2021-08 Modifications to FAC-008 | SAR

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Start Date: 12/09/2021
End Date: 01/27/2022

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Hot Answers

WEC Energy Group supports the EEI comments on the SAR.  The SAR appears to be based on a fundamental misunderstanding of the purpose of FAC-008.  Implementation Guidance to clear up this confusion may be necessary, 

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

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LDWP accounts for mechanical limitations in its ratings. For this reason, it is felt that the proposed changes relating to mechanical elements would be unnecessary.

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

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Other Answers

BHC agrees with the proposed scope as described in the SAR.

Jennifer Malon, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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On the mechanical rating side, our generator rating methodology correctly captured the turbine and other mechanical limits. This seemed to be an obvious interpretation of the standard. Manitoba Hydro doesn't believe a generator can misoperate a plant and exceed the turbine rating. There is a possibility to have a modelling error and the turbine limit is ignored. However, all the other electrical elements are considered and there would be no downstream reliability issue. Through testing, the model would eventually be adjusted to match field results. MOD-025-2 standard (Verification and Data Reporting of Generator Real and Reactive Power Capability and Synchronous Condenser Reactive Power Capability) is developed to test and verify both Real and Reactive power output of BES generators.

Nazra Gladu, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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Entergy, Segment(s) 1, 5, 12/13/2017

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AEP disagrees with the perceived industry needs provided in this SAR, and recommends that it not be pursued. The concerns addressed in the SAR regarding the determination and reporting of generating unit capability are already addressed by other standards such as MOD-025 and MOD-026, so as a result, this SAR does not advance or improve the reliability of the BES. Rather than a formal NERC Project which creates or revises existing standards and/or definitions , the author might instead consider other means in obtaining the clarity they seek.

The proposed SAR fails to distinguish between generating unit capability and thermal capability of the series path between generator and POI (point of interconnection). In transmission system modeling, parameters establishing unit capability are entirely separate from those establishing ratings of the connection facilities between the generator and the transmission grid. It is possible for a generating unit to be capable of an output greater than the rating of the facilities connecting the generator to the grid, and vice versa. Generator capabilities can be impacted by changes to the mechanical elements driving the generator. If a GO improves the capability of a unit, one needs to determine whether that increased capability can be safely transmitted to the grid. For that to be obtained, one also needs to know the electrical rating of the series path. As an example, and further demonstrating the sufficiency of the current standard, FAC-008 R1.1 states “Operational information such as commissioning test results, performance testing or historical performance records, any of which may be supplemented by engineering analyses.”

In addition, AEP believes that the existing phrase “jointly owned” as related to facilities is sufficiently clear.

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5, 6

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Tammy Porter, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

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Hot Answers

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

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

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Other Answers

It is nonsensical to solely use electrical equipment ratings for generator facility ratings because the limiting factor is thermodynamic or mechanical capability.  In facility design, electrical equipment starts with thermodynamic capability, and then has margin added to ensure that electrical equipment will never be the limiting factor.   BHC feels a unit’s actual rating should include any and all limiting factors that contribute/inhibit the actual realized capability of the unit.

Jennifer Malon, On Behalf of: Black Hills Corporation - MRO, WECC - Segments 1, 3, 5, 6

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Manitoba Hydro believes that the current FAC-008 standard does not have any reliability gaps.

Manitoba Hydro also believes that requirement R8 of the current FAC-008 standard correctly addressed the data sharing requirements for long- term and near-term planning.

Perhaps, additional compliance guidance may be required to address any NERC concerns.

Nazra Gladu, On Behalf of: Manitoba Hydro , , Segments 1, 3, 5, 6

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Entergy, Segment(s) 1, 5, 12/13/2017

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Thomas Foltz, On Behalf of: AEP, , Segments 3, 5, 6

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Tammy Porter, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

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