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2007-17.4 PRC-005 FERC Order No. 803 Directive SAR

Description:

Start Date: 06/11/2015
End Date: 07/10/2015

Associated Ballots:

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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On page 2 of the proposed SAR, strike the following sentence: “The SDT shall also consider changes to the standard and supporting documents that provide consistency and alignment with other Reliability Standards.”

 

On page 3 of the proposed SAR, change “[m]odify the informative Supplementary Reference Document (provided as a technical reference for PRC-005-3) as necessary to provide application guidance to industry” to “[m]odify the informative Supplementary Reference Document (provided as a technical reference for PRC-005-3) as necessary to provide application guidance to industry pertaining to changes supporting FERC Order 803.”

John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 3, 5, 6

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 2

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Control circuitry associated with the reclosing relay or supervisory relays is unclear and needs a better definition.  Closing circuitry devices that are to be excluded should be enumerated for clarity.

Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 5, 6

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Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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 Dominion does not agree with inclusion of Balancing Authority in the Reliability Functions portion of the SAR.

Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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We agree that the SAR addresses the directive in Order No. 803, however we have issues with the revised definition of Automatic Reclosing in the draft of PRC-005-6.  See response in question #2.

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 5/13/2015

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Stanley Beasley, On Behalf of: Georgia Transmission Corporation - SERC - Segments 1

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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Occidental Chemical Corporation (OCC) agrees that the project team took the proper action to re-write the SAR to directly focus on Order No. 803.  Although the previous version accurately reflected the intent of the initiative in our view, the attempt to include the work description in the original SAR was clearly confusing to some stakeholders.  We agree that a consensus will only be reached if the document tightly reflects the language in FERC’s directives – and cannot be interpreted in a manner that expands scope beyond that point.

Venona Greaff, On Behalf of: Oxy - Occidental Chemical, , Segments 7

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Jeri Freimuth, On Behalf of: APS - Arizona Public Service Co., WECC, Segments 1, 3, 5, 6

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SERC PCS, Segment(s) 1, 10, 7/10/2015

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

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

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The Balancing Authority should not be included in the Reliability Functions section of the SAR.  PRC-005 does not apply to a Balancing Authority.

NPCC--Project 2007-17.4 , Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/10/2015

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1, 5

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The revised SAR is much clearer than the previously posted version.  In the “Detailed Description” section, bullet item #1, we believe that “PRC-002i” was intended to read “PRC-005-2i”.  If so, we see no need to consider PRC-005-2(i) in the implementation plan work of this SDT since FERC’s approval of PRC-005-2(i) on 5/29/2015 has effectively already aligned the implementation plan of PRC-005-2(i) with that of the now retired PRC-005-2.

In the “Reliability Functions” section, we believe the Balancing Authority (BA) function was checked in error.  If not, the reasoning behind expanding the applicability of PRC-005 to the BA should be explained in the SAR.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

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 Hydro One recognizes the fact that the wording in the Objectives, and in particular, the addition of ‘definitions’ has been added to align with the recommendation made on the previously proposed SAR.

Oshani Pathirane, On Behalf of: Hydro One Networks, Inc., NPCC, Segments 1, 3

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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SPP Standards Review Group, Segment(s) 1, 3, 5, 7/10/2015

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

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

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Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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Karen Webb, On Behalf of: Karen Webb, , Segments 1, 3, 5

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John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 3, 5, 6

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 2

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See comments for Question 1 above.

Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 5, 6

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Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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At ComEd, the overwhelming majority of the reclosing relays for BES Elements are microprocessor based and have the supervisory functionality built into the reclosing relay.   Additionally, the majority of our solid state relays for BES elements have the supervisory functionality built into the reclosing relay.   Although the standard meets the intention of FERC Order 803, the term “supervisory relay” refers to an antiquated methodology.   It seems that “supervisory functionality” would be more appropriate.  ComEd would prefer that the NERC standard changed the definition of Automatic Reclosing in the standard to state:  “Automatic Reclosing Equipment - Equipment which automatically restores a BES Element(s) after a Protection System Operation.   This equipment includes the device which issues the actual reclose pulse, any supervisory functionality (e.g, voltage check, sync check, or timing), any voltage sensing devices associated with the supervisory functionality, and any control circuitry necessary for the automatic reclosing to perform as designed.  Note that the purpose of including Automatic Reclosing Equipment in the PRC-005 standard is to ensure that a premature close is not issued to a circuit breaker, not to ensure that a non-RAS circuit breaker actually recloses.”    

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 5/13/2015

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Stanley Beasley, On Behalf of: Georgia Transmission Corporation - SERC - Segments 1

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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OCC commends the project team for updating the definition of “Automatic Reclosing” to directly align with the Commission’s order.  The previous version was open-ended in our view, and could apply to other supervisory functions beyond voltage and synch control that have no effect on BES reliability.

Venona Greaff, On Behalf of: Oxy - Occidental Chemical, , Segments 7

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Jeri Freimuth, On Behalf of: APS - Arizona Public Service Co., WECC, Segments 1, 3, 5, 6

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SERC PCS, Segment(s) 1, 10, 7/10/2015

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

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

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The definition of Automatic Reclosing should have words to describe what Automatic Reclosing is in addition to the components that comprise it.  Suggest wording similar to:  Automatic Reclosing is a control scheme or system for automatically closing circuit breakers that have automatically tripped in response to abnormal system conditions.  The PSMTSDT should consider changing the nomenclature of what is to be defined to “Automatic Reclosing System”. 

The listing of new definitions in Section 6 of the Introduction of the Standard is inconsistent with other NERC standards which have them listed on the Definitions of Terms Used in Standard page.

NPCC--Project 2007-17.4 , Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/10/2015

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1, 5

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We do not agree with the addition of “Voltage sensing devices associated with the supervisory relay(s)” to the Automatic Reclosing definition, and believe these devices are beyond the scope of the FERC directive.  We recommend removing the third bullet of the Automatic Reclosing definition, and modifying the second bullet of the Component Type to read “Any one of the three specific elements of Automatic Reclosing.”

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

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Although Hydro One is generally satisfied with the existing definition of “Automatic Reclosing” as it includes the 4 major components constituting its functionality, the definition could further add to it the general intention of Automatic Reclosing.

 

Hydro One is also satisfied that the definition of “Component Type” has been extended to include all four components of an auto-reclose scheme (reclose relay, supervisory relay – voltage and synchro check, voltage sensing devices, and control circuits).

Oshani Pathirane, On Behalf of: Hydro One Networks, Inc., NPCC, Segments 1, 3

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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SPP Standards Review Group, Segment(s) 1, 3, 5, 7/10/2015

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

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Duke Energy suggests that additional language be provided to the definition or perhaps the Supplementary Reference/FAQ document which further clarifies that supervisory devices do not include SCADA/SCADA control. Specifically, the last bullet in the proposed definition of Automatic Reclosing could be misunderstood to mean SCADA supervisory control. It may be helpful to provide more detail into what constitutes said “supervisory relay” similar to the scope that NERC proposed in its NOPR comments to FERC, and which FERC approved, that stated that:

“supervisory devices to be encompassed in the Reliability Standard are those providing voltage supervision, supervisory inputs associated with selective auto-reclosing, and sync-check relays that are part of a reclosing scheme covered by PRC-005-3.”

We feel that adding more detailed language, as provided above, may decrease the possibility of misinterpretation or the wrongful inclusion of areas such as SCADA control into the scope of this standard.

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

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Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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Karen Webb, On Behalf of: Karen Webb, , Segments 1, 3, 5

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John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 3, 5, 6

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 2

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Closing circuitry devices that are to be excluded should be specifically stated in the Standard.

Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 5, 6

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Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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We agree with the intervals and the intent.   We do not agree with the names in the Component Attributes because of our disagreement with the Automatic Reclosing Definition.   See our response in #2.

 

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 5/13/2015

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Stanley Beasley, On Behalf of: Georgia Transmission Corporation - SERC - Segments 1

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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OCC agrees that the maintenance activities and intervals are consistent with all the other Protection System components subject to PRC-005-6.

Venona Greaff, On Behalf of: Oxy - Occidental Chemical, , Segments 7

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Jeri Freimuth, On Behalf of: APS - Arizona Public Service Co., WECC, Segments 1, 3, 5, 6

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SERC PCS, Segment(s) 1, 10, 7/10/2015

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There are no questions provided regarding Table 4-1 and the following appeared to fit here best.  Please clarify the following:  In Table 4-1, is it correct to assume ”preceding row” as referenced on page 35 is referencing all the Component Attributes for the 12 Calendar Years “row” ? Or just certain aspects of the “preceding row” (e.g. supervisory relay attributes ONLY)?

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

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

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NPCC--Project 2007-17.4 , Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/10/2015

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Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1, 5

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As stated above, we do not agree with the addition of “Voltage sensing devices associated with the supervisory relay(s)” to the revised Automatic Reclosing definition.  Therefore we believe Table 4-3 is unnecessary.  In the event that “Voltage sensing devices associated with the supervisory relay(s)” remains a part of the revised definition, we believe the maintenance interval for that component type is already addressed in Table 1-3.  Minor wording changes to Table 1-3 would be preferable to having two tables that address the same component type.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

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Oshani Pathirane, On Behalf of: Hydro One Networks, Inc., NPCC, Segments 1, 3

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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SPP Standards Review Group, Segment(s) 1, 3, 5, 7/10/2015

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

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

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Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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Karen Webb, On Behalf of: Karen Webb, , Segments 1, 3, 5

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John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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On pages 26-27 of the redlined version of the Supplementary Reference and FAQ, do not add the paragraphs regarding protection functions that are embedded in a Generator’s voltage regulator.  This addition is inconsistent with the purpose of the proposed SAR.  Furthermore, it is unclear how many in the industry interpreted a voltage regulator or excitation system, or elements thereof, as a protective relay when the industry previously balloted the current definition of a Protection System.

John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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

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Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 3, 5, 6

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 2

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We have been told numerous times that the Supplementary Reference and FAQ are not part of the Standard; however, for clarity the newly added closing circuitry devices (components) that require periodic maintenance should be strictly defined, and those closing devices excluded from maintenance should be clearly stated in the Standard.  As a suggestion, a typical closing circuit diagram could be shown in the Supplementary Reference illustrating the closing circuitry device inclusions and exclusions.  As to the use of inclusions and exclusions, these were used to better define the BES definition as completely defined by the BES SDT, as an example.

Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 5, 6

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However, ATC has the following clarifications:

The first Frequently-asked Question in Section 15.8.1 (page 101) contains a typographical error. The last sentence should read, “Automatic Reclosing is included in the PSMP because it is a more pragmatic approach as compared to creating a parallel and essentially identical ‘Control System Maintenance Program for the four Automatic Reclosing component types.”

 

Also, ATC recommends revising the response to the question, “Do we have to test the various breaker closing circuit interlocks and controls such as anti-pumps?” (p. 102) to strike the second sentence that states, “They are indirectly verified by performing the Automatic Reclosing control circuitry verification as established in Table 4.” This statement is inaccurate.

Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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As mentioned above in #2, we do not agree with the definition of Automatic Reclosing, otherwise FAQ is okay.

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 5/13/2015

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On page 103, the bullet “27 or 59 – supervisory contact from a undervoltage of overvoltage” has a typo.  “of” should be “or”.  Also, please see SERC PCS comments.

Stanley Beasley, On Behalf of: Georgia Transmission Corporation - SERC - Segments 1

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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Venona Greaff, On Behalf of: Oxy - Occidental Chemical, , Segments 7

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Excitation and voltage regulating systems should not be classified as Protection Systems, rather these should more accurately be classified as control systems with protection functionality. AZPS recommends removing the guidance that would include these devices within this standard.

Jeri Freimuth, On Behalf of: APS - Arizona Public Service Co., WECC, Segments 1, 3, 5, 6

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1) NERC Glossary defines “Control circuitry associated with protective functions through the trip coil(s) of the circuit breakers or other interrupting devices.” But Control circuitry is also one of the Components for Automatic Reclosing, which is a control function.  For protective functions the extent of the ‘Control circuitry’ is clear.  For Automatic Reclosing it is not as clear. 

 

Please add another FAQ in section 15.8.1: ‘What Control circuitry for Automatic Reclosing must be maintained? 

Answer: As noted on page 12 of the SAMS/SPCS report, the concern being addressed within the standard is premature auto reclosing that has the potential to cause generating unit or plant instability.  Responsible entities will need to verify all parts of the Control circuitry that could cause a premature closing command to the breaker close circuitry.  Permissive or supervisory contacts like device 86b, 43 control switch, or 79 cutoff, and the breaker anti-pump circuitry are generally outside of the intended Control circuitry, and would not need to be verified.  The wiring connecting the supervisory devices 25, 27 or 59 to Automatic Reclosing device 79 is generally within the intended Control circuitry, and would need to be verified.’

 

2) Change the page 110 Figure 1 & 2 Legend – Components of Protection Systems as follows:

 For row 2 state ‘including most sync check systems’ in the Excludes column rather than deleting ‘sync check systems’.  PRC-005-6 will only include a few sync check systems;

 

 3) Also add or clearly identify the control circuitry for automatic reclosing, supervisory relay and voltage sensing devices to Figure 1 to help identify the applicable circuitry.  This could be a separate figure identifying these components if not feasible to add to Figure 1.

SERC PCS, Segment(s) 1, 10, 7/10/2015

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Texas RE noticed the document references PRC-005-4.  Is this correct?  PRC-005-6 is only referenced once on a “Requirements Flowchart” diagram on page 23.

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

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Ameren supports and agrees with the SERC PCS / Region – Project-2015-05 PRC-005-06 FERC Order 803 Comments for Question #4 and includes them by reference.

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

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From page 7 of the Supplementary Reference and FAQ Document:

“What is synchronizing or synchronism (Sync-Check - (25)) - check relay (Sync-Check - 25)?

A synchronizing device that produces an output that supervises closure of a circuit breaker between two circuits whose voltages are within prescribed limits of magnitude and, phase angle. It may or may not include voltage or speed control. A sync-check relay permits the paralleling of two circuits that are within prescribed (usually wider) limits of voltage magnitude and, phase angle.”

Suggest replacing “paralleling” with “connecting”.

From page 106:

“Is it necessary to verify the close signal operates the breaker?

Only when the control circuitry associated with automatic reclosing is a part of a RAS, then all paths that are essential for proper operation of the RAS must be verified, per table 4-2(b).”

It is good practice when testing to ensure that a close signal operates a breaker regardless of whether it is part of a RAS or not.

NPCC--Project 2007-17.4 , Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/10/2015

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Entergy supports comments by SERC PCS group.

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1, 5

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1) The NERC Glossary of Terms definition for Protection System includes “Control circuitry associated with protective functions through the trip coil(s) of the circuit breakers or other interrupting devices.”  Control circuitry is also one of the Component Types listed in the Automatic Reclosing definition, which is a control function.  For protective functions the extent of the ‘Control circuitry’ is clear, but for Automatic Reclosing it is not as clear. Please add the following FAQ / response to section 15.8.1 to help clarify:

Question: ‘What Control circuitry for Automatic Reclosing must be maintained?

Answer: As noted on page 12 of the SAMS/SPCS report, the concern being addressed within the standard is premature auto reclosing that has the potential to cause generating unit or plant instability. Responsible entities will need to verify all parts of the Control circuitry that could cause a premature closing command to the breaker close circuitry. Permissive or supervisory contacts like device 86b, 43 control switch, or 79 cutoff, and the breaker anti-pump circuitry are generally outside of the intended Control circuitry, and would not need to be verified. The wiring connecting the supervisory devices 25, 27 or 59 to Automatic Reclosing device 79 is generally within the intended Control circuitry, and would need to be verified.’ 

2) Please change the page 110 “Figure 1 & 2 Legend – Components of Protection Systems” table as follows:

For row 2, replace the strikethrough with ‘including most sync check systems’ in the Excludes column rather than deleting ‘sync check systems’. PRC-005-6 will only include a few sync check systems.

3) Please add or clearly identify the control circuitry for automatic reclosing, supervisory relay and voltage sensing devices to Figure 1 to help identify the applicable circuitry. This could be a separate figure identifying these components if not feasible to add to Figure 1.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

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In the definition of a synchronizing device, Hydro One agrees with the NPCC TFSP in that the word “paralleling” used to describe the closing effect of connecting two circuits upon the close of a circuit breaker should perhaps be replaced by “connecting” .

Oshani Pathirane, On Behalf of: Hydro One Networks, Inc., NPCC, Segments 1, 3

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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SPP Standards Review Group, Segment(s) 1, 3, 5, 7/10/2015

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

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Duke Energy is of the belief that the addition made on page 26-27 of the Supplementary Reference Document concerning the protection function that is embedded in a Generator’s voltage regulator, appears to be a significant change/addition to the established scope of the standard. If an expansion of the scope of the standard was the intent of the addition, we recommend that a revision be made to Section 2.4 “Applicable Relays”. The existing verbiage in Section 2.4  is not sufficiently clear that a generator exciter or generator voltage regulator can be a relay. The variants of the term relay includes electromechanical relay, numerical relay, microprocessor relay, sudden pressure relay, reclosing relay, others and now generator exciter and generator voltage regulator. Additionally, Duke recommends that a change of this significance, if an expansion of scope was intended, be included in a revision of the PRC-005 standard itself in Section 4.2 “Facilities” with associated implementation, and not addressed in a Supplementary Reference Document.

Also, Duke Energy suggests that clarification is needed regarding the following question and answer that has been added on page 107 of the Supplementary Reference and FAQ Document. The question is as follows:

“My reclosing circuitry contains the following inputs listed below; what supervising relays would need to tested per PRC-005?”

We feel that the question is a bit confusing/misleading, and seems to mix subject matter. Is it the drafting team’s intent that the control circuitry must also be tested in the example? It so, should the control circuitry be added to the answer given? If it was the drafting team’s intent to separate the supervisory relays from the control circuitry, then the answer would appear to be appropriate, but the question appears to mix the two. Combining supervisory relays with control circuitry and not keeping them separate, as they have been in parts of the standard, may lead to confusion amongst industry stakeholders.

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

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Page 26 of the FAQ seemingly expands the testing and maintenance requirements of PRC-005 to include generator components that have not previously been the subject of PRC-005.  It is not clear what gap in reliability exists between the testing of the generator relays that is currently required under existing standards and the generator control systems referenced in the FAQ.  Additionally, if the scope of PRC-005 is to be expanded, an FAQ document is not the appropriate instrument to do so.

Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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Page 26 of the FAQ seemingly expands the testing and maintenance requirements of PRC-005 to include generator components that have not previously been the subject of PRC-005.  It is not clear what gap in reliability exists between the testing of the generator relays that is currently required under existing standards and the generator control systems referenced in the FAQ.  Additionally, if the scope of PRC-005 is to be expanded, an FAQ document is not the appropriate instrument to do so. 

Karen Webb, On Behalf of: Karen Webb, , Segments 1, 3, 5

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John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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Hot Answers

Andrea Jessup, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

John Fontenot, On Behalf of: John Fontenot, , Segments 1, 5

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

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We agree with the PSMTSDT on combining the Implementation Plans for the previous versions of PRC-005. However, we request that NERC formally recommend that FERC delay the enforcement of the earlier versions of this standard until PRC-005-6 has been finalized (balloted and implemented) in the NERC Standards Development Process. In our opinion, the various versions of this standard has caused confusion amongst the industry on what goals need to be accomplished by each of the drafting teams assigned to the development of the respective standards. We firmly believe that this suggested approach will be productive and efficient in getting all goals met in the standards development process especially, in reference to this particular family of standards.

Finally, we would suggest to the drafting team in reference all the newly defined terms added to PRC-005-6 that they ensure these terms are included into relevant documentation such as: The NERC Glossary of Terms, and Rules of Procedure (RoP) so they will be aligned properly.

Kaleb Brimhall, On Behalf of: Kaleb Brimhall, , Segments 1, 3, 5, 6

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 2

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There is an inconsistency in the use of April 1st and January 1st dates for compliance.  The January 1st dates eliminate at least one full quarter of time allowed for compliance maintenance activities.  All references to January 1st dates in the implementation plan should be changed to April 1st dates for items 2, 3, 4, and 5 on page 6 of the Implementation Plan.

Maryclaire Yatsko, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 5, 6

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Andrew Pusztai, On Behalf of: Andrew Pusztai, , Segments 1

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Dominion - RCS, Segment(s) 1, 6, 3, 5, 4/6/2015

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We strongly agree with combining the Implementation Plans for the various versions of PRC-005.

Other Commnets: We are providing a commnet about a section of PRC-005 not directlry related to the SAR. We find the wording of the exclusion for 4.2.7.1 &4.2.7.2 to be very confusing, and don't understand the basis for it. Automatic Reclosing addressed in Section 4.2.7.1 and 4.2.7.2 may be excluded if the equipment owner can demonstrate that a close-in three-phase fault present for twice the normal clearing time (capturing a minimum trip-close-trip time delay) does not result in a total loss of gross generation in the Interconnection exceeding the gross capacity of the largest relevant BES generating unit where the Automatic Reclosing is applied. As we understand it, normal clearing time at a generating station is typically 4 to 5 cycles. There may be some exceptions for faults on certain lines, but in general a 3-phase fault lasting 8 to 10 cycles would likely result in units at generating plant to be unstable.

Exelon Utilities, Segment(s) 1, 3, 5/19/2015

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NSRF strongly supports the proposal to align the Implementation Plans for the previous versions of PRC-005 into a single PRC-005-6 Implementation Plan.  A single implementation plan will help the industry avoid tracking and maintaining multiple implementation and completion schedules associated with each component type is added when each version becomes effective.  NSRF appreciates PSMTSDT’s effort on this proposal.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 5/13/2015

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Balancing Authority should be removed from the SAR as one of the applicable entities since the standard does not apply to the BA.

We also disagree with the general considerations section on page 3 because it states that “each registered entity must be prepared to identify…Automatic Reclosing and Sudden Pressure Relaying” while implementing PRC-005-2.  These items were added in PRC-005-3 and PRC-005-4.  As a result, in accordance with the implementation plan, identification would not be required until these requirements became effective as a part of PRC-005-6.

While we agree with the concept of the combined implementation plan, we believe clarity could be added to the implementation plan. Since PRC-005-6 will simply supersede all revisions inclusive of PRC-005-2 onward (including all revisions of PRC-005-3, PRC-005-4, and PRC-005-5), a single reference to the PRC-005-2 implementation plan could greatly simplify the proposed PRC-005-6 implementation plan.  For example, something along the lines of “All Components with existing requirements under PRC-005-2 will continue to follow the PRC-005-2 implementation plan.  Those Components and/or Facilities newly introduced by PRC-005-6 (including Sudden Pressure Relaying, Automatic Reclosing Components, and Distributed Generation Resources) will be covered by the following implementation plan: followed by the timelines laid out beneath each PRC-005-6 heading in the existing implementation plan draft.  We believe such wording would provide some improved clarity.  Also, please see SERC PCS comments.

Stanley Beasley, On Behalf of: Georgia Transmission Corporation - SERC - Segments 1

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Molly Devine, On Behalf of: Molly Devine, , Segments 1

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OCC supports the project team’s proposal to consolidate the implementation plans for the five in-process PRC-005 standards.  We believe that without a combined implementation plan, extensive confusion could result as each version independently takes effect.  OCC finds the consolidated implementation plan to be clear and the time frames reasonable.

Venona Greaff, On Behalf of: Oxy - Occidental Chemical, , Segments 7

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Jeri Freimuth, On Behalf of: APS - Arizona Public Service Co., WECC, Segments 1, 3, 5, 6

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We agree with the PSMTSDT on combining the Implementation Plans for the previous versions of PRC-005 (including PRC-005-3, PRC-005-3i, PRC-005-3ii, PRC-005-4 and PRC-005-5). We are concerned that FERC approval will occur too late to avert PRC-005-3 implementation, which is effective 4/1/2016.  The SDT timeline is to file PRC-005-6 with FERC in December 2015.  Therefore, we request that NERC formally recommend that FERC delay the enforcement of the earlier versions of this standard until PRC-005-6 has been finalized (balloted and implemented) in the NERC Standards Development Process. In our opinion, the various versions of this standard has caused confusion amongst the industry on what goals need to be accomplished by each of the drafting teams assigned to the development of the respective standards. We firmly believe that this suggested approach will be productive and efficient in getting all goals met in the standards development process especially, in reference to this particular family of standards.

 

 

The comments expressed herein represent a consensus of the views of the above-named members of the SERC EC Protection and Control Subcommittee only and should not be construed as the position of SERC Reliability Corporation, its board, or its officers.

SERC PCS, Segment(s) 1, 10, 7/10/2015

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Texas RE noticed the Implementation Plan has no reference to Table 4-3 implementation requirements.

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

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While we do agree, we are concerned that FERC approval will occur too late to avert PRC-005-3 implementation, which is effective 4/1/2016.  The SDT timeline is to file PRC-005-6 with FERC in December 2015.  Furthermore, since we prefer to begin a Calendar Year on January 1st our plan is to begin PRC-005-3 on 1/1/2016.

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

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NPCC--Project 2007-17.4 , Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 7/10/2015

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Entergy supports comments by SERC PCS group.

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1, 5

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We agree with the PSMTSDT on combining the Implementation Plans for the previous versions of PRC-005 (including PRC-005-3, PRC-005-3i, PRC-005-3ii, PRC-005-4 and PRC-005-5). We are concerned that FERC approval will occur too late to avert PRC-005-3 implementation, which is effective 4/1/2016.  The SDT timeline is to file PRC-005-6 with FERC in December 2015.  Therefore, we request that NERC formally recommend that FERC delay the enforcement of the earlier versions of this standard until PRC-005-6 has been finalized (balloted and implemented) in the NERC Standards Development Process.  In our opinion, the various versions of this standard has caused confusion within the industry on what goals need to be accomplished by each of the drafting teams assigned to the development of the respective standards.  We firmly believe that this suggested approach will be productive and efficient in getting all goals met in the standards development process, especially with respect to this collection of standards.

Dennis Chastain, On Behalf of: Tennessee Valley Authority - SERC - Segments 1, 3, 5, 6

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Hydro One also agrees with the IESO (Ontario) that although we generally agree with combining the subsequent Implementation Plans, we would like to reserve our judgment when the standard and its Implementation Plan are re-posted for formal comments and balloting.

Oshani Pathirane, On Behalf of: Hydro One Networks, Inc., NPCC, Segments 1, 3

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Payam Farahbakhsh, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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We agree with the PSMTSDT on combining the Implementation Plans for the previous versions of PRC-005. However, we request that NERC formally recommend that FERC delay the enforcement of the earlier versions of this standard until PRC-005-6 has been finalized (balloted and implemented) in the NERC Standards Development Process. In our opinion, the various versions of this standard has caused confusion amongst the industry on what goals need to be accomplished by each of the drafting teams assigned to the development of the respective standards. We firmly believe that this suggested approach will be productive and efficient in getting all goals met in the standards development process, especially in reference to this particular family of standards.

Finally, we would suggest the drafting team review all the newly defined terms added to PRC-005-6 in order to ensure these terms are included in relevant documentation such as The NERC Glossary of Terms and Rules of Procedure (RoP) so they will be aligned properly.

SPP Standards Review Group, Segment(s) 1, 3, 5, 7/10/2015

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We generally agree with the proposed implementation plan, but reserve our judgment when the standard and its implementation plan are posted for formal comment and balloting. Note that the March 31, 2027 date throughout the Implementation Plan document could be a typo.

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

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

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Scott Langston, On Behalf of: Tallahassee Electric (City of Tallahassee, FL), , Segments 1, 3, 5

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Karen Webb, On Behalf of: Karen Webb, , Segments 1, 3, 5

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John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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