non-conforming generator at onset of the event) could result in over recovery of frequency and therefore the adverse impact to reliability.  Again, this result could be more detrimental to reliability than if the non-conforming generator was included in the UFLS plan.
 
Dominion believes that, for all of the reasons cited above, the proposed NERC standard, which recognizes that there are generators which can’t conform to the UFLS set points (and requires that this be taken into consideration in developing the UFLS plan) is superior to the RFC proposed standard.

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.

 Dominion is opposed to establishment of a definitive time to complete required changes as it does not know what the changes might entail (R11). Dominion could support if the requirement read ‘…..Each Distribution Provider, Transmission Owner and/or Generator Owner shall complete the required changes to the implementation of the UFLS program, if any, within three calendar years of the date that the Planning Coordinator made the assessment of implementation available, or as mutually agreed upon by the entity and the Planning Coordinator.

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.

Dominion cannot support until the changes proposed to requirements 7, 8 and 11 are incorporated. 
Dominion also understands that RFC intends to address concerns with the effective date of RFC regional standards at its upcoming Board meeting, but notes that this change does not appear to be reflected in this proposed regional standard. Dominion remains opposed to an effective date that is not based upon FERC approval.

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