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2013-03 Geomagnetic Disturbance Mitigation SAR

Description:

Start Date: 12/16/2016
End Date: 01/20/2017

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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Hot Answers

NPCC RSC support the proposed scope for Project 2013-03.

RSC no Dominion and OPG, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 1/20/2017

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(1)   We believe the proposed scope captures the directives identified in FERC Order No. 830.  However, we believe several references to the FERC Order are taken out of context, and should be removed from the SAR’s Detailed Description Section.  The Commission wants GIC monitoring and magnetometer data to be gathered through collaboration with academia and government agencies.  The reference to include “…any device that must be added…”could misdirect the SDT from the Commission’s intentions.  We recommend the removal of this particular reference to limit the scope of data collection.

(2)   We feel the FERC directive references should be mapped to existing requirements to identify proposed changes.  For example, we recommend adding a reference to Requirement R3 when listing the directives associated with Benchmark Events.  Likewise, when listing directives for Transformer Thermal Impact Assessment or Corrective Action Plans, Requirement R6 and Requirement R7 should be included as references, respectively.

(3)   We question the addition of a reference to move the data collection of GIC monitoring and magnetometer data to a different Reliability Standard.  We feel this inclusion opens the door to a Commission suggestion to incorporate data collection as part of real-time reliability monitoring and analysis and relocated to the TOP Reliability Standards.  We feel that if such data was required for real-time operations, it likely would have been incorporated in NERC Reliability Standard EOP-010-1, as part of emergency Geomagnetic Disturbance Operations.  We recommend the removal of this reference to focus the scope of this project on TPL-007.

(4)   The SAR briefly lists the development of an implementation plan, although does not elaborate on what may change within the SAR’s Detailed Description Section.  While the current five year implementation plan takes effect starting July 2017, we feel a significant portion of the implementation plan will pass by the time the Commission approves the work of this SDT.  We recommend the addition of a reference within the SAR’s Detailed Description Section to incorporate modifications to the implementation plan that accounts for the transition away from the current implementation plane.  We believe the transition period should not be less than 18 months to accommodate an impacted entity’s effort to implement modeling and software changes, additional resource procurements, and quality assurance of assessments.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 1/20/2017

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Other Answers

Karie Barczak, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

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Jeffrey DePriest, On Behalf of: Jeffrey DePriest, , Segments 3, 4, 5

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Tho Tran, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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

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The NSRF agrees with the proposed scope for Project 2013-03 SAR but would like to make several suggestions that will benefit the reliable operation of the BES. If the standard drafting team plans to incorporate real-time reliability monitoring and analysis to satisfy the GMD monitoring requirements, we suggest the SDT add Transmission Operator (TOP) as an applicable Reliability Function in the SAR.

 

Rationale

FERC gives NERC the option to incorporate the GMD monitoring data collection in another reliability standard. The TOP is the responsible entity to complete real-time reliability monitoring.

 

“NERC may also propose to incorporate the GIC monitoring and magnetometer data collection requirements in a different Reliability Standard (e.g., real-time reliability monitoring and analysis capabilities as part of the TOP Reliability Standards).” (FERC Order 830, P.91) .

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/4/2017

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

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BPA would like to know if the model validation encompasses equipment and system models for accurate GIC current determination (like transformer behavior).  BPA would also like to know if the model validation encompass hysteresis curves for VAR consumption determination?  BPA believes the model should contain both. 

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

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The proposed revision to standard TPL-007-1 to address localized peaks in GMD events and not rely solely on the spatially-averaged data has the potential to impact much more of the transmission system and many more EHV Y-connected transformers than we had previously estimated.  It is unknown at this time how the SDT will modify the standard to include this FERC mandated revision, but this would be a major concern for TOs.

 

It appears that Ameren as a TO will be required to install GIC monitoring equipment and magnetometers, collect data from these devices, and make the data available to those that have a need for the information.  Details are still to be determined by the SDT, with the cost to install such equipment and maintain data is unknown. 

 

Although the FERC directive allows for TOs to apply for an exemption to collect necessary GIC monitoring data, exemption criteria has not been proposed to determine if the exemption would or would not be allowed in a particular case.  Regardless, because of our location in the Midwest and because of the number of 345 kV lines and EHV Y-connected transformers connected to the Ameren system, it is unlikely that Ameren would be allowed an exemption from installing monitoring equipment and collecting the GIC data, regardless of our southerly location in relation to the geomagnetic north pole.

 

Due to the fact that FERC is mandating these modifications, we are concerned that input from industry on the drafting of the revised standard would be given minimal consideration.

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

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

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

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

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

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

2013-03_GMD_SAR_Unofficial_Comment_Form_121516.docx

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Our subject matter experts do not believe that collected data should be available to the public.  Or clearly define what is meant by "publicly available" and what specifically can be available. 

Seattle City Light Ballot Body, Segment(s) 1, 4, 6, 5, 3, 12/2/2016

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SPP Standards Review Group, Segment(s) , 1/20/2017

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

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Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5, 6

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Hot Answers

RSC no Dominion and OPG, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 1/20/2017

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(1)   We believe the SDT should collaborate its activities with existing industry technical groups, including the NERC Geomagnetic Disturbance Task Force, when designing GIC monitoring and magnetometer data collection criteria.  We propose limiting the focus of this SAR to GIC monitoring and magnetometer data collection, and allow NERC and these other groups to address how such data will be shared publicly.  We fear the SDT’s involvement with the distribution of data could lead to unnecessarydevelopment of new Reliability Standards for currently unregistered entities and functions.

(2)   We thank you for this opportunity to provide these comments.

ACES Standards Collaborators, Segment(s) 1, 3, 5, 4, 1/20/2017

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Other Answers

Please consider an approach where GIC monitor locations are determined on a regional basis in order to obtain the most value from each installation and insure that all areas are covered appropriately. An individual GO/TO may not have the information needed to properly place equipment. Also, providing monitoring equipment specifications would insure that manufacturers would design, and entities would install, capable monitors that will provide reliable data.

Karie Barczak, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

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Please consider an approach where GIC monitor locations are determined on a regional basis in order to obtain the most value from each installation and insure that all areas are covered appropriately.  An individual GO/TO may not have the information needed to properly place equipment.  Also, providing monitoring equipment specifications would insure that manufacturers would design, and entities would install, capable monitors that will provide reliable data.

Jeffrey DePriest, On Behalf of: Jeffrey DePriest, , Segments 3, 4, 5

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Tho Tran, On Behalf of: Oncor Electric Delivery - Texas RE - Segments 1

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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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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PacifiCorp supports the proposal to incorporate the GIC monitoring and magnetometer data collection requirements in a different Reliability Standard.  This separation would allow more attention to the specific upgrades already outlined in the SAR.

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

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None

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 1/4/2017

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

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BPA would like to know how the Standard Drafting Team envisions collecting the data to perform the studies.  If there is no regional data collection effort similar to MOD-032, then how is it envisioned that accurate GIC studies to determine DC currents will be run?  BPA believes a documented process needs to be created WECC wide (or nationally).  BPA envisions the data collection included with MOD-032 to be collected every 5 years (or according to study schedule with version 2 of TPL-007).  BPA’s experience is that most entities are not willing to take on extra work if they do not have to. 

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

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The change in deadlines for mitigation of GMD events would not be a concern in Ameren's case.  Ameren is not interested in installing blocking devices to Y-connected EHV transformers.  Therefore, operational solutions will provide the likely mitigations.

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

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

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Because commercially available models and tools do not currently exist for performing transformer thermal impact assessments, we ask the SDT to continue considering suitable alternates (e.g., look up tables, development of flowcharts or processes).

Also, we ask the SDT to provide clarification of the event included in Table 1 - Steady State Planning Events. In particular, with regards to protection system misoperation due to harmonics during a GMD event, please provide clarification as to what is expected. Will this require that large scale harmonic penetration studies be performed in order to analyze potential impact of half-cycle saturation generated harmonics on system protection and/or equipment controls? Or will engineering assessments that identify credible scenarios be sufficient?

SDT to consider that the procurement and installation of instrument transformers for the collection of GIC monitoring and magnetometer data takes months to implement. SDT to consider realistic timelines for implementation, as well as providing technical guidance for implementation of GIC measurement devices.

We ask the SDT to provide additional clarification on R2. In particular, SDT to elaborate on "maintaining System models and GIC System Models." Is R2 referring to gathering and maintaining dc and ac models (e.g., substation dc resitances, dc network data) of the system under study? Does it require having to complete a GIC analysis by R2 deadline, so that GIC system models can be produced and maintained? Please provide clarification.

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

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

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

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

2013-03_GMD_SAR_Unofficial_Comment_Form_121516.docx

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Thank you for seeking our input in advance.

Seattle City Light Ballot Body, Segment(s) 1, 4, 6, 5, 3, 12/2/2016

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After reviewing the transcript associated with the Level 2 Appeal of Foundation For Resilient Societies, INC. in reference to TPL-007-1, we suggest the drafting team review and use this document as guidance throughout their modification process to the Standard. In our review, we found some similarities of concerns shared by both The Foundation for Resilient Societies, INC and FERC Order 830 such as, transformer thermal impact assessments as well as data collection and how that information would be made publicly available.

SPP Standards Review Group, Segment(s) , 1/20/2017

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Texas RE made the following observations:

  • Paragraph 91 in Order No. 830 discusses the ability for a Transmission Owner to apply for an exemption.  Texas RE is concerned if the responsible entity determined in R1 is allowed to grant exemptions, many entities that are registered as a TP and TO will be able to grant itself an exemption.  Texas RE recommends determining who is responsible for granting exemptions, since Order No. 830 does not specify.

  • The “Industry Need” section includes details about NERC making GMD-related data publicly available, but “Detailed Description” section does not.

  • In the “Collection of GMD Data” section, the SAR states that “Each responsible entity that is a transmission owner should be required to collect necessary GIC monitoring data.” However, TPL-007-1 R1 currently defines a “responsible entity” as either a TP or a PC. When updating the Standard, the SDT should avoid using “responsible entity” when referencing a TO.

  • Texas RE recommends emphasizing sufficient and appropriate compliance documentation, regarding an “equally efficient and effective alternative”.  An entity would be required to demonstrate efficiency and effectiveness.  For the data submittal portion, there needs to be care in addressing timing as the directive included historical and new data.  There is no discussion of data requirements, per se, and the content, format, or timing associated with the data.

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

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The approach related to the GMD benchmark definition and transformer thermal impact assessment needs to balance ease of implementation with the quality of results.

A methodology similar to that employed in PRC-002 should be utilized to limit the required number of installations of monitoring data (e.g. based on short circuit MVA or some other parameter).  Not every TO should be required to install monitoring data.  This may be better accomplished by rolling the monitoring requirement into another standard (e.g. PRC-002).

NERC should consider extensions of time for CAPs and/or hardware installation on a case-by-case basis.

Teresa Krabe, On Behalf of: Lower Colorado River Authority, , Segments 1, 5, 6

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