Regional Standard:
 
Directory#4 System Protection Criteria
 
Comment Period (3/25/2019 - 5/9/2019)
 DateOrganization 
05/09/2019Ontario Power Generation Inc.View Attachment
 
Comments: OPG appreciates the opportunity to provide comments on the subject posting. At this time OPG has the following comments for the subject posting (see attached file). Let us know if additional information is required. Best regards, Constantin Chitescu, P.Eng. ONTARIO POWER GENERATION Regulatory Analyst Regulatory Affairs, Reliability Compliance 700 University Avenue, Toronto, ON M5G 1X6 External Phone: 416-592-6055
05/09/2019Ontario Power Generation Inc.View Attachment
 
Comments: OPG comments for “Revised NPCC Directory #4 System Protection Criteria and Cost Effectiveness-Resilience Survey”: ? Footnote #3 “Reference NERC Lessons Learned dated October 2, 2013 on loss of converter station due to initiation of a top oil temperature signal from the transformer A protection system.” is not available on NERC lessons learned postings for 2013. Suggest to confirm if the actual Lesson Learned # is 20150201 and add the required information. ? Appendix A – Guideline and Recommendations for Bulk Power System Protection, Transformer Protection, Page A8 – 2.15.1 - OPG suggest that providing specific guidelines for the Buchholtz relay (due to electrical considerations) warrants clarification that should clearly state: “need not be duplicated”. ? Page A9 – Generator start up and shut down additional protective relays requires clarification regarding need for duplication (i.e. 2.17.2.3). ? Throughout the entire Directory #4 OPG suggest that instead of “PRC-006-NPCC-2 Underfrequency Load Shedding Program Requirements” to use “PRC-006-NPCC-2 Automatic Underfrequency Load Shedding or successors” ? Page A10 OPG suggest that the reference to requirements specified in “Section 5.2 and Section 5.4 of Emergency Operation Criteria (Directory #2)” can be removed, however the reference to Directory #12 can be removed only after the retirement of D#12 which is a function of the NERC approval of PRC-006-NPCC-2 Underfrequency Load Shedding Program Requirements. The Northeast Power Coordinating Council, Inc. (NPCC) just requested that NERC post Regional Reliability Standard PRC-006-NPCC-2 – Automatic Underfrequency Load Shedding for industry review and comment in accordance with the NERC Rules of Procedure. For Existing Facilities NPCC Directory #4 specifies that “It is the responsibility of individual companies to assess the protection systems at existing facilities and to make modifications which are required to meet the intent of these criteria as follows. ……two independent sets of protective relays …” 5.0 NPCC Full Member, More Stringent Criteria, 5.2 Criteria for Dependability specifies “two protection groups, each of which is independently capable of performing the specified protective function for that element.” OPG is merely suggesting that clarification are required for “two independent sets of protective relays”, “two protection groups”, “independent protection groups” and “backup Protection” in the context of NPCC Directory #4 and with respect to duplication requirements.
05/09/2019New Brunswick Power CorporationView Attachment
 
Comments:
05/08/2019Hydro-Quebec TransEnergieView Attachment
 
Comments: Comment 1: 1.6.2.2.4 : Missing what must be reported like in section 16.2.2.2 and 16.2.2.3. Please add “The new bulk power system element shall be reported to the TFSP” Comment 2: In 5.4.3 we ask that the LAN is constantly monitored. In 5.11.1.3, the same requirements is asked, but for teleprotection equipment. There should be a criteria asking for the protection relay be constantly monitored and annunciated. Comment 3: 5.5 : Directory No. 1 -> Change to Directory # 1 Comment 4: 5.6.1: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) 5.6.3: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) 5.6.4: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) 5.6.5: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) Comment 5: 5.8.2: Add criteria 5.8.2.1 : It is not required that the battery and charger supply the total load if both systems are supply by a set of independent chargers and independent batteries such as a single component failure will not compromise the supply of the system load (N+1 philosophy for new battery technology). Comment 6: 5.8.3: Add criteria 5.8.3.1: The transfer arrangement is not required if both systems are supply by a set of independent chargers and independent batteries such as a single component failure will not compromise the supply of the system load (N+1 philosophy for new battery technology). Comment 7: 5.8.6: Add “and annunciated” Comment 8: 5.12.1 and 5.11.1.1.1 are redundant in respect to teleprotection equipment. Remove 5.11.1.1.1. and rephrase 5.12.1 as such : “The equipment for each protection group and teleprotection protecting the same system element shall be separated physically on non-adjacent vertical mounting assemblies or enclosures and designed to minimize the risk of both protection groups being disabled simultaneously by a single event or condition, except as noted in 5.12.7.” Comment 8: 5.12.9 : Rephrase to “separated physically on non-adjacent panel” (like criteria 5.11.1.1.1) Comment 9: 5.12.6 is the continuation of 5.12.5 and should therefore be 5.12.5.1 Comment 10: 5.16.1: Should be sent to the appendix as it is more of a best practice than a requirement and doesn’t improve reliability or add any value. Comment 11: 5.19 D4 makes no distinction between VSC type and LCC type converter. Hydro-Québec converter group propose the following: “5.19 HVDC System Protection Criteria 5.19.1 LCC-type (Line Commutated Converter) converter Criteria 5.19.1.1 The ac portion of an HVdc converter station, up to the valve-side terminals of the converter transformers, shall be protected in accordance with these criteria. 5.19.1.2 Multiple commutation failures, unordered power reversals, and faults in the converter bridges and the dc portion of the HVdc link which are severe enough to disturb the bulk power system shall be detected by more than one independent control or protection group and appropriate corrective action shall be taken, in accordance with the considerations in these criteria. 5.19.2 VSC-type (Voltage Source Converter) converter Criteria 5.19.2.1 The ac portion of an HVdc converter station, up to the converter arms terminals, shall be protected in accordance with these criteria. 5.19.2.2 Abnormal voltage, frequency and harmonic distortion, and faults in the converter arms and the dc portion of the HVdc link which are severe enough to disturb the bulk power system shall be detected by more than one independent control or protection group and appropriate corrective action shall be taken, in accordance with the considerations in these criteria.” Comment 12: 6.0: Replace R1, R2 and R3 by 6.1, 6.2 and 6.3. Comment 13: Appendixes A: Remove 2.16.1 in the appendixes since it is already included in criteria 5.2.3 Comment 14: Appendixes B : Add a link to the PSRF form.
05/08/2019Hydro-Quebec TransEnergieView Attachment
 
Comments: Comment 1: 1.6.2.2.4 : Missing what must be reported like in section 16.2.2.2 and 16.2.2.3. Please add “The new bulk power system element shall be reported to the TFSP” Comment 2: In 5.4.3 we ask that the LAN is constantly monitored. In 5.11.1.3, the same requirements is asked, but for teleprotection equipment. There should be a criteria asking for the protection relay be constantly monitored and annunciated. Comment 3: 5.5 : Directory No. 1 -> Change to Directory # 1 Comment 4: 5.6.1: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) 5.6.3: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) 5.6.4: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) 5.6.5: Replace Current Transformer by CT (or remove CT and replace it by Current transformer in 5.6.2) Comment 5: 5.8.2: Add criteria 5.8.2.1 : It is not required that the battery and charger supply the total load if both systems are supply by a set of independent chargers and independent batteries such as a single component failure will not compromise the supply of the system load (N+1 philosophy for new battery technology). Comment 6: 5.8.3: Add criteria 5.8.3.1: The transfer arrangement is not required if both systems are supply by a set of independent chargers and independent batteries such as a single component failure will not compromise the supply of the system load (N+1 philosophy for new battery technology). Comment 7: 5.8.6: Add “and annunciated” Comment 8: 5.12.1 and 5.11.1.1.1 are redundant in respect to teleprotection equipment. Remove 5.11.1.1.1. and rephrase 5.12.1 as such : “The equipment for each protection group and teleprotection protecting the same system element shall be separated physically on non-adjacent vertical mounting assemblies or enclosures and designed to minimize the risk of both protection groups being disabled simultaneously by a single event or condition, except as noted in 5.12.7.” Comment 8: 5.12.9 : Rephrase to “separated physically on non-adjacent panel” (like criteria 5.11.1.1.1) Comment 9: 5.12.6 is the continuation of 5.12.5 and should therefore be 5.12.5.1 Comment 10: 5.16.1: Should be sent to the appendix as it is more of a best practice than a requirement and doesn’t improve reliability or add any value. Comment 11: 5.19 D4 makes no distinction between VSC type and LCC type converter. Hydro-Québec converter group propose the following: “5.19 HVDC System Protection Criteria 5.19.1 LCC-type (Line Commutated Converter) converter Criteria 5.19.1.1 The ac portion of an HVdc converter station, up to the valve-side terminals of the converter transformers, shall be protected in accordance with these criteria. 5.19.1.2 Multiple commutation failures, unordered power reversals, and faults in the converter bridges and the dc portion of the HVdc link which are severe enough to disturb the bulk power system shall be detected by more than one independent control or protection group and appropriate corrective action shall be taken, in accordance with the considerations in these criteria. 5.19.2 VSC-type (Voltage Source Converter) converter Criteria 5.19.2.1 The ac portion of an HVdc converter station, up to the converter arms terminals, shall be protected in accordance with these criteria. 5.19.2.2 Abnormal voltage, frequency and harmonic distortion, and faults in the converter arms and the dc portion of the HVdc link which are severe enough to disturb the bulk power system shall be detected by more than one independent control or protection group and appropriate corrective action shall be taken, in accordance with the considerations in these criteria.” Comment 12: 6.0: Replace R1, R2 and R3 by 6.1, 6.2 and 6.3. Comment 13: Appendixes A: Remove 2.16.1 in the appendixes since it is already included in criteria 5.2.3 Comment 14: Appendixes B : Add a link to the PSRF form.
04/26/2019ISO-New England, Inc. 
 
Comments: The addition to Directory #4 page A-2: 2.3.4. For DCB schemes, design considerations should include pertinent alarms to minimize the risk associated with failure of these schemes. If this language is to reflect the recommendation from the recently issued by TFSP white paper on DCB schemes then the message got lost. It is the remote control not just alarms which should be considered. The recommendation in “Directional Comparison Blocking Schemes - Single Component Failure: Over-Trip Report prepared by TFSP” page 12 reads: When mutual agreement exists between protection system owners and system operators, consideration could be given to add design provision of remote control capability to allow operators to respond to an alarmed failure of a DCB component. Reducing this recommendation to alarming by stripping away the control function defeats the purpose of design recommendation which TFSP came up with.
04/16/2019National Grid 
 
Comments: RE: Cost Effectiveness and Resilience Questions: Question #1 Response = Yes, National Grid agrees that the Directory #4 reliability criteria are important to enhancing NPCC's BPS reliability and system resilience. Question #2 Response = No. No cost effective alternatives were identified.
04/16/2019National Grid 
 
Comments: Section 3: Should PRC-027 Coordination of Protection Systems for Performance During Faults be added to Section 3? Section 4: PRC-006-NPCC-02 should be PRC-006-NPCC-2 (or it could simply reference PRC-006-NPCC to avoid future edits. Section 5: Suggestion to change wording to read as: These Criteria are in addition, more stringent or more specific than NERC continent-wide standards or any NPCC regional reliability standard. Section 5.2.4: Remove extra "." at the end of the section. Section 5.14.1: Suggestion to change wording to read as: Protection system settings shall not constitute a loading limitation as per NERC continent-wide PRC standards. Appendix A, Section 2.18.6.1: Change PRC-006-NPCC-2 Underfrequency Load Shedding Program Requirements to read as PRC-006-NPCC Automatic Underfrequency Load Shedding.