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2008-02.2 Phase 2 UVLS PRC-004-5 & PRC-010-5

Description:

Start Date: 02/20/2015
End Date: 04/08/2015

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2008-02.2 Phase 2 UVLS PRC-004-5 & PRC-010-2 IN 1 ST 2008-02.2 Phase 2 UVLS PRC-004-5 & PRC-010-2 02/20/2015 03/27/2015 03/27/2015 04/07/2015

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See the Unofficial Comment Form on the Project Page for additional background information.

Hot Answers

Bernard Johnson, 4/8/2015

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Terry BIlke, 4/8/2015

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Other Answers

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

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John Fontenot, 2/20/2015

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Ken Lindberg, On Behalf of: Bryan Texas Utilities, Texas RE, Segments 5

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Glenn Pressler, On Behalf of: CPS Energy, , Segments 1, 3, 5

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Ken Lindberg, On Behalf of: Ken Lindberg, , Segments 1, 5

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John Williams, 3/10/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Gul Khan, 3/23/2015

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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Dana Wheelock, On Behalf of: Dana Wheelock, , Segments 1, 3, 4, 5, 6

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Glenn Pressler, CPS Energy, 3, 3/27/2015

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Thomas Foltz, AEP, 5, 3/27/2015

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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David Jendras, Ameren - Ameren Services, 3, 3/30/2015

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Mike Smith, Manitoba Hydro , 3, 3/30/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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John Merrell, Tacoma Public Utilities (Tacoma, WA), 1, 3/30/2015

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Michael Jones, National Grid USA, 1, 3/31/2015

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Michael Shaw, 3/31/2015

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Brian Shanahan, National Grid USA, 3, 3/31/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Stephen Pogue, M and A Electric Power Cooperative, 3, 4/1/2015

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John Fontenot, 4/1/2015

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christina bigelow, 4/1/2015

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Daniel Gacek, Exelon, 1, 4/2/2015

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Shari Heino, Brazos Electric Power Cooperative, Inc., 5, 4/2/2015

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Shari Heino, Brazos Electric Power Cooperative, Inc., 5, 4/2/2015

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Chris Gowder, On Behalf of: Florida Municipal Power Agency, FRCC, Segments 3, 4, 5, 6

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Kaleb Brimhall, 4/6/2015

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Barb Nutter, On Behalf of: Other, NA - Not Applicable, Segments NA - Not Applicable

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NPCC--RSC--2008-02.2 4-7-15, Segment(s) 10, 3, 2, 1, 5, 9, 6, 8, 4/7/2015

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

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Matt Culverhouse, On Behalf of: Matt Culverhouse, , Segments 3

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Payam Farahbakhsh, Hydro One Networks, Inc., 1, 4/7/2015

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SERC PCS Proj 2008-2.2, Segment(s) 10, 1, 3, 5, 6, 4/7/2015

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Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/7/2015

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Oliver Burke, Entergy - Entergy Services, Inc., 1, 4/7/2015

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Gul Khan, 4/7/2015

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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Catherine Wesley, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Brian Evans-Mongeon, Utility Services, Inc., 4, 4/7/2015

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

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Paul Malozewski, Hydro One Networks, Inc., 3, 4/7/2015

Hydro One Comment on Project 2008-02.2.docx

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George Tatar, 4/7/2015

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ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4/7/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 4/7/2015

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Daniela Hammons, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Paul Shipps, On Behalf of: Lakeland Electric, , Segments 1, 3, 5, 6

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Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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

Hydro One's additional comments on Project 2008-02.2.docx

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Molly Devine, 4/7/2015

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Project 2008-02.2, Segment(s) 1, 4/7/2015

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Hot Answers

Bernard Johnson, 4/8/2015

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Terry BIlke, 4/8/2015

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Other Answers

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

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John Fontenot, 2/20/2015

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Ken Lindberg, On Behalf of: Bryan Texas Utilities, Texas RE, Segments 5

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Glenn Pressler, On Behalf of: CPS Energy, , Segments 1, 3, 5

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Ken Lindberg, On Behalf of: Ken Lindberg, , Segments 1, 5

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John Williams, 3/10/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Gul Khan, 3/23/2015

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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Dana Wheelock, On Behalf of: Dana Wheelock, , Segments 1, 3, 4, 5, 6

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Glenn Pressler, CPS Energy, 3, 3/27/2015

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Thomas Foltz, AEP, 5, 3/27/2015

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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David Jendras, Ameren - Ameren Services, 3, 3/30/2015

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Mike Smith, Manitoba Hydro , 3, 3/30/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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John Merrell, Tacoma Public Utilities (Tacoma, WA), 1, 3/30/2015

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Michael Jones, National Grid USA, 1, 3/31/2015

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Michael Shaw, 3/31/2015

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Brian Shanahan, National Grid USA, 3, 3/31/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Stephen Pogue, M and A Electric Power Cooperative, 3, 4/1/2015

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John Fontenot, 4/1/2015

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christina bigelow, 4/1/2015

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Daniel Gacek, Exelon, 1, 4/2/2015

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Shari Heino, Brazos Electric Power Cooperative, Inc., 5, 4/2/2015

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Shari Heino, Brazos Electric Power Cooperative, Inc., 5, 4/2/2015

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Chris Gowder, On Behalf of: Florida Municipal Power Agency, FRCC, Segments 3, 4, 5, 6

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Kaleb Brimhall, 4/6/2015

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Barb Nutter, On Behalf of: Other, NA - Not Applicable, Segments NA - Not Applicable

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NPCC--RSC--2008-02.2 4-7-15, Segment(s) 10, 3, 2, 1, 5, 9, 6, 8, 4/7/2015

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

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Matt Culverhouse, On Behalf of: Matt Culverhouse, , Segments 3

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Payam Farahbakhsh, Hydro One Networks, Inc., 1, 4/7/2015

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SERC PCS Proj 2008-2.2, Segment(s) 10, 1, 3, 5, 6, 4/7/2015

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Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/7/2015

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Oliver Burke, Entergy - Entergy Services, Inc., 1, 4/7/2015

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Gul Khan, 4/7/2015

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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Catherine Wesley, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Brian Evans-Mongeon, Utility Services, Inc., 4, 4/7/2015

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

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Paul Malozewski, Hydro One Networks, Inc., 3, 4/7/2015

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George Tatar, 4/7/2015

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ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4/7/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 4/7/2015

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Daniela Hammons, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Paul Shipps, On Behalf of: Lakeland Electric, , Segments 1, 3, 5, 6

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Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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

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Molly Devine, 4/7/2015

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Project 2008-02.2, Segment(s) 1, 4/7/2015

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Hot Answers

Bernard Johnson, 4/8/2015

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Terry BIlke, 4/8/2015

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Other Answers

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

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John Fontenot, 2/20/2015

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Ken Lindberg, On Behalf of: Bryan Texas Utilities, Texas RE, Segments 5

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Glenn Pressler, On Behalf of: CPS Energy, , Segments 1, 3, 5

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Ken Lindberg, On Behalf of: Ken Lindberg, , Segments 1, 5

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John Williams, 3/10/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Gul Khan, 3/23/2015

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Charles Yeung, On Behalf of: Southwest Power Pool, Inc. (RTO), SPP RE, Segments 2

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Dana Wheelock, On Behalf of: Dana Wheelock, , Segments 1, 3, 4, 5, 6

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Glenn Pressler, CPS Energy, 3, 3/27/2015

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PRC-010-2, R5:
UVLS entities should have input in the development of the CAP, as opposed to simply having it provided to them. We suggest adding the phrase “in accordance with the UVLS entities” so that R5 instead reads… “Each Planning Coordinator or Transmission Planner that identifies deficiencies in its UVLS Program during an assessment performed in either Requirement R3 or R4 shall, in accordance with the UVLS entities, develop a Corrective Action Plan to address the deficiencies and subsequently provide the Corrective Action Plan, including an implementation schedule, to UVLS entities…”
 

 

While AEP is supportive of the overall direction and substance of the proposed changes, we have chosen to vote negative driven by our objections to not involving the UVLS entities in the development of the CAP in R5.

Thomas Foltz, AEP, 5, 3/27/2015

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Si Truc Phan, On Behalf of: Hydro-Qu?bec TransEnergie, NPCC, Segments 1

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David Jendras, Ameren - Ameren Services, 3, 3/30/2015

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Mike Smith, Manitoba Hydro , 3, 3/30/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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The proposed revisions appear to address Misoperation identification and correction of UVLS equipment.  However, there may be some cases in which the timeframes in PRC-004-5 and PRC-010-2 are not completely compatible.  Specifically, under PRC-010-2 Requirement R4, the Planning Coordinator (PC) or Transmission Planner (TP) has 12 calendar months of an event that resulted in a voltage excursion for which its UVLS Program was designed to operate to perform an assessment to evaluate the performance (i.e., operaton and non-operation) of the UVLS Program equipment.  However, under PRC-004-5 Requirement R1, each Transmission Owner (TO) and Distribution Provider (DP) that owns a BES interrupting device that operated under the circumstances in Parts 1.1 through 1.3 only has 120 calendar days of the BES interrupting device operation to identify whether its Protection System component(s) caused a Misoperation.  It seems like a TO or DP would have to determine if there was a Misoperation before the PC or TP might have completed their assessment.  Could this result in premature determination by a TO or DP; or could a TO or DP come to a different conclusion than their PC or TP?  It seems like the timeframes in these requirements need to be better aligned.  Alternatively, perhaps only PRC-010-1 should be revised, or perhaps the distinction between what the two standards are requiring needs to be made clearer.  Another possible issue is that each standard requires development of CAPs, and the timeframes required to develop the CAPs are different.

John Merrell, Tacoma Public Utilities (Tacoma, WA), 1, 3/30/2015

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National Grid voted Negative regarding PRC-010-1 and continues to vote Negative regarding PRC-010-2.  The concern is that R2 gives considerable authority to the Planning Coordinator or Transmission Planner.  Nowhere in the new standard is there any provision for a UVLS entity such as a Transmisison Owner to comment or advise on the feasibility of the program specification, and particulary the implementation schedule.  There should be an opportunity for the UVLS entity to provide input to the plan and schedule, and a mechanism for resolving disagreement.   We have a similar concern with R5 with regard to the specification and executation of the Corrective Action Plan.

Please consider having separate ballots for PRC-010-2 and PRC-004-5, instead of a combined ballot.

 

Michael Jones, National Grid USA, 1, 3/31/2015

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Michael Shaw, 3/31/2015

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National Grid voted Negative regarding PRC-010-1 and continues to vote Negative regarding PRC-010-2.  The concern is that R2 gives considerable authority to the Planning Coordinator or Transmission Planner.  Nowhere in the new standard is there any provision for a UVLS entity such as a Transmission Owner to comment or advise on the feasibility of the program specification, and particularly the implementation schedule.  There should be an opportunity for the UVLS entity to provide input to the plan and schedule, and a mechanism for resolving disagreement.   We have a similar concern with R5 with regard to the specification and execution of the Corrective Action Plan.

Please consider having separate ballots for PRC-010-2 and PRC-004-5, instead of a combined ballot.

Brian Shanahan, National Grid USA, 3, 3/31/2015

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Dennis Minton, On Behalf of: Dennis Minton, , Segments 1, 3

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Stephen Pogue, M and A Electric Power Cooperative, 3, 4/1/2015

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John Fontenot, 4/1/2015

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christina bigelow, 4/1/2015

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Daniel Gacek, Exelon, 1, 4/2/2015

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Shari Heino, Brazos Electric Power Cooperative, Inc., 5, 4/2/2015

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See ACES comments

Shari Heino, Brazos Electric Power Cooperative, Inc., 5, 4/2/2015

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Chris Gowder, On Behalf of: Florida Municipal Power Agency, FRCC, Segments 3, 4, 5, 6

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Kaleb Brimhall, 4/6/2015

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Team -  this is a test comment from Barb Nutter

Barb Nutter, On Behalf of: Other, NA - Not Applicable, Segments NA - Not Applicable

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A general comment regarding the Applicability Section of PRC-004-5 is that the items listed under sub-Part 4.2.1 are not Facilities by NERC definition.

 

The addition of 4.2.3 to the Facilities Section “Undervoltage load shedding (UVLS) that is intended to trip one or more BES Elements” is not necessary.  The BES definition excludes Elements that serve radial load.  UVLS schemes are normally intended to trip loads which are supplied by radial circuits (feeders), and these circuits (feeders) would not normally be included in the BES definition.  It may be helpful for the drafting team to include an example in the application guideline to provide greater clarity.

 

In the Basis for Revision Section of what should be PRC-010-2, on page 3 of the standard, the last two sentences affirm that the rationale boxes in the Supplemental Material section of the standard will remain.  The rationale box for Requirement R5 will be removed.  The only Rationale Box in the B. Requirements and Measures section of the standard is for R4.  Should the statement read “The rationale box for Requirement R4 will be removed.”

 

We agree that the Misoperation identification and correction of UVLS equipment as retired by PRC-022-1, Requirements R1 and Part R1.5 is addressed by the proposed revisions of PRC-004-5 and PRC-010-2. However, the addition of Part 4.2 to PRC-010-2 may create duplicate effort for evaluating proper operations and misoperations of UVLS equipment.

 

This comment is made on the basis that PRC-004-4 already requires UVLS entities (TO, GO and DP) to assess and identify whether or not misoperations were the cause of BES interrupting device(s) (which now include UVLS) operations. Through this assessment and identification process, the proper or improper operations of the UVLS equipment would have been identified and, where necessary and appropriate, corrective action plans would have been developed and implemented. To have an additional Part 4.2 which requires the Planning Coordinator or Transmission Planner to evaluate the performance (i.e., operation and non‐operation) of the UVLS Program seems redundant and unnecessary, despite such evaluation is performed by different responsible entities.  Propose that Part 4.2 be removed.

 

Additionally, it is not clear which UVLS Misoperations are the subject of the proposed revised PRC-004-5 standard. The UVLS facilities of PRC-004-5 are “Undervoltage load shedding (UVLS) that is intended to trip one or more BES Elements.”  The typical UVLS schemes trip circuits (feeders) that supply loads. These circuits (feeders) are not normally BES elements since they are excluded by the BES definition that became effective July 1, 2014.  Clarification is needed.

NPCC--RSC--2008-02.2 4-7-15, Segment(s) 10, 3, 2, 1, 5, 9, 6, 8, 4/7/2015

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

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Matt Culverhouse, On Behalf of: Matt Culverhouse, , Segments 3

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The posted PRC-010-2 has requirement 4.2 applicable to PC and TP.  However, PC/TP generally don’t have the expertise for the design/engineering aspects.  The SDT should consider making 4.2 applicable to the owners of the schemes.

Payam Farahbakhsh, Hydro One Networks, Inc., 1, 4/7/2015

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We agree that the Misoperation identification and correction of UVLS equipment as retired by PRC-022-1, Requirements R1 and R1.5 is addressed by the proposed revisions of PRC-004-5 and PRC-010-2. However, the addition of Part 4.2 to PRC-010-2 may create duplicated effort for evaluating proper operations and misoperations of UVLS equipment.

This comment is made on the basis that PRC-004-4 already requires UVLS entities (TO, GO and DP) to assess and identify whether or not misoperations were the cause of BES interrupting device(s) (which now include UVLS) operations. Through this assessment and identification process, the proper or improper operations of the UVLS equipment would have been identified and, where necessary and appropriate, corrective action plans would have been developed and implemented. To have an additional Part 4.2 which requires the Planning Coordinator or Transmission Planner to evaluate the performance (i.e., operation and non‐operation) of the UVLS Program seems redundant and unnecessary, despite such evaluation is performed by different responsible entities.

We therefore propose that Part 4.2 be removed.

Moreover, the IESO notes that the addition to the Facilities Section, bullet 4.2.3 “Undervoltage load shedding (UVLS) that is intended to trip one or more BES Elements” does not appear to be necessary. The BES definition excludes elements that serve radial load. UVLS schemes are normally intended to trip loads which are supplied by circuits (feeders). These circuits (feeders) would not normally be included in the BES definition.  It may be helpful for the draft team to include an example in the application guideline to provide greater clarity.

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1) On the clean versions of PRC-010-2 and PRC-004-5, please remove the 'under' after ‘BES Element’ in the Basis for Revision on page 2 last paragraph. "The two‐pronged approach ensures that any UVLS Program equipment containing a deficiency is identified and corrected under PRC‐010 and UVLS that trips a BES Element under is corrected under PRC‐004 to address the requirements in the retired PRC‐022‐1."

 

2) PRC-004-5 and PRC-010-2 both require development of corrective action plans (CAP) with different time requirements (PRC-010-2 provides 12 months to analyze an operation.  PRC-004-5 R1 requires identification in 120 days.  Does the 120 days start during the 12 months of analysis or is the expectation that the Misoperation will be identified in the first 120 days if a BES Element is involved? )  Can you provide examples to clarify which standard is to be referenced for developing the CAP?

 

3) Please explain how there is no double jeopardy having requirements for CAPS in multiple standards?

Example:  An entity has a BES breaker that should have tripped during a UVLS event but did not trip.   Is this reportable under PRC-010-2 or PRC-004-5?  Which standard’s time frame applies?

SERC PCS Proj 2008-2.2, Segment(s) 10, 1, 3, 5, 6, 4/7/2015

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Texas RE is concerned that an entity will not analyze a mis-operation if it does not trip a BES element.  The language in PRC-004-5, “intended to trip one or more BES elements”, may create a reliability gap.  In the ERCOT region, there is little to no UVLS or UFLS that will or is intended to trip a BES element.  It is not in the best interest of reliability to have a mis-operation occur and an entity not be required to analyze the issue and provide corrective actions.    

 

Furthermore, there is an inconsistency with the language in PRC-010-2 and PRC-004-5 due to the use of the word “impact” indicated in PRC-010-2.  In the ERCOT region, relays can have a major impact on the BES and would meet the requirements of PRC-010-2.  Unfortunately, because of the language included in PRC-004-5, if entity determines that the UVLS is not intended to trip BES elements, the mis-operation would not need to be analyzed.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 4/7/2015

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Entergy supports comments provided by SERC PCS group.

Oliver Burke, Entergy - Entergy Services, Inc., 1, 4/7/2015

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Gul Khan, 4/7/2015

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Kathleen Black, On Behalf of: DTE Energy, RF, Segments 3, 4, 5

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Catherine Wesley, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Brian Evans-Mongeon, Utility Services, Inc., 4, 4/7/2015

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Duke Energy agrees with the proposal made by the drafting team. We thank the drafting team for their efforts.

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

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Paul Malozewski, Hydro One Networks, Inc., 3, 4/7/2015

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George Tatar, 4/7/2015

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(1) We believe that the modifications to PRC-010 and PRC-004 are duplicative and overlapping.   As proposed, PRC-004 will require equipment owners to evaluate any UVLS relay that they have installed regardless of whether it is part of an RAS, UVLS Program or installed independently for local reasons, while PRC-010 requires the PC or TP to evaluate the “performance of UVLS Program equipment” for voltage excursions.  While we disagree with the TP or PC having responsibility to evaluate equipment performance, we are even more concerned that there is not a clear delineation between when PRC-004 applies for evaluating equipment performance and when PRC-010 applies.  As written now, there would appear to be an overlap when UVLS relays that are part of a UVLS program operate.  A simple solution to eliminate this overlap and duplication would be to strike Part 4.2.  Then, the PC and TP would appropriately rely the equipment owners to perform their own evaluation, which is where the responsibility should belong.

 

(2)  The supporting documentation such as the Basis for Revision, Guidelines and Technical Basis and Frequently Asked Questions neither adequately explain the need for duplication between PRC-004 and PRC-010 nor the demarcation for responsibility for evaluating equipment performance.  In fact, these supporting documents actually are contradictory at times.  For example, the end of the second paragraph states that PRC-004 does not cover the “performance (operation or non-operations) of UVLS Program equipment not covered by the strict process of PRC-004”.  Yet it never explains how PRC-004 does not cover the performance.  We disagree and believe it does cover the performance.  If the drafting team intends the performance of the equipment to be something different than whether the UVLS relays operated correctly or not, this needs further explained in the technical guidelines as there is little to no explanation of what is meant beyond correct operation of the relays.  Near the end of the first paragraph for the “Guidelines for Requirement R4,” the paragraph states that “Misoperation of UVLS equipment is addressed as a deficiency” in PRC-010.  This seems to contradict the inclusion of all UVLS equipment installed to trip BES equipment in thePRC-004 applicability section where it is processed as a Misoperation.  In the second paragraph of the response to the fourth FAQ, there is a statement that the definition of UVLS Program “does not explicitly note that the term excludes centrally controlled undervoltage-based load shedding.”  To the contrary, the last sentence of UVLS program quite clearly excludes centrally controlled UVLS.

 

(3)  As proposed, PRC-004 will apply to all UVLS relays that can trip BES Elements including those that are part of a UVLS program and those that are not part of a UVLS program.  That latter category include the centrally controlled UVLS or UVLS installed to protect local areas or equipment.  While application of PRC-004 to UVLS installed to protect local areas may be appropriate, it is not appropriate to include those that are part of a centrally controlled system as this would be considered a RAS to which PRC-016 would apply.  In the “Guideline for UVLS Program Definition,” it is stated very clearly that a centrally controlled UVLS system is a RAS.

 

(4)  The VSLs for PRC-010 R4 were not modified in response to the modification of the requirement.  It is now possible to partially meet the main requirement within the associated time frame.  The VSLs should reflect this.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 6, 4/7/2015

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We agree that specific steps are needed to be taken to continuously improve the reliability of the Bulk Electric System (BES). The evaluating and documenting of the process helps to identify critical facilities (which could lead to Misoperations) and to ensure that the same issues doesn’t reoccur on the system. Additionally, the documented information can be used to help develop and implement a Correction Action Plan (CAP) with accuracy when it’s required. We would like to thank the drafting team for making great efforts to address the industry’s needs.

Additionally, we would like to suggest to the drafting team to include the term ‘undervoltage-based load shedding’ to the definition of the Remedial Action Scheme for consistency. In the Compliance Assessment Approach Specifics Section (RSAW-PRC-010-2) R1…Note to Auditor, our interpretation is that the term ‘undervoltage-based load shedding’ is not a part of the UVLS Program and it states that this term falls under the NERC Glossary definition of Remedial Action Scheme (RAS). However if you go out to the NERC site, the current definition of Remedial Action Scheme (RAS) doesn’t not contain this particular term.

SPP Standards Review Group, Segment(s) 1, 3, 5, 4/7/2015

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(1) CenterPoint Energy agrees that the Misoperation identification and correction of UVLS equipment as retired by PRC-022-1, Requirements R1 and R1.5, is addressed by the proposed revisions of PRC-004-5 and PRC-010-2.  However, the Company cannot support this draft of PRC-010-2 due to the current wording of Requirement R4.2.

(2)  The drafting team proposes to add Requirement R4.2 to Requirement R4 in PRC-010 as follows:  Each Planning Coordinator or Transmission Planner shall, within 12 calendar months of an event that resulted in a voltage excursion for which its UVLS Program was designed to operate, perform an assessment to evaluate:  4.1. Whether its UVLS Program resolved the undervoltage issues associated with the event, and 4.2. The performance (i.e., operation and non‐operation) of the UVLS Program equipment.  CenterPoint Energy believes a more relevant method to capture the essence of PRC-022 Requirements R1 and R1.5 is to revise Requirement R4.2 as follows: Whether the UVLS entity(ies) adhered to the UVLS Program specifications.  With this revised wording for Requirement R4.2, the assessment required under Requirement R4 would address whether the UVLS Program resolved the undervoltage issue associated with the event and whether the UVLS entity or entities involved adhered to the established UVLS Program specifications.  It would be obvious that the operation of the UVLS Program equipment performed adequately when the amount(s) of load shedding in a voltage excursion event meets the expected minimum amount(s) as specified in a UVLS Program.  However, while an assessment (Requirement R4.1) may determine the voltage excursion event was resolved for the specific system conditions and specific contingency, the UVLS Program may have been developed for other system conditions and more severe contingencies.  Therefore, the assessment (Requirement R4.2) must include whether the UVLS entity(ies) met the obligated amount of load shedding specified by the Planning Coordinator or Transmission Planner.  With a large number of UVLS equipment components, it is possible that a small number may not operate (i.e., “non-operation”).  Examples of UVLS equipment non-operation would include the following:  equipment problems such as a defective trip coil in a distribution circuit breaker or a defective relay and distribution circuit breaker unavailability due to maintenance (routine preventive or corrective) or construction (breaker replacement or station expansion).  A small number of non-operations are inconsequential if the amount(s) of load shedding meets Planning Coordinator or Transmission Planner expectations.  Furthermore, any deficiencies identified by either the proposed Requirement R4.1 or the revised wording for Requirement R4.2 would result in a Corrective Action Plan under Requirement R5.

Daniela Hammons, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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Paul Shipps, On Behalf of: Lakeland Electric, , Segments 1, 3, 5, 6

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Tri-State suggests changing the implementation plans for PRC-004-5 and PRC-010-2. They both use PRC-010-1 as a reference point even though it has not yet been approved by FERC and therefore has no definitive effective date. If PRC-010-1 doesn’t get approved before these versions do then, according to the implementation plans, these versions will be effective the 1st day of the 1st calendar quarter after the standards get approved by FERC. The drafting team should edit the implementation plans to allow more time for entities to prepare for the effective date if that were the case. We would suggest some language stating that the standards will become effective on the 1st day of the 1st calendar quarter that is 12 months after approval which would be similar to the time provided in PRC-010-1.

Sergio Banuelos, On Behalf of: Tri-State G and T Association, Inc., MRO, WECC, Segments 1, 3, 5

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

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In PRC-004-5 Applicability section 4.2.3 I suggest using the phrase "Undervoltage Load Shedding (UVLS) Program equipment that is intended to trip one or more BES Elements".  This clarifies the equipment to be analyzed is part of a UVLS Program, which I believe is the intent.

Molly Devine, 4/7/2015

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Project 2008-02.2, Segment(s) 1, 4/7/2015

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