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2007-17.4 Order 803 Directive | PRC-005 SAR

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Start Date: 03/12/2015
End Date: 04/11/2015

Associated Ballots:

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

Hot Answers

Shannon Fair, On Behalf of: Shannon Fair, , Segments 1, 3, 5, 6

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

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

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

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 1

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

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

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

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

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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

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RoLynda Shumpert, On Behalf of: SCANA - South Carolina Electric and Gas Co., SERC, Segments 1, 3, 5, 6

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

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Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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

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

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Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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

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David Kiguel, On Behalf of: David Kiguel, , Segments 8

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

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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

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

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Duke Ballot Body Members, Segment(s) 1, 5, 6, 4/8/2015

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Dan Bamber, On Behalf of: ATCO Electric, WECC, Segments 1

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

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Andy Bolivar, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Texas RE, NPCC, Segments 1

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SERC PCS , Segment(s) 10, 1, 3, 5, 6, 4/10/2015

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

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

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Paul Malozewski, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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

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ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 4/10/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 4/10/2015

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

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Hot Answers

Shannon Fair, On Behalf of: Shannon Fair, , Segments 1, 3, 5, 6

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

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

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

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 1

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

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

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

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

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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

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RoLynda Shumpert, On Behalf of: SCANA - South Carolina Electric and Gas Co., SERC, Segments 1, 3, 5, 6

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

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Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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

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

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Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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

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David Kiguel, On Behalf of: David Kiguel, , Segments 8

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

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christina bigelow, On Behalf of: christina bigelow, , Segments 2

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NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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

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

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Duke Ballot Body Members, Segment(s) 1, 5, 6, 4/8/2015

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Dan Bamber, On Behalf of: ATCO Electric, WECC, Segments 1

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

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Andy Bolivar, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Texas RE, NPCC, Segments 1

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SERC PCS , Segment(s) 10, 1, 3, 5, 6, 4/10/2015

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

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

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Paul Malozewski, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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

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ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 4/10/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 4/10/2015

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

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Hot Answers

1. We disagree with the findings of  the NERC System Protection and Control Subcommittee technical paper in regards to sudden pressure relays being critical to the Reliability of the BES.  Therefore including sudden pressure relays is not meeting the FERC directive in Order No. 803.

Sudden pressure relays, which do trip some transformers, are not important in preventing “instability, cascading, or separation.” CSU believes that the inclusion of sudden pressure relays in the NERC Standards will not improve

The reliability of the BES, and are outside the FPA Section 215 jurisdiction. The following are some additional notes on this topic:

• Many transformers are not protected using sudden pressure relays. In fact,

due to the sensitivity of sudden pressure relays to vibration, some areas of

the

country purposefully do not use sudden pressure relays for transformer

protection.

• Many transformers that are protected using sudden pressure relays use a

guarded trip scheme. For example, in order for the sudden pressure relay to

trip the transformer there must also be another condition present such as an

over current or differential trip.

• There is not a consistent application of sudden pressure relays in the

industry, many transformers do not utilize these relays for protection, and

no requirements exist to have sudden pressure relays. CSU believes that

including them in a standard will discourage their use and/or encourage those that

currently use them to remove them from their protection scheme. Sudden

pressure relays when applied correctly can be an asset in transformer

protection, but are not important in preventing “instability, cascading, or

separation.

2. We also dis-agree with including a requirement that the BA be required to provide largest unit information.  This will happen upon request and does not need a requirement .

Shannon Fair, On Behalf of: Shannon Fair, , Segments 1, 3, 5, 6

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

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

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

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 1

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

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

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Entergy support comments of the SERC Protection and Control Subcommittee (PCS).

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

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AEP believes the overall scope and objectives of the revised SAR are appropriate, however as discussed below, a definition needs to drafted for “supervisory relay” so that it is clear exactly which devices are, and are-not, supervisory relays. As such, the SAR should be modified to accommodate the addition of this definition.

 

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

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     The consideration of the applicability of generator station service transformers, and possible inconsistency with PRC-025-1, is not mentioned anywhere in FERC Order No. 803, contradicts the BES Definition application process, exceeds the scope of the mandate, and should be removed from the SAR.  The NSRF believes that this may have been left in this version of the SAR since the orginal SAR has been updated for this Project.

     There is no conflict with PRC-025-1.  The Applicability section of PRC-025-1 only capitalizes “Facilities” as a subsection heading, not to indicate BES Element per the defined term.  “The following Elements associated with Bulk Electric System (BES) generating units…” proves this, as Element is defined as any electrical device, not necessarily BES.  The Elements are only associated with BES Elements, otherwise Section 3.2 would just read “The following BES Elements…”.  FERC Order No. 733, paragraph 104, directs NERC to address Unit Auxiliary Transformers in PRC-025; there is no equivalent direction in Order No. 803 for PRC-005.

     These are no BES Elements per the BES Definition.  Per the NERC Bulk Electric System Definition Reference Document, April 2014, page 12:  “The presence of a system service, a station service, or a generator auxiliary transformer does not affect the application of Inclusion I2. Transformers associated with system service, station service, or generator auxiliaries are evaluated under the core definition and Inclusion I1.”  They do not meet I1:  “Transformers with the primary terminal and at least one secondary terminal operated at 100 kV or higher…”, are not BES Elements, and do not belong in PRC-005.

     We understand this paragraph is legacy wording from the previous recycled SAR.  It would be best to remove it before this SAR is finalized.

MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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

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RoLynda Shumpert, On Behalf of: SCANA - South Carolina Electric and Gas Co., SERC, Segments 1, 3, 5, 6

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

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Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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Ingleside Cogeneration LP (ICLP) agrees that the project team has captured FERC’s language and intent in the SAR for Project 2007-17.4.  However, we agree with a number of respondents to Order 803 that the reliability costs do not match the expected benefit.  As a result, we would like to see the project team solicit this kind of information from stakeholders for further analysis.  We believe that this supports the Risk-based processes that NERC has been moving toward – realizing that scarce resouces expended on low-value initiatives takes attention away for more pressing ones (e.g.; cyber security and frequency response.)

Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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

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

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a)      The Directive does not specifically require the addition “Voltage and Current Sensing Devices associated with the supervisory”.

b)      Although we do not disagree that the appropriate voltage needed to determine ‘hot vs dead line’ and ‘synch check’ associated with reclosing schemes should be verified at the appropriate input to the supervisory relays, the devices themselves should not be included. See suggested solution in 2c.

c)     The SAR should be fresh and not drag along with it the original PRC-005-4 SAR wording – that previous SAR has already been vetted, voted, and the work resulting from it is already pending FERC approval.

d)     The SAR indicates various versions of the standards as the finished product – these conflicts should be resolved (won’t the product of this drafting work be -6?)

e)     The SAR should be clean and only address the FERC Order 803.  The red text at the bottom of page 3 of the SAR should be the content of the Industry Need section.    

f)     The second paragraph of the Purpose or Goal section of the SAR is not needed.

g)     In the Detailed Description paragraph, suggest changing Item 2 from “Revise the implementation plans of PRC-005-2, PRC-005-3, … to assure consistent and systematic implementation.”  to  “Revise the implementation plans of PRC-005-3, …. to assure practically possible implementation.”  [note that PRC-005-2 has been removed and words have been changed].

Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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

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David Kiguel, On Behalf of: David Kiguel, , Segments 8

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

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ERCOT references and supports the comments provided by the ISO/RTO Standards Review Committee.

christina bigelow, On Behalf of: christina bigelow, , Segments 2

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The Objective section on page 4 of the SAR should be revised to stipulate the revisions that will be needed for Automatic Reclosing, and Component Type that are listed in the Definitions Used in this Standard section of PRC-005-3.   (The Proposed Methodology - PRC-005 Directive states on its page 2 that “This version of PRC-005 uses PRC-005-5 being developed under Project 2014-01 as the starting point for revisions to address the directive.”)  Suggest revising the Objectives section in the SAR to read “Provide clear, unambiguous requirements, standard specific definitions, and standard(s)…”

NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Hydro-Quebec TransEnergie supports comments from RSC-NPCC

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

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

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Duke Ballot Body Members, Segment(s) 1, 5, 6, 4/8/2015

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Supervisory relay and voltage and current sensing devices are required on elements that need true synchronization. The sync-check required elements are at generating sites or on interconnecting elements that tie two transmission systems together.

Elements within a transmission system have limited sync-check functionality that can be by-passed. Does required maintenance in Table 4-3 actually enhance reliability on the BES? Can the maintenance cost out-weight the reliability benefits?

Dan Bamber, On Behalf of: ATCO Electric, WECC, Segments 1

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

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 NHT is in general agreement with the revised scope/objective included in this SAR regarding the addition of Supervisory type relays and voltage/current sensing devices.  However,  this revision  when combined with the terminology  “control circuitry associated with the reclosing relay or supervisory relay” (as stated in Proposed Methodology PRC-005 Directive bullet 4) may lead to misinterpretation by end users. Use of the terminology provided in the SAR may imply that circuit breaker”control circuit”  testing  will need to include formal  “close (circuit) checks” to verify integrity of the entire close circuit. This may lead to unnecessary cycling/wear and tear  of circuit breakers.  Recommend that “bullet 4” be entirely eliminated or consider modifying the language in bullet 4  to “close circuitry interconnections associated with the reclosing relay or supervisior relay” 

Andy Bolivar, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Texas RE, NPCC, Segments 1

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1) The Directive specifically required the addition of the “Supervisory relay that monitors BES quantities (such as voltage, frequency, or voltage angle) and supervises operation of the reclosing relay’” but does not require the addition of the “Voltage and Current Sensing Devices associated with the supervisory”.  The addition of the “Voltage and Current Sensing Devices” seems to be an increase in scope relative to the original Directive.

To make the language acceptable,  remove all requirements for Voltage and Current Sensing Devices associated with supervisory relays.

SERC PCS , Segment(s) 10, 1, 3, 5, 6, 4/10/2015

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

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The proposed language is an expansion of scope beyond the directive in that it includes “Voltage and Current Sensing Devices associated with supervisory relays”, which is not a requirement of the directive.  To make this language acceptable, please remove all requirements for “Voltage and Current Sensing Devices associated with supervisory relays”.

As currently proposed, the scope of this SAR is not clear.  The cover page suggests that version 4 is being proposed by this SAR, while other edits suggest we are considering version 6.  Superfluous information has been retained  from the issue of this document as the SAR for PRC-005-4.  Consequently, the “Industry Need” section is unnecessarily muddied.  From the third paragraph forward, this section discusses Sudden Pressure relays rather than auto-reclosing schemes, and also addresses BA obligations, inconsistency with PRC-025-1, developments that followed PRC-005 versions 2 or 3, and the 24-year record retention requirements.  These issues were supposedly addressed in the SAR for PRC-005-4 dated 2/12/2014.  Were they not resolved in version 4?

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

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The Revised SAR should recognize that definitions would also require revision in order to address the FERC directive in Order 803. We suggest the following addition on Page 4 of the Revised SAR: “Provide clear, unambiguous requirements, definitions, and standard(s)…”.

Paul Malozewski, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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

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(1)  First, we are disappointed in NERC’s response to the NOPR.  We found it to be inappropriately specific in prescribing modifications to the standard.  We believe the comments more appropriately would have simply agreed to address the Commission’s concerns through the use of the standards development process.  We believe NERC’s very specific response was inconsistent with the purpose and intent of the standards development process, and that , in essence, NERC’s action constitutes  developing a standard outside the standards development process.  We do note that the careful wording of the Commission directive does not appear to require NERC to implement the changes exactly as NERC proposed in its response.  The Commission simply indicated that they find NERC’s proposed changes acceptable, but there is no language ordering those changes to be implemented.  The Commission directive is to “include supervisory devices,” and not to implement NERC’s proposed changes.  This would be consistent with previous Commission guidance regarding reliability standards directives in which the Commission allows equally efficient and effective alternatives that meet the directive to be used.

 (2)  We believe a new clean SAR should be issued.  The SAR appears to append the inclusion of supervisory relays in a Automatic Reclosing scheme to the previous SAR which authorized adding sudden pressure relaying to PRC-005.  However, the scope of the previous SAR has been completed since the sudden pressure relaying project will be presented to the NERC Board of Trustees for adoption in May.

(3)  We are not opposed conceptually to the approach of including important supervising relays in the standard.  However, our main concerns are around the process utilized as expressed above.

ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 4/10/2015

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SPP Standards Review Group, Segment(s) 1, 3, 5, 4/10/2015

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It is FMPA’s opinion that the effort to address the FERC directive in Order No. 803 should be initiated by a new SAR, and not by a revision to an existing SAR, especially one that has been completed. The revised SAR contains a number of artifacts referring to development of PRC-005-4, which as already been adopted by the BOT and filed with FERC. The proposed methodology for addressing the directive states that PRC-005-5 will be used as the starting point for revisions, however, there is no mention of PRC-005-5 in the revised SAR.

The revised SAR states that the “SDT will develop requirement(s)”, but the proposed methodology being presented states that no revisions to Requirements are being proposed. The statement “(t)he SDT may elect to propose revisions to the standard regarding the scope of supervisory devices” is confusing to FMPA since NERC has already told FERC in its NOPR comments what the industry’s position is without consulting the industry through the standard development process. It seems to FMPA that NERC has already determined what standard revisions are to be made, and the SDT does not have any leeway to elect to do anything other than accept the scope of devices proposed by NERC.

FMPA is also confused as to why Balancing Authority has been selected as an applicable functional entity.

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

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Hot Answers

Shannon Fair, On Behalf of: Shannon Fair, , Segments 1, 3, 5, 6

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Fuchsia Davis, On Behalf of: Bonneville Power Administration - WECC - Segments 1, 3, 5, 6

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Other Answers

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

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

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Gul Khan, On Behalf of: Oncor Electric Delivery, Texas RE, Segments 1

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

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

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Entergy supports comments of the SERC Protection and Control Subcommittee (PCS).

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

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Since there is no universally accepted definition of supervisory relays, simply adding “supervisory relays” as a qualifier to the definition of Automatic Reclosing would not be sufficient, as it is not clear which devices would or would-not be considered a supervisory relay. AEP recommends that clarity be provided as to the exact meaning of “supervisory relay”, as well as the team’s intent in including it, to remove any ambiguity in its potential application. AEP would like to clarify that the inclusion of the supervisory relay fuction pertains only to those funcitons which are automatic in nature. The following is what AEP would consider the difference between automatic supervisory relays (which we believe the team wishes to include) and manual supervisory relays (which we believe should be excluded from the proposed definition). 

Automatic Supervisory Relay
An automatic supervisory relay uses a combination of one or more signal inputs, as listed below, within a predefined logic to initiate action on a certain component/circuit. Typically, this is done to verify proper operation/function.

· Voltage/Potential

· Current

·  Frequency

·  Communication signal from another device

Manually Operated Supervisory Relay
A manually operated supervisory relay is a static device that permits an operator/user to initiate action on a certain component/circuit. This can be done both:

·       Locally - Allows local operators/users, on-site, to initiate action on a certain component/circuit.

·       Remotely – Allows remote operators, typically in a dispatch center, to initiate action on a certain component/circuit.

AEP would also like to seek clarity on the maintenance activities applicable to supervisory relays. For example, the testing and calibration of supervisory relays as opposed to simply verifying their operation.

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

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MRO-NERC Standards Review Forum (NSRF), Segment(s) 3, 4, 5, 6, 1, 2, 4/8/2015

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

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RoLynda Shumpert, On Behalf of: SCANA - South Carolina Electric and Gas Co., SERC, Segments 1, 3, 5, 6

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Related to the third bullet: Please delete 'and Current Sensing' from “Voltage and Current Sensing Devices”.  No Automatic Reclosing technologies use Current Sensing because current is not yet flowing.  Both the ‘hot vs dead line’ and the ‘synch check’ are voltage functions.

 

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

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Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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ICLP believes the language that has been proposed for the standard is technically accurate and consistent with other NERC Glossary terms.  However, we are concerned that it does not directly match that used in the FERC Order.  This will not be a problem if the rationale is provided in the initial posting of PRC-005-TBD, and clearly captured in the Supplementary Reference and RSAW.  We assume that is the intent – but want to reinforce the reality that any ambiguity will be almost certainly be interpreted in the most all-encompassing manner; even penalizing those who are doing their best to comply with FERC’s directives.

Michelle D'Antuono, On Behalf of: Michelle D'Antuono, , Segments 5

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

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

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a)      Related to the third bullet:

1.      If it remains note that ‘relay’ is missing after supervisory in third bullet.

2.      Please explain the need for ‘Current Sensing Devices since both the ‘hot vs dead line’ and the ‘synch check’ are voltage functions.

b)      Our specific recommendation is as follows:

1.      Make relay potentially plural in the first and forth bullet: ‘relay(s)’

2.      Remove the third bullet from the SAR language. Note: If it remains, add ‘relay’ after supervisory

3.     Change ‘four’ to ‘three’ in bullet sixth bullet.

c)      In order to address the voltage inputs to the Supervisory Relays, we recommend a similar approach that was done with the UFLS distributed relays. As such, add a Maintenance Activity associated with the Supervisory Relays to “Verify acceptable measurement of power system input values”.

Southern Company, Segment(s) 1, 3, 5, 6, 3/27/2015

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

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 The proposed definition of "Automatic Reclosing" should not be restricted to "Supervisory relay that monitors BES quantities ."  The definition should be sufficiently general to include all supervisory relays that monitor electrical quantities (such as voltage, frequency, or voltage angle).  The applicability to  Supervisory relays that monitor BES quantities should then appear in the PRC-005 standard itself.   

David Kiguel, On Behalf of: David Kiguel, , Segments 8

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Tacoma Power generally supports the revised definitions, but has two comments.  First, “Voltage and Current Sensing Devices associated with the supervisory” should be changed to “Voltage and current sensing devices associated with the supervisory relay.”  Second, clarification will be needed for what is intended by “Control circuitry associated with the...supervisory relay.”

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

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ERCOT references and supports the comments provided by the ISO/RTO Standards Review Committee.

christina bigelow, On Behalf of: christina bigelow, , Segments 2

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“Any one of the two specific elements of Sudden Pressure Relaying.” does not appear in the posted PRC-005-3, but it does appear in PRC-005-4, PRC-005-5.  Sudden Pressure Relaying should only be capitalized if it is formally defined.  It is assumed that the two specific elements of sudden pressure relaying are the actuating device and the associated control wiring. 

 

 

NPCC--RSC--2014-04, Segment(s) 10, 3, 2, 1, 9, 6, 5, 8, 4/10/2015

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Hydro-Quebec supports comments from RSC-NPCC

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

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

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Duke Energy suggests the following revisions to Automatic Reclosing:

 

A.    In bullet 2, replace “BES quantities” with “AC quantities”. We believe that “BES quantities” is undefined, unmeasurable, and vague. We believe this revision clarifies the components that are contained within an Automatic Reclosing scheme. For example, personnel performing the testing would actually be testing and/or verifying AC quantities and not BES quantities. Finally, any BES Element subject to the family of PRC-005 revisions would already be encompassed as part of the Applicability Section.

 

B.     In bullet 3 we suggest changing “associated with the supervisory” with “associated with the supervisory relay” for consistency.

Duke Ballot Body Members, Segment(s) 1, 5, 6, 4/8/2015

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Is the terminology “BES quantities” correctly used here? BES is usually refers to elements such as lines, transformers, etc.

Dan Bamber, On Behalf of: ATCO Electric, WECC, Segments 1

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Minor comment; neither of the links provided in the SAR work (Roster, IERP report).

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

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Andy Bolivar, On Behalf of: NextEra Energy - Florida Power and Light Co., FRCC, Texas RE, NPCC, Segments 1

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1) Related to the third bullet: if “Voltage and Current Sensing Devices” remains, please explain the need for ‘Current Sensing Devices’ since both the ‘hot vs dead line’ and the ‘synch check’ are voltage functions.

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

SERC PCS , Segment(s) 10, 1, 3, 5, 6, 4/10/2015

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

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To our knowledge, current sensing devices cannot be used to supervise reclosing.  This needs correcting in the proposed language.

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

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Sudden pressure relays are not included in the NERC Glossary of Terms. We recommend de-capitalizing the term “Sudden Pressure Relays” .

Paul Malozewski, On Behalf of: Hydro One Networks, Inc., , Segments 1, 3

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

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ACES Standards Collaborators, Segment(s) 1, 5, 3, 4, 4/10/2015

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We would suggest to the drafting team to include in the standard a definition for the term ‘Supervisory Devices’ to make sure that there is no confusion on how this term will be used in reference to Automatic Reclosing Components.

SPP Standards Review Group, Segment(s) 1, 3, 5, 4/10/2015

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FMPA does not agree that the addition of supervisory devices to PRC-005 is necessary to ensure the reliable operation of the Bulk Electric System. However, FMPA regonizes such additions have been directed by FERC, and agrees that the proposed revisions acomplish that goal.

The third bullet under Automatic Reclosing appears to be incomplete, and should have " relay." added to the end.

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

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