Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications

Transcription

1 Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications Please use this form to submit comments on the proposed Reliability Guideline: Generating Unit Operations During Complete Loss of Communications. Comments must be submitted by January 29, You may submit the completed Microsoft Word form by to with the words Reliability Guideline: Generator Loss of Communication in the subject line. Only comments submitted in Microsoft Word format using this comment form will be accepted. Red-line document changes, PDF versions of this document, or comments will NOT be accepted. Comments may be submitted by individuals or groups. If the comments are from an individual, please provide the contact information for the submitter in Information Table 1, and provide the requested affiliation information in Information Table 2. If the comments are from a group, please provide the contact information for the leader of the group in Information Table 1, the requested affiliation information in Information Table 2, and a list of all group participants in Information Table 3. Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. If you have any questions on the subject information, please contact Larry Kezele at Larry.Kezele@nerc.net.

2 Name: Entity Name: Thomas Foltz American Electric Power Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information Select each NERC Region that you represent: ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA Not Applicable Information Table 2 Select each Industry Segment that you represent: 1 Transmission Owners 2 RTOs, ISOs 3 Load-serving Entities 4 Transmission-dependent Utilities 5 Electric Generators 6 Electricity Brokers, Aggregators, and Marketers 7 Large Electricity End Users 8 Small Electricity End Users 9 Federal, State, and Provincial Regulatory or other Government Entities 10 Regional Reliability Organizations and Regional Entities NA Not Applicable Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 2

3 Information Table 3 Group Comments (Complete this page if comments are from a group.) Group Name: Additional Member Name Additional Member Entity Name Region(s) Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

4 Enter All Comments in the tables below. Red-line Changes will not be accepted. Submit this form in Microsoft Word format only. There are two forms provided for your use to submit comments on this guideline. The first form is used to provide general comments on the guideline. These general comments should not reference a specific section or page in the guideline, but rather, should be overall comments on the guideline or concepts in the guideline, and may include repeating comments that are applicable to a number of sections. The second form is used to provide comments to specific sections of the guideline, such as spelling, punctuation or word usage comments, as well as to provide specific comments to concepts on the indicated page and line of the guideline. When performing the review, please use the clean version (not any redline versions) of the document in order to ensure consistently in provided comments from multiple commenters. Please provide sufficient information in your comments to allow the working group to understand the issue being commented upon, and provide suggested changes to the guideline that the working group may use to update the guideline. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 4

5 Instructions for general comments: Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the working group to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Comment Section: Purpose - Normal communication protocol is that the plant operator communicates primarily with Generator Operator (GOP) for operating instructions and status. The plant operator is not normally in direct communication with TOP, BA or RC. Loss of communication (voice and data) for emergency operation as prescribed in COM-002 R1 has historically been communication between GOP, BA, RC, and TOP. Section: Purpose - Comment: On-site generator operator and term Generator Operator are both used with the guidance document in referencing the entity. This is confusing as to whether the GO or GOP is actually being referenced. We believe the purpose and intent of this guidance document is clear, however this guideline should obviously support (i.e. not run counter to) existing NERC standards. Proposed Change Would recommend loss of communication recommendations be outlined for communication between GOP, TOP, BA, and RC. Separate recommendations could be provided for GO to GOP (in some regions also the QSE and MOC) or include GOP in the GO path of communication. Clearly define the generator operator that the guideline pertains to, i.e. refer to GO or GOP as plant operator and generator operator respectively. Ensure that the business functions provided in the guidance align with the business functions that are referenced within existing NERC requirements. Comment resolution adopted by the working/task group on each comment submitted Agree that the COM-002, R1 is for communications between the GOP, BA, TOP and RC. Understand that in some areas the GOP may not be located at the generator and may field calls for multiple units and the GOP would then communicate with the on-site generator operator. The intent of this Guideline is to provide the on-site generating unit operator, who has lost all voice and data communication and is observing turbine speed/frequency beginning to deviate, guidance as to how to respond. Added on-site generating unit(s) operator where Generator Operator appears to clarify both have actions within the guideline. Reviewed the Guideline in light of this comment and believe that the Generator Operator working with the applicable BA, TOP & RC to develop training, procedure provides the check and balances to keep business functions aligned with Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

6 Comment Guideline Details: It is stated that frequency is the only data point available to on-site generator operator. Eastern Interconnection Section: The turbine speed governor deadband is typically +/ for steam and is automatic function in the control. Further action by the plant operator may only occur if rate of recovery needs to deviate from control; the operator can take over in manual mode with generation output by adding or removing generation output. The governor is not normally operated in manual mode. Care should be taken in giving recommendations in a guide, where NERC standards require operating parameters and trip settings. The information provided in each interconnect should give the same message as to method of operation and discussion of trip zones verses operating zones. The Western Interconnect section discusses the trip zones while the other interconnects do not. Proposed Change Along with frequency, system voltage is an input to the local controls for maintaining both a stable BES system as well as generation equipment operation. This document may also need to acknowledge the usage of turbine speed as an alternative data point to frequency. Ensure that the guidance aligns with the parameters provided within existing NERC, security regions, TOP, and BA requirements. The 4 bullet guidance provided in the callout of Chart 1 is quite beneficial, and should be incorporated into the narrative of the guidance document. Ensure that the guidance aligns with the parameters provided within existing NERC requirements. Trip zones should be included in the interconnect guides to show operation is occurring in a no trip zone. Comment resolution adopted by the working/task group on each comment submitted existing NERC requirements This Guideline is intended to provide a strategy to keep frequency within allowable limits. Agree that frequency isn't the only system parameter available to the on-site generator unit(s) operators. Within the Purpose section of the Guideline it cautions the on-site generating unit(s) operators to take whatever action to protect their personnel and equipment. The Guideline also references within the Guideline Detail section that there may be other indications of a system disturbance. In addition, the Appendix on training provides a reference to the EPRI Power System Dynamics Tutorial which provides more specific detail power system dynamics. Also added turbine speed as a parameter to monitor. The bullets reference the color of the zones in the chart and would be out of place else where in the document. The first bullet is also covered in the Assumption Section of the document. Modified some sections of the Guideline to eliminate any potential conflicts with NERC Standard Requires such as PRC-024. Rather than provided more detail in this Guideline as requested, provided conceptual information as to not conflict with NERC Standard Requirements. The no trip zone is covered in NERC Reliability Standard PRC-024. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

7 Comment Does taking the corrective action(s) specified in the guidance document potentially put an entity at risk of violating any existing NERC standards, especially in the event of an over-reaction? Proposed Change Ensure that the guidance aligns with the parameters provided within existing NERC requirements. Comment resolution adopted by the working/task group on each comment submitted Working with the applicable BA, TOP and RC to develop the training, procedures and guides should avoid conflict with NERC requirements. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 7

8 Instructions for specific comments on the text of the document: Provide a page number and line number reference for each comment (page and line numbers are provided in the review version of the document). When referencing page and line numbers, refer to the clean version of the posted document. Please DO NOT refer to page and line numbers in redline versions of documents. Identify each comment as either E (editorial), i.e., spelling, punctuation, formatting; or, T (technical) i.e., content changes. Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the NERC Operating Committee to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Page Line Type of Comment (Editorial / Technical) Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 8

9 Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications Please use this form to submit comments on the proposed Reliability Guideline: Generating Unit Operations During Complete Loss of Communications. Comments must be submitted by January 29, You may submit the completed Microsoft Word form by to with the words Reliability Guideline: Generator Loss of Communication in the subject line. Only comments submitted in Microsoft Word format using this comment form will be accepted. Red-line document changes, PDF versions of this document, or comments will NOT be accepted. Comments may be submitted by individuals or groups. If the comments are from an individual, please provide the contact information for the submitter in Information Table 1, and provide the requested affiliation information in Information Table 2. If the comments are from a group, please provide the contact information for the leader of the group in Information Table 1, the requested affiliation information in Information Table 2, and a list of all group participants in Information Table 3. Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. If you have any questions on the subject information, please contact Larry Kezele at Larry.Kezele@nerc.net.

10 Name: Entity Name: Andrew Gallo Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information City of Austin dba Austin Energy andrew.gallo@austinenergy.com Select each NERC Region that you represent: ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA Not Applicable Information Table 2 Select each Industry Segment that you represent: 1 Transmission Owners 2 RTOs, ISOs 3 Load-serving Entities 4 Transmission-dependent Utilities 5 Electric Generators 6 Electricity Brokers, Aggregators, and Marketers 7 Large Electricity End Users 8 Small Electricity End Users 9 Federal, State, and Provincial Regulatory or other Government Entities 10 Regional Reliability Organizations and Regional Entities NA Not Applicable Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 2

11 Information Table 3 Group Comments (Complete this page if comments are from a group.) Group Name: Additional Member Name Additional Member Entity Name Region(s) Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

12 Enter All Comments in the tables below. Red-line Changes will not be accepted. Submit this form in Microsoft Word format only. There are two forms provided for your use to submit comments on this guideline. The first form is used to provide general comments on the guideline. These general comments should not reference a specific section or page in the guideline, but rather, should be overall comments on the guideline or concepts in the guideline, and may include repeating comments that are applicable to a number of sections. The second form is used to provide comments to specific sections of the guideline, such as spelling, punctuation or word usage comments, as well as to provide specific comments to concepts on the indicated page and line of the guideline. When performing the review, please use the clean version (not any redline versions) of the document in order to ensure consistently in provided comments from multiple commenters. Please provide sufficient information in your comments to allow the working group to understand the issue being commented upon, and provide suggested changes to the guideline that the working group may use to update the guideline. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 4

13 Instructions for general comments: Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the working group to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

14 Instructions for specific comments on the text of the document: Provide a page number and line number reference for each comment (page and line numbers are provided in the review version of the document). When referencing page and line numbers, refer to the clean version of the posted document. Please DO NOT refer to page and line numbers in redline versions of documents. Identify each comment as either E (editorial), i.e., spelling, punctuation, formatting; or, T (technical) i.e., content changes. Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the NERC Operating Committee to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Page Line Type of Comment (Editorial / Technical) Comment Technical AE would like clarification of the task Identify and test the most frequency responsive control modes of your generator(s) (emphasis added) Proposed Change No specific proposal for change, but a request for the Drafting Team to clarify what it means by most frequency responsive control modes of your generator. Comment resolution adopted by the working/task group on each comment submitted Modified the wording to clarify the statement to mean generator(s) governor. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

15 Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications Please use this form to submit comments on the proposed Reliability Guideline: Generating Unit Operations During Complete Loss of Communications. Comments must be submitted by January 29, You may submit the completed Microsoft Word form by to with the words Reliability Guideline: Generator Loss of Communication in the subject line. Only comments submitted in Microsoft Word format using this comment form will be accepted. Red-line document changes, PDF versions of this document, or comments will NOT be accepted. Comments may be submitted by individuals or groups. If the comments are from an individual, please provide the contact information for the submitter in Information Table 1, and provide the requested affiliation information in Information Table 2. If the comments are from a group, please provide the contact information for the leader of the group in Information Table 1, the requested affiliation information in Information Table 2, and a list of all group participants in Information Table 3. Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. If you have any questions on the subject information, please contact Larry Kezele at Larry.Kezele@nerc.net.

16 Name: Entity Name: Denton McGregor Black Hills Corporation Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information denton.mcgregor@blackhillscorp.com Select each NERC Region that you represent: ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA Not Applicable Information Table 2 Select each Industry Segment that you represent: 1 Transmission Owners 2 RTOs, ISOs 3 Load-serving Entities 4 Transmission-dependent Utilities 5 Electric Generators 6 Electricity Brokers, Aggregators, and Marketers 7 Large Electricity End Users 8 Small Electricity End Users 9 Federal, State, and Provincial Regulatory or other Government Entities 10 Regional Reliability Organizations and Regional Entities NA Not Applicable Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 2

17 Information Table 3 Group Comments (Complete this page if comments are from a group.) Group Name: Additional Member Name Additional Member Entity Name Region(s) Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

18 Enter All Comments in the tables below. Red-line Changes will not be accepted. Submit this form in Microsoft Word format only. There are two forms provided for your use to submit comments on this guideline. The first form is used to provide general comments on the guideline. These general comments should not reference a specific section or page in the guideline, but rather, should be overall comments on the guideline or concepts in the guideline, and may include repeating comments that are applicable to a number of sections. The second form is used to provide comments to specific sections of the guideline, such as spelling, punctuation or word usage comments, as well as to provide specific comments to concepts on the indicated page and line of the guideline. When performing the review, please use the clean version (not any redline versions) of the document in order to ensure consistently in provided comments from multiple commenters. Please provide sufficient information in your comments to allow the working group to understand the issue being commented upon, and provide suggested changes to the guideline that the working group may use to update the guideline. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 4

19 Instructions for general comments: Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the working group to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Comment I do realize this is in fact a guideline, however, I do not understand why we would want generator operators to adjust frequency when communication with all other parties is lost. If automatic governor response is not adequate, why would you want the Generator Operators to attempt to adjust frequency? If communications are completely lost I would prefer my units stand still so I can dispatch other units which I have communications with, or if my BA has communication with their units, they can respond. Having a process in place for units to begin moving their units could gravely impact the Reliability Coordinators ability to restore the interconnection following a major event. Also consider that units ramping up or down may begin inadvertently overloading transmission lines, if communications are down and processes are being followed, how do you combat the effects of the units when you can t communicate with them? I understand the spirit of this guideline may be to keep the interconnection alive if all communication is lost, but I feel that a unit response during a loss of communication will have a greater negative impact, than overall benefit. Proposed Change If anything we should have a guideline in place to have all units that have lost communication stay at their current level, so those with communications can make a valid plan and work towards restoring communications and the interconnection. Comment resolution adopted by the working/task group on each comment submitted The Guideline was developed in response to the NERC Severe Impact Resilience Task Force (SIRTF) Recommendations. The NERC Operating Committee modified this Guideline in response to similar concerns and added Generator Operators coordinate the development of procedures and training with input and concurrence from their applicable Balancing Authority, Transmission Operator and Reliability Coordinator to address these concerns. If due to transmission system limitations or a generator's ability to follow the recommendations within this Guideline these can be taken into account with this coordination. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

20 Instructions for specific comments on the text of the document: Provide a page number and line number reference for each comment (page and line numbers are provided in the review version of the document). When referencing page and line numbers, refer to the clean version of the posted document. Please DO NOT refer to page and line numbers in redline versions of documents. Identify each comment as either E (editorial), i.e., spelling, punctuation, formatting; or, T (technical) i.e., content changes. Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the NERC Operating Committee to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Page Line Type of Comment (Editorial / Technical) Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

21 Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications Please use this form to submit comments on the proposed Reliability Guideline: Generating Unit Operations During Complete Loss of Communications. Comments must be submitted by January 29, You may submit the completed Microsoft Word form by to with the words Reliability Guideline: Generator Loss of Communication in the subject line. Only comments submitted in Microsoft Word format using this comment form will be accepted. Red-line document changes, PDF versions of this document, or comments will NOT be accepted. Comments may be submitted by individuals or groups. If the comments are from an individual, please provide the contact information for the submitter in Information Table 1, and provide the requested affiliation information in Information Table 2. If the comments are from a group, please provide the contact information for the leader of the group in Information Table 1, the requested affiliation information in Information Table 2, and a list of all group participants in Information Table 3. Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. If you have any questions on the subject information, please contact Larry Kezele at Larry.Kezele@nerc.net.

22 Name: Entity Name: Kathleen Black DTE Electric Co. Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information blackk@dteenergy.com Select each NERC Region that you represent: ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA Not Applicable Information Table 2 Select each Industry Segment that you represent: 1 Transmission Owners 2 RTOs, ISOs 3 Load-serving Entities 4 Transmission-dependent Utilities 5 Electric Generators 6 Electricity Brokers, Aggregators, and Marketers 7 Large Electricity End Users 8 Small Electricity End Users 9 Federal, State, and Provincial Regulatory or other Government Entities 10 Regional Reliability Organizations and Regional Entities NA Not Applicable Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 2

23 Information Table 3 Group Comments (Complete this page if comments are from a group.) Group Name: Additional Member Name Additional Member Entity Name Region(s) Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

24 Enter All Comments in the tables below. Red-line Changes will not be accepted. Submit this form in Microsoft Word format only. There are two forms provided for your use to submit comments on this guideline. The first form is used to provide general comments on the guideline. These general comments should not reference a specific section or page in the guideline, but rather, should be overall comments on the guideline or concepts in the guideline, and may include repeating comments that are applicable to a number of sections. The second form is used to provide comments to specific sections of the guideline, such as spelling, punctuation or word usage comments, as well as to provide specific comments to concepts on the indicated page and line of the guideline. When performing the review, please use the clean version (not any redline versions) of the document in order to ensure consistently in provided comments from multiple commenters. Please provide sufficient information in your comments to allow the working group to understand the issue being commented upon, and provide suggested changes to the guideline that the working group may use to update the guideline. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 4

25 Instructions for general comments: Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the working group to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Comment A power plant operator is not trained to control frequency. Remove the wording of stabilizing system frequency. The operator should be instructed to maintain normal sync spend of generator which will provide the same result. The operator s primary goal is to protect the equipment which includes maintaining synchronous speed. Generator unit status- operators will not bring on additional equipment without knowing the system configuration. The operator will attempt to keep the existing generation on line only. Low Frequency Emergency Response may consist of loading all available hydro generation, followed by commitment of quick-start generation unit(s) (Primarily Proposed Change Maintain generator synchronous speed while communication channels are unavailable. Remove the wording indicating starting additional generation. The power plant operator is not a generation dispatcher. Without communication channels, the operator does not have the information available to make that decision. If a Combustion turbine is also a Black start resource, it should not be started for low frequency in case the system slides into a Black out the unit may now be unavailable. Comment resolution adopted by the working/task group on each comment submitted The NERC Operating Committee modified this Guideline adding the recommendation for Generator Operators to coordinate the development of procedures and training with input and concurrence from their applicable Balancing Authority, Transmission Operator and Reliability Coordinator to address these type of concerns. In addition, the Appendix provides some recommended training for generator operators. The modification to this Guideline for the Generator Operators to coordinate the development of procedures and training with input and concurrence from their applicable Balancing Authority, Transmission Operator and Reliability Coordinator to address these type of concerns. This should be address when the Generator Operators coordinates the developments the procedures with input and concurrence from Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

26 Comment combustion turbines) and, finally, under frequency load shedding. In general it may be a better solution to add several forms of alternative communications. Proposed Change Comment resolution adopted by the working/task group on each comment submitted their applicable Balancing Authority, Transmission Operator and Reliability Coordinator to address these type of concerns. The intent is to address loss of all communication regardless of how redundant the existing communication infrastructure. Instructions for specific comments on the text of the document: Provide a page number and line number reference for each comment (page and line numbers are provided in the review version of the document). When referencing page and line numbers, refer to the clean version of the posted document. Please DO NOT refer to page and line numbers in redline versions of documents. Identify each comment as either E (editorial), i.e., spelling, punctuation, formatting; or, T (technical) i.e., content changes. Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the NERC Operating Committee to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Page Line Type of Comment (Editorial / Technical) Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

27 Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications Please use this form to submit comments on the proposed Reliability Guideline: Generating Unit Operations During Complete Loss of Communications. Comments must be submitted by January 29, You may submit the completed Microsoft Word form by to with the words Reliability Guideline: Generator Loss of Communication in the subject line. Only comments submitted in Microsoft Word format using this comment form will be accepted. Red-line document changes, PDF versions of this document, or comments will NOT be accepted. Comments may be submitted by individuals or groups. If the comments are from an individual, please provide the contact information for the submitter in Information Table 1, and provide the requested affiliation information in Information Table 2. If the comments are from a group, please provide the contact information for the leader of the group in Information Table 1, the requested affiliation information in Information Table 2, and a list of all group participants in Information Table 3. Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. If you have any questions on the subject information, please contact Larry Kezele at Larry.Kezele@nerc.net.

28 Name: Entity Name: Michael Lowman Duke Energy Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information Michael.lowman@duke-energy.com Select each NERC Region that you represent: ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA Not Applicable Information Table 2 Select each Industry Segment that you represent: 1 Transmission Owners 2 RTOs, ISOs 3 Load-serving Entities 4 Transmission-dependent Utilities 5 Electric Generators 6 Electricity Brokers, Aggregators, and Marketers 7 Large Electricity End Users 8 Small Electricity End Users 9 Federal, State, and Provincial Regulatory or other Government Entities 10 Regional Reliability Organizations and Regional Entities NA Not Applicable Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 2

29 Information Table 3 Group Comments (Complete this page if comments are from a group.) Group Name: Duke Energy Additional Member Name Additional Member Entity Name Region(s) Paul Schmidt Duke Energy FRCC BA, TOP Tom Pruitt Duke Energy SERC BA, TOP Andy Ali Duke Energy FRCC BA, TOP Doug Hils Duke Energy RFC BA, TOP Dave McRae Duke Energy SERC BA, TOP Cherie Broadrick Duke Energy FRC BA, TOP Brett Koelsch Duke Energy SERC BA, TOP Scott Watts Duke Energy SERC BA, TOP Greg Stone Duke Energy SERC BA, TOP Don Steinmetz Duke Energy SERC, FRCC, RFC GO,GOP Kristen Kocon Duke Energy WECC, ERCOT GO,GOP Colby Bellville Duke Energy SERC Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

30 Enter All Comments in the tables below. Red-line Changes will not be accepted. Submit this form in Microsoft Word format only. There are two forms provided for your use to submit comments on this guideline. The first form is used to provide general comments on the guideline. These general comments should not reference a specific section or page in the guideline, but rather, should be overall comments on the guideline or concepts in the guideline, and may include repeating comments that are applicable to a number of sections. The second form is used to provide comments to specific sections of the guideline, such as spelling, punctuation or word usage comments, as well as to provide specific comments to concepts on the indicated page and line of the guideline. When performing the review, please use the clean version (not any redline versions) of the document in order to ensure consistently in provided comments from multiple commenters. Please provide sufficient information in your comments to allow the working group to understand the issue being commented upon, and provide suggested changes to the guideline that the working group may use to update the guideline. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 4

31 Instructions for general comments: Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the working group to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

32 Instructions for specific comments on the text of the document: Provide a page number and line number reference for each comment (page and line numbers are provided in the review version of the document). When referencing page and line numbers, refer to the clean version of the posted document. Please DO NOT refer to page and line numbers in redline versions of documents. Identify each comment as either E (editorial), i.e., spelling, punctuation, formatting; or, T (technical) i.e., content changes. Provide a description (or explanation) of your comments in the Comment column. Provide a proposed wording (or other) change in the proposed change column. The text in the proposed change column will be used by the NERC Operating Committee to update the document. The last column will be used by the working group during the comment resolution process, and should not be filled out on this comment form. *Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. Page Line Type of Comment (Editorial / Technical) Comment Editorial Add their and coordination into the sentence on lines Proposed Change The applicability of this document is to Balancing Authorities and Transmission Operators, in coordination with their RC, to provide guidance for the coordination and training of the onsite generating unit(s) operator should all communications be interrupted, particularly 31 during a severe impact event. Comment resolution adopted by the working/task group on each comment submitted Accepted edits 1 34 Editorial Remove local and replace with Replace with applicable as follows: Accepted edits Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

33 Page Line Type of Comment (Editorial / Technical) Comment applicable. The NERC term Local Balancing Authority (LBA) is used by the PJM RTO. Using local within the Reliability Guideline Document could cause confusion and misinterpretation. Proposed Change The applicable Balancing Authority, Transmission Operator or Reliability Coordinator may require a generator or 34 group of generators to deviate from the guidance provided in this Reliability Guideline due to their electrical 35 interconnection point to the Bulk Electric System. Comment resolution adopted by the working/task group on each comment submitted 1 37 Editorial Remove local and replace with applicable. The NERC term Local Balancing Authority (LBA) is used by the PJM RTO. Using local within the Reliability Guideline Document could cause confusion and misinterpretation Editorial Add the into the sentence. This is added for consistency throughout the Guideline document. 2 4 Editorial Add the into the sentence. This is added for consistency throughout the Guideline document. Replace with applicable as follows: The applicable Balancing Authority, Transmission Operator or Reliability Coordinator may require a generator or 34 group of generators to deviate from the guidance provided in this Reliability Guideline due to their electrical 35 interconnection point to the Bulk Electric System. the on-site generating unit(s) operator the on-site generating unit(s) operator Accepted edits Accepted edits Accepted edits Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 7

34 Page Line Type of Comment (Editorial / Technical) Comment 2 41 Editorial Add structured to the sentence on line 41. We believe that the word structured adds clarity to the intent of the Guideline that the GOP should have a structured approach to achieve frequency control. 3 1 Editorial Remove local and replace with applicable. The NERC term Local Balancing Authority (LBA) is used by the PJM RTO. Using local within the Reliability Guideline Document could cause confusion and misinterpretation. Proposed Change This guideline proposes a structured approach to achieve frequency control Replace with applicable as follows: The applicable Balancing Authority, Transmission Operator or Reliability Coordinator may require a generator or 34 group of generators to deviate from the guidance provided in this Reliability Guideline due to their electrical 35 interconnection point to the Bulk Electric System. Comment resolution adopted by the working/task group on each comment submitted Accepted edits Accepted edits 2& , 1-4 Editorial Rewrite paragraph for better flow of document. In order to maintain stable system operations with either an intact grid or as part of an island, it is necessary to maneuver generation output to match changes in system demand. Generator Operators should coordinate with their applicable Balancing Authority, Transmission Operator and Reliability Coordinator the development of procedures and Accepted edits Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 8

35 Page Line Type of Comment (Editorial / Technical) Comment Proposed Change training specific to each on-site generating unit operator for total loss of communication to incorporate any local actions that may deviate from the guidance provided in this document:. Without communications from the System Operator, this can only be done by the on-site generating unit(s) operator controlling to frequency. 40 This guideline proposes a structured approach to achieve frequency control for each of the following Interconnections. Comment resolution adopted by the working/task group on each comment submitted 4 15 Editorial Remove local and replace with applicable. The NERC term Local Balancing Authority (LBA) is used by the PJM RTO. Using local within the Reliability Guideline Document could cause confusion and misinterpretation Editorial Add the into the sentence. This is added for consistency throughout the Guideline Replace with applicable as follows: The applicable Balancing Authority, Transmission Operator or Reliability Coordinator may require a generator or 34 group of generators to deviate from the guidance provided in this Reliability Guideline due to their electrical 35 interconnection point to the Bulk Electric System. the on-site generating unit(s) operator Accepted edits Accepted edits Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 9

36 Page Line Type of Comment (Editorial / Technical) document. Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted 15 7 Editorial Remove local. The NERC term Local Balancing Authority (LBA) is used by the PJM RTO. Using local within the Reliability Guideline Document could cause confusion and misinterpretation Replace communication with communications. Since the title of the guideline is Complete Loss of Communications, this change maintains consistency within the Guideline Document. Replace with applicable as follows: The applicable Balancing Authority, Transmission Operator or Reliability Coordinator may require a generator or 34 group of generators to deviate from the guidance provided in this Reliability Guideline due to their electrical 35 interconnection point to the Bulk Electric System. Generator Operators may have a fleet of generators that crossover a 5 number of Balancing Authorities and Transmission Operators footprints. Generator Operators should coordinate with each applicable Balancing Authority and Transmission Operator and Reliability Coordinator to develop guidelines and training specific to each generating unit operator for total loss of communications. Accepted edits Accepted edits Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 10

37 Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications Please use this form to submit comments on the proposed Reliability Guideline: Generating Unit Operations During Complete Loss of Communications. Comments must be submitted by January 29, You may submit the completed Microsoft Word form by to with the words Reliability Guideline: Generator Loss of Communication in the subject line. Only comments submitted in Microsoft Word format using this comment form will be accepted. Red-line document changes, PDF versions of this document, or comments will NOT be accepted. Comments may be submitted by individuals or groups. If the comments are from an individual, please provide the contact information for the submitter in Information Table 1, and provide the requested affiliation information in Information Table 2. If the comments are from a group, please provide the contact information for the leader of the group in Information Table 1, the requested affiliation information in Information Table 2, and a list of all group participants in Information Table 3. Note: If you need to add a row to the table below please select Table from the above toolbar then Insert Row Above or Row Below. If you have any questions on the subject information, please contact Larry Kezele at Larry.Kezele@nerc.net.

38 Name: Entity Name: Craig Jones Idaho Power Company Telephone: (208) Information Table 1 Individual Commenter or Group Leader Contact Information Select each NERC Region that you represent: ERCOT FRCC MRO NPCC RFC SERC SPP WECC NA Not Applicable Information Table 2 Select each Industry Segment that you represent: 1 Transmission Owners 2 RTOs, ISOs 3 Load-serving Entities 4 Transmission-dependent Utilities 5 Electric Generators 6 Electricity Brokers, Aggregators, and Marketers 7 Large Electricity End Users 8 Small Electricity End Users 9 Federal, State, and Provincial Regulatory or other Government Entities 10 Regional Reliability Organizations and Regional Entities NA Not Applicable Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 2

39 Information Table 3 Group Comments (Complete this page if comments are from a group.) Group Name: Additional Member Name Additional Member Entity Name Region(s) Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

40 Enter All Comments in the tables below. Red-line Changes will not be accepted. Submit this form in Microsoft Word format only. There are two forms provided for your use to submit comments on this guideline. The first form is used to provide general comments on the guideline. These general comments should not reference a specific section or page in the guideline, but rather, should be overall comments on the guideline or concepts in the guideline, and may include repeating comments that are applicable to a number of sections. The second form is used to provide comments to specific sections of the guideline, such as spelling, punctuation or word usage comments, as well as to provide specific comments to concepts on the indicated page and line of the guideline. When performing the review, please use the clean version (not any redline versions) of the document in order to ensure consistently in provided comments from multiple commenters. Please provide sufficient information in your comments to allow the working group to understand the issue being commented upon, and provide suggested changes to the guideline that the working group may use to update the guideline. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 4