Comments on Draft 7 SERC UFLS Standard_PRC-006-SERC-01_ ...

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4identify UFLS entities included in their scheme. The SERC standard cannot reduce thisapplicability. However, the SERC standard does contain a requirement (R4, part 4.2) for aUFLS entity identified by a PC that has a total load less than 100 MW shall not be requiredby the PC to have more than one UFLS step. Is Draft 7 clear that it does not broaden theapplicability beyond what is contained in the NERC UFLS standard?YesNoIf your answer is “No” please provide comments on any proposed revisions to address thisconcern.<strong>Comments</strong>:7. Do you have additional comments on any item(s) not addressed in Questions 1 through 6?YesNo<strong>Comments</strong>:
From:To:Cc:Subject:Date:Shah, Kirit SSERC Regional StandardsShah, Kirit SAmeren comments on draft SERC UFLS StandardThursday, March 24, 2011 3:09:26 PM1) The second sentence in requirement R2.3 ‘This does not apply to UFLS relays with timedelay of one second or longer applied to prevent the frequency from stalling at less than60Hz.’ Does this mean if a relay has a delay of more than 1.0 second it can’t be used at thetop frequency set point? We believe that this requirement should be reworded orclarified.2) Requirement R7. The Regional standard needs to include limits on when Generators areallowed to take their units off line. Presently there are no restrictions on generator ownerswho want no risk in protecting their units.Presently the only requirements which exist is that the generator owners have to providetheir trip settings, with no restriction on where they trip the units off line. New IPPs wantto protect their generators and therefore trip their units off at relatively high set pointsand short time delays. This will obviously make an underfrequency event worse. Thetraditional utilities which are responsible for reliability to our customers are left 100%responsible, with our generators supporting the system and risking damage to ourgenerators. All generator owners need to share the responsibility and be required to keeptheir generation on line as long as possible, to maintain reliability to the system. Generatortrip settings need to be restricted. I believe the NERC standards give the regions the rightto enforce these restrictions.We believe that the above issue should be addressed before this standard can be finalized.3) There is no restriction or limit on how long the underfrequency delays can be set. Thiscould result in one area or utility losing it’s load and a neighboring utility retaining its load.Same as item #2 above, we believe that the above issue should be addressed before thisstandard can be finalized.–Kirit Shah: : : : : : : : : : : : : : : : : : : : : : : : :KIRIT SHAHManagerReliability Standards ComplianceT 314.554.3542F 314.554.3268E kshah@ameren.com.........................
Page 1 and 2: 1Comment Form for: Draft 7 of the S
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