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2017-05 NUC-001-3 Periodic Review | Preliminary Team Recommendation

Description:

Start Date: 12/15/2017
End Date: 01/29/2018

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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Hot Answers

This does not warrant an immediate revision.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Reclamation recommends to remove the word “the” preceding “proposed new or revised NPIRs.” The requirement should read, “The Nuclear Plant Generator Operator shall provide proposed new or revised NPIRS in writing to the applicable Transmission Entities…”

Reclamation also recommends R1 be further revised to specify a time frame in which the NPIRs must be provided.

Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

The proposed change is an enhancement to the existing Standard Requirement language.  Consideration for review as part of the next revision to the Standard is acceptable.

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

AEP believes that the proposed revision is unnecessary, as the obligation is sufficiently clear in its current form.

In response to the question posed, AEP has no objection to PRT’s assertion that their observation does not warrant immediate revisions to the Standard.

 

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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PJM agrees with the PRT’s suggested clarification, and agrees that the proposed change does not warrant immediate revision to the standard.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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The California ISO supports the comments of the ISO/RTO Council (IRC) Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - Segments 2

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

- 0 - 0

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Texas RE does not have comments on this question.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

- 0 - 0

We concur that the observed “shortfall” does not warrant immediate revisions to the Standard, but also question whether such a change is necessary, since the term “proposed NPIRs” is sufficiently broad to include new or revised NPIRs. 

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

- 0 - 0

We concur that the observed “shortfall” does not warrant immediate revisions to the Standard.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

PSEG agrees that this determination does not warrant immediate revisions to the standard.

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

- 0 - 0

ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

- 0 - 0

Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

- 0 - 0

Hot Answers

We agree with the alignment to defined terms.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Reclamation recommends R3 be revised to reference R2 as the source of the Agreements and specify a time frame in which the results of the planning analyses be communicated to Nuclear Plant Generator Operators.

Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

- 0 - 0

Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Revising the Standard Requirement to better align with the NERC Glossary of Terms time dependent definitions will be a clarification to the Standard.  However, it is Exelon’s opinion that this observation does not warrant an immediate revision to the Standard. 

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

AEP believes that the proposed revision is unnecessary, as the obligation is sufficiently clear in its current form.

In response to the question posed, AEP has no objection to PRT’s assertion that their observation does not warrant immediate revisions to the Standard.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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PJM believes that there is some value in the clarification of the planning analyses term used in the standard, although it is likely that in absence of the clarification, most entities would incorporate NPIRs into both near-term and long-term planning analysis. PJM does agree with the PRT’s assertion that this proposed change does not warrant immediate revision to the standard.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

- 0 - 0

Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

- 0 - 0

Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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The California ISO supports the comments of the ISO/RTO Council (IRC) Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - Segments 2

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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We suggest keeping the language as is, not adding in this proposed detail.  The details of what horizon should be used is up to the NPLRs to determine, not this document.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

- 0 - 0

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Texas RE does recommend defining planning analysis or use a term that is defined such as Operations Planning Analysis.  Additionally, Texas RE recommends defining “electric system” which is used in both Requirements R3 and R4.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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We concur that the identified potential “issue” does not warrant immediate revisions to the Standard. Under the existing standard language, responsible entities would simply incorporate the NPIRs into their planning analysis for both near-term and long-term horizon. While it is possible that including the requirement in both of the horizons may not be absolutely needed or applicable for certain entities in every case, there is no reliability gap if planning analyses for both horizons are conducted.  Further, to the extent that the concern is that Transmission Entities may be unsure how to apply R3 per the recent updates to the NERC Glossary for the different time horizons, NERC could conduct an anonymous survey to assess whether there is a reliability gap before making any change.

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

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We concur that the identified potential “issue” does not warrant immediate revisions to the Standard. Without the “planning analysis” more clearly specified or defined, responsible entities would simply incorporate the NPIRs into their planning analysis for both near-term and long-term horizon. While either of the horizons may not be absolutely needed or applicable for certain entities, there is no reliability gap if planning analyses for both horizons are conducted.

We suggest deleting the second part of R3, ‘and shall communicate the results of these analyses to the Nuclear Plant Generator Operator’. Communication is not necessary if no impact has been identified during the planning analyses.  In practice, this would just be an administrative burden to the applicable entities, with no reliability benefit.  If there is an impact, the communication need is covered by Requirement R8.  

 Alternatively, to cater for cases where the Generator Operator may occasionally need these results, this part could be changed to ‘and shall make the results of these analyses available to the Nuclear Plant Generator Operator.’.

 Publicly posting the results can be deemed sufficient without requiring any additional communication.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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PSEG agrees that this determination does not warrant immediate revisions to the standard.

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

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We agree with the PRT’s assertion that this observation does not warrant immediate revisions to the Standard.  In its response to the technical accuracy of Requirement 3 of NERC Reliability Standard NUC-001-3 (i.e. question 10 of the Periodic Review Template), we believe the PRT should include the terms “Planning Assessment” and “Corrective Action Plan” within its list of applicable terms from the NERC Glossary.  Similar references to “Real-time Assessment” and “Operational Planning Analysis” should be incorporated into Requirement R4 at a later date as well.

ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

- 0 - 0

Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

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Hot Answers

This does not warrant an immediate revision.

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Reclamation agrees that the addition of Same-day to the R4 Time Horizons does not warrant immediate revisions to the Standard because the minimum Time Horizon is already covered by the inclusion of Real-time Operations.

Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Revising the Standard Requirement to better align with appropriate Time Horizons will be a clarification to the Standard.  However, it is Exelon’s opinion that this observation does not warrant an immediate revision to the Standard. 

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

AEP believes that the proposed revision is unnecessary, as the obligation is sufficiently clear in its current form.

In response to the question posed, AEP has no objection to PRT’s assertion that their observation does not warrant immediate revisions to the Standard.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

- 0 - 0

PJM agrees with the PRT’s suggested inclusion of the “Same-day” Time Horizon for R4, and agrees that the proposed change does not warrant immediate revision to the standard.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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The California ISO supports the comments of the ISO/RTO Council (IRC) Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - Segments 2

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Duke Energy agrees that this observation does not warrant immediate revisions to the Standard. We agree that this clarification is needed if Same day is currently used and understood throughout the industry. That said, it does not appear that Same day (or Operations Planning) is included in the NERC Glossary of Terms. We would recommend that some consideration be given to creating definitions for these in the NERC Glossary of Terms.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

- 0 - 0

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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We concur that the observed exclusion of “Same-day” in the Time Horizon does not warrant revisions to the standard—immediate or otherwise. Part 4.1 stipulates that the Responsible Entities incorporate the NPIRs into their operating analyses, which is deemed adequate to cover the same-day time frame.

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

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We concur that the observed exclusion of “Same-day” in the Time Horizon does not warrant immediate revisions to the standard. Part 4.1 stipulates that the Responsible Entities incorporate the NPIRs into their operating analyses, which is deemed adequate to cover the same day time frame.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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PSEG agrees that this determination does not warrant immediate revisions to the standard.

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

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ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

- 0 - 0

Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

- 0 - 0

Hot Answers

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Reclamation asserts the PRT has identified a gap in the standard created by the absence of R9.2.4. Since the current standard does not require that NPIRs based on Bulk Electric System requirements be included in Agreements to address and implement NIPRs, Reclamation recommends this requirement be immediately added to the standard to fill the gap.

Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Exelon agrees that the addition of a new Sub-part for Requirement R9 will, for some Transmission Entities, be a needed clarification to the Standard.  However, it is Exelon’s opinion that this observation does not warrant an immediate revision to the Standard.

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

AEP has no objection to possibly pursuing the Sub-part as suggested above.

In response to the question posed, AEP has no objection to PRT’s assertion that their observation does not warrant immediate revisions to the Standard.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

- 0 - 0

PJM agrees with the assertion that the proposed change does not warrant immediate revision to the standard. Regarding the change, PJM believes that there is merit to the clarification that NPIRs may include BES requirements identified by Transmission Entities, given that R1 states that NPGOs (not the Transmission Entities) provide the NPIRs. 

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

- 0 - 0

Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

- 0 - 0

The California ISO supports the comments of the ISO/RTO Council (IRC) Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - Segments 2

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Duke Energy agrees with the PRT that this observation does not warrant immediate revision to the Standard. It is unclear, whether this potential revision is needed at all. Would this revision prompt an entity to create a list with all of the elements that include BES requirements that support an NPLR?

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

- 0 - 0

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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In order to be consistent with other Reliability Standards, Texas RE recommends using the term “Responsible Entities” rather than “Transmission Entities” in section A4.2.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

- 0 - 0

We concur that the observed potential “gap” does not warrant immediate revisions to the standard.

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

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We concur that the observed potential “gap” does not warrant immediate revisions to the standard.

In fact, we do not believe there is a need to add the proposed sub-part since by definition, NPIR already includes those “….requirements based on Bulk Electric System requirements that have been mutually agreed to by the Nuclear Plant Generator Operator and the applicable Transmission Entities.” The proposed 9.2.4 will thus be redundant with what is already included in the definition for development “…Agreement that include mutually agreed to NPIRs” per R2.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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BPA believes that the proposed sub-part 9.2.4 needs more clarification, and potentially may be unnecessary. BPA believes that the agreement that includes NPIR requirements could be more stringent than the BES requirement. Some nuclear plants may require the Transmission Entity to maintain unusually high voltage at their primary station service bus to enable the plant operator to shutdown safely during Loss of Coolant Accident. The BES requirement (planning standards) allows the Transmission Entity to develop acceptable voltage criteria which may be lower than the required voltage level by the plant operator. Therefore, adding this sub-part would make it confusing and unnecessary.

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

PSEG agrees that this determination does not warrant immediate revisions to the standard.

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

- 0 - 0

ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

- 0 - 0

Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

- 0 - 0

Hot Answers

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

- 0 - 0

Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

- 0 - 0

Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Exelon agrees with the potential errata changes identified by the PRT.

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

- 0 - 0

PJM agrees with the administrative errata corrections such as the consistent terminology usage for “applicable entities” in the NUC-001 VSL section. PJM concurs that these errata corrections do not warrant immediate revision to the standard.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

- 0 - 0

Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

- 0 - 0

Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

- 0 - 0

The California ISO supports the comments of the ISO/RTO Council (IRC) Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - Segments 2

- 0 - 0

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

We agree as long as the errata changes do not include the following from the EPR Template: “The locally defined term “Transmission Entity” within the Reliability Standard should be re-examined.” We do not believe the term needs to be re-examined; changes to this term may result in the need to revise Agreements which would not be a productive exercise for entities to be forced to undertake.

RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

- 0 - 0

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

While the review team identified several changes that could be made to this standard, it is not clear whether the review team considers these changes errata changes or opportunities for future revisions.  Texas RE requests a list of the specific errata changes the review team identified. 

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

- 0 - 0

From the EPR Template, we are unable to make out which errata have been identified.  If the PRT is referring to the removal of LSE from the Applicability Section (Item 11. Functional Model), then we concur.

At any rate, we agree that errata do not need to be corrected at this time.

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

- 0 - 0

From the EPR Template, we are unable to make out which errata have been identified. If the PRT is referring to the removal of LSE from the Applicability Section (Item 11. Functional Model), then we concur.

At any rate, we agree that errata do not need to be corrected at this time.

 

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

- 0 - 0

BPA agrees with the observations

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

- 0 - 0

To conform to other NERC Reliability Standards, we believe this standard should use the reference “Responsible Entity” as the applicable functional entity instead of “Transmission Entity”.  This reference should also be identified within the standard’s applicability section as any functional entity that has been assigned a responsibility to provide service through a Nuclear Plant Interface Requirement.

ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

- 0 - 0

Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

- 0 - 0

Hot Answers

There is some administrative cost with the standard so some may have a different definition of cost effectiveness

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

None

Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

- 0 - 0

Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

- 0 - 0

Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

- 0 - 0

PJM agrees that there are no concerns with the cost effectiveness of the standard as drafted.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

- 0 - 0

Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

- 0 - 0

Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

- 0 - 0

No Comment

Richard Vine, On Behalf of: Richard Vine - - Segments 2

- 0 - 0

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

- 0 - 0

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

- 0 - 0

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

- 0 - 0

RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

- 0 - 0

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

- 0 - 0

Texas RE does not have comments on this question.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

- 0 - 0

No comment.

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

- 0 - 0

We neither agree nor disagree since the PRT only indicates that “The Reliability Standard as written allows flexibility in implementation for merchant power plants and vertically-integrated utilities”, which we do not assess to be a cost-effectiveness assessment of various alternatives that could meet the intent or objective of the standard.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

- 0 - 0

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

- 0 - 0

PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

- 0 - 0

ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

- 0 - 0

Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

- 0 - 0

Hot Answers

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

- 0 - 0

Reclamation recommends the standard be immediately revised to include the proposed requirement R9.2.4. See the response to Question 4.

Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

- 0 - 0

Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

- 0 - 0

Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Exelon agrees that the suggested clarifications will be improvements to the Standard but also agrees with deferring the changes to a future revision.

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

- 0 - 0

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

- 0 - 0

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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PJM agrees with the PRT’s assertion that the suggested clarifications be deferred for later consideration as there are no identified reliability gaps.

Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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The California ISO supports the comments of the ISO/RTO Council (IRC) Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - Segments 2

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

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RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

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Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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The SAR for Project 2017-07 Standards Alignment with Registration suggests that LSE function may be removed through periodic review instead of the standards alignment project.  Since the periodic review team elected to not revise Reliability Standard NUC-001-3 at this time, Texas RE wants to ensure that the Registration Alignment changes will be made under project 2017-07.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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We agree with this assessment, although we do not believe that any of the proposed revisions are necessary or appropriate, with the exception of the removal of the LSE function from the Applicability section, as noted above in response to Question 5.

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

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We agree with this assessment and proposal.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

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ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

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Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

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Hot Answers

Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Wendy Center, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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Other Answers

Brad Harris, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Exelon Segment 3 representative supports the commnets filed by Exelon Generation.

Kinte Whitehead, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Exelon supports and endorses the findings of the NUC-001-3 EPR team and has no additional comments.

Cynthia Lee, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Exelon MKT Segment 6 supports and endorses the findings of the NUC-001-3 EPR team and has no additional comments.

Becky Webb, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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Exelon TO Segment 1  supports and endorses the findings of the NUC-001-3 EPR team and the comments of Exelon Generation. We have  no additional comments.

Daniel Gacek, On Behalf of: Exelon, , Segments 1, 3, 5, 6

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no

DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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There may be opportunity to provide greater clarity regarding exactly which situations drive the NPIR’s applicability. For example, the NPIR needs to clearly define the individual unit status, load requirements of the plant, and the configuration of the low side reactive control in addition to defining the high side of the plant requirements.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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The California ISO supports the comments of the ISO/RTO Council (IRC) Standards Review Committee

Richard Vine, On Behalf of: Richard Vine - - Segments 2

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Duke Energy agrees with the assertion made by the PRT in the Periodic Review Template, that the term “Transmission Entities” should be considered for revision in the future. The term Transmission Entities could be viewed as ambiguous, and clarity of the standard could be improved with further explanation of this term.

Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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In the standard in Requirement7 and M7 as well as R8 and M8 in the sentence that ends with "electric system to meet the NPIRs", we suggest you add, right after NPIRs, " or the Nuclear Plant Generator Operators ability to operate the plant to meet the NIPRs."

The way it's currently written it implies that it is always incumbent on the system to make the changes to meet the NPIRs whether the plant or the TO/TOP needs to make a change.  That is most problematic if the plant decides to make changes, operational or design, that will result in needing to change the NPIRs or how either party operates.  The way it is stated it seems that the system is left unable to meet the NPIRs when, in fact, the plant could operate differently to meet the NPIRs following the change. Example: A plant has declared they will no longer open a circuit switcher to accommodate an outage of plant downstream equipment.  This would constitute an operational change for the plant since the switcher has been there since the plant came online and has always been the preferred method to clear their transformer(s).  The next outage would cause the TOP to need to take a bus outage for a plant transformer outage.  The same thing could happen if the plant decided they didn't want to pay for a repair of their SVCs.  They could just say they are not going to use SVCs.  The way NUC is currently written, the TOP would not have the ability to operate the electric system to meet the NPIRs.

The addition of the language mentioned above could clarify that it is anticipated that the plant can also make a change to be able to meet the NPIR. 

David Jendras, On Behalf of: Ameren - Ameren Services, , Segments 1, 3, 6

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No other comments.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 10/5/2015

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No changes are recommended for Section D (Regional Variances) of the NERC standard NUC-001-3 as it is still applicable to Canadian (CANDU) Nuclear Power Plants.

RSC no HQ and ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 1/29/2018

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Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Texas RE does not necessarily disagree with the review team’s assertion that these changes are not warranted at this time.  Texas RE does, however, request technical justification for not making the changes at this time.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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Notwithstanding the above general concurrence, we are curious as to why this standard is being put through a periodic review given that NUC-001-3 has been in place for less than 2 years and not even through a single audit cycle.  The Rules of Procedure indicate that standards only need to be reviewed once every 10 years.

ISO/RTO Council Standards Review Committee (SRC), Segment(s) 2, 1/29/2018

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None.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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None

Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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PSEG REs, Segment(s) 5, 6, 3, 1, 11/2/2017

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We thank you for this opportunity to provide these comments.

ACES Standards Collaborators, Segment(s) 1, 3, 1/29/2018

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The GO provides NPIRs to the TE.  The NPIRs are then included in one or more agreements between the GO & the TE.  Those agreements are used as Measures to indicated compliance with NUC-001-3 Requirements 3,4,5,6,7,8 & 9.  Listing the NPIRs separately in Requirement 1 is redundant to the evidence provided for Requirements 3 through 9.  Requirements R1 & R2 could be consolidated into R3 and then referred to in subsequent Requirements.

Also, The GO provides NPIRs to the TE.  The NPIRs are then included in one or more agreements between the GO & the TE.  Those agreements are used as Measures to indicated compliance with NUC-001-3 Requirements 3,4,5,6,7,8 & 9.  Listing the Agreement(s) separately in Requirement 2 is redundant to the evidence provided for Requirements 3 through 9. Requirements R1 & R2 could be consolidated into R3 and then referred to in subsequent Requirements.

Lauren Price, On Behalf of: American Transmission Company, LLC, MRO, RF, Segments 1

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