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: Operating Reserve Management. Comments must be submitted by February 28, 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: David Dockery Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information Associated Electric Cooperative Inc ddockery@aeci.org 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: Associated Electric Cooperative Inc - JRO00088 Additional Member Name Additional Member Entity Name Region(s) Central Electric Power Coop. SERC 1,3 Segment(s) KAMO Electric Cooperative SERC 1,3 M & A Electric Power Coop SERC 1,3 Northeast MO Elec. Pwr Coop SERC 1,3 N.W. Electric Pwr Coop Inc. SERC 1,3 Sho-Me Power Electric Coop SERC 1,3 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 Proposed Change Comment resolution adopted by the working/task group on each comment submitted Generator Operation in Red low-frequency regions Generator Operation in Red high-frequency regions For: Generator Operation in Red low-frequency regions Recommend: No operator action and let transmission system protective relaying handle per engineering design. Rationale: Gen Op is flying blind. BES is obviously in trouble. Best case, operator action could create or further deteriorate BES dynamic instability due to boiler-lag coupled with operators taking drastic control measures. Worst case, over-injection of MWs into a heavily damaged system could very likely overload BES lines, unnecessarily delaying system restoration and adding unnecessary cost to those transmission owners. Generation operator action to compensate VARs however could make sense but this drafting team should assure such a recommendation would be worded to guard against field excitation current being lowered too far so as to risk unnecessarily slipping poles and creating yet another serious system restoration issue and unnecessary Generator Owner cost. For: Generator Operation in Red high-frequency regions Recommend: 2x (or possibly up to 4x?) the Yellow-region Underfrequency protection is the last line of defense to protect the BES. All steps should be taken to include increasing generation and adding generation to prevent UFLS from operation. The generator speed is an important operating component related to a generator. This metric provides visibility of the frequency. The guideline encourages generators to make small steps in generation while monitoring the frequency trend or speed and adjust accordingly. In addition, the NERC RS has widened the Green operating range for the Eastern Interconnection to allow more time for the frequency to recover and provide greater confidence to the Generator Operator something uncharacteristic. The generator guideline advises the Generator Operator to take all actions to protect its generator. The guideline encourages generators to make small steps in generation while monitoring frequency trend or speed and adjust accordingly. Generators Operators are Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

6 Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted recommended operator action based upon drafting-team s feel for appropriate response that would likely avoid Operatorinduced frequency oscillations due to boiler-lags on very large thermal units. not requested to exceed their operating limits. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

7 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 7

8 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: Operating Reserve Management. Comments must be submitted by February 28, 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.

9 Name: Entity Name: Andrea Jessup Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information Bonneville Power Administration BPA TxRP Standards Coordination <TxRPStandardsCoordination@bpa.gov> Select each NERC Region that you represent: ERCOT FRCC MRO NPCC RFC SERC SPP X WECC NA Not Applicable X 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

10 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

11 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

12 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 Bonneville Power Administration supports the Reliability Guideline: Generating Unit Operations During Complete Loss of Communications and thanks the drafting team for creating a thorough guideline. We have no proposed changes; therefore, no Comment Form is attached. Proposed Change Comment resolution adopted by the working/task group on each comment submitted The NERC Resource Subcommittee thanks you for your comment. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

13 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

14 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: Operating Reserve Management. Comments must be submitted by February 28, 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.

15 Name: Entity Name: Randi Heise Dominion 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 3

16 Information Table 3 Group Comments (Complete this page if comments are from a group.) Group Name: Dominion Additional Member Name Additional Member Entity Name Region(s) Connie Lowe RFC 5, 6 Louis Slade SERC 5, 6 Segment(s) Mike Garton NPCC 5, 6 Michael Crowley SERC 1, 3 Randi Heise MRO 6 Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 4

17 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 5

18 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 Dominion Dominion is concerned about the potential liability that may result in synchronizing units when the GO/GOP has no knowledge of the status or conditions on the transmission side of the breaker. Dominion is concerned of the impact to the frequency of system resulting from GO/GOP starting their units without the knowledge of how many additional units are operational or in the process of starting. In order to mitigate this concern, the guideline encourages BA s/ TOP to conduct training outlined in the Appendix with its Generator Operators. The guideline considers this and requests generators to take initial small steps to determine the impact of the additional generation and to continually monitor. Dominion s internal operating policy requires the generator to receive a switching order from the Transmission Owner (TO) prior to synchronizing This policy is not unique and most likely consistent with all generators and there Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

19 Comment the generating unit. Without communication between the TO and the GO/GOP, the switching order is not received by the GO.GOP and the generating unit is unable to begin synchronization without violation of Dominion s operational policy. Proposed Change Comment resolution adopted by the working/task group on each comment submitted TO/TOP. In the absence of all communications coupled with extreme deviations of frequency, the generator guideline encourages Generator Operators to consider adding or reducing the generator output as the final measures to protect the BES. However, the guideline reminds that safety of the personnel and equipment has precedence at all time. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 7

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 Editorial Dominion notes that the given assumption, loss of communication between the System Operator for the Balancing Area, Transmission Operator and Reliability Coordinator, would prevent the knowledge of the status of the system s stability outside of an event. Without the ability to understand the status of the neighboring system, the impact of The guideline considers this and requests generators to take initial small steps to determine the impact of the additional generation and to continually monitor. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 8

21 Page Line Type of Comment (Editorial / Technical) Comment any action upon the frequency or stability of the system is unknown and potentially devastating. Proposed Change Comment resolution adopted by the working/task group on each comment submitted 3 27 Technical Dominion notes for consideration that Low Frequency- quick start units may not have a system operator on site for a period of 24/7 and may require a site visit to start thus limiting the impact of quick starting generation Technical Dominion supports the staggering of hydro generation so that frequency set-points are met for the stabilization of hydro generation. 5 9 Technical Dominion does not believe that the recommendation to calibrate plant frequency equipment on an annual basis is warranted. We propose a 6 year period which coincides with many of the tables in PRC The NERC Resource Subcommittee agrees that lack of on-site generators operators would limit the ability of those resources to be available. The Guideline is referencing the actions to be taken to quick start resources that are staffed. The guideline advises the Generator Operator to take steps to protect its unit and not exceed the operating characteristics of the generator. The guideline is intended to provide a recommended practice not a minimum per a NERC Standard. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 9

22 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: Operating Reserve Management. Comments must be submitted by February 28, 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.

23 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

24 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) Mitzi Archambo Duke Energy SERC GO, GOP Mark Thiemann Duke Energy SERC GO, GOP Colby Bellville Duke Energy SERC Iris Sandidge Duke Energy SPP, TRE, WECC GO,GOP Sam Holeman Duke Energy SERC BA, TOP Greg Stone Duke Energy SERC BA, TOP Brett Koelsch Duke Energy SERC BA, TOP Paul Schmidt Duke Energy FRCC BA, TOP Glen Dooley Duke Energy FRCC BA, TOP Doug Hils Duke Energy RFC BA, TOP Greg Cecil Duke Energy RFC GOP John Swez Duke Energy SERC GOP Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

25 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

26 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 Selective Response is not a NERC defined term Full Response is not a NERC defined term. Emergency Response is not a NERC defined term. Reword quick start generating units for added clarity Other than where this definition is introduced, use selective response throughout the document. Other than where this definition is introduced, use full response throughout the document. Other than where this definition is introduced, use emergency response throughout the document. of quick start generating resources The NERC Resource Subcommittee thanks you for your comment. Changes made. The NERC Resource Subcommittee thanks you for your comment. Changes made. The NERC Resource Subcommittee thanks you for your comment. Changes made. The NERC Resource Subcommittee thanks you for your comment. Changes made. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

27 Comment Proposed Change Comment resolution adopted by the working/task group on each comment submitted Operation is not a NERC defined term. Such operation should be The NERC Resource Subcommittee thanks you for your comment. Changes made. Suggest adding a note in the Assumptions section or a sentence in the Purpose section that addresses how to use this guide in conjunction with internal processes, procedures, or guidelines already developed by the Registered Entity. This guideline is not intended to supersede processes, procedures or guidelines that have already been developed, but to aid in the development or modification of those documents. The NERC Resource Subcommittee thanks you for your comment. Sentence added. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

28 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 7

29 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: Operating Reserve Management. Comments must be submitted by February 28, 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.

30 Name: Entity Name: Cheryl Moseley ERCOT Telephone: (512) 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

31 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

32 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

33 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 The Reliability Guideline: Generating Unit Operations During Complete Loss of Communications could create confusion or conflict where regional policies, regulations, or guidance exists. Therefore, ERCOT requests that the working group consider deleting the guidance for the ERCOT Interconnection. Alternatively, ERCOT requests that the working group consider adding a disclaimer to direct Generator Operators or other users of this guide to the regional policies where additional clarifications or requirements may exist. Delete page 6-8 or insert the following disclaimer: In the event of a conflict between this guideline and the ERCOT governing documents, then the ERCOT governing documents will control. The recommended disclaimer was added. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

34 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

35 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: Operating Reserve Management. Comments must be submitted by February 28, 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.

36 Name: Entity Name: Gregory Campoli Telephone: Information Table 1 Individual Commenter or Group Leader Contact Information IRC Standards Review Committee gcampoli@nyiso.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

37 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) Ben Li IESO NPCC RTOs, ISOs Charles Yeung SPP SPP RTOs, ISOs Cheryl Moseley ERCOT TRE RTOs, ISOs Ali Miremadi CAISO WECC RTOs, ISOs Segment(s) Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 3

38 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

39 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 The SRC believes that allowing generators to respond with existing controls (governors) to respond to frequency and to allow underfrequency relays to respond to protect individual units is a more globally accepted solution. Proposed Change The SRC would propose that the guideline simply direct generators to maintain status at the time communications was lost. As frequency deviations are observed allow existing controls to manage frequency and if necessary remove the generator from the system to protect the unit. This may in turn protect other elements on the system. Comment resolution adopted by the working/task group on each comment submitted Primary Frequency Response is performed by a functioning governor on generators arresting the event typically in duration of less than a minute. Secondary frequency response is an increase/ or decrease in generation after primary frequency response typically provided by AGC in the form of frequency bias in the ACE equation and by the recovering BA. In the absence of any and all communications occurring at the same time large imbalance of load or generation, this secondary response can only come from manual action taken by a Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 5

40 Comment There are concerns that, without knowing the full extent of the outage, multiple generators that have lost communication and are now chasing frequency could cause thermal overloads and high frequency issues. If a generator lost communications, how would a generator know if they were alone or with a group of generators? There are coordination issues that need to be further considered. If an island occurred with a group of generators, the generators that continue to have communication will be responding to frequency changes as directed by their TOP/BA in addition to the TOP/BA requesting the start up or shut down of generators to manage the frequency changes. A single or group of generators that have lost communication, responding based on the guideline could exacerbate the situation. Proposed Change In cases where this would be an acceptable solution. Regions or areas could adopt similar guidelines on a more local basis. Comment resolution adopted by the working/task group on each comment submitted Generator Operator. The guideline encourages training between BA, TO, RC and GO s. The guideline encourages generator operators to make small steps in changes of generators to realize whether they are part of small or larger interconnection. If communications exist between BA/ TOP/ RC and GO, this guideline does not apply. In the event of only certain GO s absent of communication with its BA/TOP/RC it is highly unlikely that frequency deviate outside of the level of requested response from the guideline. Official Comment Form Reliability Guideline: Generating Unit Operations During Complete Loss of Communications 6

41 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 7

42 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: Operating Reserve Management. Comments must be submitted by February 28, 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.

43 Name: Entity Name: Nazra Gladu Manitoba Hydro 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