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Individual or group.  (13 Responses)
Name  (6 Responses)
Organization  (6 Responses)
Group Name  (7 Responses)
Lead Contact  (7 Responses)
Contact Organization  (7 Responses)
Question 1  (13 Responses)
Question 1 Comments  (13 Responses)
Question 2  (13 Responses)
Question 2 Comments  (13 Responses)
Question 3  (13 Responses)
Question 3 Comments  (13 Responses)
Question 4  (0 Responses)
Question 4 Comments  (13 Responses)
 
Individual
James H. Sorrels, Jr.
American Electric Power
Yes
 
Yes
 
Yes
 
 
Group
NPCC
Guy Zito
NPCC
No
Change appears to be for clarification purposes regarding the use of the term "coping". "Coping" should be made a defined term.
Yes
 
Yes
 
 
Individual
Greg Rowland
Duke Energy Corporation
Yes
 
No
The reference to coping time should not be included in Requirement R9.3.5 because it creates confusion. Coping time is the amount of time a nuclear plant can function without any AC power source. However to meet its license requirements, a nuclear plant will have provisions for emergency AC power that could come from on-site or off-site sources. Requirement R9.3.5 should only state: "Provision to consider the amount of time a nuclear plant can function without an off-site AC power source."
Yes
 
 
Individual
Darryl Curtis
Oncor Electric Delivery
Yes
 
Yes
 
Yes
 
 
Group
SERC Engineering Committee Planning Standards Subcommittee
Phillip R. Kleckley
South Carolina Electric & Gas
Yes
 
Yes
 
Yes
 
 
Individual
Kirit Shah
Ameren
No
As stated above in the background information, the purpose of this standard is nuclear safety and not BES reliability. This is certainly a necessary and laudable purpose but these particular changes are not needed for BES reliability.
No
We agree that the revisions distiguish the two issues. However (1) From the auditable compliance perspective, it does not provide any substantive clarification. The revisions are still ambiguous and additional clarification is needed regarding the "provision to consider". Does this mean that that the Operations and Maintenace section of the agreement between the Nuclear Plant Operator and Transmission Entity must ensure that the coping time is not violated? Does it mean that Transmission Entity has to include that value in some analysis? If this is the intent, the language does not reflect this clearly. (2) The original requirement applied to the loss of Off-site Power and the new requirement expands applicability to the loss of On-Site AC Power Sources as well.
Yes
The word execute typically applies to contracts between two legal entities so we think this word should not be used. We suggest the following wording will meet the intent. "1. Agreements may include mutually agreed upon procedures or protocols in effect between entities or between departments of a vertically integrated system."
The effective date in the footer of the standard does not match the effective date in section 5 of the standard.
Individual
Dan Rochester
Ontario IESO
No
This SAR does not emerge from reliability needs. However, the proposed changes are useful, as they enhance understanding of the requirements in the standard and bring consistency with other governing documents.
Yes
 
Yes
 
 
Group
IRC Standards Review Committee
Ben Li
IESO
No
As stated in the background information above, the purpose of this standard is nuclear safety and not BES reliability. These particular changes are not needed for reliability nor is the standard in general needed for reliability. This is certainly a necessary and laudable purpose but simply does not meet the requirements for a NERC enforceable reliability standard.
Yes
We agree that the revisions significantly improve clarification and distinguish the two issues.
Yes
The word execute typically applies to contracts between two legal entities so we think this word should not be used. We suggest the following wording will meet the intent. "1. Agreements may include mutually agreed upon procedures or protocols in effect between entities or between departments of a vertically integrated system."
The effective date in the footer of the standard does not match the effective date in section 5 of the standard. While we agreed in question 2 that the revisions significantly improve clarification and distinguish the two issues, we believe the modifications appear to take the directive of the Commission a step farther. The original requirement applied to the loss of Off-site Power and the new requirement expands applicability to the loss of On-Site AC Power Sources as well.
Group
Midwest ISO Standards Collaborators
Jason Marshall
Midwest ISO
No
As stated in the background information above, the purpose of this standard is nuclear safety and not BES reliability. These particular changes are not needed for reliability nor is the standard in general needed for reliability. This is certainly a necessary and laudable purpose but simply does not meet the requirements for a NERC enforceable reliability standard.
Yes
We agree that the revisions signficantly improve clarification and distiguish the two issues. Additional clarification is needed regarding the "provision to consider". Does this mean that that the Operations and Maintenace section of the agreement between the Nuclear Plant Operator and Transmission Entity must ensure that the coping time is not violated? We assume this is what is intended; however, the language is not this strong and does not reflect this.
Yes
The word execute typically applies to contracts between two legal entities so we think this word should not be used. We suggest the following wording will meet the intent. "1. Agreements may include mutually agreed upon procedures or protocols in effect between entities or between departments of a vertically integrated system."
The effective date in the footer of the standard does not match the effective date in section 5 of the standard. While we agreed in question 2 that the revisions signficantly improve clarification and distiguish the two issues, we believe the modifications appear to take the directive of the Commission a step farther. The original requirement applied to the loss of Off-site Power and the new requirement expands applicability to the loss of On-Site AC Power Sources as well.
Group
FirstEnergy
Sam Ciccone
FirstEnergy Corp.
No
1. Changes made to R9.3.5 have added clarity to the requirement but do not appear to have made a significant reliability-related improvement. 2. Although the change in term from Planning Authority to Planning Coordinator is consistent with the NERC Functional Model, this change does not improve reliability. One thing to note, however, is that the use of Planning Coordinator in the standards does not yet match the NERC Compliance Registry and the NERC Rules of Procedure where these entities are still registered as and referred to as Planning Authorities. If NERC wishes to move in the direction of "PC", then all NERC documents, rules, registries and standards should consistently use this term. 3. Although it adds clarity, the change to include a vertically integrated entity requirement to document interdepartmental procedures and method of executing agreements does not impact reliability. This is an open access issue. 4. The changes to the compliance measures are administrative and do not impact reliability.
Yes
 
Yes
 
 
Individual
Jason Shaver
American Transmission Company
No
ATC agrees that NERC has been directed to address the following issue: "clarify the references to coping times and off-site power restoration to address the concerns raised in the comments through its Reliability Standards development process." (FERC Order 716 Paragraph 107) ATC also agrees that the modification to Footnote 1 provides additional clarity but disagrees that NERC was directed to make this change. FERC directed the ERO "to require that an integrated entity provides documentation of its arrangements, including appropriate procedures and protocols, ensuring that its business units perform the functions under NUC-001-1 that would otherwise be met by separate entities." (Paragraph 73) ATC disagrees with the replacement of the term "Planning Authority" with the term "Planning Coordinator". Issues with this change: - The Planning Coordinator designation is not in NERC's Rules of Procedure - There are no entities currently registered as Planning Coordinators - NERC currently does not have any criteria for registering entities as Planning Coordinators - The Functional Model Document is a reference document and not part of NERC's Rules of Procedure
No
The concept of "coping time" originated in the Nuclear Regulatory Commission's Station Blackout (SBO) Rule (10 CFR 50.63). The term "station blackout" refers to the complete loss of alternating current electric power to the essential and non-essential switchgear buses in a nuclear plant. Station blackout therefore involves the loss of offsite power concurrent with a turbine trip and the failure of the on-site emergency alternating current power systems (i.e.; emergency diesel generators) Under the SBO Rule, nuclear plants are required to be able to “cope” with or withstand a station blackout for a specific period of time. Specifically, during a station blackout, nuclear plants must be able to maintain reactor core cooling and containment heat removal capabilities. In the event of a station blackout, most plants utilize emergency station batteries to power essential safety related systems to meet these cooling and heat removal requirements. Essentially, the coping time is the period of time during which the plant has demonstrated it has the capability to ensure that the core is cooled and containment integrity maintained during station blackout conditions. The SBO Rule, and the plant’s licensing requirements, requires the nuclear plants to be able to restore their on-site emergency alternating current (AC) power supplies (i.e. emergency diesel generators) within their coping time. There are no NRC rules or regulations which require that the off-site power be restored within the coping time. The draft language misrepresents the concept of coping time by linking it to the restoration of off-site AC power. As required by licensing requirements, the nuclear plant operator has responsibility to restore the on-site emergency AC power sources within the demonstrated coping time. We suggest the following language: Provision to consider a nuclear plant's coping time for coordinating the required restoration of on-site emergency AC power and the prioritization of the restoration of off-site power following a station blackout event We believe that our draft language is consistent with the philosophy advocated by the Nuclear Energy Institute (NEI) comments contained in paragraph 105 of Order 716.
No
The modification provides additional clarity but we disagree with the statement that this change was directed by the Commission. The Commission directed the ERO to require that integrated entities provide appropriate procedures and/or protocols ("Agreements") to demonstrate compliance. The Commission did not direct changes to the footnote. Does the SDT believe that vertically integrated companies are currently exempt from NUC-001?
 
Group
MRO NERC Standards Review Subcommittee
Michael Brytowski
MRO
No
This is a safety issue that should be addressed by the Nuclear industry and not a BES issue. Every Nuclear facility is already required to have a 7 day (off-site AC) independent redundant supply of electricity. For example, the Turkey point nuclear facility was able to withstand hurricane Andrew in 1992 and it lost off-site power for 5 days. The NERC reliability standards are for the protection of the BES. The reliability need should be independent of the generator heat source which drives the prime mover.
No
MRO NSRS believes this revision does clarify and distinguish between the two coping time issues. However, the concept of "coping time" originated in the Nuclear Regulatory Commission's Station Blackout (SBO) Rule (10 CFR 50.63). The term "station blackout" refers to the complete loss of alternating current electric power to the essential and non-essential switchgear buses in a nuclear plant. Station blackout therefore involves the loss of offsite power concurrent with a turbine trip and the failure of the on-site emergency alternating current power systems (i.e.; emergency diesel generators) Under the SBO Rule, nuclear plants are required to be able to “cope” with or withstand a station blackout for a specific period of time. Specifically, during a station blackout, nuclear plants must be able to maintain reactor core cooling and containment heat removal capabilities. In the event of a station blackout, most plants utilize emergency station batteries to power essential safety related systems to meet these cooling and heat removal requirements. Essentially, the coping time is the period of time during which the plant has demonstrated it has the capability to ensure that the core is cooled and containment integrity maintained during station blackout conditions. The SBO Rule, and the plant’s licensing requirements, requires the nuclear plants to be able to restore their on-site emergency alternating current (AC) power supplies (i.e. emergency diesel generators) within their coping time. There are no NRC rules and regulations which require that the off-site power be restored within the coping time. The draft language misrepresents the concept of coping time by linking it to the restoration of off-site AC power. As required by licensing requirements, the nuclear plant operator has responsibility to restore the on-site emergency AC power sources within the demonstrated coping time. MRO NSRS suggests the following language: Provision to consider a nuclear plant's coping time for coordinating the required restoration of on-site emergency AC power and the prioritization of the restoration of off-site power following a station blackout event MRO NSRS believes that our draft language is consistent with the philosophy advocated by the Nuclear Energy Institute (NEI) comments contained in paragraph 105 of Order 716.
Yes
 
NERC should reconsider the primary objective of this standard and determine whether the scope of this SAR should be modified to delete any requirement that doesn't address a grid reliability need. The MRO NSRS questions whether the VRF values for six requirements should be increased (R2 - Lower to Medium, R4 - Medium to High, R5 - Medium to High, R7 - Medium to High, R8 - Medium to High, R9 - Lower to Medium) without explanation or justification. For example in R2, having an agreement does not have a direct material effect on the BES.
Group
Bonneville Power Administration
Denise Koehn
Transmission Reliability Program
Yes
 
Yes
"Off-site" and "On-site" should either not be capitalized or need to be defined under the NERC Glossary of Terms.
Yes
 
NERC Glossary of Terms needs to be updated with definition of Planning Coordinator, now that it has been changed from Planning Authorities. Also needs to be updated with definition of Compliance Enforcement Authority, now that it has been changed from Compliance Monitor. In Section 4.2 "Generator Owners" and "Generator Operators" are not normally considered Transmission Entities but are identified as one in section 4.2.