Consideration of Comments on FRCC Standard for Regional Generator Performance During Frequency and Voltage Excursions (FRCC-S-PRC-024) Version 2

Similar documents
Comment form for FRCC Standard for Regional Generator Performance During Frequency and Voltage Excursions (FRCC-S-PRC-024) version 3

Standard Development Timeline

PRC Coordination of Protection Systems for Performance During Faults

Standard Development Timeline

4.1.1 Generator Owner Transmission Owner that owns synchronous condenser(s)

4.1.1 Generator Owner Transmission Owner that owns synchronous condenser(s)

Project Protection System Misoperations

Unofficial Comment Form Project Protection System Maintenance and Testing Phase 3 (Sudden Pressure Relays)

Order No Assessment of Protection System Single Points of Failure Based on the Section 1600 Data Request. September, 2015

Table of Issues and Directives Project Relay Loadability: Stable Power Swings

Unofficial Comment Form 1st Draft of PRC-005-3: Protection System and Automatic Reclosing Maintenance (Project )

DRAFT Reliability Standard Audit Worksheet 1

136 FERC 61,187 UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION. 18 CFR Parts and 40. [Docket No. RM ]

Standards Authorization Request Form

Approval...6. Current Revision...7. Introduction... 8 About PJM Manuals... 8 About This Manual... 8 Using This Manual...9

Information Document PRC-001-AB3-1.1(ii) Protection System Coordination ID # RS

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

Background Information TPL Transmission System Planning Performance Requirements

Standard CIP 007 3a Cyber Security Systems Security Management

NERC Relay Loadability Standard Reliability Standards Webinar November 23, 2010

Unofficial Comment Form Project Disturbance Monitoring

FRCC Disturbance Monitoring Equipment Outage Reporting

Standard CIP Cyber Security Critical Cyber As s et Identification

Standard Development Timeline

Requests for Clarifications And Responses Order No. 754 Data Request The Study of Single Point of Failure

ERO Enterprise Registration Practice Guide: Distribution Provider directly connected Determinations Version 2: July 5, 2018

Supplemental Information

CIP Cyber Security Configuration Change Management and Vulnerability Assessments

Consideration of Issues and Directives Federal Energy Regulatory Commission Order No. 791 June 2, 2014

System Protection and Control Subcommittee

Project Posting 8 Frequently Asked Questions Guide

CIP Cyber Security Configuration Management and Vulnerability Assessments

Violation Risk Factor and Violation Severity Level Justification Project Modifications to CIP-008 Cyber Security Incident Reporting

Project Modifications to CIP Standards. Consideration of Comments Initial Comment Period

Standard CIP Cyber Security Critical Cyber As s et Identification

TOP-010-1(i) Real-time Reliability Monitoring and Analysis Capabilities

Proposed Clean and Redline for Version 2 Implementation Plan

Group PacifiCorp Sandra Shaffer No

Unofficial Comment Form Project Operating Personnel Communications Protocols COM Operating Personnel Communications Protocols

Project Retirement of Reliability Standard Requirements

Standard INT Dynamic Transfers

This section is maintained by the drafting team during the development of the standard and will be removed when the standard becomes effective.

Cyber Security Reliability Standards CIP V5 Transition Guidance:

Standard Development Timeline

Standard COM-002-2a Communications and Coordination

CIP Cyber Security Configuration Change Management and Vulnerability Assessments

Comment Form Revised FRCC Regional Reliability Standard Development Process Document (FRCC-RE-STD-001)

Violation Risk Factor and Violation Severity Level Justifications Project Modifications to CIP Standards

Standard Development Timeline

Disturbance Monitoring Standard Drafting Team August 7, p.m. 5 p.m. August 8, a.m. 5 p.m. August 9, a.m. noon

Standard Development Timeline

Consideration of Issues and Directives Federal Energy Regulatory Commission Order No. 791 January 23, 2015

Standard INT Dynamic Transfers

Purpose. ERO Enterprise-Endorsed Implementation Guidance

Disclaimer Executive Summary Introduction Overall Application of Attachment Generation Transmission...

CIP Cyber Security Configuration Change Management and Vulnerability Assessments

Response to Stakeholder Comments on Draft and Revised Draft Tariff Language CCE3 and RSI Clarifications

Reliability Coordinator Procedure PURPOSE... 1

Supplementary Reference and FAQ

Cyber Security Incident Report

Standard CIP 007 4a Cyber Security Systems Security Management

Project , COM Operating Personnel Communications Protocols Rationale and Technical Justification

Bulk Electric System Definition Changes and Reporting

CIP Cyber Security Critical Cyber Asset Identification. Rationale and Implementation Reference Document

Unofficial Comment Form

Rationale for the Use of Local and Remote (Zone 3) Protective Relaying Backup Systems A Report On The Implications And Uses Of Zone 3 Relays

Standards Development Update

CIP Cyber Security Configuration Change Management and Vulnerability Assessments

Re: Exposure Draft Proposed ISAE 3402 on Assurance Reports on Controls at a Third Party Service Organization

CIP Cyber Security Security Management Controls. Standard Development Timeline

Standard CIP-006-3c Cyber Security Physical Security

Standard CIP 004 3a Cyber Security Personnel and Training

This section is maintained by the drafting team during the development of the standard and will be removed when the standard becomes effective.

Internal Controls Procedure

NERC Request for Data or Information: Protection System Misoperation Data Collection August 14, 2014

Supplementary Reference and FAQ

CIP Cyber Security Personnel & Training

Questions and Answers about Consistent Protection System Misoperation Reporting

November 9, Revisions to the Violation Risk Factors for Reliability Standards IRO and TOP

MISO Transmission Planning BPM 020 Updates February 16, 2016

Progress Report Negotiations on the Registrar Accreditation Agreement Status as of 1 March 2012

This draft standard is being posted for an initial comment and ballot. The draft includes modifications to meet the directives of FERC Order No. 791.

Reliability Standard Audit Worksheet 1

Project Cyber Security - Order No. 791 Identify, Assess, and Correct; Low Impact; Transient Devices; and Communication Networks Directives

Meeting Minutes Reliability Metrics Working Group

NERC Management Response to the Questions of the NERC Board of Trustees on Reliability Standard COM September 6, 2013

This section is maintained by the drafting team during the development of the standard and will be removed when the standard becomes effective.

PG&E Transmission Interconnection Handbook. Update Section Date Added Figure G5-1 Simplified Flow Chart of Pre- Section G5 Aug.

Standard CIP Cyber Security Physical Security

PUBLICLY AVAILABLE SPECIFICATION

EUIPO Ex-ante product quality audits (trademarks and designs) Prior Checking Opinion Case

CIP V5 Updates Midwest Energy Association Electrical Operations Conference

Standard CIP 005 2a Cyber Security Electronic Security Perimeter(s)

Standards Authorization Request Form

Memorandum. This memorandum requires Board action. EXECUTIVE SUMMARY

Project Consideration of Commission Directives in Order No. 693

TOP for Transmission Operators

Procedure For NPCC Bulk Electric System Asset Database

Agenda Event Analysis Subcommittee Conference Call

Lesson Learned Initiatives to Address and Reduce Misoperations

Transcription:

1. In response to comments received, the Drafting Team has modified the Applicability section and now includes applicability of the standard to sites > 75 MVA (gross aggregate nameplate). Do you agree with this change? Alan Gale City of Tallahassee John Mulhausen Florida 2. Requirement 1 now requires islanding schemes to be compliant with the time durations specified in Appendix A. Do you agree? Alan Gale City of Tallahassee The requirement does not specify a pre-planned islanding scheme or any tripping by the transmission system protection. By including the words as written, I am afraid we have extended this standards applicability to the Transmission Owner or Operator. If the intent is to only prohibit "islanding" if the generator with it's own auxiliaries, that is not clear by the language provided. Additionally, the verbiage in the requirements should match the verbiage in Appendix A. (i.e. "No generator tripping or islanding" in the first column.) Page 1 of 6

In order to maintain clarity of responsibility and applicability along with promoting a clear understanding of the standard, the DT intentionally refers to the generator islanding concept specifically, within the standard. The intent of the DT, with this standard, has been to focus on Regional coordination of generator performance. Islanding Schemes are required to be addressed under NERC Reliability standard PRC-006-0 (UFLS programs). The complementary FRCC UFLS standard being developed in parallel with this standard includes the requirement for coordination of other frequency activated switching in requirement R3 of that standard. The DT deliberated about your comment but concluded that the current applicability language improves clarity of the requirements, meets the technical intent of the standard, addresses the NERC Reliability standard requirements and adequately addresses the reliability implications of islanding in the context of both the generator owners and load serving entities. The DT team agrees with the addition of islanding being specifically included in the performance criteria in the first column of appendix A in order to match the language of Requirement R1. The standard has been revised accordingly. Reliant Energy John Simpson 3. Based on comments received, the Drafting Team has modified Risk Factors. Do you agree with the Risk Factors of this draft? City of Tallahassee Alan Gale Page 2 of 6

4. The Drafting Team has added Compliance elements of this standard to Section D of this draft. Do you agree with the elements of Section D, Compliance? City of Tallahassee Alan Gale My disagreement is with the Data Retention section 1.3. To require retention of documentation for the "service life of the generator" is unduly burdensome for the GO. Documentation retention that could be 30 years or longer is excessive. A more limited retention is warranted. I would recommend 3 years at the most. We should not be concerned if the generator met the requirements 5 years ago. We should be concerned that it meets the requirements right now! The DT agrees with your comment and has revised the standard to limit the data retention period to 3 (three) years to coincide with the current entity compliance monitoring audit cycle. Page 3 of 6

Reliant Energy John Simpson 5. In response to comments received, the Drafting Team made minor clarifications to Appendix A. Do you agree with these clarifications? Alan Gale City of Tallahassee DT agrees and has incorporated in current revision of the standard. A) See 2 above to make verbiage match requirements. B) Remove carriage return after "105%" and before "of rated". John Muhausen Florida The last requirement from Appendix A, Generator overexcited stator current (or generator apparent impedance) less than 150% of nameplate rating needs further clarification. The phrase or generator apparent impedance is intended to apply to backup phase distance relays but it is not specifically stated and could easily be misinterpreted. I propose splitting the requirement into two separate requirements: Page 4 of 6

1.Generator overexcited stator current less than 150% of nameplate rating current when applying generator phase overcurrent relays. 2.Generator MVA less than 150% of nameplate at rated power factor when applying generator backup phase distance relays. I would like to state that the SPCTF at NERC is likely to recommend a 200% setting based on IEEE Guidelines in a future SAR/Standard. If adopted FRCC will have to change to 200% since it is more stringent. An associated voltage requirement footnote still has to be associated with both of the split requirements. It should be selected for 90% to 110% terminal voltage. I have a concern with the second part of footnote 4 that states "without faulted conditions within the generator or GSU." This could be used in some way as an escape clause to set tripping elements within the specified FRCC "No Trip" ranges. The Standard does not state how this clause would actually be applied in the relay settings. This could lead to unintended consequences. Examples should be provided. The DT agrees with your comment and has incorporated 1 and 2 above into the revision to appendix A. The DT feels that the standard should continue to be developed in accordance with the historical settings that have been established within the FRCC. If the NERC standards are developed and eventually require a 200% setting the standard in-place at that time, can be revised to address this via the standards process. The DT discussed footnote 4 of appendix A and the consensus was that along with your suggested requirement Page 5 of 6

clarifications, the coordination requirements are now clear and well defined (as revised). Reliant believes there has been an incorrect modification made to the last box in Appendix A. The apparent impedance varies inversely to the stator current so we do not want to trip the generator if the stator current is less than 150% of nameplate or if the apparent impedance is GREATER than the equivalent apparent impedance at that current level. The language as written is confusing and seems to be opposite this last point. The DT agrees with your comment and has incorporated revisions to appendix A, to clarify the language used to convey the technical basis of the coordination requirement. 6. Do you have any other comments on Draft #2 of this standard? City of Tallahassee Alan Gale None None None Page 6 of 6