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John Bee

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Exelon

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Dave Belanger
Alison MacKellar
John Gyrath
Sudhir Thakur
Eric Mortenson

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.

Other regions have remanded this standard until the NERC version has been completed.  We feel the standard is not necessary when a NERC standard exists and having the two standards will create confusion in the industry.

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.

This standard overlaps with the NERC version.  The SDT needs to identify what constitutes an island, and what criteria will be used to select an island.  Additionally, the mitigation criteria needs to be established based on probability of occurrence.  Also, the standard should specifically state that it does not contain a requirement to build facilities.

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.

This regional standard is not necessary for GOs due to the work that is being done under NERC Project 2007-09, PRC-024, "Generator Performance During Frequency and Voltage Excursions," and therefore suggest that the RFC UFLS Standard remove GOs from applicability section.
It is not clear that the criteria proposed in this standard are really more specific than the performance criteria proposed in the NERC Standard PRC-006,"Development and Documentation of Regional UFLS Programs," currently at the FERC.  The intent of the threshold for additional Regional Standards is to address a Regional issue.  There doesn’t appear to be a particular issue to the RFC Region that is different than the rest of the Eastern Interconnection.  Changing a setpoint value that already is an outcome of the performance criteria doesn’t necessarily provide additional specificity.
For a Region to have requirements that are not included in the continent-wide Standard is problematic, there should be some geographic or electric justification for such a difference, otherwise the Requirements should be incorporated into the continent-wide Standard.  Simply adding a Requirement that is not in the pending NERC Standard does not make the Regional Standard necessary.

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.

Most nuclear power plants will not meet the requirements for frequency due to NRC required protection for Reactor Coolant Pumps, Reactor Protection System Motor Generator sets, or Reactor Protection System Underfrequency protection.  A provision for exemption should be allowed based on equipment limitations similar to that permitted in the NERC Standard draft PRC-024.  Exelon requests that the RFC SDT communicate with the NRC and with the FERC to ensure a conflict of dual regulation is not imposed on a nuclear generating unit without the necessary evaluation.
The SDT needs to add requirements related to what the PC can require a DP, TO or GO to install.  We feel that the PC authority needs to be specifically outlined and identified regarding this requirement.

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.

for GOs there needs to be close integration with Standards being developed by NERC.  Similar to other Regions, RFC PRC-006-01 should be suspended until NERC Project 2007-09 and NERC Project 2007-01 are complete. 
SERC PRC-006-01 is currently on hold.
PRC-006-FRCC-01 is currently on hold in the FRCC Region with the status "pending the completion of the NERC Reliability Standard Development Project 2007-01 "Underfrequency Load Shedding."
PRC-006-MRO-01 is currently on hold in the MRO Region with the status "suspended."
PRC-006-TRE-01 is also currently on hold in the TRE Region with the status "following the progress of the NERC UFLS SDT."
Exelon suggests that the SDT also suspend progress on RFC PRC-006-01 and similarly follow the progress of NERC Projects 2007-09 and 2007-01.  At that time SERC should reevaluate if additional Regional guidance is necessary. 
Consideration should be given to ensure that Planning Coordinators not be given the ability to develop defacto NERC Requirements without due process.  For example; the Planning Coordinator will have the sole discretion to determine what an island is, determine needed remediation, and determine the UFLS scheme in general without a process for stakeholders to formally interact. 
As stated previously, Exelon does not see the need for Regional Standard when a NERC Standard will likely be approved by FERC.  
Given that FERC is expected to issue a NOPR on PRC-001-1, is a regional standard really needed or should the additional details be in some kind of guidance or procedural document?
 

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