RFC Webinar June 17, 2009 Presented By: Mark Kuras Chair, UFLS SDT

RFC WebinarJune 17, 2009

Presented By: Mark Kuras Chair, UFLS SDT

June 17, 2009 2 ReliabilityFirst Webinar

Standards Committee approved SAR on February 24th, 2006

RFC standard was created to meet the requirements of the present NERC PRC-006 standard

Proposed standard lists requirements for:

▪ UFLS Program implementation (R1)

▪ Creation of a Credible Island determination methodology (R2)

▪ Assessment of credible islands (R3)

▪ Generator under frequency protection (R4)

▪ Creation of UFLS Database (R5)

▪ Population of the UFLS Database (R6)

▪ UFLS Program effectiveness evaluation (R7)

▪ Information exchange (coordination) (R8)


Posted for 5 comment periods

▪ 5/16/07 thru 6/14/07 – 20 commenters

▪ 10/29/07 thru 11/28/07 – 21 commenters

▪ 5/1/08 thru 5/30/08 – 24 commenters

▪ 9/5/08 thru 10/6/08 – 23 commenters

▪ 1/21/09 thru 2/19/09 – 21 commenters


During the last rounds of commenting, only seven general issues came up


Issue Applicability goes beyond the NERC Compliance

Registry CriteriaSDT View Distinguishing between BES and non-BES is not a

factor in the reliability impact of lost generation during an under-frequency condition

The material impact to reliability is solely a function of the physics of electricity Loss of generation from a 69 kV station has precisely the

same effect on BES frequency as loss of the same amount of generation from a BES station


The NERC Compliance Registry Criteria is subject to considerations other than reliability and so a conflict has arisen between reliability and other considerations

The SDT has compromised on the applicability from previous drafts of the standard, but believes that reliability would be poorly served if further compromises were made in deference to these other considerations

Also Note 4 of the Compliance Registry Criteria states4. If an entity is part of a class of entities excluded based on the criteria above

as individually being unlikely to have a material impact on the reliability of the bulk power system, but that in aggregate have been demonstrated to have such an impact it may be registered for applicable standards and requirements irrespective of other considerations.


Issue LSE no longer exists in the Standard, but

Distribution Provider should be removed tooSDT View Distribution Provider is a valid NERC

Functional Model entity that is presently required to be registered, even though they are not part of the BES

The NERC Functional Model indicates that Distribution Providers are responsible for UFLS implementation, not Transmission Owners


Issue Small Distribution ProvidersSDT View Compliance problems lie in the number

of feeders available to balance steps equally

Can group together Exemption criteria included Complete exclusion would unfairly

burden other Distribution Providers


Issue Generator Protection

SDT View Establishes minimum clearing times Having no protection makes you

compliant Very common Operators must realize that they should not

trip units faster then the standard minimums


Issue My generator cannot meet the standard’s

minimum clearing requirementsSDT View Time periods based on major

manufacturer protection requirements Also based on legacy Regional

requirements Historically very little exposure to these

frequencies


IssueEffective DatesSDT ViewStandard will apply to applicable RFC

Members on RFC Board approvalStandard will apply to applicable RFC

Registered Entities on FERC approvalThe same for all regional standards


Issue Stop RFC’s UFLS standard development

and wait for NERCSDT View This standard is to meet the

requirements of the presently in place NERC standard

This standard will apply in the interim until NERC approves PRC-006-01

NERC standard is still a ways away


Questions?Our Goal

RELIABILITY

Documents

RFC Webinar June 17, 2009 Presented By: Mark Kuras Chair, UFLS SDT