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2019-04 Modifications to PRC-005-6 | Standard Authorization Request (Second Posting)

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Start Date: 06/02/2020
End Date: 07/08/2020

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The initial SAR draft was to provide clear guidance on the applicability scope to protective functions included in the AVR. Now the scope seems to have expanded to include protection functions that respond to electrical quantities inside other control systems (in addition to AVRs).  This may create more ambiguity and, as currently drafted, does not provide sufficient clarity to assess the impact to the PRC-005 maintenance and testing program.

BC Hydro recommends that the protective functions included in excitation systems and other applicable control systems be appropriately defined and identified to be able to assess if they should be included in PRC-005.

BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

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Please see comments submitted by the Edison Electirc Institute.

Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

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Other Answers

While Duke agrees the BES protective functions should be included in PRC-005, the SDT should ensure protections within Exciters/AVRs are well defined.  For example, there are some electrically measured quantities that are considered to be equipment protection rather than standard defined protection elements.  Control systems should also be defined to ensure elements that act to trip or cease current injection are only applicable if acting directly upon BES elements.  These considerations will be needed to avoid misinterpretation and scope creep into auxiliary systems.

Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

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Robert Hirchak, On Behalf of: Cleco Corporation, , Segments 1, 3, 5, 6

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AEP is very concerned by the inclusion of “and other control systems” in the SAR. The initial SAR was clearly and appropriately addressing protective functions within the AVRs themselves, however the most recently-revised SAR and its inclusion of the phrase “and other control systems”, and the lack of boundaries and specifics that phrase infers, not only expands the scope but essentially changes the intended purpose of PRC-005. For example, control devices with non-electrical inputs (mechanical, pneumatic, hydraulic, etc.) should not be within the scope of this standard. Not only would their inclusion change the intention and purpose of this standard, but it would also be detrimental to the synergy in which PRC-005 integrates-with and relates-to other standards.

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

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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Rahn Petersen, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments 5

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We support this SAR as it provides some direction to deal with Excitation controls related protection function. This has been a gray area in the past. We would like to see similar approach taken in PRC-005 relays when dealing with the maintenance frequencies of  protection functions in exciter controls systems based on technology, for eg. Monitored and unmonitored exciter control systems, 12 years vs 6 years etc.

 

Implementation timeframe for these requirements should be 3 years, providing sufficient time to implement any changes to maintenance systems, tasks, and frequencies.

 

Please clarify maintenance tasks on digital exciters (for example, is a setting file comparison sufficient?)

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

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Reclamation agrees that adding additional tracking and visibility of exciter protective devices and relay input sensors would close reliability gaps. However, the inclusion of additional elements may not improve reliability.

Overvoltage relays and field ground relays in AVRs are easily identified as relays and can be included in the PRC-005 maintenance program. Some entities may not use the protective functions available in the microprocessor-based DECs 400 or the ECS2100. If these protective elements were enabled, how would their functions be tested?

Reclamation recommends using a supplemental reference document, implementation guidance, or FAQ document to explain how AVR components should be tested.

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

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Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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Talen Energy supports the comments of the NAGF, particularly as regards having the expression, "trip BES elements," in the SAR be replaced by, "trip the generator," to match the language in para. 4.2.5.1 of PRC-005-6.  Protective functions that trip fans and pumps, open excitation breakers, close fuel valves and the like cause generation units to shut-down and can therefore be said to trip BES elements, but only those that (directly or through a lockout) open the generator breaker are rightly part of the Protection System. 

Donald Lock, On Behalf of: Talen Generation, LLC, , Segments 5

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The reference to other BES element control systems raises some concerns about the scope of the proposed project.  If a registered entity has a DVAR, STATCOM, WindFree, capacitor banks, or reactor banks are the protective systems on those included?  Will entities now be required to perform all of the DC control circuit checking, AC input/output checking, trip coil checking, trip checking, etc?

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

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Wayne Guttormson, On Behalf of: SaskPower, , Segments 1

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Alliant Energy supports the comments submitted by the MRO NSRF.

Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

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Dominion Energy agrees with EEi's comments that the scope of the SAR should be limited to the orginal SAR submitted by NAGF and not this completely new SAR and scope that was not reviewed by the Standards Committee or endorsed by the original party who submitted the SAR.

Dominion, Segment(s) 3, 5, 1, 9/19/2019

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CPS Energy agrees with the recommendation, however the scope shall be limited to only specific protection functions that respond only to electrical quantities as they would for microprocessor based protective relays.  In addition, the scope shall only apply to automatic voltage regulators with protection functions that are similar to stand alone protective relays as defined by PRC-005-6.

Gladys DeLaO, On Behalf of: CPS Energy, , Segments 1, 3, 5

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We believe this question is too vague, since control functions of an excitation system also respond to electrical quantities.  The facilities under section 4.2.5.1 specify Protection Systems that act to trip the generator directly or via lockout or auxiliary tripping relays.  We are concerned that including protective functions inside control systems could inadvertently bring into scope protection systems for non-BES elements that reside inside plant control systems that trip the generator directly. From our perspective the intention of this SAR is that functions which provide protection for the generator or field are covered, and this should be clearly specified. We would also like clarity on devices that provide exciter ground protection by checking for the presence of a ground by applying a recommended test quantity.

mark fowler, On Behalf of: Ameren - Ameren Services - SERC - Segments 1

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IPL agrees that these types of protective functions are important, but is not convinced there is sufficient cause to assume that existing maintenance activities already employed by utilities are not sufficient; IPL does not believe that requiring additional oversight and/or maintenance cycles is necessary. 

Colleen Campbell, On Behalf of: AES - Indianapolis Power and Light Co., , Segments 3

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Basin Electric supports comments drafted by the NAGF.

Jerry Horner, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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On May 9, 2019, the North American Generator Forum (NAGF) submitted the original SAR for Reliability Standard PRC-005-6, "Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance," to clarify the applicability of PRC-005-6 to the protective functions within an Automatic Voltage Regulator (AVR) and provide the prescribed maintenance activities. The SAR also requested that the PRC-005-6 Supplementary Reference and FAQ be updated to reflect the changes to the standard.

The SAR was originally drafted by the Nuclear Energy Institute (NEI) and the NAGF following multiple discussions with NAGF members on open conference calls in the fall of 2018 and spring of 2019 to review and challenge the scope and wording.  The SAR was carefully worded and reviewed by the NAGF members to be clear that the request was intended to be limited only to the "protective functions" of the AVR and limited to a Generator Owner (GO) that owns a synchronous generating unit with an installed digital AVR.  The SAR was also communicated in advance and discussed with NERC prior to submittal.

The updated SAR currently posted for comment appears to have expanded the scope significantly from the original wording of the NAGF SAR and evolved into a draft that the NAGF can no longer support.  Specifically, the scope is now expanded as written to "other control systems" that respond to electrical quantities and act to cease injecting current (75 MVA or greater) or trip BES elements either directly or via lockout or auxiliary tripping relays" and was not the intent of the original request.  Such an expansion of scope will have significant impacts on entity maintenance programs without justified reliability benefits.

Furthermore, the expansion into battery-based station DC technologies or "other emerging technologies" is also not supported by the NAGF given there is no definition for either term and therefore no limit on the interpretation of such technologies.  Once an emerging technology is clearly defined then the applicability and application of the PRC-005-6 tables can be modified.

For these reasons the NAGF requests that the SAR drafting team revert back to the original SAR as previously submitted on May 9, 2019 and limit this project to providing clear guidance on the scope and applicability of Automatic Voltage Regulator (AVR) protective functions on a synchronous generating unit with an installed digital AVR.

The revision can sufficiently address the question of applicability of the Standard to AVR protective funcitions by either a)  adding a footnote to "Protection Systems" to indicate that this includes any actively used protective relaying functions contained within the program logic of the excitation control system on a synchronous generator or  b) by modifying the Facilities section 4.2.5.4 to indicate the same. 

Wayne Sipperly, On Behalf of: NAGF, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1, 2, 3, 6

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NA

LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, RF - Segments 1

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

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Tacoma Power agrees that PRC-005 should include certain protective functions in the AVR.  The in-scope protective functions within the AVR should be limited to electrical quantities measured at the generator terminals. Other protection functions such as those associated with the field (eg. field ground, field current which may not be feasible to measure) and internal AVR protection (eg. failure of the thyristor, controller failure) should not be included.

Jennie Wike, On Behalf of: Tacoma Public Utilities (Tacoma, WA) - WECC - Segments 1, 3, 4, 5, 6

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Oklahoma Gas & Electric supports Edison Electric Institute's response to Question 1.

OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

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WEC Energy Group does not agree that protective functions that respond to electrical quantities inside excitation systems and other BES element control systems should be included in PRC-005. 

Applicability section 4.2.1 clearly states that  this standard applies to Protection System and Sudden Pressure Relaying that are installed for the purpose of detecting Faults on BES Elements. AVR is the control system installed for the purpose of controlling the excitation system and any protection functions internal to the controls is for the purpose of detecting a malfunction of the excitation system and it’s controls. This is in contrast to Protection Systems which are installed to detect Faults in BES Elements.

In addition, NERC PRC-019 differentiates between generator voltage regulator controls and generator Protection Systems.

Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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Fannie Champagne, On Behalf of: Hydro-Qu?bec Production, NPCC, Segments 1, 5

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

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This is beyond the scope of interest (and expertise) of many of the members of the IEEE Energy Storage and Stationary Battery (ESSB) Committee.  As a result we will abstain from a Yes or No Vote or comment on this point.

Christopher Searles, On Behalf of: IEEE Energy Storage and Stationary Battery Committee, NA - Not Applicable, Segments NA - Not Applicable

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AZPS supports the original SAR submitted by the NAGF to include Automatic Voltage Regulator protective functions.  AZPS does not agree with the expanded Scope of the SAR which now includes “emerging technologies” as this is an undefined term that could have wide and varied interpretations resulting in a very broad and unbounded scope.

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

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TVA agrees with the comments of the NAGF and supports  providing clarity regarding applicability of digital AVRs that have protective relay functions.  Furthermore, TVA disagrees with significant expansion of scope in the modified SAR and the resulting departure from criteria language currently in version 6.  This departure is implied where the SAR broadens the application of the phrase “directly trip or trip via a lockout or auxiliary tripping relays” to include BES Elements in general, instead of only generators as stated in PRC-005-6, and in the associated Supplementary Reference.

The version 6 Supplementary Reference (p.6) documents that the V6 SDT intended for PRC‑005‑6 Section 4.2.1 to address non-generator BES Elements with base criteria that PRC-005 applies to “Protection Systems and Sudden Pressure Relaying  that are installed for the purpose of detecting Faults on BES Elements (lines, buses, transformers, etc.)”.  Similarly, Sections 4.2.5 and 4.2.6, where the direct trip/lockout language currently resides, currently addresses BES Generators.  To apply the direct trip criteria to non-generator BES Elements would represent a significant and unnecessary expansion in the scope of PRC-005 applicability.  For instance, consider an Auxiliary Station Service transformer fed from a BES bus with double breakers in the switchyard of a generating facility.  A Stations Service Transformer not fed from the generator bus and whose Protection System has no direct ability to trip the generator would currently have no applicability under 4.2.5 or 4.2.6.  If the language in the SAR is replicated in the revised standard, the protection system of the described transformer would be brought into PRC-005 applicability because it directly trips the double breaker BES tie bus.

The purpose of the original SAR was to improve clarity in applying PRC-005 to digital AVRs.  TVA objects to the additional scope in the modified SAR.  When taken with the application of the direct trip clause to apply generically to all BES Elements, the clause “act to cease injecting current,” serves to negate some or all of the potential improvement in clarity originally sought.  Does the cessation of injecting current apply to a certain class of technology, for instance, inverter based generation?  The use of this phrase without clearly stating the scope of applicability is just one example of why TVA cannot support the modified SAR as written.

Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

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Additional clarification is requested on the devices and equipment included in the scope for the referenced “other control systems”. From previous PRC-005 audit experiences of cooperatives, this type of ambiguity has led to unintended audit scope creep. It is important to identify which BES elements are included in the control systems in the purview of this SAR . It is expected that the SDT will provide the specific applicable equipment/systems in the revised standard after proper engineering research and outreach.


In addition to the project scope outlined in the SAR, it is recommended that a revision to PRC-005-6 be added to the scope to clearly define the applicability found in Section 4.2.1 to state BES Lines, transformers, and buses including breakers associated with each of those elements. This language would clarify the exact items Regional Entities are requesting during requests for information. The inclusion of
“etc.” in the standard does not provide the desired clarity.

ACES Standard Collaborations, Segment(s) 1, 5, 3, 7/8/2020

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We agree that protection elements embedded with the software of digitial excitation control systems on synchronous machines need to be included in the class of microprocessor based protection.  We, like others, have been including them in the PRC-005 Protection System Maintenance Program for many years.  We disagree with the relevance and need to include any revision of this standard to "other BES element control systems".  The implication that the clarifying changes of this revision apply to dispersed power-producing resources from the point of aggregation (greater than 75 MVA) to the point of Interconnection is contradictory to the function and systhesis of the dispersed power-producing plant voltage regulators.  There are no excitation control systems for dispersed power-producing resources whose includion in the BES scope requires aggregation.   Further, Power Plant Control (PPC) systems used at renewable energy sites which include voltage regulating functions are control systems explicitly and do not include protection elements as do the synchronous machine excitation control system devices.    

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

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Minnkota Power Cooperative supports comments submitted by the MRO NERC Standards Review Forum.

Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1

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Our position is that this is beyond intended scope of the standard.

Randy Cleland, On Behalf of: GridLiance Holdco, LP, , Segments 1

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EEI supports the original SAR submitted by the NAGF to provide clarity on the scope of applicability to the Automatic Voltage Regulator protective functions.   The revised scope of the SAR has been expanded to include issues that go beyond the original intent of the NAGF request, have no apparent relationship to the request, and are not technically justified.   This SAR now appears to propose to expand that scope from protective functions to control functions, which includes equipment capabilities and limits without justification.

While the existing definition of Protection System provides sufficient language to ensure that protective functions regardless of where they reside (e.g., Automatic Voltage Regulators (AVRs) and other control systems) are included within PRC-005, we acknowledge that GO compliance with PRC-005-6, as it relates to AVRs, is not clear.  Moreover, as an alternative, Implementation Guidance may be a more effective solution for addressing many of the NAGF concerns.  That said, we would not oppose adding language within PRC-005-6 that adds greater clarity to better address NAGF concerns related to this issue. 

Additionally, the Scope for this SAR should not include “emerging technologies.”  While EEI supports efforts to modify existing standards or create new standards to address reliability gaps, it is not clear what gap the inclusion of “emerging technology” is intended to address.  Moreover, PRC-005-6 already includes “Protection System Station dc Supply Using Non Battery Based Energy Storage,” so it is unclear what other new technology the SDT intends to address. 

One area that may require SDT attention is Table 1 of Reliability Standard (PRC-005-6) which may not be sufficiently explicit to define generator resource protective functions and associated maximum maintenance interval and maintenance activity that should be conducted to address AVR maintenance.

For these reasons, EEI does not support the proposed SAR as currently written.

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

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SRC PRC005, Segment(s) 1, 2, 7/8/2020

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Westar Energy and Kansas City Power & Light, Evergy Companies, incorporate by reference, Edison Electric Institute's response to Question 1.

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

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The original SAR proposed by NAGF was to clarify the applicability to digital AVR systems. The drafting team has expanded the issue to include other control systems. In our opinion, this will increase confusion regarding applicability and the testing burden, and delay a revision to the standard. Protective functions that are clearly defined, and performed by common protective relays, should be included when implemented as part of the excitation system.

Ginette Lacasse on behalf of PUD #1 Chelan County, Segment(s) 5, 3, 1, 6, 7/6/2020

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Specifically, the scope is now expanded as written to "other control systems" that respond to electrical quantities and act to cease injecting current (75 MVA or greater) or trip BES elements either directly or via lockout or auxiliary tripping relays" and was not the intent of the original request.  Such an expansion of scope will have significant impacts on entity maintenance programs without justified reliability benefits.

 

Due to the lack of clear guidance on the scope and applicability of the Excitation systems /Automatic Voltage Regulator (AVR) on PRC-005.  Excitation system includes several controls, limiting and protective functions – control functions regulate specific quantities at the desired level, and the limiting functions prevent certain quantities from exceeding set limits and these are examined closely and reported as part of PRC-019.

 

We agree fundamentally that any BES protective function that responds to electrical quantities inside excitation systems and other BES Element’s control systems that would operate in the same manner as a protective relay should be included in PRC-005. It is important to note that a protective relay is a device designed to trip a circuit breaker when a fault is detected. Therefore it is imperative that the SDT makes a clear differentiation between a control system that is responding to electrical quantities by adjusting generator output in response to a variation in system conditions as these types of control systems do not actually trip the generation offline, are not associated with a protective relay and therefore are entirely independent of a Protection System.

 

The revised standard should remain “technology neutral”. While an AVR does respond to electrical quantities, not all AVR’s contain protective functions that would trip the generation offline.

 

Clarification that the control system protective function must meet the functionality of a protective relay with the ability to trip a circuit breaker when certain conditions are met is required. Control system is a broad term and there are many variations of “control system” that respond to electrical quantities that affect the output of generation but do not trip the generation offline. For example, because a wind farm generation site’s typical voltage control is through a proprietary digital control system, and not an automatic voltage regulator (AVR) as typically seen on conventional generation, the SAR should clarify that this type of digital technology will not require maintenance and testing activities per PRC-005-6.  Typically, these proprietary digital control devices will switch to power factor mode if automatic voltage regulation fails, and will not cause a trip of generation either directly or via lockout or auxiliary relays.

NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/8/2020

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We echo AEP's comments (.a-b-48756)

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

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Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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James Baldwin, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

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Texas RE agrees with the proposed inclusions for the Standard Authorization Request (SAR).  Texas RE does, however, seek clarification regarding the location of in-scope protective functions.  In particular, Texas RE notes that the current SAR provides that “BES Protection Systems and protective functions applied on generators, dispersed power-producing resources from the point of aggregation (greater than 75 MVA) to the point of Interconnection.”  The current SAR then states that protective functions enabled within “other control systems, that respond to electrical quantities and act to cease injecting current (75 MVA or greater) or trip BES elements either directly or via lockout or auxiliary tripping relays are within the scope of the standard.”

 

In Texas RE’s experience, past momentary cessation events involving dispersed power production resources occurred as a result of control system issues at the individual turbine level, resulting in BES generators ceasing to inject current or tripping of BES elements.  Moreover, Texas RE is not currently aware of many protective functions within control systems at the plant control level (75 MVA or greater) that act to cease injecting current or trip BES elements in this manner.  Accordingly, Texas RE seeks clarity whether “other control systems” responding to electrical quantities and acting to cease injecting current would include control systems at the individual turbine level that can result in momentary cessation or BES element trips in this manner.  From a reliability perspective, Texas RE recommends including such individual turbine level protective functions within the scope of the proposed SAR.

Texas RE does note that there are other protective functions, including voltage control protective functions, which are not related to electrical signals or power measurement.  Texas RE recommends the drafting team consider such protection systems within this scope of this project as well.

In addition, Texas RE has a few addition suggestions, as shown by section below.

 

Industry Need Section

  • Since current is not measured in MVA and thus the phrase “75 MVA or greater”, should not be used.  Texas RE recommends using a different phrase such as “cease injecting current”, “cease injecting current to the BES” or “cease injecting current”, which is used in the Project Scope and Detailed Description sections.  

  • Since “Station” is not a defined term, it should not be capitalized.

 

Purpose or Goal Section

  • Since “Station” is not a defined term, it should not be capitalized.

 

Project Scope Section

  • Since “Interconnection” is used in the context of “point of Interconnection” and not the context of the NERC Glossary-defined term, it should not be capitalized.

 

Requested Information

 

  • Since “Interconnection” is used in the context of “point of Interconnection” and not the context of the NERC Glossary-defined term, it should not be capitalized.

Other

Texas RE has experienced confusion regarding Table 1-4.  For example in Table 1-4(f), the formatting has led some to pick any Component Attribute to exclude a maintenance activity. It was not clear that each exclusion of a maintenance activity has a specific Component Attribute associated with it.  In Table 1-4(b), the formatting has led some to pick an interval for a maintenance activity that is not associated with that interval.  Reformatting the table where the entirety of the rows connect would solve such a misinterpretation.

 

     

     

     

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

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    Exelon concurs with the comments provided by the EEI and offers the following additional feedback.  

    On May 9, 2019, the North American Generator Forum (NAGF) submitted the original SAR for Reliability Standard PRC-005-6, "Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance," to clarify the applicability of PRC-005-6 to the protective functions within an Automatic Voltage Regulator (AVR) and provide the prescribed maintenance activities. The SAR also requested that the PRC-005-6 Supplementary Reference and FAQ be updated to reflect the changes to the standard.  The SAR was limited only to the "protective functions" of the AVR and limited to a Generator Owner (GO) that owns a synchronous generating unit with an installed digital AVR. 

     

    The updated SAR currently posted for comment appears to have expanded the scope significantly from the original wording of the NAGF SAR and evolved into a draft that Exelon cannot support without revision.  Specifically, the scope is now expanded as written to "other control systems" that respond to electrical quantities and act to cease injecting current (75 MVA or greater) or trip BES elements either directly or via lockout or auxiliary tripping relays" which was not the intent of the original request.  The definition of Protection System includes protective functions within control systems while the proposed SAR expands that definition to also include non-protective functions (i.e., control functions) within that definition.  Such an expansion of scope will have significant impacts on entity maintenance programs without justified reliability benefits. 

     

    Our understanding is that the SAR drafting team intended the SAR to be limited to protection systems associated with other control systems, not expanded to control systems in general. 

    Therefore, Exelon is either requesting that the SAR be reverted back to the original SAR submitted by the NAGF or revised as follows:

     

    "PRC-005-6 will be revised to provide clarity that the protective functions enabled within excitation systems (including analog/digital Automatic Voltage Regulators (AVRs)), and protective functions of other control systems, that respond to electrical quantities and act to cease injecting current (75 MVA or greater) or trip BES elements either directly or via lockout or auxiliary tripping relays are within the scope of the standard.

     

    Furthermore, the expansion into battery-based station DC technologies or "other emerging technologies" is also not supported by Exelon given there is no definition for either term and therefore no limit on the interpretation of such technologies.  Once an emerging technology is clearly defined then the applicability and application of the PRC-005-6 tables can be modified.

     

    If the SAR reverts back to the original wording, the revision can sufficiently address the question of applicability of the Standard to AVR protective funcitions by either a) adding a footnote to "Protection Systems" to indicate that this includes any actively used protective relaying functions contained within the program logic of the excitation control system on a synchronous generator or  b) by modifying the Facilities section 4.2.5.4 to indicate the same.  

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

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    DTEE supports comments submitted by the NAGF.

    DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

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    Applicability of AVRs would largely be dependent on the settings for each case, i.e., whether an AVR is set for operation or protection purposes. AVRs set on the maximum range will typically rely on relays for protection, whereas those set to trip earlier are performing a protective function and have more merit to being included. In addition, AVR verification is already being performed pursuant to other Standards, such as MOD-026-1, for which AVR testing might not be in the right place for PRC-005, rather than expanding other Standards to include AVR testing.

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

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    Eversource Group, Segment(s) 3, 1, 4/12/2019

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    We disagree with the first 2 paragraphs of the comment form submitted by NPCC RSC.

    We agree with the remainder of the comments except for the comment regarding exclusion of digital technology not requiring maintenance and testing activities as per PRC-005-6 (such as the casd for wind farm generation’s voltage control through a proprietary digital control system and not an automatic voltage regulator (AVR) as typically seen in conventional generation.). 

    We do not support the last three paragraphs of the comment form as submitted by NPCC RSC. 

    Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

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    FE Voter, Segment(s) 1, 3, 5, 6, 4, 10/31/2019

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    BPA believes testing of trip paths that take BES equipment out of service is good practice. Trips that come from non-BES excitation systems but trip BES equipment through a lockout or other auxiliary relay(s) should be tested. If NERC proceeds, BPA recommends that any equipment included have its own table in PRC-005, with maintenance tasks and cycles, that are supported by data on failure modes, level of risk to the BES systems, and best practices for these specific Protection Systems.

    Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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    Xcel Energy supports the comments of the Edison Electric Institute (EEI).

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

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    NV Energy believes that AVRs are not Protection Systems, under the current definition, and should not be included explicitly within the scope of future revisions of PRC-005-6.  Although the AVR measures the same electrical quantities as the protective relays, its exclusion from consideration resides in its primary function of excitation control, and not system protection.  The primary protective function of the AVR or excitation control system are to specifically protect the exciter, and not BES equipment (i.e. generator and GSU).  Generator protective relays primary function is to protect the generator, and are already sufficiently covered by PRC-005-6. NV Energy does acknowledge that GO compliance with PRC-005-6, as it relates to AVRs, is not clear. Moreover, as an alternative, Implementation Guidance may be a more effective solution for addressing many of the NAGF concerns.

    Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

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    Seattle City Light does not believe that it is prudent to add the AVR functions to the protection systems maintenance program.  The AVR is meant to control generator voltage and not to provide any sort of protection functions.  As such there are numerous relays functions that already detect under excitation, loss of field, reverse power - etc.  Adding AVR functions to this would be redundant and would add unnecesssary burden for testing and maintenance.  Specifically changes in AVR settings for protection functions may trigger the need to do generator verifications or testing which can be tricky depending upon the amount on geneators and entity operates. 

    Also it seems as if some of the proposed additions for this SAR are already accouted for in other standards as well such as PRC-024.  By setting the limiters correctly and operating the machines within those limits in should not spur the need to have the AVR being included in the PRC-005 program.

    The final point is a question.  How many trips are being caused by AVR related functions anyway?  Is it enough that it would even warrant addition to the PRC-005-6 standard?  Is it such a pervasive issue in the industry that it merits addtion to a standard, or even it's own stand alone standard?

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

    - 0 - 0

    Hot Answers

    BC Hydro recommends that the protective functions included in excitation systems and other applicable control systems be appropriately defined and identified to be able to assess if they should be included in PRC-005.

    BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

    - 0 - 0

    Please see comments submitted by the Edison Electirc Institute.

    Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

    - 0 - 0

    Other Answers

    None.

    Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

    - 0 - 0

    Robert Hirchak, On Behalf of: Cleco Corporation, , Segments 1, 3, 5, 6

    - 0 - 0

    AEP does not agree with revising the definition of Protection System to address the concerns regarding PRC-005. It is important to differentiate between sensing devices and inputs which truly protect the system from those devices and inputs used to monitor the stability and regulation of the system. As a result, we do not believe it is advisable to revise the definition of Protection System. Instead, we recommend a new definition be developed for “Stability Monitoring System” for identifying those devices and inputs which are specificially tasked with maintaining system stability.

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

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    Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

    - 0 - 0

    Rahn Petersen, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments 5

    - 0 - 0

    The above definition provided in the Glossary of terms should not be changed, as it provides a clear meaning of the protection function. If protection functions in generator exciter controls need added to the PRC-005 standard that should be dealt with outside of the definition, similar to how auto reclose functions etc. were added to the PRC-005 standard, using the Applicability section similar to 4.2.7

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

    - 0 - 0

    There are several terms in the definition of Protection System that cause confusion if expanded to control systems. Reclamation suggests that one possible cause is the difference between relays and other control circuitry capable of sending a trip signal. If a sudden pressure switch is tested and the relay is tested, there are no additional components that produce such a signal. The same is true for microprocessor relays used in recloser systems. Currently recloser control circuitry testing requirements cause considerable challenges with microprocessor relays.

    Reclamation supports clarifying the scope of PRC-005 to include protective functions embedded in control systems. Reclamation recommends the SDT identify the intended components in a Table and describe the component attributes, maintenance activities, and maximum maintenance intervals.

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

    - 0 - 0

    Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

    - 0 - 0

    Talen Energy supports the comments of the NAGF, noting also that it has already been well-established that a PRC-005-6 relay is not necessarily a discrete device.  A line of code that responds to electrical quantities and opens the generator breaker directly or through a lockout falls under Table 1-1 of the standard whether the programming is in the AVR (e.g. for V/Hz protection) or in a multifuction microprocessor relay.  The Protection System definition is correct as-is, but so terse as to lack clarity.  The SAR should stick to the original intent of establishing clarity in PRC-005 and in the associated Supplementary Reference and FAQ document, saying that AVRs may harbor relays, using the existing Protection System definition.

    Modifying the Protection System definition to include functions that "measure similar quantities and may yield similar outcome as protective relays," would consitute a massive change and increase rather than reduce the amount of confusion, and should not be attempted.  Elements that trip fans and pumps, open excitation breakers, close fuel valves and the like are not and should not be included in the Protection System definition.  This point is especially important for modern gas turbine units, for which the OEM control system has many protective functions that the user cannot adjust and some that we can't even see.

    Donald Lock, On Behalf of: Talen Generation, LLC, , Segments 5

    - 0 - 0

    Given the scope of the SAR, it is logical that the definition is considered for revision, however, we recommend caution as to the extent of change, given the potential to impact other standards, see question 5.

    MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

    - 0 - 0

    Wayne Guttormson, On Behalf of: SaskPower, , Segments 1

    - 0 - 0

    Alliant Energy supports the comments submitted by the MRO NSRF.

    Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

    - 0 - 0

    Dominion Energy agrees with comments submitted by EEI.

    Dominion, Segment(s) 3, 5, 1, 9/19/2019

    - 0 - 0

    No, the current definition does not create confusion.  Excitation and other control systems are clearly not identified in current definition, therefore maintenance for these devices should not be applicable to PRC-005-6.  If a revision is made to the standard, it should clearly identify the Excitation system as an individual protection system component with maintenance activities listed under the same table for microprocessor protective relays or a separate table.

    Gladys DeLaO, On Behalf of: CPS Energy, , Segments 1, 3, 5

    - 0 - 0

    The standard through Table 1-1 in PRC-005-6 provides different activities for unmonitored versus monitored microprocessor relays. An AVR or other control system with protective functions may consist of many components assembled in one cabinet. At what point do the subparts have to be treated as being subject to different requirements in the standard?

    We agree that the definition of Protection System is unclear and we support modifications or additional reference documentation. In the context of PRC-005 specifically, we believe it should only apply to Protection Systems that protect the BES, which for generation specifically would be the field and armature.

    mark fowler, On Behalf of: Ameren - Ameren Services - SERC - Segments 1

    - 0 - 0

    IPL agrees with the NAGF comments.  The definition of Protection Systems as currently written only creates confusion if expanded to control systems.  

    Colleen Campbell, On Behalf of: AES - Indianapolis Power and Light Co., , Segments 3

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    Basin Electric supports comments drafted by the NAGF.

    Jerry Horner, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

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    The definition of Protection Systems as currently written only creates confusion if expanded to control systems which the NAGF does not support. The NAGF could support a change or note to clarify the applicability is limited to the protective functions within an installed digital (AVR) of a synchronous generating unit.

    Wayne Sipperly, On Behalf of: NAGF, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1, 2, 3, 6

    - 0 - 0

    American Transmission Company (ATC) supports modification of the NERC Glossary of Terms “Protection System” definition, provided that the modifications are consistent with proposed changes to the standard related to AVR.

    LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

    - 0 - 0

    Expand protective relay to devices that perform protective functions. Clarify that protective functions for bullets 2, 4, and 5 are referring to those in the first bullet (i.e. not sudden pressure relays).

    Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, RF - Segments 1

    - 0 - 0

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

    - 0 - 0

    Tacoma Power supports changing the definition to include “protective functions”. However, as discussed in our comment to question 1 above, discretion should be used to determine what is included in the definition of “protective function”. The protective functions should be limited to only those functions that impact the overall reliability and security of the BES.

    Jennie Wike, On Behalf of: Tacoma Public Utilities (Tacoma, WA) - WECC - Segments 1, 3, 4, 5, 6

    - 0 - 0

    Oklahoma Gas & Electric supports Edison Electric Institute's response to Question 2.

    OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

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    WEC Energy Group does not agree that the definition of Protection System includes the controls associated with AVRs.  Any protective functions embedded into control system within the AVRs are used to detect malfunctions of the AVR.

    Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

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    Fannie Champagne, On Behalf of: Hydro-Qu?bec Production, NPCC, Segments 1, 5

    - 0 - 0

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

    - 0 - 0

    This is beyond the scope of interest (and expertise) of the many of the members of the IEEE Energy Storage and Stationary Battery (ESSB) Committee.  As a result we will abstain from a Yes or No Vote or comment on this point.

    Christopher Searles, On Behalf of: IEEE Energy Storage and Stationary Battery Committee, NA - Not Applicable, Segments NA - Not Applicable

    - 0 - 0

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

    - 0 - 0

    TVA cannot support this change.  The definition of Protection Systems as currently written creates confusion only if expanded to include control systems.  TVA could support a change or note to clarify the applicability is limited to the protective relaying functions in the programmable logic of a digital (AVR) on a synchronous generating unit.

    The basic criteria for applicability of a programmable digital AVR should be restricted to include only the functions in such systems that respond to electrical quantities and trip a generator either directly, or via a lockout or auxiliary tripping relay when performing the function of a protective relay.  Phrases such as “may measure similar quantities and may yield similar outcome” introduce unacceptable ambiguity to the process of determining applicability.

    Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

    - 0 - 0

    ACES Standard Collaborations, Segment(s) 1, 5, 3, 7/8/2020

    - 0 - 0

    We believe that sufficient instructions within PRC-005 can serve to make it clear that entities using the excitation control system based protection functions within the microprocessor-based program are to perform the minimum maintenance activities that are present in Table 1-1 for the microprocessor based relays (non-monitored and monitored, as appropriate).    We do not believe that the NERC Glossary definition needs to be revised.  Stating that Table 1-1 applies, and possibly modifying the title of Table 1-1 title from "Component Type - Protective Relay" to "Component Type - Protective Relay and protective functions enabled within AVRs".   The addition of device numbers is not recommended because not all AVR manufacturers use them within the control programs of their equipment and the scope of PRC-005 is already clear to protection engineers.  Again, including other control systems in the question is beyond the scope of the clarification request. 

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

    - 0 - 0

    Minnkota Power Cooperative supports comments submitted by the MRO NERC Standards Review Forum.

    Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1

    - 0 - 0

    Randy Cleland, On Behalf of: GridLiance Holdco, LP, , Segments 1

    - 0 - 0

    Generally, protection functions have traditionally resided in protective relays but now reside within a wide range of devices and systems. That said, the current definition for Protection System may create some confusion with protective functions embedded in control systems since the definition currently specifies protective relays, which is an undefined term, but generally well understood.  For this reason, EEI could support changes that clarify that protective functions within control systems are to be maintained under the PRC-005 Reliability Standard. 

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

    - 0 - 0

    SRC PRC005, Segment(s) 1, 2, 7/8/2020

    - 0 - 0

    Westar Energy and Kansas City Power & Light, Evergy Companies, incorporate by reference, Edison Electric Institute's response to Question​ 2

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

    - 0 - 0

    The confusion comes from expansion of the first bullet from "protective relays" to include voltage regulators and other control systems. Expanding the definition to include "protective functions" in other technologies than "protective relays" should be done carefully such that more confusion is not created. Chelan suggest that protective functions be defined as only those standard device/function numbers identified in Section 3 of IEEE Standard C37.2 that respond to electrical quantities.

    Ginette Lacasse on behalf of PUD #1 Chelan County, Segment(s) 5, 3, 1, 6, 7/6/2020

    - 0 - 0

    Yes, we agree that the definition creates confusion because the current definition of the protection system is protective relay centric. It should be technology or equipment neutral and focuses on protective functions.

    NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/8/2020

    - 0 - 0

    We echo AEP's comments (.a-b-48757)

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

    - 0 - 0

    Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    James Baldwin, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

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

    - 0 - 0

    The definition of Protection Systems as currently written only creates confusion if expanded to control systems which Exelon does not support.

    Exelon concurs with the EEIs comments on the question. 

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

    - 0 - 0

    DTEE supports comments submitted by the NAGF.

    DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

    - 0 - 0

    LDWP believes that the current Protection System definition is clear and should continue to exclude AVR. There can be AVRs that do not serve any protective functions. Revising the definition would require establishing how to differentiate between an AVR being a protective device versus being a control device. How would a revised definition apply to other control systems, such as PLCs?

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

    - 0 - 0

    Include this as a facility and not change the definition. 

    Eversource Group, Segment(s) 3, 1, 4/12/2019

    - 0 - 0

    We agree with the comments submitted by NPCC RSC and have an additional comment.

    Protection systems are aimed at interrupting a current that flows into the protected equipment.  In most cases, this is done by tripping breakers that are in series with the equipment.  But when it comes to series compensation systems, the tripping logic is reversed: instead of tripping breakers, a protection system has to close breakers that are in parallel with the protected equipment.

    The way the Standard is written, focus is being placed on “tripping” and “trip coils”, but the actual goal of a protection system is to “remove” an equipment from a circuit whether by tripping or closing breakers.

    Thus, both the PRC-005 Standard and the Glossary definition of “Protection System” should consider these reversed logic protection schemes so that the action of a protective function is not limited to tripping breakers or other interrupting devices.

    Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

    - 0 - 0

    FE Voter, Segment(s) 1, 3, 5, 6, 4, 10/31/2019

    - 0 - 0

    BPA disagrees that the definition is vague in this area. Excitation systems that trip BES equipment are both 1) “Voltage and current sensing devices providing inputs to protective relays” and 2) “Control circuitry associated with protective functions through the trip coil(s) of the circuit breakers or other interrupting devices.” BPA believes further definition is unecessary.

    Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

    - 0 - 0

    We support the comments of EEI.

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

    - 0 - 0

    Generally, protection functions have traditionally resided in protective relays but now reside within a wide range of devices and systems. That said, the current definition for Protection System may create some confusion with protective functions embedded in control systems since the definition currently specifies protective relays, which is an undefined term, but generally well understood. For this reason, NV Energy agrees that the definition creates confusion, but not as it relates to protective functions embedded in control systems. Thus, NV Energy would support changes to the definition that clarify that protective functions within control systems are to not be maintained under the PRC-005 Reliability Standard.

    Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

    - 0 - 0

    No.  The AVR only provides inputs and is not sensing electrical quantities - it is an electrical quantity.  It does not fit this definition and does not belong in the guidelines of a Protection System.  As stated above the function of an AVR is to provide voltage regulation for the generator - there are already adequate protection functions provided by the generator relays.

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

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    Hot Answers

    BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

    - 0 - 0

    Please see comments submitted by the Edison Electirc Institute.

    Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

    - 0 - 0

    Other Answers

    None.

    Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

    - 0 - 0

    Robert Hirchak, On Behalf of: Cleco Corporation, , Segments 1, 3, 5, 6

    - 0 - 0

    The drafting team may wish to also consider how their proposed revisions may or may not be impacted by continuing, future innovations in technology.

     

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

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    Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

    - 0 - 0

    Rahn Petersen, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments 5

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    These technologies need a clearer definition before they can be included in to PRC-005 standard, otherwise a vague inclusion may leave the standard open to interpretation and confusion.

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

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    Reclamation recommends the term “emerging” is too subjective and should be clarified. It is unclear which technologies that do not use conventional batteries are intended to be included.

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

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    Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

    - 0 - 0

    Talen Energy supports the comments of the NAGF.

    Donald Lock, On Behalf of: Talen Generation, LLC, , Segments 5

    - 0 - 0

    MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

    - 0 - 0

    Wayne Guttormson, On Behalf of: SaskPower, , Segments 1

    - 0 - 0

    Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

    - 0 - 0

    Dominion Energy agrees with the comments submitted by EEI. This proposal is not technically supported or justified and should not be included in the project.

    Dominion, Segment(s) 3, 5, 1, 9/19/2019

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    CPS Energy agrees only if the emerging Protection System Station DC supply technologies do not fall under what is already identified and are associated with protective functions.  Their maintenance activity requirements should be clearly listed in the maintenance tables.

    Gladys DeLaO, On Behalf of: CPS Energy, , Segments 1, 3, 5

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    We believe the standard already provides the necessary activities for non-battery DC systems. See Table 1-4(d) in PRC-005-6. We recommend modifying this table to include battery and non-battery systems not covered in the previous tables.

    mark fowler, On Behalf of: Ameren - Ameren Services - SERC - Segments 1

    - 0 - 0

    IPL does not agree with the concept of requiring maintenance activities for unspecified “emerging technologies” tied to Protection Systems.  Any element applicable under PRC-005 must be clearly defined and identified so there is no ambiguity for both the registered entity and auditors. 

    Colleen Campbell, On Behalf of: AES - Indianapolis Power and Light Co., , Segments 3

    - 0 - 0

    Basin Electric supports comments drafted by the NAGF.

    Jerry Horner, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

    - 0 - 0

    The NAGF agrees with the comments of the EEI and also does not support the proposed modifications to this SAR because the description of the technology and associated reliability gaps have not been adequately stated and explained in the SAR.  It is also unclear how the current standard does not already adequately address this technology. Proposed changes to a Reliability Standard should clearly address any reliability gaps and other industry needs within the Industry Needs section of the SAR. At this time, no justification has been provided.

    Wayne Sipperly, On Behalf of: NAGF, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1, 2, 3, 6

    - 0 - 0

    ATC does not support proposed modifications to this SAR, because the description of technologies and associated reliability gaps have not been adequately stated in the SAR. It remains unclear how the current standard does not already adequately address these technologies. Proposed changes to a reliability standard should clearly address any reliability gaps and other industry needs within the “Industry Need” section of the SAR. At this time, no justification or description of technologies have been provided.

    LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

    - 0 - 0

    It is important that future DC supplies are maintained. We feel that standard should address infrequently used technologies (i.e. manufacturer recommendations), but should be integrated into the standard with prescriptive requirements once they become commonplace. Table 1.4(d) could be expanded to include these sources  (battery and non-battery based) to address these technologies.

    Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, RF - Segments 1

    - 0 - 0

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

    - 0 - 0

    Tacoma Power supports adding the emerging technology to PRC-005. However, in order to definitely conclude that this should be added to the scope of PRC-005, Tacoma Power requests that the drafting team clarify with example emerging technologies (e.g. inverter, flywheels, chargers, etc.). This clarification does not need to be captured in the Standard, but would be helpful in subsequent webinars or implementation guidance development.

    Jennie Wike, On Behalf of: Tacoma Public Utilities (Tacoma, WA) - WECC - Segments 1, 3, 4, 5, 6

    - 0 - 0

    Oklahoma Gas & Electric supports Edison Electric Institute's response to Question 3.  

    OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

    - 0 - 0

    WEC Energy Group does not support the proposed modifications to this SAR because the description of the technology and Industry need has not been adequately stated and explained in the SAR.  Proposed changes to a Reliability Standard should clearly address any reliability gaps. It is not clear what gap the inclusion of “emerging technology” is intended to address. 

    PRC-005-6 already includes “Protection System Station dc Supply Using Non Battery Based Energy Storage,” so it is unclear what other new technology the SDT intends to address.

    Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

    - 0 - 0

    Fannie Champagne, On Behalf of: Hydro-Qu?bec Production, NPCC, Segments 1, 5

    - 0 - 0

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

    - 0 - 0

    The expanding use of lithium-ion (several varieties), flow batteries, flywheels and other emerging energy storage technologies are and will continue play an expanded role in all areas of electric utility functions (transmission, power generation, and distribution).  Also the increasing role of distributed energy resources utilizing these technologies interconnecting with the grid (bulk power system) make it essential that maintenance and safety related issues be addressed with guidance/requirements adopted in PRC 005-6.  The actual placement in the standard and its relationship to other published standards including NFPA 855 (and thereby other installation and maitnenance standards) which references NERC PRC 005 can be properly solidified. 

    Christopher Searles, On Behalf of: IEEE Energy Storage and Stationary Battery Committee, NA - Not Applicable, Segments NA - Not Applicable

    - 0 - 0

    AZPS does not agree with the expanded Scope of the SAR which now includes “emerging technologies” as this is an undefined term that could have wide and varied interpretations resulting in a very broad and unbounded scope.

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

    - 0 - 0

    TVA does not support this proposed modification to the subject SAR.  The description of the potential new technology and any associated reliability gaps have not been adequately stated and explained in the SAR.  It is also unclear how the current standard does not already adequately address this technology, assuming there is indeed a reliability gap. 

    Proposed changes to a Reliability Standard should include a clearly identified reliability gap and describe how that gap would be addressed by the proposed change.  Merely not having maintenance activites established in PRC-005 for undefined “emerging” technologies is not necessarily a reliability gap unless the technologies are in broad use and have recognized best-practice maintenance activities on which to base minimally essential and achievable required maintenance activities to list in the standard.

    Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

    - 0 - 0

    ACES Standard Collaborations, Segment(s) 1, 5, 3, 7/8/2020

    - 0 - 0

    Non Battery Based energy storage protection system station dc supply maintenance requirements are already included in Table 1-4(d) of PRC-005-6.    

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

    - 0 - 0

    Minnkota Power Cooperative supports comments submitted by the MRO NERC Standards Review Forum.

    Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1

    - 0 - 0

    Randy Cleland, On Behalf of: GridLiance Holdco, LP, , Segments 1

    - 0 - 0

    EEI does not support the proposed modifications to this SAR because the description of the technology and Industry need has not been adequately stated and explained in the SAR.  It is also unclear how the current standard does not already adequately address this technology.  Proposed changes to a Reliability Standard should clearly address any reliability gaps and other industry needs within the Industry Needs section of the SAR.  At this time, no justification has been provided nor has the increased scope been approved by the Standards Committee.

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

    - 0 - 0

    No comment

    SRC PRC005, Segment(s) 1, 2, 7/8/2020

    - 0 - 0

    Westar Energy and Kansas City Power & Light, Evergy Companies, incorporate by reference, Edison Electric Institute's response to Question​ 3.

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

    - 0 - 0

    CHPD recognizes that there are Registered Entities that are currently using batteries and other DC supply methods (for Protection System DC supply) that are not covered by Table 1-4 (DC Supply/Battery/Battery Charger Table) of the standard.  Any change to Table 1-4 should be very clear as to what DC supply equipment, applicability, and what maintenance activities are expected.  Performance-based alternative approaches should be included consistent with IEEE standards.

    Ginette Lacasse on behalf of PUD #1 Chelan County, Segment(s) 5, 3, 1, 6, 7/6/2020

    - 0 - 0

    It must be clear that this is only pertaining to the DC supply for the Protection System. Maintenance items for Protection System DC supply should not be confused with maintenance activities for DC technologies which are installed for any other purpose (i.e. supplying services to the BES).

     

    Another consideration is as technology evolves the standard should not limit the use of new technologies that are not contemplated by the standard. It will be important to avoid specifically defining what these technologies are in order to allow entities to use the new technologies.

     

    It is proposed that the SAR drafting team modify the SAR to more clearly describe the technology it believes PRC-005 presently applies and excludes, and to more directly state the reliability gap that is being addressed. It is also unclear how the current standard does not already adequately address this technology.  Proposed changes to a Reliability Standard should clearly address any reliability gaps and other industry needs within the Industry Needs section of the SAR.  At this time, no justification has been provided.

    NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/8/2020

    - 0 - 0

    We echo Manitoba Hydro’s comments (.a-b-48781)

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

    - 0 - 0

    Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    James Baldwin, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    Since “Station” is not defined in the NERC Glossary, it should not be capitalized.

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

    - 0 - 0

    Exelon agrees with the comments of the EEI and also does not support the proposed modifications to this SAR because the description of the technology and associated reliability gaps have not been adequately stated and explained in the SAR.  It is also unclear how the current standard does not already adequately address this technology.  Proposed changes to a Reliability Standard should clearly address any reliability gaps and other industry needs within the Industry Needs section of the SAR.  At this time, no justification has been provided.

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

    - 0 - 0

    DTEE supports comments submitted by the NAGF.

    DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

    - 0 - 0

    Additional information is required regarding the specific DC supply technologies proposed for addition.

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

    - 0 - 0

    PRC-005 Table 1.4(d) describes non-battery based energy storage maintenance, so there already is a table for non-battery based DC supplies. However if Lithium Ion or other technologies are the concern, this would be out of scope for this SAR and we recommend that this concern be handled with another SAR.

    Eversource Group, Segment(s) 3, 1, 4/12/2019

    - 0 - 0

    We agree with the comments submitted by NPCC RSC.

    Furthermore, the current Standard is not technology neutral regarding batteries associated with the Protection System Station dc supply. Requirement R1 part 1.1 of the current PRC-005-6 standard requires: “All batteries associated with the station dc supply Component Type of a Protection System shall be included in a time-based program as described in Table 1-4 and Table 3”. Table 1-4(d) provides requirements for Non Battery Based Energy Storage, but for a battery technologies that are not covered in Tables 1-4(a) to 1-4(c) there is no alternatives provided in Table 1-4. Thus entities with battery technology that are not covered by Table 1-4 cannot apply time-based interval of requirement R1. The Standard does not allow for performance-based maintenance activities to ensure that the intend of the Standard is met for the Protection System Station dc supply.

    Currently, Hydro-Quebec and other entities are considering the replacement of existing battery with new battery technology based on Lithium-ion and sodium-nickel-chloride for example. These new batteries chemistry are not identified in PRC-005-6 and compliance concerns due to technology-specific tables are causing undue restrictions and adverse impact on the competitiveness as defined in section 2.3 of the Standards Processes Manual.

    Hydro-Québec is considering using lithium-ion batteries, specifically LFP type (lithium ferrophosphate) in 5 of its substations in the short term. Since there is no long-term data on the performance to define time-base intervals, the battery will be monitored with a Battery Management System (BMS).

    Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

    - 0 - 0

    FE Voter, Segment(s) 1, 3, 5, 6, 4, 10/31/2019

    - 0 - 0

    BPA believes testing of proven, acceptable, Protection System Station DC supply technology is good practice. If NERC proceeds, BPA recommends that any equipment included have its own table in PRC-005, with maintenance tasks and cycles, that are supported by data on failure modes, level of risk to the BES systems, and best practices for these specific Protection System Station DC supply technologies (battery-based and non-battery-based).

    Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

    - 0 - 0

    We support the comments of EEI.

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

    - 0 - 0

    NV Energy shares EEI's comments on that we do not support the proposed modifications to this SAR because the description of the technology and Industry need has not been adequately stated and explained in the SAR. It is also unclear how the current standard does not already adequately address this technology. Proposed changes to a Reliability Standard should clearly address any reliability gaps and other industry needs within the Industry Needs section of the SAR. At this time, no justification has been provided nor has the increased scope been approved by the Standards Committee.

    Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

    - 0 - 0

    The SAR was worded very vaguely.  If there are DC supply technologies (or emerging technologies) that serve the exact purpose of what is already included in the defintion then it is already covered and this is redundant.  The items should already be included because they are DC systems supporting protection functions. 

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

    - 0 - 0

    Q:

    4. Entities registered as ULFS-only DPs have PRC-005-applicable Protection Systems, but are not expressly listed as Applicable Entities in Section 4.1. UFLS-only DPs should be added to the Applicability Section to avoid any confusion and to be consistent with the FERC-approved RBR registration changes. Project 2017-07 Standards Alignment with Registration Do you agree with adding UFLS-only DPs as a Functional Entity applicable to PRC-005 to align with registration? If you do not agree, or if you agree but have comments or suggestions, provide your recommendation or proposed modification below.

    Hot Answers

    BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

    - 0 - 0

    Please see comments submitted by the Edison Electirc Institute.

    Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

    - 0 - 0

    Other Answers

    None.

    Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

    - 0 - 0

    Robert Hirchak, On Behalf of: Cleco Corporation, , Segments 1, 3, 5, 6

    - 0 - 0

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

    - 0 - 0

    Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

    - 0 - 0

    Rahn Petersen, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments 5

    - 0 - 0

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

    - 0 - 0

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

    - 0 - 0

    PacifiCorp has no answer for this question

    Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

    - 0 - 0

    Talen Energy supports the comments of the NAGF.

    Donald Lock, On Behalf of: Talen Generation, LLC, , Segments 5

    - 0 - 0

    MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

    - 0 - 0

    Wayne Guttormson, On Behalf of: SaskPower, , Segments 1

    - 0 - 0

    Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

    - 0 - 0

    Dominion, Segment(s) 3, 5, 1, 9/19/2019

    - 0 - 0

    CPS Energy agrees that UFLS-only DPs should be added to the Applicability Section to avoid any confusion and to be consistent with the FERC-approved RBR registration changes.

    Gladys DeLaO, On Behalf of: CPS Energy, , Segments 1, 3, 5

    - 0 - 0

    None.

    mark fowler, On Behalf of: Ameren - Ameren Services - SERC - Segments 1

    - 0 - 0

    Not applicable to IPL.

    Colleen Campbell, On Behalf of: AES - Indianapolis Power and Light Co., , Segments 3

    - 0 - 0

    Basin Electric has no opinion.

    Jerry Horner, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

    - 0 - 0

    The NAGF does not have an opinion or comment related to the applicability of entities registered as ULFS-only DPs.

    Wayne Sipperly, On Behalf of: NAGF, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1, 2, 3, 6

    - 0 - 0

    NA

    LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

    - 0 - 0

    Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, RF - Segments 1

    - 0 - 0

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

    - 0 - 0

    Tacoma Power supports adding the “DP - UFLS Only” registered function to the Applicable Entities in Section 4.1. 

    Jennie Wike, On Behalf of: Tacoma Public Utilities (Tacoma, WA) - WECC - Segments 1, 3, 4, 5, 6

    - 0 - 0

    OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

    - 0 - 0

    Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

    - 0 - 0

    Fannie Champagne, On Behalf of: Hydro-Qu?bec Production, NPCC, Segments 1, 5

    - 0 - 0

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

    - 0 - 0

    This is beyond the scope of interest (and expertise) of many of the members of the IEEE Energy Storage and Stationary Battery (ESSB) Committee.  As a result we will abstain from a Yes or No Vote or comment on this point.

    Christopher Searles, On Behalf of: IEEE Energy Storage and Stationary Battery Committee, NA - Not Applicable, Segments NA - Not Applicable

    - 0 - 0

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

    - 0 - 0

    TVA has no comment related to the applicability of entities registered as ULFS-only DPs and abtains on this question.

    Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

    - 0 - 0

    ACES Standard Collaborations, Segment(s) 1, 5, 3, 7/8/2020

    - 0 - 0

    Yes, provided that there are not any DPs with UFLS systems for which PRC-005-6 is not applicable.  If there are, then the addition of this entity to the applicability will cause confusion and is not recommended.   

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

    - 0 - 0

    Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1

    - 0 - 0

    Randy Cleland, On Behalf of: GridLiance Holdco, LP, , Segments 1

    - 0 - 0

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

    - 0 - 0

    SRC PRC005, Segment(s) 1, 2, 7/8/2020

    - 0 - 0

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

    - 0 - 0

    Not applicable to CHPD as we are not registered as a UFLS only DP.

    Ginette Lacasse on behalf of PUD #1 Chelan County, Segment(s) 5, 3, 1, 6, 7/6/2020

    - 0 - 0

    Yes, this change should be made to correspond with the NERC’s Rules of Procedure Appendix 5B: Statement of Compliance Registry Criteria.

    NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/8/2020

    - 0 - 0

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

    - 0 - 0

    Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    James Baldwin, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

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

    - 0 - 0

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

    - 0 - 0

     DTEE abstains on commenting related to the applicability of entities registered as ULFS-only DPs.

    DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

    - 0 - 0

    Project 2017-07 appears to specify replacing Distribution Providers (DP) with the more-limited UFLS-only DP to the Applicability Section of PRC-005, as opposed to simply adding it.

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

    - 0 - 0

    Eversource Group, Segment(s) 3, 1, 4/12/2019

    - 0 - 0

    Yes, this change should be made to correspond with the NERC’s Rules of Procedure Appendix 5B: Statement of Compliance Registry Criteria.

    Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

    - 0 - 0

    FE Voter, Segment(s) 1, 3, 5, 6, 4, 10/31/2019

    - 0 - 0

    Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

    - 0 - 0

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

    - 0 - 0

    Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

    - 0 - 0

    This question raises a question.  How many of these entities exist and how much impact do they have on the BES?  Would it be burdensome to add them to the applicability list if they do not have components that trip BES elements?  Does their distribution level system trip large amounts of BES equipment or is it localized?  This seems to be a question of impact on the BES and also on the DP's who would be impacted by the change.

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

    - 0 - 0

    Hot Answers

    BC Hydro’s interpretation is that the protective functions within excitation systems refer to Field over current, Field over voltage, V/Hz protection, Converter fault detection, Field ground fault detection and Crowbar. BC Hydro does not rely on these protective functions within excitation controller; generator Protection System is used instead.  Most of generation exciters have electrical trip functions disabled during commissioning, and BC Hydro does not plan to include such protective functions in the future.

    BC Hydro’s view is that including protective functions that respond to electrical quantities inside excitation systems and other control systems in PRC-005 does not provide sufficient clarity on the on the impact to the scope of the BC Hydro’s PRC-005 maintenance and testing program.

    The addition of testing excitation systems’ protective functions requires fleet-wide review of exciters to confirm where these protective functions within exciters are enabled. The level of effort required to maintain excitation and other control systems’ protective functions is deemed substantial.

    Implementation of maintenance requirements and changes to preventative maintenance programs will also have additional costs deemed significant for the BC Hydro generation fleet.

    Additionally, some of the digital exciter maintenance testing may require complex software modification to enable these protective functions verifications, as the current software may not have built-in functionalities for testing purposes.

    BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

    - 0 - 0

    Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

    - 0 - 0

    Other Answers

    None.

    Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

    - 0 - 0

    Robert Hirchak, On Behalf of: Cleco Corporation, , Segments 1, 3, 5, 6

    - 0 - 0

    Protection functions within these suggested systems have designs which can be very specialized and contain confidential design information that may allow only specific parties to work-on and maintain with a high degree of accuracy. Such constraints would likely lead not only to logistical challenges, but quite possibly cost impacts as well due to the confidential and specialized knowledge requirements necessary to work on the equipment. The SDT will need to consider how such specialized, proprietary designs could be properly maintained for those functions in a way that would not be unduly burdensome in effort or cost.

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

    - 0 - 0

    Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

    - 0 - 0

    Rahn Petersen, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments 5

    - 0 - 0

    Aligning maintenance requirements so the frequencies are multiples of each other will reduce station visits. For example VLA batteries have a 4 month interval for specific checks, then a 18 month interval for more detailed checks. The two checks don’t align and the result is additional station visits and costs.

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

    - 0 - 0

    Reclamation recommends providing language to clarify what is meant by “control system;” e.g., “PRC-005-6 will be revised to provide clarity that the protective functions enabled within excitation systems (including analog/digital Automatic Voltage Regulators (AVRs) and other control systems that respond to electrical quantities…”. Reclamation also recommends that the SAR Drafting Team perform a cross-walk between PRC-005-6, PRC-019-2, MOD-025, and MOD-026 to ensure that efforts concerning voltage regulator testing are not duplicated across multiple standards.

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

    - 0 - 0

    Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

    - 0 - 0

    Talen Energy supports the comments of the NAGF.

    Donald Lock, On Behalf of: Talen Generation, LLC, , Segments 5

    - 0 - 0

    The NSRF has concerns that there may be a significant amount of time and resources required to evaluate all applicable generation assets for their functions and limiter points.  Additionally, all GOs would need to develop procedures to test (verify) the protective functions of the exciter, inverter, or other control systems (AVR) and identify test equipment that could be used to inject signals to simulate high and low conditions.  The fact that it does not seem practical to test/trigger the protections with the unit running also adds to the complexity and cost.  Many small GOs would have to depend on outside resources (engineering consultants) to perform these tests with an unknown cost.  Due to the significant cost and resource demands required by this change, we would recommend the consideration of a longer implementation plan. 

    There is another potential significant burden associated with the explicit inclusion of Automatic Voltage Regulation (AVR) or its equivalent wind / solar voltage regulation protection systems.  The explicit inclusion of these protection systems into PRC-005-6 potentially ties these systems into the TPL-001-5 redundancy requirements.  The MRO NSRF recommends the SAR scope clearly exempt synchronous and asynchronous AVR protection systems from TPL-001-5 due to the unnecessary burden it would impose.  The redundancy burden is significant and would not significantly impact BES reliability.  The MRO NSRF isn’t aware of any BES events where non-redundant AVR protection was the root cause.

    MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

    - 0 - 0

    Due to the potential for significant cost and resource demands, would recommend consideration of a longer implementation plan.

    Wayne Guttormson, On Behalf of: SaskPower, , Segments 1

    - 0 - 0

    Alliant Energy supports the comments submitted by the MRO NSRF.

    Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

    - 0 - 0

    Dominion, Segment(s) 3, 5, 1, 9/19/2019

    - 0 - 0

    Yes, there will be significant logistical and cost consideration burdens to CPS Energy GO to confirm protective funtions in the automatic voltage regulator systems.  In order to confirm the protective functions, the owners will require outages and coordination with OEM vendors.  As the number of subject matter experts and available technicians continue to decrease, it could become increasingly difficult to schedule these activities in timelines established by any revisions that are made.  In order to ensure a cost effective solution, CPS Energy recommends that any activities for confirming protective functions in automatic voltage regulator systems have a maximum maintenance interval of 12 yrs.  In addition, any recent commissioning or maintenance performed on automatic voltage regulators that meet the required maintenance activities should be allowed to count towards meeting any implementation plans established.

    Gladys DeLaO, On Behalf of: CPS Energy, , Segments 1, 3, 5

    - 0 - 0

    Measuring DC quantities in an excitation system can be problematic due to the high voltage conditions.  Excitation systems with PLC-type controls, which do not easily facilitate reading settings as with relays, require special software for verifying inputs. We look forward to the Standard Drafting Team's considerations for testing strategies of excitation systems and we recommend a separate table entry for AVR devices specifically.

    mark fowler, On Behalf of: Ameren - Ameren Services - SERC - Segments 1

    - 0 - 0

    This would involve both a feasibility study followed by actual data gathering activities. Both draw a financial and logistical burden for any utility.  IPL does not agree with the inclusion of these protective functions.

    Colleen Campbell, On Behalf of: AES - Indianapolis Power and Light Co., , Segments 3

    - 0 - 0

    Basin Electric supports comments drafted by the NAGF.

    Jerry Horner, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

    - 0 - 0

    If the scope is expanded to "other control systems" the NAGF is concerned with the significant impact to the GO/GOP maintenance and testing programs. The NAGF submitted the SAR in an attempt to provide clear guidance on applicability of AVR protective functions and to request clarity on what testing is acceptable to meet the maintenance activities prescribed by PRC-005-6. By expanding into control systems, battery-based station DC technologies and other "emerging technologies" the SAR drafting team has created more ambiguity and will create significant burden to equipment owners attempting to implement the Standard requirements.

    Wayne Sipperly, On Behalf of: NAGF, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1, 2, 3, 6

    - 0 - 0

    LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

    - 0 - 0

    These protective functions could be embedded in the control systems for assets that are managed by manufacturers under maintenance contracts (such as SVCs). Understanding and the testing of these functions will involve the manufacturers. These systems are significantly more complicated than traditional BES protection systems.

    Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, RF - Segments 1

    - 0 - 0

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

    - 0 - 0

    When drafting the phased implementation schedule, the SDT should provide sufficient time to develop appropriate testing methods and execute the testing especially for those exciters/ AVRs where testing the protective functions could be a challenge. Tacoma Power recommends providing five to six years for the implementation period.

    Jennie Wike, On Behalf of: Tacoma Public Utilities (Tacoma, WA) - WECC - Segments 1, 3, 4, 5, 6

    - 0 - 0

    OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

    - 0 - 0

    Significant financial burden will be added due to the fact that AVR equipment is usually proprietary in nature. Any servicing or testing requires manufacturer’s mobilization.

    It is unsured what would be required for testing these control system, in many cases the protective functions are buried within the code of control systems and we cannot simply inject signals to test individual functions like what is done on traditional protective systems.

    Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

    - 0 - 0

    Fannie Champagne, On Behalf of: Hydro-Qu?bec Production, NPCC, Segments 1, 5

    - 0 - 0

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

    - 0 - 0

    This is beyond the scope of interest (and expertise) of many of the members of the IEEE Energy Storage and Stationary Battery (ESSB) Committee.  As a result we will abstain from a Yes or No Vote or comment on this point.

    Christopher Searles, On Behalf of: IEEE Energy Storage and Stationary Battery Committee, NA - Not Applicable, Segments NA - Not Applicable

    - 0 - 0

    Although the cost consideration is unknown at this time, AZPS requests that the drafting team consider whether the component attribute is monitored or unmonitored when determining the maintenance frequency, which is consistent with the treatment of other components currently applicable to PRC-005-6.

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

    - 0 - 0

    A significant burden to equipment owners will result from confirmation of applicability of PRC-005 to protective relay functions in the broad grouping of exciter, inverter, or other control systems.  Based on the breadth of exciter/AVR, inverter, and control system technologies in service today, and the equally diverse methods of testing likely required, significant training hours will be required to prepare existing and new resources to perform the required tests, especially for legacy systems. 

    Additional burden will be required to evaluate all applicable configurations, develop test procedures that will satisfy new standard requirements, and develop necessary associated training content.  Implementation of newly required maintenance activities will invariably be scheduled concurrent with unit outages.  Due to these and other unexpected logistical challenges, along with the implied acknowledgement that the existing confusion has made prior exclusion of these imbedded functions likely, TVA cannot support any proposed revision of PRC-005-6 without a staged implementation approach for any new requirement or any specific components added to the applicability tables.  The duration and milestones of this staged implementation should be commensurate with those of the existing PRC-005-6 implementation plan.

    Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

    - 0 - 0

    Cost analysis and length of the implementation period should be assessed within the scope of the SAR to allow applicable entities to determine accurate implementation cost. The following are factors for consideration:

    • Identifying all the applicable elements by GOs will require additional evaluation and creation of compliance documentation to address the newly identified elements. Considering the global pandemic and prolonged uncertainty, industry resources are even more constrained, and implementing the suggested changes without a proper detailed implementation plan will take additional time and incur additional costs, which have yet to be defined or even understood.
    • Testing protection systems oftentimes requires units to go offline. Therefore, the scope should define what course of time and period the implementation of the revised standard will be applied.
    • Due to GOs’ limited resources and complexity with the implementation of the proposed SAR, outside resources and engineering firms will likely be required to assist GOs with testing and implementation of the standard. Reliable outside resources are limited and often costly.

    ACES Standard Collaborations, Segment(s) 1, 5, 3, 7/8/2020

    - 0 - 0

    Certainty on the cost affect of changes to PRC-005 cannot be realized until the scope of the changes is determined.  For entities not already including digital excitation control system with microprocessor based protection funnctions in their Protection System Maintenance Program will certainly incur additional costs for including the maintenance activities for those pieces of equipment during outages.   The assimilation of that equipment into the maintenance cycles will have to be allowed to be done over the normal coarse of the maintenance interval periods - up to 6 years for those entities who may have just completed a maintenance outage.  Otherwise, the requirement for an immediate outage solely to perform maintenance on this equipment for compliance with PRC-005 can be expensive due to lost generation revenue and start up costs.    

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

    - 0 - 0

    Minnkota Power Cooperative supports comments submitted by the MRO NERC Standards Review Forum.

    Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1

    - 0 - 0

    Randy Cleland, On Behalf of: GridLiance Holdco, LP, , Segments 1

    - 0 - 0

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

    - 0 - 0

    No comment

    SRC PRC005, Segment(s) 1, 2, 7/8/2020

    - 0 - 0

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

    - 0 - 0

    Testing of protective functions within exciters, inverters, and other control systems is frequently not accessible to the owner or operator. Adding these to periodic testing requirements will force us to use service calls by the supplier for the needed testing, adding cost and burden. We suggest that if the function is tested and set by the supplier at commissioning, and the software and setting are not changed, that a simple attestation to this is sufficient confirmation in lieu of a retest or examination of the code to confirm the setting.

    Ginette Lacasse on behalf of PUD #1 Chelan County, Segment(s) 5, 3, 1, 6, 7/6/2020

    - 0 - 0

    The drafting team should avoid treating these control systems as relays since they do not function in the same way as a protective relay. Therefore the methods of testing and maintaining this equipment will require careful consideration and may not align with the current requirements of relay maintenance. Considerations should be made to ensure that it is not cost-prohibitive or introduce the risk of damage to test and maintain this equipment.

    NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/8/2020

    - 0 - 0

    We echo AEP’s comment (.a-b-48760)

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

    - 0 - 0

    Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    James Baldwin, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    Texas RE suggests the drafting team consider aligning the timing of periodic requirements to other standards that are connected with the review of settings or testing of the performance of protective functions not directly associated with relays which have their own time frames.  For example, PRC-019-2 Requirement R1 requires coordination every five calendar years, while PRC-005 requires maintenance activity every 6 calendar years.  It may be helpful for these to be in aligned.

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

    - 0 - 0

    If the scope is expanded to "other control systems" Exelon is concerned with the impact to the an entities maintenance and testing programs.  The NAGF submitted the SAR in an attempt to provide clear guidance on applicability of AVR protective functions and to request clarity on what testing is acceptable to meet the maintenance activities prescribed by PRC-005-6.  By expanding into control systems, battery-based station DC technologies and other "emerging technologies" the SAR drafting team has created more ambiguity and will create significant burden to applicable entities attempting to implement the Standard requirements.

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

    - 0 - 0

    DTEE supports comments submitted by the NAGF.

    DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

    - 0 - 0

    The proposed scope expansion could require entities to carve out additional resources from existing groups or form entirely new ones to accomplish maintenance, as well as possibly involve contractors. In addition to organizing group resources, entities would have to develop training and tools with protection and plant personnel. As verifying the functionality of AVR is currently covered in MOD-026-1, it could be more cost-effective to expand that Standard as opposed to adding AVR testing to PRC-005.

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

    - 0 - 0

    No comment

    Eversource Group, Segment(s) 3, 1, 4/12/2019

    - 0 - 0

     We agree with the comment submitted by NPCC RSC. 

    In addition, any maintenance activities are required on an AVR or control system, it should be coordinated with MOD-026 activities. In addition, even if no BES protective functions are within the AVR, the SDT should consider if there will be a benefit to the reliable operation of the BES to verify that settings are as specified (no BES protection functions are enabled) and that measurement of power system input and output values are acceptable. Acceptable AC/DC voltage and current measurements are essential to proper AVR control and its verification is not specifically covered in MOD-026-1. The settings changes are covered by R4 of MOD-026-1, as it is in R3 of PRC-001-1.1(ii) for protection relays. MOD-026-1 verification is performed every 10 years whereas PRC-005-6 tables 1-1 is 12 years, SDT should consider coordinating time interval with MOD-026-1 period if a new table is added specifically for the AVR.

    Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

    - 0 - 0

    FE Voter, Segment(s) 1, 3, 5, 6, 4, 10/31/2019

    - 0 - 0

    Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

    - 0 - 0

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

    - 0 - 0

    NV Energy believes there will be an undue financial burden to Generation Owners and Operators if excitation systems are included in PRC-005 scope. Some excitation systems have proprietary control systems, and thus, cannot be internally maintained by an Entity's current staff due to inability to access system equipment to conduct maintenance testing. Therefore, Entities will be required to contract out services from the vendor to conduct the maintenance testing. The procurement of these services can be costly and time consuming. 

    AVR testing is not a widespread knowledge-based for protection and control technicians, due to the proprietary nature of the equipment, thus these personnel are not trained in AVR testing, which again will force Entities to contract the testing to specialized companies and a considerable cost.  

    Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

    - 0 - 0

    As noted in response 1 - by adding the AVR and other controls systems into the PRC-005-6 mix there are then changes being made that could precipitate the need to do generator testing, modeling and validation on schedules that are outside the normal for entities.  This drives costs up and could hurt small entities.  Also - there is a need to provide additonal training to relay crews to work in this non-protective equipment systems and will probably annoy generation engineers who now have less qualifed people making changes to their equipment.

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

    - 0 - 0

    Hot Answers

    BC Hydro, Segment(s) 3, 5, 1, 12/18/2018

    - 0 - 0

    Robert Blackney, On Behalf of: Edison International - Southern California Edison Company, WECC, Segments 1, 3, 5, 6

    - 0 - 0

    Other Answers

    None.

    Duke Energy, Segment(s) 1, 5, 6, 4/11/2019

    - 0 - 0

      “Protective Functions” is used through the SAR and the current PRC-005 standard. For clarity purposes, protective function(s) should be defined.

     

    Robert Hirchak, On Behalf of: Cleco Corporation, , Segments 1, 3, 5, 6

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

    - 0 - 0

    Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

    - 0 - 0

    Rahn Petersen, On Behalf of: PNM Resources - Public Service Company of New Mexico - WECC - Segments 5

    - 0 - 0

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

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    Reclamation recommends expanding the scope of the SAR to specify a process for carrying out maintenance that is missed during equipment overhauls or other unavailability during the required maintenance interval. Confusion has occurred on the method for performing online or energized testing when returning a unit to service. The revised standard should address the testing requirements and allowable timelines to perform the required maintenance. The timelines should permit the missed maintenance to be performed prior to returning the equipment to Commercial Operation. The measure for Requirement R3 should be updated to include documentation that allows for extension of the maintenance interval while the equipment is not connected to the BES.

    Reclamation also recommends expanding the scope of the SAR to clarify the language used in R5 for corrective maintenance activities. Specifically, Reclamation recommends the Measure M5 state the information required to be documented for each Unresolved Maintenance Issue. Examples of documentation may include, but are not limited to work orders, invoices, project schedules with completed milestones, purchase orders, procedure and/or test results.

    Reclamation requests the SDT clarify the first sentence in the “Industry Need” section. Reclamation is unsure what the present statement means; specifically, any intended correlation between the reference to “act to cease injecting current” and AVRs. Does it mean tripping the regulator? In AVR mode the regulator works by maintaining terminal voltage, not so much of injecting current. Reclamation recommends this sentence be revised and simplified for clarification.

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

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    Sandra Shaffer, On Behalf of: Sandra Shaffer, , Segments 6

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    Talen Energy support the comments of the NAGF.

    Donald Lock, On Behalf of: Talen Generation, LLC, , Segments 5

    - 0 - 0

    The SAR Drafting Team may need to review VAR-002-4.1, to address the situation where a generator is exempt from having an AVR in-service  and clarifying if the verification of limiter points and exciter functions would be required

    MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/29/2020

    - 0 - 0

    Wayne Guttormson, On Behalf of: SaskPower, , Segments 1

    - 0 - 0

    Alliant Energy supports the comments submitted by the MRO NSRF.

    Larry Heckert, On Behalf of: Alliant Energy Corporation Services, Inc., , Segments 4

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    Dominion Energy agrees with the comments submitted by EEI and is of the opinion that the new prioposed SAR is speculative and premature.

    Dominion, Segment(s) 3, 5, 1, 9/19/2019

    - 0 - 0

    CPS Energy recommends that NERC considers limiting the PRC-005-6 revision scope to only automatic voltage regulators that perform protective functions similar to stand alone protective relays that are already defined in PRC-005-6.  Limiting the scope, along with making considerations to the value and effectiveness of periodic maintenance on the microprocessor based automatic voltage regulator systems, will minimize the cost and logistical burden on the owners to maintain reliable protection systems.

    Gladys DeLaO, On Behalf of: CPS Energy, , Segments 1, 3, 5

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    n/a

    mark fowler, On Behalf of: Ameren - Ameren Services - SERC - Segments 1

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    IPL appreciates the efforts of the SAR drafting team and offers no further comments.

    Colleen Campbell, On Behalf of: AES - Indianapolis Power and Light Co., , Segments 3

    - 0 - 0

    Basin Electric supports comments drafted by the NAGF.

    Jerry Horner, On Behalf of: Basin Electric Power Cooperative, , Segments 1, 3, 5, 6

    - 0 - 0

    The project scope of the updated SAR as written has expanded the scope significantly from the original wording of the NAGF SAR and evolved into a draft that the NAGF can no longer support. The expansion of scope to "other control systems" that respond to electrical quantities and act to cease injecting current (75 MVA or greater) or trip BES elements either directly or via lockout or auxiliary tripping relays" will likely have significant impacts to GO/GOP maintenance and testing programs without any explained reliability benefit.

    The expansion into "battery-based station DC technologies" or "other emerging technologies" is also not supported by the NAGF given there is no definition for either term and therefore no limit on the interpretation of such technologies.

    Wayne Sipperly, On Behalf of: NAGF, MRO, WECC, Texas RE, NPCC, SERC, RF, Segments 1, 2, 3, 6

    - 0 - 0

    None

    LaTroy Brumfield, On Behalf of: American Transmission Company, LLC, , Segments 1

    - 0 - 0

    Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, RF - Segments 1

    - 0 - 0

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

    - 0 - 0

    Jennie Wike, On Behalf of: Tacoma Public Utilities (Tacoma, WA) - WECC - Segments 1, 3, 4, 5, 6

    - 0 - 0

    OKGE, Segment(s) 6, 1, 3, 5, 4/10/2019

    - 0 - 0

    Thomas Breene, On Behalf of: WEC Energy Group, Inc., , Segments 3, 4, 5, 6

    - 0 - 0

    None

    Fannie Champagne, On Behalf of: Hydro-Qu?bec Production, NPCC, Segments 1, 5

    - 0 - 0

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

    - 0 - 0

    It is the judgment of the IEEE Energy Storage and Stationary Battery (ESSB) Committee Task Force that a potentially liable situation exists with the requirements for proving the “battery can perform as manufactured. . .” in Tables 1-4 (a) and 1-4 (b) of PRC 005-6.  There is substantial industry documentation that confirms that ohmic measurement testing is not a reliable or proven means to confirm the battery can perform as manufactured. 

    Therefore we propose that references to the suggested means to prove the battery will perform as manufactured should be eliminated and allow the FAQ and Supplemental Guide to inform the user (functional entity) on the accepted means to prove performance "as manufactured” until more data is provided to show that ohmic measurement data or other alternaive means alone prove the battery can perform as manufactured.

    Implication:  The standard then only states that the user (functional entity) must prove the battery will perform as manufactured. This corrects an implication in the standard that ohmic measurements or float current readings are an assured means for proving capacity or reliability of the battery.  The FAQ and Supplemental Guide provides solid reference to the issues associated with ohmic measurements and other methods to  prove “battery performance as manufactured," including the most reliable method used by the stationary battery industry to prove the requirement.  By removing the relative particulars from the tables, the responsibility for determining the method to prove the Table 1-4 (a) and Table 1-4 (b) requirements is put on the functional entity.  

    The standard is then clear of any liability for prescribing the accuracy (or inaccuracy) of any stated means as a requirement while sustaining the intended actual requirement of proving the battery will perform as manufactured. 

    The IEEE ESSB Committee offers to provide a knowledgeable member or two with seasoned BESS experience from its Committee to assist the SAR drafting team in appropriately working on the two dc power related issues addressed above (Questions 3 & 6).

    Christopher Searles, On Behalf of: IEEE Energy Storage and Stationary Battery Committee, NA - Not Applicable, Segments NA - Not Applicable

    - 0 - 0

    None

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

    - 0 - 0

    TVA finds the additional scope and the associated ambiguity of the modified SAR unacceptable.  Specifically, use of the following has departed from the original intent of the NAGF/NEI proposal and would create more ambiguity, confusion, and burden on all BES equipment owners, not just GO/GOP entities, if not extensively moderated to a more narrow scope or eliminated altogether:

    • Other control systems
    1. This was not included in the scope or intent of the original NAGF/NEI SAR.
    2. This phrase is over-inclusive and ambiguous.  Consideration of such a change in scope should be part of a subsequent revision so that the industry will have adequate time for consideration and participation in developing another SAR.  Prerequisite to such consideration would be establishment of a bright line between control functions and protective functions in a control system.  Consequently, TVA supports NAGF’s request to revert back to the scope of the original SAR submitted on May 9, 2019.  
    • Excitation systems (including analog/digital AVRs)”
    1. Expansion of the original scope which did not include analog AVRs is unacceptable. Any requirement to inject signals and activate outputs is widely recognized as being very difficult, of not prohibitively infeasible.
    • "May measure and utilize similar quantities as protective relays and may perform similar functions as protective relays” (in the SAR); 

    Protective functions that are typically (but not always) associated with relays” (in the SAR);

    May measure similar quantities and may yield similar outcome” (in this form)

    1. Use of these or similar phrases in the revised standard would increase ambiguity and confusion significantly over what exists today in PRC-005-6.  The potential breadth of interpretations would create an intolerable environment for compliance, especially in conjunction with “other control systems.”  
    • Act to cease injecting current
    1. Without further specificity, TVA cannot support the use of this phrase in lieu of existing applicability criteria.
    • Trip BES Elements either directly or via lockout or auxiliary tripping relays;” 

    “The clarifying changes would apply to BES Protection Systems and protective functions applied on generators, dispersed power-producing resources from the point of aggregation (greater than 75 MVA) to the point of Interconnection, static and synchronous condensers and other BES elements as defined.”

    1. At first glance, the drafting team’s intention seemed to be to focus on generation elements, but the generic term of BES Elements again represents a significant expansion of scope.  This is unacceptable in that it would unnecessarily blend the non-generator applicability criteria with the generator applicability criteria, confusion and inconsistency would ensue, all without improvement to reliability. 
    2. One might assume “greater than 75 MVA” is a reference to the entirety of Inclusion I4 of the BES definition, but taken with the overwhelming ambiguity in the rest of the document, could the SAR team be suggesting elimination of the 100kV or higher criteria for dispersed generation?  

    Finally, why is the “New Standard” box checked on the modified SAR form?  Isn’t the SAR proposing a revision of PRC-005-6? 

    Tennessee Valley Authority, Segment(s) 1, 3, 5, 6, 9/7/2017

    - 0 - 0

    Thank you for the opportunity to comment.

    ACES Standard Collaborations, Segment(s) 1, 5, 3, 7/8/2020

    - 0 - 0

    The SAR needs to be revised to match the original SAR produced by the NAGF and address only the issues raised in that version.       1.  The SAR type should be "Revision to Existing Standard" rather than "New Standard"   2.  The scope of the SAR should be limited to the initiating source of the reason for the SAR and not widened to other topics.   3.   The revision can sufficiently address the question of applicability of the standard to excitation control systems by either a)  footnoting "Protection Systems" to indicate that this includes any actively used protective relaying functions contained within the program logic of the excitation control system or  b)  by modifying the Facilities section 4.2.5.4 to indicate the same.   The following action is recommended to address the maintenance activity request in the SAR:   Since the programming, testing, and functionality of generator protective relaying elements in use within excitation control systems is essentially identical to that provided by multi-function microprocessor-based discrete protective relaying, the appropriate maintenance activities match those for microprocessor relays found in the existing Table 1-1 of PRC-005-6.   These 6 calendar year activities are:   1)  verify that the settings in the device, 2)  verity the digital inputs & outputs are functional,  3)  verify that the analog inputs are transduced properly (analog/digital conversion).  We believe that no additional discussion or specification of the myriad of possible protective relaying functionality and testing methods is necessary or needed.   The test methods are similar to those used for microprocessor-based protective relays.  As with other discrete multi-function microprocessor-based protective relaying, only those elements that are chosen to be used in the protective device should be in the scope of maintenance activities required by PRC-005.  No revision to the Supplementary Reference and FAQ document is needed because the existing sections addressing microprocessor-based protective relaying already covers that functionality which may exist within excitation control systems rather than within free-standing, discrete, multi-function, microprocessor-based protective relaying solutions.  

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

    - 0 - 0

    Minnkota Power Cooperative supports comments submitted by the MRO NERC Standards Review Forum.

    Andy Fuhrman, On Behalf of: Minnkota Power Cooperative Inc. - MRO - Segments 1

    - 0 - 0

    Randy Cleland, On Behalf of: GridLiance Holdco, LP, , Segments 1

    - 0 - 0

    The Project Scope, as currently written, appears to expand on what is meant by the undefined term “protective function.”  While the defined term Protection System includes protective functions associated within control circuitry, it does not clearly identify those protective functions.  More importantly, control circuitry is generally understood by the Industry to mean control wiring, not control systems.  While it is reasonable to accept that protective relays and protective functions are synonymous, control functions have a very different meaning.  While we recognize that improvements to the definition of Protection System may be beneficial, it should not include control functions in that definition.   

    It is also important to recognize that the proposed SAR goes well beyond what the NAGF originally intended. It is this expansion that we believe could result in the blurring of the lines between protection and control functions having many unintended long-term consequences.

    EEI also cautions against modifying NERC Reliability Standards to address “emerging technologies” until it has been demonstrated that those technologies have been adopted by the industry and are not already adequately addressed in the current body of NERC Reliability Standards.  Emerging technologies is also an undefined term that could have wide and varied interpretations resulting in a broad and unbounded scope that should not be approved.

    EEI recognizes that industry guidance is needed to support GOs in developing PRC-005 maintenance programs, given the advances in control systems and the merging of protection functions within generator control systems.  However, the problem does not lie within the existing definition of Protection Systems.

    EEI additionally notes that the SAR has been incorrectly identified as developing a “New Standard” while the language contained in the SAR indicates a “Revision to Existing Standard”.

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

    - 0 - 0

    We thank the drafting team's responses to our last comments submitted

    SRC PRC005, Segment(s) 1, 2, 7/8/2020

    - 0 - 0

    Westar Energy and Kansas City Power & Light, Evergy Companies, incorporate by reference, Edison Electric Institute's response to Question 6.

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

    - 0 - 0

    The need is to resolve the confusion regarding electrical protection functions performed by digital voltage regulators. Expansion may be needed as other digital control systems implement more protective functions, but doing so at this time will delay the resolution of the primary question raised with little benefit.

    Ginette Lacasse on behalf of PUD #1 Chelan County, Segment(s) 5, 3, 1, 6, 7/6/2020

    - 0 - 0

    Please consider changing the “SAR Type” to read as “Revision to Existing Standard” instead of “New Standard.”

     

    1.      In the “Industry Need” section, the SAR states: “… and other control systems, that respond to electrical quantities and act to cease injecting current (75 MVA or greater)…” Does this include BES Definition Inclusion 2 generation? If so, this would already be addressed in the applicability statements in PRC-005-6.

    2.       In the “Industry Need” section, the SAR states: “Without clear applicability…”. This needs to be re-stated. Applicability refers to entities. The purpose of the SAR is to define what components are considered “Relays” within the definition of Protection System, or redefining what a Protection System is and is in section 4.2 “Facilities”.

    3.      The project scope states the following: “Modify PRC-005 to provide clarity that the protective functions enabled within analog/digital AVRs, excitation systems, and other control systems that respond to electrical quantities and act to cease injecting current or trip BES elements either directly or via lockout or auxiliary tripping relays are within the scope of the standard. Modifications to PRC-005-6 could also include defining terms, revising applicability, modifying maintenance activities and intervals, or other appropriate modifications needed to provide clarity. In addition, modify the PRC-005-6 Supplementary Reference and FAQ to align with revisions to PRC-005-6.  The clarifying changes would apply to BES Protection Systems and protective functions applied on generators, dispersed power-producing resources from the point of aggregation (greater than 75 MVA) to the Point of Interconnection, static and synchronous condensers and other BES elements as defined.”

    It will be extremely difficult to appropriately capture “control systems that respond to electrical quantities and act to cease injecting current…”  Momentary cessation occurs at individual inverters. The standard is limited to only controls that impact 75MVA or greater as it is understood that individual dispersed resources do not have a significant impact on BES reliability. Due to the sheer number of these devices that may be embedded in dispersed generation resources, Maintenance and testing activities for these entities could potentially be cost-prohibitive.

    4.      The above statement also mentions “… also include defining terms, revising applicability, modifying maintenance activities and intervals, or other appropriate modifications needed to provide clarity.” If this is the case, then the appropriate boxes will need to be checked in the “SAR Type”.

    5.      The statement to modify the PRC-005-6 Supplementary Reference and FAQ should not be included in the SAR. This activity would be done outside the SAR.

    6.      It is important for the SAR language to allow flexibility for the SDT.  Currently, the SAR uses language such as “…provide clarity that the protective functions…” which leads to a presupposed position. The SDT should conduct the technical analysis to make the determinations of applicability to the standard. The SAR should be modified in recognition of the SDT purpose. 

    NPCC Regional Standards Committee, Segment(s) 10, 2, 4, 7, 3, 1, 5, 6, 7/8/2020

    - 0 - 0

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

    - 0 - 0

    Currently the SAR includes the following wording:

    “PRC-005 will be modified to provide clarity on the inclusion of protective functions enabled within excitation systems (analog/digital AVRs), and other control systems that respond to electrical quantities and act to cease injecting current or trip BES elements either directly or via lockout or auxiliary tripping relays.”

    I would like to suggest the addition of the phrase “based on those electrical quantities”  between the words “and” and “act” to clarify the intention of the paragraph.

    The revised paragraph would read:

    PRC-005 will be modified to provide clarity on the inclusion of protective functions enabled within excitation systems (analog/digital AVRs), and other control systems that respond to electrical quantities and, based on those electrical quantities, act to cease injecting current or trip BES elements either directly or via lockout or auxiliary tripping relays.”

     

    Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    Currently the SAR includes the following wording:

    “PRC-005 will be modified to provide clarity on the inclusion of protective functions enabled within excitation systems (analog/digital AVRs), and other control systems that respond to electrical quantities and act to cease injecting current or trip BES elements either directly or via lockout or auxiliary tripping relays.”

     

    I would like to suggest the addition of the phrase “based on those electrical quantities”  between the words “and” and “act” to clarify the intention of the paragraph.

    The revised paragraph would read:

    PRC-005 will be modified to provide clarity on the inclusion of protective functions enabled within excitation systems (analog/digital AVRs), and other control systems that respond to electrical quantities and, based on those electrical quantities, act to cease injecting current or trip BES elements either directly or via lockout or auxiliary tripping relays.”

    James Baldwin, On Behalf of: Lower Colorado River Authority, , Segments 1, 5

    - 0 - 0

    Since the PRC-005-6 Supplementary Reference and FAQ document was written prior to the Compliance Guidance Policy, Texas RE recommends the drafting team conduct a thorough review of the document.  The determination may need to be made as to whether or not the document should be split into an implementation guidance document and a technical rationale document rather than simply be updated to address the issues in this SAR.

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

    - 0 - 0

    Exelon concurs with the comments provided by the EEI and offers the following additional feedback.  

    The expansion of scope to "other control systems" that respond to electrical quantities and act to cease injecting current (75 MVA or greater) or trip BES elements either directly or via lockout or auxiliary tripping relays" could have an impact to maintenance and testing programs without any explained reliability benefit.  Exelon requests that if the scope is to be expanded in this manner that the SAR drafting team provide justification to support.

     

    The expansion into "battery-based station DC technologies" or "other emerging technologies" is also not supported by Exelon given there is no definition for either term and therefore no limit on the interpretation of such technologies.

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

    - 0 - 0

    DTEE supports comments submitted by the NAGF.

    DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 1/24/2020

    - 0 - 0

    As MOD-026-1 currently verifies AVR functionality on a periodic basis, there would be questionable benefit to requiring a separate maintenance window for AVR maintenance. In addition, it is useful to consider that the original intent of the SAR, as developed by NAGF, was to be limited to synchronous generating units with installed digital AVRs.

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

    - 0 - 0

    No comment

    Eversource Group, Segment(s) 3, 1, 4/12/2019

    - 0 - 0

    We agree with the comments submitted by NPCC RSC except for item number 5 regarding the PRC-005-6 Supplmentary Reference and FAQ.

    Chantal Mazza, On Behalf of: Hydro-Qu?bec TransEnergie - NPCC - Segments 1

    - 0 - 0

    N/A

    FE Voter, Segment(s) 1, 3, 5, 6, 4, 10/31/2019

    - 0 - 0

    Cain Braveheart, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

    - 0 - 0

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

    - 0 - 0

    Kevin Salsbury, On Behalf of: Berkshire Hathaway - NV Energy, , Segments 5

    - 0 - 0

    This SAR likely causes more burden than benefit to the protection and control of our BES assets.  If there is sufficient evidence to show that AVR trips are causing havoc across the interconnections perhaps it is worth further consideration.  However as it is currently written this SAR seems to add little value for the amount of effort it would entail to employ.

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

    - 0 - 0