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2018-04 Modifications to PRC-024-2 | Supplemental SAR

Description:

Start Date: 06/27/2019
End Date: 07/26/2019

Associated Ballots:

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Hot Answers

Dominion Energy does not agree that a reliability gap was identified in the proposed SAR. The orignal scope of the SAR is appropriate to address the identified and substantiated issue related to inverters during system events. The equipment mentioned in the SAR (GSUs and collector transofrmers) have nevfer been part of PRC-024. The mention in a foot note of this equipment is ONLY in reference to defining point of interconnection within the standard and inclusion 4 of the BES definition does not include or even mentions these pieces of equipment. The scope of the project should NOT be expanded to an issue that has not been substantiated and reliability risk identified.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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CenterPoint Energy Houston Electric, LLC agrees with the comments submitted on behalf of The Edison Electrical Institute.

Armin Klusman, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Other Answers

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

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

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AEP has no objections to altering the scope and direction of this project as proposed in the most recent SAR, however we do object to the manner in which it is being pursued. It appears that this “supplemental SAR” would be applied to Project 2018-04 along with the existing SAR, bringing the total number of SARs for this project to two. AEP is not aware of any precedent of multiple, concurrent SARs governing a NERC project at a single point in time. A SAR helps set a project’s direction and scope, and while a project’s SAR may be revised over time, AEP does not believe Appendix 3A of the Standards Process Manual provides an allowance for multiple, concurrent SARs to govern a single NERC project. Rather, the SPM allows a project’s existing SAR to be revised to accommodate any changes believed to be necessary. If this project’s scope or direction needs to be revised, the current and governing SAR should be revised accordingly rather than developing an additional SAR to somehow expand upon its predecessor.

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

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Bette White, On Behalf of: Bette White, , Segments 3

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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

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The Supplemental SAR is attempting to expand the scope of the PRC-024 changes beyond the intent of providing clarity for inverter response.

Allen Schriver, On Behalf of: NextEra Energy, , Segments 5

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Anthony Jablonski, On Behalf of: ReliabilityFirst , , Segments 10

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We agree with including the setting of voltage and frequency protective relays (if applied) on GSUs or collector transformers, however, there still remains a reliability gap in the scope.  The scope should also include auxiliaries critical to maintain plant output.  The supply to other critical auxiliaries like lubricating systems, governing and excitation systems that allow the generating unit to maintain its output level must also meet PRC-024 requirements for reliability.

 

Having auxiliaries trip too early on voltage or frequency which cause output to change is by definition an interaction between the plant and the power system.  The diagram in the Supplemental SAR should be amended to show the Motor Control Center (MCC) handling a critical load be subject to PRC-024 (within the shaded area), as the operation of this would result in tripping and defeat the reliability intent of the standard.  The diagram can also show a non-critical load handled by the MCC not subject to the PRC-024 (outside the shaded area) to highlight that if the tripping auxiliary does not affect that would to be P,Q, or Vt of the units, then they do not need to be included.

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

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Ameren agrees with revising the Applicability to include all relevant Registered Entities and facilities to make the standard more comprehensive, and revise the requirement language to improve the clarity and completeness of the standard.  Ameren supports this effort to ensure the voltage and frequency protection on all applicable equipment (including the GSU or collector transformer) up to the point of interconnection that could cause a generating resource to trip or cease to inject current meets the voltage and frequency ride-through requirements of PRC-024, thus enabling the generating resource to support grid stability during defined system voltage and frequency excursions.

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

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As the terms ‘GSU’ and ‘collector transformer’ appear to be used inconsistently across the industry‚Äč--clarification within the Reliability Standard or definitions may be necessary to achieve consistency.

Duke Energy, Segment(s) 1, 5, 6, 3, 7/17/2019

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Sandra Kennedy, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 1, 3, 4, 5

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Reclamation supports the scope clarification of the Supplemental SAR and recommends the figure on page 3 of the Supplemental SAR be included in the Guidelines and Technical Basis of the revised standard.

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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AZPS suggests generator side terminal voltage be used instead of the high-side voltage. Using high-side GSU voltage unnecessarily creates confusion and calculation burden, when there has been no realistic case study or other justification presented that would support using the terminal voltage or that indicates that use of the generator side terminal voltage will not be adequate. In fact, due to AVR, AZPS respectfully asserts that use of the generator terminal voltage is steadier and more appropriate than use of the high-side voltage. AZPS suggests generator side terminal voltage be used instead of the high-side voltage. Using high-side GSU voltage unnecessarily creates confusion and calculation burden, when there has been no realistic case study or other justification presented that would support using the terminal voltage or that indicates that use of the generator side terminal voltage will not be adequate. In fact, due to AVR, AZPS respectfully asserts that use of the generator terminal voltage is steadier and more appropriate than use of the high-side voltage. 

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

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Kjersti Drott, On Behalf of: Kjersti Drott, , Segments 1, 3, 5

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Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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We consider it important to subject the appropriate relays regardless of the owner. This approach is consistent with NERC's approach in other standards that require the applicability to facilities necessary to reliability, for example, FAC-008, PRC-005, PRC-025. These standards all apply to both TO and GO as function and specify the facilities subject to the standards, regardless of ownership, and there is no gap.

The extension of the applicability to the TO is justified on its technical merits and the impact to a TO without GSU would be, at worse, a bit of paperwork. If a Regional Entity were to audit a TO that does not own GSU for a version of PRC-024 that applies to TO that own GSU, which seems a bit senseless to us, the TO can fill in an RSAW easily, saying, "Not applicable because we do not own a GSU." 

As a technical quibble, we note that the Supplemental SAR defines the "point of interconnection" as the high-side of the step-up transformer (with a parenthetical remark). We think that, like in FAC-008, the standard (and the supplemental SAR) need not introduce and use the POI term. It can just use the term "high-side of the step-up transformer" directly. That said, with the parenthetical remark and the graphic, it is quite clear what is intended in the supplemental SAR.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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None

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

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V/Hz protective relay setting requirement for the GSUs or collector transformers should be added to the standard (V/Hz ride through curve).

 

Bruce Reimer, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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

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The California ISO supports the comments submitted by the ISO/RTO Council Standards Review Committee (SRC)

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

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EEI Member companies do not support the proposed Supplemental SAR because it does not provide a technical justification that describes a reliability gap that needs to be addressed.  The Supplemental SAR also does not provide a technical basis for adding new obligations to Transmission Owners (TOs) who may own Generator Step-up (GSUs) and collector transformers. 

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

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The PRC-024 was developed at a time when generators and generator step-up transformers were more often than not owned by the same asset owner.  As such coordination between generator protection schemes and associated transmission equipment may not have required any explicit requirements and the PRC-024 applicability to only the generator side of the interconnection was sufficient.  Today, with the separation of ownership of assets at the generator point of interconnection, NERC must ensure the intent of PRC-024 is met through adding explicit requirements which may or may not fall within the original construct of the standard. 

SRC, Segment(s) 2, 1, 7/25/2019

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Exelon might agree to the scope of the SAR if the Standard Drafting Team provides sufficient technical basis.  At this point in time, Exelon does not believe that sufficient technical basis has been provided to move forward with the supplemental SAR.

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

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Exelon might agree to the scope of the SAR if the Standard Drafting Team provides sufficient technical basis.  At this point in time, Exelon does not believe that sufficient technical basis has been provided to move forward with the supplemental SAR.

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

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Exelon might agree to the scope of the SAR if the Standard Drafting Team provides sufficient technical basis.  At this point in time, Exelon does not believe that sufficient technical basis has been provided to move forward with the supplemental SAR.

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

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Exelon might agree to the scope of the SAR if the Standard Drafting Team provides sufficient technical basis.  At this point in time, Exelon does not believe that sufficient technical basis has been provided to move forward with the supplemental SAR.

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

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SRP recommends the scope to only include phase over/under voltages that are enabled and not 3VO overvoltage like in the case of a zero sequence over voltage.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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We would like to request that the drafting team provide industry the opportunity to address and clarify some of the concerns with the existing draft of the PRC-024-3 language at a later time.

ACES Standard Collaborations, Segment(s) 1, 5, 7/26/2019

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LCRA Compliance, Segment(s) 6, 5, 1, 5/11/2015

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Steven Rueckert, On Behalf of: Western Electricity Coordinating Council, , Segments 10

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

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Westar Energy and Kansas City Power & Light Company endorse the Edison Electric Institute's response to Question 1.

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

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The protection elements on main station transformers have not been reported to have been nor are known to have been the cause of plant tripping due to transmission system voltage or frequency disturbances.  No established need exists relative to system reliability improvement.  The scope expansion is not needed.    The SAR fails to clearly and sufficiently identify a gap in BES reliability.

Southern Company, Segment(s) 1, 5, 6, 3, 7/26/2019

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OPG agrees with closing the reliability gap. Suggestion is made to consider the use of Main Output Transformers (MOT) instead of GSU.

Constantin Chitescu, On Behalf of: Ontario Power Generation Inc., , Segments 5

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RSC no Dominion and HQ, Segment(s) 10, 2, 4, 5, 7, 3, 1, 0, 6, 7/26/2019

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Hot Answers

Dominion Energy does not have anmy of these aseets that are owned by our Transmission Owner regitration (we are also separetly registered as a GO). We are also unaware of any other entities in the United States that fit this criteria.

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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CenterPoint Energy Houston Electric, LLC agrees with the comments submitted on behalf of The Edison Electrical Institute.

Armin Klusman, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Other Answers

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

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

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

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Bette White, On Behalf of: Bette White, , Segments 3

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Not aware of others, not applicable to BHC

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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Texas RE does not have comments on this question.

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

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Allen Schriver, On Behalf of: NextEra Energy, , Segments 5

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Anthony Jablonski, On Behalf of: ReliabilityFirst , , Segments 10

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

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

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Duke Energy, Segment(s) 1, 5, 6, 3, 7/17/2019

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Sandra Kennedy, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 1, 3, 4, 5

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Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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While there may be instances of a Transmission Owner owning a GSU or collector transformer, these are more likely to be exceptional cases or anomalies, which do not justify modifying the applicability of the standard or adding additional burden to Transmission Owners to assess applicability.

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

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Kjersti Drott, On Behalf of: Kjersti Drott, , Segments 1, 3, 5

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Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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Hydro-Québec TransÉnergie is a TO that owns the GSU associated with about 37 GW of generation which we do not own. We are not registered as a GO since we do not own any generators.

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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None

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

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Bruce Reimer, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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

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The California ISO supports the comments submitted by the ISO/RTO Council Standards Review Committee (SRC)

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

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EEI is not aware of any instances, among member companies, of the situation described in Question 2 that exists based on readily available information.  

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

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We are aware there are entities that are concerned that including the generator step up transformer as part of a generator protection standard may be inappropriate because the original intent of PRC-024 is to apply to generator protection systems. However, the importance to coordinate the protection schemes for inverter based resources and the transmission grid cannot and should not be limited to what registered entity a standard is applicable to.

SRC, Segment(s) 2, 1, 7/25/2019

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Exelon supports EEI's comments that this question alone may be insufficient to gather the data needed to identify the magnitude of this issue because all relevant parties may not choose to respond.

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

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Exelon supports EEI's comments that this question alone may be insufficient to gather the data needed to identify the magnitude of this issue because all relevant parties may not choose to respond.

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

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Exelon supports EEI's comments that this question alone may be insufficient to gather the data needed to identify the magnitude of this issue because all relevant parties may not choose to respond.

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

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Exelon supports EEI's comments that this question alone may be insufficient to gather the data needed to identify the magnitude of this issue because all relevant parties may not choose to respond.

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

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If a Generator Owner owns the generator and a Transmission Owner the GSU, they should both have PRC-024 and PRC-025 compliance responsibility of their assets and coordinate via PRC-001. This has become a gray area in the industry of who has the compliance obligation. For example, the GO doesn’t share or update the generator capability and characteristics so the TO can properly verify the associated coordination. And, it’s difficult for the TO to be responsible for tracking the GO’s generator information since it’s not their asset.

In a different example, if the GO owns the generator and the GSU, because the standard doesn’t dictate that the TO has PRC-024 or PRC-025 obligation on the intertie, this exclusion of language in the standard defeats the reliability intent.

Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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ACES Standard Collaborations, Segment(s) 1, 5, 7/26/2019

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As an organization, LCRA is registered as both TO and GO. 

LCRA Compliance, Segment(s) 6, 5, 1, 5/11/2015

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Steven Rueckert, On Behalf of: Western Electricity Coordinating Council, , Segments 10

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

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Westar Energy and Kansas City Power & Light Company incorporate by reference the Edison Electric Institute's response to Question 2.

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

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The number of TO owned main generating station transformers is believed to be very few.   In Southern Company, the number of TO owned generator step up transformers is zero.  

Southern Company, Segment(s) 1, 5, 6, 3, 7/26/2019

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OPG is not aware of such cases.

Constantin Chitescu, On Behalf of: Ontario Power Generation Inc., , Segments 5

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RSC no Dominion and HQ, Segment(s) 10, 2, 4, 5, 7, 3, 1, 0, 6, 7/26/2019

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Hot Answers

Dominion, Segment(s) 3, 5, 1, 4/6/2017

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No

Armin Klusman, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Other Answers

No other comments.

Matthew Nutsch, On Behalf of: Seattle City Light, WECC, Segments 1, 3, 4, 5, 6

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no.

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

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

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None.

Bette White, On Behalf of: Bette White, , Segments 3

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Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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NA

faranak sarbaz, On Behalf of: Los Angeles Department of Water and Power, , Segments 1, 3, 5, 6

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Texas RE recommends the SDT add “TO that owns synchronous condenser(s)” to the applicability of PRC-024, with “Synchronous condenser greater than 20 MVA (gross nameplate rating) directly connected to the Bulk Electric System” as an “applicable Facility.” This addition would make the applicability of PRC-024 consistent with PRC-019-2 and MOD-025-2, and increase the reliability of the BES by requiring large Reactive Resources remain connected during voltage excursions.

 

Additionally, Texas RE recommends the SDT consider adding any dynamic Reactive Power resource (SVC, STATCOM, D-VAR) that meet a capability threshold as “applicable Facilities”, as the loss of these resources during a voltage excursion can lead voltage instability on the BES.

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

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Allen Schriver, On Behalf of: NextEra Energy, , Segments 5

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ReliabilityFirst supports the changes. We beliveve they address the issues in the “White Paper” and remove ambiguity and add clarity.

Anthony Jablonski, On Behalf of: ReliabilityFirst , , Segments 10

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The proposed standard requires to use the nominal voltages (e.g. 230 kV) as 1 pu for the voltage boundary curves that define No Trip Zone. The operating voltages boundaries can vary significantly around the nominal voltages. For example, there are entities that operate continuously at 250 kV facilities that have the nominal voltage of 230 kV. If the nominal voltage value is used in this case, there is a risk of tripping, considering that the overvoltage settings based on the nominal voltage might not provide enough margin to cover measuring errors.

 

We propose that the scope of the Supplemental SAR is expanded to allow for some margin to be added to the defined setting points when the continuous operating voltages exceed or are below the nominal voltages (e.g., by more than 5%).

 

There is also an error in the Table on Voltage Boundary Data Points in Attachment-2 (Voltage No-Trip Boundary – Eastern, Western, and ERCOT Interconnection) of the proposed standard. 

 

The last line in the table currently shows the high voltage at less than or equal to 1.10 pu with a minimum time 4 seconds and the low voltage at greater than or equal to 0.90 pu with a minimum time 4 seconds:

“High Voltage at < 1.10 pu at Minimum Time 4.00 sec and Low Voltage at > 0.90 at Minimum Time 4.00 sec”.

 

However, consistent with the lines above, the high voltage should be at greater than or equal to 1.10 pu with a minimum time 4 seconds and the low voltage should be at less than or equal to 0.90 pu a minimum time 4 seconds.  We propose the last line in the table be modified as follows:

“High Voltage at > 1.10 pu at Minimum Time 4.00 sec and Low Voltage at < 0.90 at Minimum Time 4.00 sec”.

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

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

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Duke Energy, Segment(s) 1, 5, 6, 3, 7/17/2019

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None.

Sandra Kennedy, On Behalf of: CMS Energy - Consumers Energy Company - RF - Segments 1, 3, 4, 5

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None

Richard Jackson, On Behalf of: U.S. Bureau of Reclamation, , Segments 1, 5

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AZPS would like to reiterate its previous comments that were submitted in regards to Draft 1 of PRC-023-3.  Please modify Attachment 2, Evaluation Protection Settings, number 1. c. as follows, because there is no realistic scenario where the high side voltage will be 1.1 pu or higher and the generator voltage will be at 0.95 pf lagging. It is most realistic to use lagging pf for low voltage conditions and leading pf for high voltage conditions. 

For low voltage protection use Power factor is 0.95 lagging (i.e. supplying reactive power to the system) as measured at the generator terminals. For high voltage settings use Power factor is 0.95 leading (i.e. taking reactive power from the system) as measured at the generator terminals. 

AZPS also reiterates concern with the addition of the TO as an applicable entity shifting compliance and cost responsibility from the GO/GOPs to TO/TOPs, which are distinct, separate entities.

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

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Kjersti Drott, On Behalf of: Kjersti Drott, , Segments 1, 3, 5

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Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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We were surprised that the SDT felt it needed to use a supplemental SAR to resolve the interpretative issue the SDT ran into regarding the scope of the SAR . That said, we strongly support this approach. The use of a supplemental SAR to clarify the scope of the project already underway seems to us an efficient way of raising this issue with industry and resolving it, rather than shipping it a few years down the road into a future project.

 

 

Michael Godbout, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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None

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

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In the Voltage Boundary Clarifications – Eastern, Western, and ERCOT Interconnections section; what does “The ‘no trip zone’ ends at 4 seconds” mean? Does it mean that there is not a standard concern if the relay trips beyond the 4 second time? Why was the 4 seconds chosen? 

Bruce Reimer, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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

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The California ISO supports the comments submitted by the ISO/RTO Council Standards Review Committee (SRC)

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

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EEI member companies believe that NERC has more effective methods and tools available that they could use to collect data and identify technical justifications for reliability gaps.

 

Mark Gray, On Behalf of: Edison Electric Institute, NA - Not Applicable, Segments NA - Not Applicable

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We ask what the rationale is for using the nominal voltage and not the operating voltage for the voltage boundary curves. The operating voltages boundaries can vary significantly around the nominal voltages (e.g. 230 kV as 1 p.u.) that define the No Trip Zone. For example, if an entity operates facilities continuously at 250 kV and the nominal voltage of 230 kV 1 p.u. is used in this case, there is a risk of premature tripping considering that the overvoltage settings based on the nominal voltage might not provide enough margin to cover measuring errors.

SRC, Segment(s) 2, 1, 7/25/2019

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

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

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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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Joshua Andersen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Thank you for the opportunity to comment.

ACES Standard Collaborations, Segment(s) 1, 5, 7/26/2019

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None.

LCRA Compliance, Segment(s) 6, 5, 1, 5/11/2015

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Steven Rueckert, On Behalf of: Western Electricity Coordinating Council, , Segments 10

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Xcel Energy believes the reliability or compliance gaps described in the Requested Information section of the SAR exist for all synchronous machines GSU transformers which have microprocessor based transformer protection relays applied that have the capability to provide voltage, frequency and volts/Hz protection functions.  Virtually  all major transformer protection manufacturers provide relays with these functions available.  As such, the gaps described in the SAR are wide spread throughout the industry.  While there is likely a very small population of GSUs owned by TOs for which this type of protection is enabled, there is a very high portion of GO owned GSU which will continue to have the these reliability and compliance gaps if GSU transformer protection is excluded from the standard. 

Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC - Segments 1, 3, 5, 6

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None.

Westar-KCPL, Segment(s) 1, 3, 5, 6, 12/18/2018

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The use of a supplemental SAR for the stated purpose is not clearly aligned with guidance in the Standards Process Manual.

Southern Company, Segment(s) 1, 5, 6, 3, 7/26/2019

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The Supplemental SAR section “Purpose or Goal (How does this proposed project provide the reliability-related benefit described above?):” states the following:

“Ensure the voltage and frequency protection on all applicable equipment (including the GSU or collector transformer) up to the point of interconnection that could cause a generating resource to trip or cease to inject current meets the voltage and frequency ride-through requirements of PRC-024, thus enabling the generating resource to support grid stability during defined system voltage and frequency excursions. Project”

 

PRC-024-2 does not have frequency ride through requirements, and merely sets the requirements for the generator frequency protective relays settings. Ride through implies performance criteria.

 

Also generating resources can negatively impact the grids reliability not only by ceasing to inject current, but also through a sensible reduction of the amount of current being injected. This is not currently covered by the existing standard nor by the proposed draft.

 

Consideration should be given also to revising the existing SAR (i.e. add to the parameters of the proposed project).

 

Please see attached the OPG comments for the SDT outreach questions.

Constantin Chitescu, On Behalf of: Ontario Power Generation Inc., , Segments 5

PRC-024-3 Outreach Questions.docx

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A Standard Authorization Request (SAR) comment form should not be used to collect data needed to justify the SAR.  If data needs to be collected, then a Section 1600 data request could be considered.  After data is collected, then a determination can be made regarding next steps.  The applicability of PRC-024 should remain as Generator Owners, at this time.

RSC no Dominion and HQ, Segment(s) 10, 2, 4, 5, 7, 3, 1, 0, 6, 7/26/2019

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