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1. previously provided in the second sentence Fifth change of its procedure to a procedure in the second sentence Sixth change procedure for placing to procedure indicating the normal practice for placing in the second sentence Seventh add during start up and shut down periods at the end of the second sentence With these changes the second sentence will read as follows If a generator is being started up or shut down with the automatic voltage control off and no Real time notification of the automatic voltage regulator status is made to the TOP the GOP should have evidence that it previously provided the TOP a procedure indicating the normal practice for placing the unit into automatic voltage control mode during start up and shut down periods iii Does the wording of the data retention section D1 2 indicate that an open ended number of years that the data for M1 M4 and M7 must be retained The current wording seems to indicate that all records for all time must be retained iv We suggest that the tardiness time frame given for the VSL for R2 more closely match the 30 minutes reporting time frame of requirement R3 and that the four thresholds for the various VSLs of R2 be 30 min 45 min 60 min rather than 5 10 and 15 min Generating plant operators are responsible for many other things in addition to Substation voltage v The word directives found in M3 should be changed to directions to eliminate possible confusion with a Relia
2. it previously provided the Transmission Operator of its procedure for placing the unit into or out of automatic voltage control mode Such evidence must include but is not limited to dated evidence of transmittal of the procedure such as an electronic message or a transmittal letter with the procedure included or attached ndividual d Davis ntergy Services Entergy continues to believe R1 of this draft standard places undue burden and requirements on Transmission Operators and adds uncertainty on the operation of the BES Therefore we again submit our comments here that we submitted in response to the last posting of this draft standard Entergy believes the Transmission Operator should not be required to have be required to update or maintain nor be required to know the startup shutdown procedures of all of the generators connected to its system TOPs should not be required to dig through a procedure to find out if the AVR should be in manual or automatic mode during startup or shutdown We also think it is not the best operation of the system for the TOP to assume the status of the AVR All of the proposed changes especially the provision of startup shutdown procedures places additional burdens on the TOP These burdens also place unwritten requirements on the TOP which auditors will definitely explore during the next review in any form of the TOP We view the requirement that the TOP receive the startup shutdown pro
3. system in the automatic voltage control mode automatic voltage regulator in service and controlling voltage unless the Generator Operator has notified the Transmission Operator of one of the following That the generator is being operated in start up or shutdown pursuant to a Real time communication e That the generator is being operated in accordance with a start up or shutdown procedure that was previously provided to the Transmission Operator That the generator is not being operated in the automatic voltage control mode for a reason other than start up shutdown With this change to R1 and the intent indicated in the above comments from the drafting team the footnotes should not be needed By stating and it will be viewed by the industry as defining what start up and shut down is the SDT is expanding the technical issues The drafting team should not attempt to define start up shut down ramp up or ramp down or place those words within a Requirement Note that within the PJM market ramp is something that is associated with a schedule where by a GOP may not ramp up until five minutes before top of the hour but could be on line producing real and reactive power The use of ramp within foot note 1 and 2 is ambiguous and will cause confusion There are too many different generator designs within our industry for the SDT to capture all possibilities by simply adding the proposed foot notes and bullets In addition wheneve
4. Individual or group 35 Responses Name 20 Responses Organization 20 Responses Group Name 15 Responses Lead Contact 15 Responses Question 1 30 Responses Question 1 Comments 35 Responses Question 2 0 Responses Question 2 Comments 35 Responses roup ortheast Power Coordinating Council uy Zito es roup PP Standards Review Group obert Rhodes The zero tolerance for error interpretation presented in the VSLs for R2 is too restrictive The Lower VSL is activated when a GOP is off its voltage or Reactive Power schedule for less than 5 minutes That means if the GOP fails to stay on schedule 100 of the time the GOP is non compliant and subject to being penalized We hope this was not the intent of the SDT and that the SDT will take action to correct this situation While being off schedule can be a serious issue with possible repercussions for the reliability of the BES typically the GOP would have time to make necessary adjustments and get back on schedule RCs and TOPs are allowed to respond to an IROL exceedance within Tv default of 30 minutes without penalty Exceeding an IROL is much more critical to the operation of the BES than a generator being off schedule We suggest that allowances be incorporated into the VSLs which provide some flexibility for the GOP in maintaining voltage and Reactive Power schedules For example the appropriate section of the Lower VSL could be changed to read failed to meet the directed val
5. R3 1 and 3 2 Since this is a revision to the standard the drafting team should consider deletions as wells as additions The NSRF contends that the words and the expected duration provide no practical Bulk Electric System reliability benefit and should be removed The TOP can request any duration during real time notification or by advance notice Delete all added material to M1 or have M1 match revised wording in R1 Revise any VRFs or VSLs appropriately roup ennessee Valley Authority GO GOP David Thompson The proposed VSLs for R2 are unreasonable In order to track and respond to the system voltage on 5 minute intervals the generator operator would have to be solely dedicated to the function of monitoring system voltage This places an unrealistic burden on the generator operator who has other duties besides just monitoring system voltage The VSLs should increment in 2 hour intervals not 5 minute intervals This proposed change is a major revision to the 5 intervals presently in the standard and is not an interpretation as the title suggests ndividual Kenneth A Goldsmith lliant Energy We do not agree with the proposed revisions to R1 R1 in our opinion was well written and adding the footnotes did nothing to clarify it The SDT is making the effort to define start up and shutdown but we believe each individual GOP needs to define that ndividual Michelle R D Antuono ngleside Cogeneration LP Ingleside Cogenerati
6. Standard will require continual monitoring by a dedicated operator 24 hours a day 7 days a week 365 days a year In addition even if a dedicated operator is continuously monitoring a Generator Operator will be in violation of the Standard if there is any deviation from the voltage schedule regardless of the magnitude or duration of the voltage excursion or success of the operator in bringing the voltage back within the prescribed voltage schedule Such a result is unreasonable and provides no increased level of reliability Content of the proposed Standard Constellation requested in their interpretation request that Requirement 1 be interpreted to clarify the expectation and communication of having an automatic voltage regulator in manual or automatic during the start up and shut down sequences of a generating unit Defining the terms start up and shut down was not part of the request and creates more confusion than it resolves The proposed definitions in the footnotes are unclear and vague The first problem with Footnote 1 concerns the term ramped up that remains in the language This is an unnecessary qualifier Secondly the term minimum is too vague The minimum in a generator user manual may be different than the minimum defined in a start up procedure Footnote 2 attempts to define shut down of a unit However the definition used is only one of numerous ways a unit may be brought offline Every unit has a uniq
7. WN PER R3 roup FirstEnergy am Ciccone FirstEnergy supports the revisions and thanks the drafting team for their hard work ndividual Howard Rulf Wisconsin Electric dba We Energies The Time Horizon for R1 is Real time Operation so it is reasonable to assume that the notifications in R1 take place in Real time R1 is worded such that even if a procedure was previously provided to the TOP as stated in the first bullet a Real time communication must be made to the TOP each time during startup or shutdown if the AVR is not in voltage control mode AVR in service and controlling voltage Please clarify that if the TOP has been provided a procedure a Real time communication is not necessary roup Dominion Mike Garton Dominion maintains that the existing standard language is clear and the revision of Requirement 1 and the addition of footnotes 1 amp 2 are unnecessary roup outhern Company ntonio Grayson i For clarity we suggest the middle portion of the first bullet of R1 be revised as follows mode pursuant to either a Real time communication or a procedure that was previously provided to ii We suggest seven changes to M1 First that the first sentence of M1 be changed to replace failed to with did not Second insert Real time communication in the second sentence between no and notification Third change will have evidence to should have evidence in the second sentence Fourth replace notified with
8. ators and other resources We also are in strong support of an exemption for power system stabilizer status during generator startup and shutdown covered in R3 should be incorporated into the standard ndividual Martin Kaufman ExxonMobil Research amp Engineering NERC has already established an SDT to review and modify the VAR standards By stepping outside the normal process for drafting standards regardless of the intent or end product NERC is setting a precedent for superseding a pre qualified SDT and the ANSI approved process for drafting standards For the time being a Generator Operator s compliance with its Transmission Operator s established scheduling process or a Generator Operator s verbal notification to the Transmission Operator that a unit is being brought online or offline and is in manual control should be sufficient notification that its AVR is not in service roup PL Corporation NERC Registered Affiliates tephen J Berger Footnote 4 to R2 does not adequately explain limitations on being able to maintain system voltage within the schedule bandwidth This generally has nothing to do with GO Facility Ratings The constraint is instead variation of the generation plant medium or low voltage bus from normal typically max 5 Such limits are encountered well before approaching the generator OEM s D curve boundary TO issued voltage schedules for our entities and probably everywhere are tighter than the max and mi
9. bility Directive vi The following phrase from R1 should be added to R3 Unless the Generator Operator has notified the Transmission Operator that the unit is being operated in start up or shutdown mode pursuant to a procedure previously provided to the Transmission Operator This phrase permits a blanket notification serve as adequate communication of the switching of the AVR mode during start up or shutdown periods in lieu of the 30 minute notification ndividual Dale Fredrickson Wisconsin Electric Power Company oO wn R1 The modifications to R1 do not serve to clarify the intent but only make this standard more complex than it needs to be We strongly assert that the standard is not an appropriate place to define the terms start up and shutdown Such definitions also have little meaning for facilities like wind farms and other intermittent resources We also object to the requirement for either a Real time communication or a procedure to be provided by the GOP to the TOP There is no clear reliability driven need to provide a procedure which by definition is usually a more detailed and complex document A simple notification by the GOP to the TOP of the circumstances and estimated timeframe that may require a generator being in an AVR mode other than Automatic is sufficient to assure coordination between the GOP and the TOP as it relates to the generator AVR status We suggest that R1 be revised to remove
10. cedures as placing new requirements on the TOP in violation of the Interpretation process Per Constellation in its Request for Interpretation A generator operator already communicates to the TOP that the unit is being started up or shutting down It would appear that a GOP could include in its procedures a requirement that the TOP be informed of the status of the AVR when the GOP is communicating to the TOP that the unit is starting up or shutting down TOPs only want to know the status of a generating unit s AVR is it in automatic or manual mode That information can be provided when the startup shutdown information is being communicated Therefore we recommend the following changes to VAR 002 2b Delete both of the new bullet points added to R1 including associated footnotes Delete 0 That the unit is being operated in start up1 or shutdown2mode pursuant to a procedure previously provided to the Transmission Operator or e That the unit is not being operated in the automatic voltage control mode for a reason other than start up or shutdown And 1 Start up is deemed to have ended when the unit is ramped up to its minimum load and the unit is preparing for continuous operation 2 Shutdown is deemed to begin when the unit is ramped down to its minimum load and the unit is preparing to go offline Also delete the new wording in M1 If a generator is being started up or shut down with the automatic voltage control off and no notification to
11. e regulator in service and controlling voltage unless the Generator Operator has notified the Transmission Operator DELETE of one of the following OF THE CONDITIONS IN R1 1 OR R1 2 Violation Risk Factor Medium Time Horizon Real time Operations R1 1 That the generator is being operated in start up footnote 1 or shutdown footnote 2 mode pursuant to R1 1 1 A Real time communication or R1 1 2 A procedure that was previously provided to the Transmission Operator HOWEVER AFTER THE PROCEDURE HAS BEEN PROVIDED NO NOTIFICATION IS REQUIRED BY THE GENERATOR OPERATOR FOR EACH SUBSEQUENT START UP OR SHUTDOWN R1 2 That the generator is not being operated in the automatic voltage control mode for a reason other than start up or shutdown 4 Change the footnotes as follows 1 Start up is deemed to have ended when the generator is ramped up to its minimum continuously sustainable load AS DEFINED BY THE GENERATOR OPERATOR IN R1 1 1 OR IN R 1 1 2 and the generator is prepared for continuous operation THE GENERATOR OPERATOR SHALL REPORT CHANGES IN THE AUTOMATIC VOLTAGE CONTROL MODE STATUS AT THE END OF START UP PER R3 2 Start up is deemed to have ended when the generator is ramped down to its minimum continuously sustainable load AS DEFINED BY THE GENERATOR OPERTOR IN R1 1 1 OR IN R 1 1 2 and the generator is prepared to go off line THE GENERATOR OPERATOR SHALL REPORT CHANGES IN THE AUTOMATIC VOLTAGE CONTROL MODE STATUS AT THE END OF SHUTDO
12. e the unit is below XX MW of output the AVR is in manual mode etc ndividual Maggy Powell xelon Corporation and its affiliates The revisions made to R2 fail to address the concerns present VAR 002 version 1 1b and as proposed revision requires that each GOP shall maintain the generator voltage or Reactive Power output as directed and Measure R2 further clarifies that each GOP shall have evidence to show it controlled its generator voltage or Reactive Power schedule to meet the voltage or Reactive Power schedule provided by the TOP However in certain situations a GOP may not be able to meet the schedule because of system variations outside of the GOP s control or internal operational constraints In this situation a GOP may be non compliant with this requirement because of issues out of its control This requirement should be revised to allow the GOP to contact the TOP when outside the schedule and to follow the TOP s instruction The revisions to R2 do not address this compliance concern Exelon concedes that use of the word schedule in place of output in R2 is more accurate The proposed SLs associated with VAR 002 Requirement R2 were revised on this draft to be contingent ona specified time limit for failure to meet the directed values of the generator voltage or Reactive Power schedule This change to the VSL criteria is not reasonable has no relation to increased reliability and is not feasible to be implemented by most i
13. ect this situation While being off schedule can be a serious issue with possible repercussions for the reliability_of the BES typically the GOP would have time to make necessary adjustments and get back on schedule RCs and TOPs are allowed to respond to an IROL exceedance within Tv default of 30 minutes without penalty Exceeding an IROL is much more critical to the operation of the BES than a generator being off schedule We suggest that allowances be incorporated into the VSLs which provide some flexibility for the GOP in maintaining voltage and Reactive Power schedules For example the appropriate section of the Lower VSL could be changed to read failed to meet the directed values for more than 30 minutes but less than 40 minutes Similarly the Moderate VSL could be changed to read for 40 minutes or more but less than 50 minutes The High VSL could be changed to read for 50 minutes or more but less than 60 minutes The Severe VSL could be changed to read for 60 minutes or more This would give the GOP 30 minutes without penalty to respond to whatever the issue is that is keeping it from maintaining the assigned schedule When modifying the VSLs the SDT may also want to factor in the amount of deviation from schedule Being a few percentage points off schedule is not as critical as being 10 15 off schedule ndividual Kirit Shah meren We strongly believe that the VSLs should remain as a percentage of the
14. f not all Generator Operators Voltage schedules are provided by the Transmission Operator or Transmission Owner if delegated by the Transmission Operator and vary from generator to generator based on the Transmission Operator Owner methodology for maintaining system wide grid voltages and on generator location Although it is an expectation that the voltage schedule be maintained the voltage monitored is dynamic and regularly and sometimes constantly fluctuates Once a Generator Operator has identified that the voltage has drifted outside of the voltage schedule then it is reasonable to expect the Generator Operator to make timely adjustments unless constrained by operating parameters to bring the voltage back within the prescribed voltage schedule and to contact the Transmission Operator Owner if attempts to bring the voltage back within the prescribed schedule are unsuccessful or not possible It should be up to the discretion of the Transmission Operator Owner in consultation with the Generator Operator to set the expectation for monitoring the voltage time allowed to adjust the voltage back within band and communications required in the event voltage cannot be brought back within the voltage schedule The VSLs as currently proposed impose a time limit that has no technical justification or relation to increased reliability and is inconsistent with Requirement R2 which does not impose a time requirement If approved as currently proposed this
15. g the attention of industry stakeholders and has asked for examples of requirements which distract from those which are far more critical Frankly we believe this is an example of such a distraction and will be providing that feedback to them ndividual had Ness merican Electric Power e If Requirement 1 were removed from VAR 002 what reliability objective would not be met by the combination of VAR 001 and VAR 002 AEP strongly believes that the existing Requirement 1 can be eliminated if VAR 002 Requirement 2 has minor enhancements or maybe no changes are required The requirements of VAR 001 require the TOP to communicate the voltage schedule or Reactive Power schedule or exempt the facility In addition the TOP is required to direct the units in real time as necessary Through this coordination initiated by the TOP and the language in VAR 002 Requirement 2 the GOP is required to follow the instructions of the TOP and be in the mode of operation the TOP deems necessary For example the TOP could provide guidance on startup and shutdown expectations for AVR modes and the GOP would then be obligated to comply with these expectations via Requirement 2 Fundamentally the problem with VAR 002 Requirement 1 and why it is subject to so many interpretations request is that it may conflict with the directions provided by the TOPs as required by VAR 001 The changes in this project and past interpretation requests do not address this fundamen
16. ge and reactive output to meet the voltage or Reactive Power schedule directed by the Transmission Operator or The Generator Operator failed to provide an explanation of why the voltage schedule could not be met ndividual ony Kroskey razos Electric Power Cooperative lease see the formal comments submitted by ACES Power Marketing lease see the formal comments submitted by ACES Power Marketing roup CES Power Marketing Standards Collaborators ason Marshall 1 We agree with changing output to schedule for consistency with VAR 001 2 R4 2 We do not agree with the VSLs As written they are open ended and subject the Generator Operator to rapidly escalating sanctions The VSLs do not define the time period over which the failure to maintain the generator voltage or Reactive Power schedule is measured Is the time period a year the audit period or something else The audit period for a GOP is six years Thus if a GOP experienced 16 minutes of failing to meet its voltage or reactive power schedule it would achieve success for 99 99949 of the minutes over the six year period but still be assessed a severe violation This Success rate approaches the maximum theoretical availability success of the Six Sigma process which is used by many industries for managing industrial processes It does not seem reasonable to consider approaching a theoretical maximum a severe violation 3 We appreciate that the drafting team included R2 in
17. get value is to be maintained during a specified period The footnote should state a tolerance band within which the target percentage value is to be maintained We recommend changing the VSL s back to percentages for both reactive power output and voltage roup lorida Municipal Power Agency rank Gaffney Constellation is essentiall what does notify mean as used in the standard and asking if previously arranged operating procedures between the GOP and TOP is notification including operating for start up and shutdown of a unit during which an AVR would be put into manual mode An interpretation of what notify means as used in the standard is more appropriate as opposed to changing the standard The response to the request is too specific and introduces new terms into the standards that are ambiguous and will cause confusion depending on the type of generator being considered e g start up and shutdown possibly spurring additional requests for interpretation of what start up and shutdown mean for say a wind or solar farm etc In addition while R1 has become clearer as to the intent it leaves R3 unclear with the same question concerning the word notify An interpretation essentially saying that pre arranged conditional notification between the GOP and TOP acts as notification in regards to both R1 and R3 is a preferably approach to a rapid revision e g every time the unit is on outage the AVR is out of service every tim
18. n limits that the TO and TOP themselves seek to maintain It makes sense that firstly all generation plants should do what they can within the equipment limits after which the TO TOP take system wide action but a single generation plant is oftentimes not able to pull its node of the grid into compliance with the TO issued voltage schedule during periods of high or low demand It is unrealistic to assume that unanimity of GO actions occurs automatically as a result of VAR 002 requirements The only means of getting all plants to pull together is through TO TOP verbal directives VAR 002 as presently written and in the proposed update version 2b sets a nearly impossible task in placing the entire burden of maintaining the schedule on each individual GO To make matters worse some TOs may set a bandwidth for GOs only a fraction of the amount the max min variation that they themselves seek to maintain It may be necessary to rewrite VAR 002 completely to address some fundamental issues with the current compliance approach roup uminant renda Hampton The VSL string Lower and High should be modified in the following manner to eliminate always being non compliant under the Lower VSL scenario Lower VSL should be the Generator Operator failed to meet the directed values within the 5 minutes or When a generator s automatic voltage regulator is out of service the Generator Operator failed to use an alternative method to control the generator volta
19. on LP agrees that a clear linkage should be established between the voltage or Reactive Power schedule developed by the TOP in VAR 001 2 R4 This clarifies the intent of the requirement and is consistent with our standard operating procedures Ingleside Cogeneration LP appreciates the additional precision the project team has added to VAR 002 2b R1 and R2 We believe this will help drive consistent auditor findings which have been inconsistent across the Regions In addition the allowance of blanket pre notifications is a powerful means to address routine operating communications Although each is important many are so routine that it is easy to miss one Too many times this has resulted in a violation even if the AVR was properly online during generator start up or shut down as the GOP cannot prove their compliance However we are concerned that the ERO is expending so much energy to address a topic which has questionable reliability benefit There is no evidence that offline AVRs during generator start up and shut down have led to a BES event or extended its scope Instead this feels like an over extended interpretation of a requirement well beyond its original intent We are aware that NERC s Compliance Team began this process in CAN 022 but they are not supposed to drive the interpretations process Because of this factor we can not support this Interpretation of VAR 002 FERC has begun to recognize that low priority tasks are consumin
20. oposed change to R1 which provides for two different types of notification from the GOP to the TOP for situations when the unit is not being operated in automatic voltage control mode The Standard Drafting Team should take this opportunity to fully incorporate the provisions of CAN 0022 into the standard and retire CAN 0022 The following phrase from R1 should be added at the beginning of R3 Unless the Generator Operator has notified the Transmission Operator that the unit is being operated in start up or shutdown mode pursuant to a procedure previously provided to the Transmission Operator If this or a similar change to R3 is not made then CAN 0022 cannot be retired ndividual Michael Falvo ndependent Electricity System Operator he IESO supports the revised standard roup MRO NSEF Please consider the following NSRF comments Several commenters in the last posting expressed concern about the footnotes that seemed to attempt to define startup and shutdown One of the standard drafting team responses included the following Flexibility has been given to the generator operators to provide documentation to the TOP that allows the GO to define the start up shut down parameters for any particular generator To better clarify that the operator is allowed to define start up and shutdown parameters the following change is recommended to R1 R1 The Generator Operator shall operate each generator connected to the interconnected transmission
21. r a foot note is used to clarify a Requirement the Requirement becomes more ambiguous Recommend that foot note 1 and 2 be deleted since they only provide examples to a certain type of generator The SDT needs to write the Requirement whereby it can be universally used by all applicable entities The NSRF recommends that R3 is clearly suited for incorporation of the requested interpretation R3 1 is written to capture status or capacity changes on any generator such as when a generator is not in the desired voltage response mode The NSRF recommends R3 to be rewritten to capture the intent of the interpretation to read R3 Each Generator Operator shall notify its associated Transmission Operator as soon as practical but within 30 minutes unless advanced notification has been provided of any of the following note underlined words have been added by the NSRF The noted advance notification will allow GOPs to establish an individual process for each generators that do not comply with R1 or fall within scope of R2 This will also allow GOPs and TOPs on how this advance warning is to be provided It may be via written procedure a mutually agreed SCADA point etc NERC has allowed stakeholders the authority to design their own programs based on their asset characteristics as in FAC 008 CIP 002 EOP 001 etc The SDT should allow each applicable entity within this Standard the same authority Delete the words and the expected duration to
22. rn about the ambiguity in the term minimum load by adding the words continuously sustainable but we do not believe this solves the ambiguity since it is not a widely accepted industry term Xcel believes that if the SDT wants to avoid ambiguity it will have to set an arbitrary load value e g 30 of rated MW 2 Xcel Energy finds the VSL structure for Requirement R2 totally unworkable The Lower VSL less than five minutes goes into effect for any deviation from the scheduled voltage band even a one millisecond excursion would be a violation The VSL as written would override any time allowance to correct for excursions given by the TOP in its Voltage Schedule provided to the GOP
23. t to come offline with the unit The reasoning is generators i e CTs will be given the order to shutdown when at various load levels including full load and at which point the TOP will no longer rely on that unit for voltage control roup Duke Energy reg Rowland NERC s CAN Process document dated April 2012 states on page 8 under section J that CANs are retired when a revised standard or interpretation that addresses the compliance application issue in the CAN is approved by FERC and is enforceable The SDT should take this opportunity to fully incorporate CAN 0022 into the standard and retire CAN 0022 In our March 23 comments we pointed out that the SDT s proposed revision to the standard did not go far enough to resolve the request for interpretation While the proposed revision does provide clarification that manual AVR status can be communicated via a start up or shutdown procedure notification as does CAN 0022 this change alone does not relieve the GOP from the existing 30 minute notification requirement under R3 Approved CAN 0022 allows the GOP to provide a blanket advance notification to the TOP in lieu of separate notifications for each change in status In this instance Constellation sought clarification of R1 as to whether or not a communication must be conducted between a GOP and TOP during start up or shutdown of a generator Thus we see a direct connection to CAN 0022 and R3 as well as R1 We agree with the SDT s pr
24. tal issue Furthermore these proposed changes introduce additional complexities that will continue to create challenges For example it would be better for the TOP to provide procedures for reporting startup and shutdown expectations rather than the GOPs develop and provide the procedures ee response to Question 1 roup Western Electricity Coordinating Council teve Rueckert wn As indicated by our Affirmative vote we agree that the revisions add clarity However from an auditing and enforcement perspective the term minimum continuously sustainable load in foot note R1 is not defined and leaves too much room for open interpretation and inconsistent auditing For instance does the term mean a time constant is applied that they are able to sustain it for 1 min or 1 hr or is it a set and fixed number It would be clearer and more manageable to audit to have a bench mark that state the minimum continuously sustainable load is a load that is set by the GOP and agreed upon by the GOP and TOP ndividual Don Schmit Z 2Z o U J The zero tolerance for error interpretation presented in the VSLs for R2 is too restrictive The Lower VSL is activated when a GOP is off its voltage or Reactive Power schedule for less than 5 minutes That means if the GOP fails to stay on schedule 100 of the time the GOP is non compliant and subject to being penalized We hope this was not the intent of the SDT and that the SDT will take action to corr
25. tation requester As Constellation pointed out there was a narrow question that an interpretation could have addressed while Project 2008 01 organized around the larger issues present in VAR 001 and VAR 002 Exelon Constellation is optimistic that Project 2008 01 is able to efficiently and effectively address the problematic language in VAR 001 and VAR 002 and that NERC provide resources to Project 2008 01 to enable development of revision proposals in a timely manner ndividual rett Holland ansas City Power amp Light The VSL s for Requirement 2 stipulate time frames that are within spans of time up to a maximum of 15 minutes This is not a reasonable expectation and is not in alignment with Requirement 3 which stipulates a Generator Operator to notify its Transmission Operator within 30 minutes of a status or capability change Requirement 3 allows the Generator Operator some time to determine a reactive production problem exists and to make a notification to the Transmission Operator Requirement 2 should afford at least the same time for the Generator Operator to recognize a problem exists and to attempt to take corrective action to meet operating expectations Recommend modifying the VSL for Requirement 2 as follows Low at 30 minutes Medium at 45 minutes High at 60 minutes and Severe at 75 minutes or longer ndividual lice Ireland cel Energy e 1 Xcel Energy appreciates that the SDT has attempted to address the conce
26. the Transmission Operator is made the Generator Operator will have evidence that it notified the Transmission Operator of its procedure for placing the unit into automatic voltage control mode Such evidence must include but is not limited to dated evidence of transmittal of the procedure such as an electronic message or a transmittal letter with the procedure included or attached ndividual nthony J ablonski ReliabilityFirst ReliabilityFirst votes in the Negative for this standard because the revision to standard does not address or include the TOPs acknowledgment of the receipt of the GOPs procedure for the start up shutdown of their generator ReliabilityFirst offers the following comments for consideration 1 ReliabilityFirst fundamentally agrees that the included bullets somewhat resolve the issue raised in the interpretation request though believes the first bullet is missing one key component ReliabilityFirst believes it is crucial for the TOP to acknowledge receipt of the GOPs procedure for start up shutdown of their generators Without required TOP acknowledgment of receipt of the procedure there is a chance that vital information may not be communicated which could result in voltage levels reactive flows and reactive resources not being maintained ndividual Daniel Duff Liberty Electric Power agree with the comments submitted by Exelon regarding the use of time criteria in the VSLs for a requirement which does not have at
27. the revised SAR scope but we believe the changes still do not go far enough to satisfy the request for interpretation The issue that Constellation identifies is essentially that the TOP may not grant an exemption for following the voltage or reactive power schedule pursuant to R2 during start up and shut down The GOP can provide the TOP with a Real Time communication or a procedure and the TOP may still not grant an exemption Per R2 since it is an independent requirement unless the TOP grants an exemption the GOP still must follow the voltage or reactive power schedule regardless of what R1 states The GOP needs not only the changes to R1 but also changes to R2 that provide a blanket exemption during start up or shut down They should not be put into a position to rely on the TOP providing an exemption during start up or shut down especially considering that the voltage or reactive power schedule provided by the TOP most likely assumed full unit capability ndividual ndrew Z Pusztai merican Transmission Company es ATC endorses and supports the comments submitted by the MRO NERC Standards Review Forum NSRF ndividual ohn Babik EA The VSLs changed using time and removed the percentages this change is unrealistic and have no merit to reliability Footnote 3 states The voltage or Reactive Power schedule is a target value communicated by the Transmission Operator to the Generator Operator establishing a tolerance band within which the tar
28. the two bullets and add new wording as follows The GOP shall operate each generator connected to the interconnected transmission system in the automatic voltage control mode AVR in service and controlling voltage unless the GOP has notified the TOP SUGGESTED WORDING FOLLOWS in advance by a Real time communication or other previous notification Likewise we propose that M1 be revised to remove the 2nd sentence which refers to startup or shutdown procedures The 3rd sentence should be expanded to include manual or electronic log entries roup Bonneville Power Administration hris Higgins BPA thanks you for the opportunity to provide commens on Project 2011 INT 02 Interpretation of VAR 002 for Constellation At this time BPA has no comments or concerns ndividual erri Pyle klahoma Gas amp Electric e The VSLs for R2 is too restrictive The Lower VSL is applicable when a GOP is off its voltage or Reactive Power schedule for less than 5 minutes While maintaining these schedules is important we do not believe that the SDT intended for this requirement to have virtually zero tolerance We would request that the SDT reconsider the timeframes for the VRLs to be more reflective of the potential impact and be in line with those that are currently active for IROLs The VAR standards need to be updated to bring the language in line iwth the latest technologies in use today i e incorporate language to cover nonsynchronous gener
29. time component ndividual ohn Seelke Public Service Enterprise Group es We suggest the following changes in R1 Capitalized terms are additional language 1 Modify the opening paragraph R1 The Generator Operator shall operate each generator connected to the interconnected transmission system in the automatic voltage control mode automatic voltage regulator in service and controlling voltage unless the Generator Operator has notified the Transmission Operator DELETE of one of the following OF THE CONDITIONS IN R1 1 OR R1 2 Violation Risk Factor Medium Time Horizon Real time Operations RATIONALE Added new language to refer to renumbered bullets see below 2 Change the bullets to subparts as follows delineating the information in the first bullet R1 1 That the generator is being operated in start up footnote 1 or shutdown footnote 2 mode pursuant to R1 1 1 A Real time communication or R1 1 2 A procedure that was previously provided to the Transmission Operator HOWEVER AFTER THE PROCEDURE HAS BEEN PROVIDED NO NOTIFICATION IS REQUIRED BY THE GENERATOR OPERATOR FOR EACH SUBSEQUENT START UP OR SHUTDOWN R1 2 That the generator is not being operated in the automatic voltage control mode for a reason other than start up or shutdown 3 Summary of 1 and 2 R1 The Generator Operator shall operate each generator connected to the interconnected transmission system in the automatic voltage control mode automatic voltag
30. ue sequence in which it is shut down Therefore Footnote 2 is too prescriptive Furthermore the footnotes are not consistent with those in VAR 001 This revision stands to create further confusion relative to VAR 001 Process Concerns Exelon Constellation reiterates the process concerns raised in the previous comment period The use of a rapid revision project in place of an interpretation was misguided and misrepresented The response to comments does not sufficiently address the process concerns raised It does not justify using an alternative process to the interpretation process The Constellation request for interpretation kept with the BOT direction by being restricted to the words contained in the standard Constellation s explanation of concerns with VAR 001 and VAR 002 should have sufficiently illustrated that a small adjustment to the wording as allowed within a rapid revision was inappropriate In general the details of what constitutes this rapid revision process are not clearly defined It is unclear what criteria are used to judge an issue to determine its qualification for rapid revision It is unclear who makes the judgments This new process is under utilization without proper rollout or justification and appears to be used in place of approved and better understood processes The Standard Committee elected to pursue the rapid revision process without understanding the interpretation request and without support of the interpre
31. ues for more than 30 minutes but less than 40 minutes Similarly the Moderate VSL could be changed to read for 40 minutes or more but less than 50 minutes The High VSL could be changed to read for 50 minutes or more but less than 60 minutes The Severe VSL could be changed to read for 60 minutes or more This would give the GOP 30 minutes without penalty to respond to whatever the issue is that is keeping it from maintaining the assigned schedule When modifying the VSLs the SDT may also want to factor in the amount of deviation from schedule Being a few percentage points off schedule is not as critical as being 10 15 off schedule We generally agree with the proposed changes to R1 and R2 in the standard That said we do believe that the VAR standards need to be updated to bring the language into line with the latest technologies in use today i e to incorporate language to cover non synchronous generators and other resources We recognize that this is beyond the scope of Project 2011 INT 02 but feel the standard needs a good review and update We also believe that an exemption for power system stabilizer status during generator start up and shutdown covered in R3 should be incorporated into the standard roup rogress Energy im Eckelkamp Yes progress Energy does not agree with the SDT definition of Shutdown and would propose the following Shutdown Unit load being decreased in local plant control with the inten
32. voltage deviation as approved earlier by FERC We also believe that the VSLs in the draft conflict with the statement provided in footnote 3 that the TOP is allowed to set a specified time period for following voltage schedules In addition we believe that the draft VSLs are not clearly defined For example it includes 5 minutes time frame as a lower VSL is this a continuous 5 minute increment or it is an accumulated 5 minutes over a period Again the GOP should follow the directives given by the TOP and VSL should be appropriately defined rather than as prescribed presently 1 We would recommend that requirements not be addressed as footnotes However If the SDT elects to choose this approach and provide footnotes as requirements then we recommend Requirement 1 footnote 3 should include specified period as directed by the Transmission Operator at the end 2 To keep the generator operators out of double jeopardy we suggest the SDT to consider the following modified language for Measure M1 The Generator Operator shall have evidence to show that it notified its associated Transmission Operator any time it failed to operate a generator in the automatic voltage control mode as specified in Requirement 1 If a generator is being started up or shut down with the automatic voltage control off and no specific notification regarding automatic voltage control mode is made to the Transmission Operator the Generator Operator will have evidence that

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