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2016-04 Modifications to PRC-025-1 | Standards Authorization Request

Description:

Start Date: 03/20/2017
End Date: 04/03/2017

Associated Ballots:

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

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Hot Answers

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

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

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Other Answers

The NSRF agrees with items 1 – 4 but is concerned about confusing individual collector circuits with less than 75 MVA of aggregate individual dispersed power producing resources with the concept of a common mode design condition that could result in the loss of 75 MVA or more of aggregate generation at a single generating Facility.

 

The NSRF suggests that the SAR clarify that the basis of inclusion for individual BES generators (individual wind turbines or solar panels) or individual collectors is the common mode loss of 75 MVA or more of generation.

 

To support the above basis that its not individual BES generators (Elements) that are of concern, that it is common mode outage that results in the loss of 75 MVA or more of generating Elements at a BES generating Facility, the NSRF suggests that the NERC definitions of Element and Facilities be clarified.  NERC Elements should refer to individual BES generators and NERC Facilities should refer to aggregating more that 75 MVA of BES generating Elements at a single Facility.

 

NERC BES Element Definition:  Any electrical device with terminals that may be connected to other electrical devices such as an individual generator or power producing resource, transformer, circuit breaker, bus section, or transmission line. An Element may be comprised of one or more components.

 

NERC BES Facility Definition:  A set of electrical equipment that operates as a single Bulk Electric System Element (e.g., a line, a a single shaft unit of greater than 20 MVA or aggregate individual dispersed power producing resources of more than 75 MVA, a shunt compensator, transformer, etc.)

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

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

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Connie Lowe, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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

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AEP has no objections to the revisions of Items 1 through 4 in the draft SAR.

 

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

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Lauren Price, On Behalf of: Lauren Price, , Segments 1

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We agree with the proposal to provide clarification and align better with the intent of the standard for relays to "not trip" under load.

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

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The SPP Review Group recommends that the drafting team provides clarity to why the term “Transmission” is capitalized in the phrase “Transmission system,” while the same term is not capitalized in the phrase “transmission network which is associated with proposed language pertaining to item 4 (page 2) of the Standard Authorization Request (SAR). The review group has a concern that there are some inconsistencies in the combination and capitalization of particular NERC defined terms and phrases.

SPP Standards Review Group, Segment(s) , 4/3/2017

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

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RSC no Dominion, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 3/13/2017

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

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When applicable, would definite time elements (50DT) be addressed similar to instantaneous 50 elements? 

Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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None

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

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Please see response to #3.

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

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Hot Answers

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

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

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Other Answers

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

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On item #6 , the language currently reads: "Clarify that a high unit capability may be used". Dominion suggests additional language in the detailed description under item 6(b)stating that “the generator nameplate rating can also be used for the real power output.” in the final recommendation.

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

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On item #6 , the language currently reads: "Clarify that a high unit capability may be used". Dominion suggests additional language in the detailed description under item 6(b)stating that “the generator nameplate rating can also be used for the real power output.” in the final recommendation.

Connie Lowe, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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Duke Energy suggests additional language be added to item c. of the Miscellaneous Items. As written, not entirely clear what the issue is, and what is meant by a “minimum criterion” in relation to the standard. More information about what the issue/concern is with this phrase would be helpful to understand the necessity of the revision.

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

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While AEP has no objections to the inclusion of Items 5 and 6 into the draft SAR, we seek clarity on 6c as the proposed language could cause a communication barrier between the TP and GO fuctions regarding “reported to the Transmission Planner”. For example, what specific reliability concern is it attempting to address, and exactly what is driving its proposed inclusion in the SAR?

 

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

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Lauren Price, On Behalf of: Lauren Price, , Segments 1

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We agree with the proposal to provide clarification and align better with the intent of the standard for relays to "not trip" under load.

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

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SPP Standards Review Group, Segment(s) , 4/3/2017

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

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RSC no Dominion, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 3/13/2017

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

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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None

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

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Please see response to #3.

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

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Hot Answers

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

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(1)   We believe the authors need to identify that Requirement R1 is only applicable to the small subset of GOs, TOs, and DPs that apply load-responsive protective relays at the Element terminals listed under the standard’s applicability section.  We recommend instructing the SDT to change the applicability of the requirement to “Responsible Entity” or “Functional Entity”.

(2)   We question the overall urgency identified within the SAR, particularly since the current implementation plan does not require 100% compliance until 2019 or 2021 for retrofits.  If there are concerns over current regional practices that exist, we believe pursing interpretations or regional variances may be a better alternative.

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

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

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Other Answers

N/A

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

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

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Connie Lowe, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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

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

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We have no additional comments at this time.

Lauren Price, On Behalf of: Lauren Price, , Segments 1

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

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The review group recommends capitalizing the term “system” in the phrase “Transmission system that’s associated with the proposed language (on page 2, 4, and 7) of the SAR. The group’s perspective is that both terms are defined in the NERC Glossary of Terms. Also, we recommend the drafting team consider collaborative efforts with The Alignment of Terms Drafting Team. The Alignment of Terms Drafting Team can provide some useful insight on how to address the inconsistencies of the combination and capitalization of particular NERC defined terms and phrases like “Transmission system.” Additionally, we recommend that the drafting team provides clarity on the meaning of the two phrases “Transmission system” and “transmission network.

SPP Standards Review Group, Segment(s) , 4/3/2017

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

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We support the SAR for Project 2016-04 Modifications to PRC-025-1.

RSC no Dominion, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 3/13/2017

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Texas RE does not have additional comments.

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

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Aubrey Short, On Behalf of: Aubrey Short, , Segments 1, 3, 4

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None

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

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The BES definition states that the individual resource should be included, however, many things within the way the standard is written can be argued otherwise.  The first example is the wording taken directly from the standard :

 

“Asynchronous generating unit(s) (including inverter‐based installations), or Elements

utilized in the aggregation of dispersed power producing resources.”

 

The OR referenced in Attachment 1, Table, (leading to Elements utilized in the aggregation of dispersed power producing re-sources) offer a choice which could eliminate the obligation to analyze down to the turbine level.

 

Another point is that the device within the wind turbine isn’t a standard relay element 51 or 51V-R.  The device in the turbine is a low voltage molded case circuit breaker.  Even more specifically,  the device ANSI representation is a 52 – AC Circuit Breaker.  What makes this even more frustrating is that generator owners and engineers within have no control of how these wind turbines were designed and commissioned by the OEM.  We did not provide the settings nor do we ever intend to change them from what the OEM originally placed.  

 

The final point to make, if entities are required to comply down to the turbine level main circuit breaker then there will be many cases that the breakers cannot be adjusted to a current that is over 130% nameplate MVA rating.    The Long time pickup is typically set slightly above nameplate with a “long” time delay (example 10 seconds).  This is a perfectly appropriate way to operate the wind turbine as there are other faster operating over current elements enabled on the same breaker (Short time and Instantaneous) that will protect for more severe faults.  The element of time delay isn’t specified in this standard which also adds issues. 

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

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