ENTERGY COMMENTS ON
NAESB VERSION 0 DRAFT STANDARDS
Ed Davis
August 9, 2004
NAESB issued first draft Version 0 Business Practices on July 9, 2004, with comments requested to be returned by August 9, 2004. NAESB also requested comments to several specific questions posed in the cover letter.
Attached to this letter are Entergy’s comments and suggested changes to the specific first draft Version 0 Business Practices. Unless noted below our comments to NAESB consist of the suggested changes to the drafts as contained in the attachments. The following are other comments on the draft Standards and on the specific questions posed in the cover letter.
In addition to our responses to the questions posed, we are very concerned about NAESB and NERC standards interfacing with each other properly and the potential for the industry to be required to conform to multiple sets of standards on the same subject with differing requirements.
NAESB/NERC STANDARDS INTERFACE
We are very aware that NAESB and NERC standards development teams are attempting to coordinate their efforts and assure the resulting standards will function properly. We hope the two organizations continue coordinating their effort and that industry participants ensure they do continue that coordination.
MULTIPLE SETS OF VOLUNTARY / MANDATORY STANDARDS AND “SHADOW” STANDARDS
We commend the authors of the NAESB and NERC draft standards for utilizing a planned transition to remove commercial issues from the reliability standards and into commercial business practices. We also suggest the industry ensure there is little or no overlap of NAESB and NERC Version 0 standards.
IMPOSITION OF REQUIREMENTS ON NERC COMMITTEES
We suggest that NAESB business practices should impose requirements on NERC Organizational Subcommittees, with the consent of NERC and the Subcommittees. The NERC organization and its committees and subcommittees are the proper source for some information on which NAESB business practices are based.
TIME ERROR CORRECTION
Please see the comments contained in the attached file.
In addition, Entergy suggests time error corrections are a construct whose reason for being has passed away. The policy of time error correction should be discontinued, rather than recreated as a business practice
INADVERTENT ENERGY PAYBACK
Please see the comments contained in the attached file.
ACE EQUATION SPECIAL CASES
Please see the comments contained in the attached file.
In addition, we suggest NAESB adopt these Special cases if NERC does not include them in the NERC Version 0 Standards or NERC puts them into a reference document. However, NAESB should not adopt them as “shadow” standards if NERC does include them in the NERC standards.
COORDINATE INTERCHANGE
Please see the comments contained in the attached file.
EMERGENCY OPERATIONS
Please see the comments contained in the attached file.
TRANSMISSION LOADING RELIEF
Please see the comments contained in the attached file.
ENTERGY SERVICES
8-9-04
NAESB TIME ERROR CORRECTION STANDARD
Version 0
1. Requirements
1.1 Each Balancing Authority shall participate in Time Error Correction procedures unless it is operating asynchronously to its Interconnection.
1.2 Balancing AuthoritIESys operating asynchronously may who establish their own time error control bands, but mustshall notify the NERC Resources Subcommittee of the bands being utilized, and shall also provide notification if they are changed.
1.23 The Operating Reliability Subcommittee shall designate, on February 1st of each year, a Reliability Authority to act as the Interconnection Time Monitor to monitor time error for each of the Interconnections and to issue time error correction orders.
1.34 Time Error Initiation. Time error corrections will shall start and end on the hour or half-hour, and notice shall be given at least one hour before the time error correction is to start or stop. All Balancing Authoritys AuthoritIES within an Interconnection shall make all Time Error corrections directed by the Interconnection Time Monitor for its Interconnection. All Balancing AuthoritIESAuthoritys within an Interconnection shall make Time Error Corrections at the same rate.
1.45 Interconnection Time Monitor. Each Interconnection Time Monitor shall monitor time error and shall initiate or terminate corrective action orders according to the procedure specified in Appendix A, “Time Error Correction Procedure.”
1.56 Time Error Correction Llabeling. Time error correction notifications shall be labeled alphabetically on a monthly basis (A-Z, AA-AZ, BA-BZ,…).
1.67 Time correction offset. The Balancing Authority may shall participate in a Time Error Correction by either one of the following two methods:
1.67.1 Frequency offset. The Balancing Authority may shall offset its frequency schedule by 0.02 Hz, leaving the Frequency Bias Setting normal, or
1.67.2 Schedule offset. If the frequency schedule cannot be offset, the Balancing Authority may shall offset its net Interchange schedule (MW) by an amount equal to the computed bias contribution during a 0.02 Hz frequency deviation (i.e., 20% of the Frequency Bias Setting).
1.78 Request for Termination or Halt of Scheduled Time Error Correction.
1.8.1 Any Reliability Authority in an Interconnection may shall have the right to request the termination of a time error correction in progress.
1.8.2 Any Reliability Authority may shall have the right to request the halt of a scheduled time error correction that has not begun.
1.8.3 Balancing AuthoritIESAuthoritys that have reliability concerns with the execution of a time error correction shall notify their Reliability Authority and request the termination of a time error correction in progress.
1.78.4 To enable NERC to track the results of the application of procedures relating to Time Control Standards, aA Reliability Authority requesting a termination or halt of a Time Error Correction shall forward an explanation for requesting the termination to the chairman of the Resources Subcommittee within 5 business days.
1.89 Interconnection time error notification. The Interconnection Time Monitor shall issue a notification of time error on the first day of each month. It shall be issue a notification of time error, accurate to within 0.01 second, to the other Reliability AuthoritysAuthorities within the Interconnection to assure uniform calibration of time standards.
1.91.10 Western Interconnection time error notification. Within the Western Interconnection, the Reliability Authority designated as the Interconnection Time Monitor shall provide the accumulated time error (accurate to within 0.001 second) to all Balancing AuthoritysAuthorities on a daily basis at 1400 PDT/PST using the WSCCNet. The alphabetic designator shall accompany time error notification if a time error correction is in progress.
1.1011 Time correction on reconnection. When one or more Balancing AuthoritysAuthorities have been separated from the Interconnection, upon reconnection, they shall adjust their time error devices to coincide with the time error of the Interconnection. A notification of the adjustment to time error shall be passed through Time Notification Channels as soon as possible after reconnection.
1.1112 Leap seconds. Balancing AuthoritysAuthorities using time error devices that are not capable of automatically adjusting for leap seconds shall arrange to receive advance notice of the leap second and make the necessary manual adjustment in a manner that will not introduce an improper Interchange Schedule into their control system.
Appendix A
Time Error Correction Procedures
Version 0
Time
/ Initiation / Termination / Scheduled Freq - HzEast /
West
/ ERCOT / East / West / ERCOTSlow / -10 / -2 / -3 / -6 / ±0.5 / ±0.5 / 60.02
Fast / +10 / +2 / +3 / +6 / ±0.5 / ±0.5 / 59.98
Notes:
For the Eastern Interconnection:
1. No coCorrections for fast time will shall not be initiated between 0400-1100 Central Time.
2. Corrections shall begin on the hour or half-hour.
3. Corrections shall last at least one hour, unless there is a cause for termination.
For all Interconnections:
1. The designated Interconnection Time Monitor shall have the right A time correction may beto halted, terminated, or extended a time correction if the designated Interconnection Time Monitor determines system conditions warrant such action.
2. After the premature termination of a manual time correction, a slow time correction can shall only be reinstated after the frequency has returned to 60 Hz or above for a period of ten minutes. A fast time correction can shall only be reinitiated after the frequency has returned to 60 Hz or lower for a period of ten minutes. At least one hour shall elapse, however, between the termination and re-initiation notices.
ENTERGY COMMENTS
8-9-04
NAESB Inadvertent Interchange Standard
Version 0
General Requirements
1. INADVERTENT INTERCHANGE Accounting. Adjacent BALANCING AUTHORITIES shall operate to a common Net Interchange Schedule and Actual Net Interchange value and shall record these hourly quantities, with like values but opposite sign. Each BALANCING AUTHORITY shall compute its INADVERTENT INTERCHANGE based on the following:
1.1. Daily accounting. Each BALANCING AUTHORITY, by the end of the next business day, shall agree with its adjacent BALANCING AUTHORITIES to:
1.1.1. The hourly values of Net Interchange Schedule.
1.1.2. The hourly-integrated MWh values of Net Actual Interchange.
1.2. Monthly accounting. Each BALANCING AUTHORITY shall use the agreed-to Daily and Monthly accounting data to compile its monthly accumulated INADVERTENT INTERCHANGE for the On-Peak and Off-Peak hours of the month. (Refer to Appendix A, On Peak – Off Peak Periods“
1.3. After-the-Fact Corrections. After-the-fact corrections to the agreed-to Daily and Monthly accounting data shall only be made to reflect actual operating conditions (e.g. a meter being used for control was sending bad data). Changes or corrections based on non-reliability considerations shall not be reflected in the BALANCING AUTHORITY (IES) INADVERTENT INTERCHANGE. After-the-fact corrections to the scheduled or actual values will notshall only be accepted without agreement of the Adjacent BALANCING AUTHORITY (sIES).
1.4. Periodic Adjustments shall be made to correct for differences between hourly MWh meter totals and the totals derived from register readings of the tie-line meters. Adjacent BALANCING AUTHORITIES shall agree upon the difference determined above and assign this correction to t the proper On-Peak and Off-Peak period at the same times and in equal quantities in the opposite directions. Any adjustments necessary due to known metering errors, franchised territories, transmission losses or other special circumstances shall be made in the same manner.
1.4.1. Adjustments to schedules shall only be made if an incorrect schedule was used by one BALANCING AUTHORITY.
1.4.2. Schedules shall not be adjusted after-the-fact due to marketing considerations or adjustments during the billing procedure.
1.
2. INADVERTENT INTERCHANGE payback. Each BALANCING AUTHORITY shall be diligent in reducing accumulated inadvertent balances. INADVERTENT INTERCHANGE accumulations shall be paid back by either of the following methods:
2.1. Energy “in-kind” payback.
2.1.1. INADVERTENT INTERCHANGE accumulated during “On-Peak” hours shall only be paid back during “On-Peak” hours.
2.1.2. INADVERTENT INTERCHANGE accumulated during “Off-Peak” hours shall only be paid back during “Off-Peak” hours. [See Appendix A, “On-Peak and Off-Peak Periods.”]
2.1.3. INADVERTENT INTERCHANGE shall be repaid by one of the methods shown below.
1.1.1. Bilateral payback. If INADVERTENT INTERCHANGE is repaid using bilateral payback, INADVERTENT INTERCHANGE accumulations may shall be repaid back via an INTERCHANGE SCHEDULE with another BALANCING AUTHORITY.
1.1.2. Opposite balances. The SOURCE BALANCING AUTHORITY and SINK BALANCING AUTHORITY must shall have inadvertent accumulations in the opposite direction.
1.1.3. Agreement on schedule. The terms of the inadvertent payback INTERCHANGE SCHEDULE shall be agreed upon by all involved BALANCING AUTHORITIES and TRANSMISSION PROVIDERS in accordance with NERC Interchange procedures.
1.1.4. Unilateral payback. If INADVERTENT INTERCHANGE is repaid using unilateral payback , INADVERTENT INTERCHANGE accumulations may shall be repaid back unilaterally controlling to a target of non-zero ACE. Controlling to a nonzero ACE ensures that the unilateral payback is accounted for in the CPS calculations. The unilateral payback control offset is shall be limited to BALANCING AUTHORITY ‘s L10 limit and shall not burden the INTERCONNECTION.
1.1.5. Other payback methods. Upon agreement by all REGIONS within an INTERCONNECTION, other methods of INADVERTENT INTERCHANGE payback may be utilized.
2.
- Inadvertent Interchange summary. Each BALANCING AUTHORITY shall submit a monthly summary of Inadvertent Interchange as detailed as specified below. These summaries shall not include any after-the-fact changes that were not agreed to by the Source BALANCING AUTHORITIES, Sink BALANCING AUTHORITIES and all Intermediary BALANCING AUTHORITIES.
3.1. Summary balances. Inadvertent Interchange summaries shall include at least the previous accumulation, net accumulation for the month, and final net accumulation, for both the “onpeak” and “off-peak” periods.
3.2. Summary submission.
3.2.1. Each BALANCING AUTHORITY shall submit its monthly summary report to its Resources Subcommittee Survey Contact by the 15th calendar day of the following month.
3.2.2. The Resources Subcommittee Survey Contact shall prepare a composite tabulation and submit that tabulation to the NERC staff by the 22nd calendar day of the month.
1.1.6. Failure to Report. A BALANCING AUTHORITY that neither submits a report nor supplies a reason for not submitting the required data by the 20th calendar day of the following month shall be considered non-compliant.
3.2.3.
4. Dispute Resolution. Adjacent BALANCING AUTHORITIES that cannot mutually agree upon their respective net actual interchange or net scheduled interchange quantities by the 15th calendar day of the following month shall, for the purposes of dispute resolution, submit a report to their respective Resources Subcommittee Survey Contact for the purposes of dispute resolution. The REPORT SHALL DESCRIBE THE NATURE AND THE CAUSE OF THE DISPUTE AS WELL AS A PROCESS FOR CORRECTING THE DISCREPANCY. The adjacent BALANCING AUTHORITIES shall submit to the dispute resolution process is as described in Appendix B, Dispute Resolution Process.
Appendix A – NAESB Inadvertent Interchange On- and Off-Peak Periods
1. On-Peak and Off-Peak Hours (Monday Through Sunday)
On and Off-Peak designation. The hourly inadvertent energy created by BALANCING AUTHORITIES is shall be classified as either On-Peak or Off-Peak inadvertent. The peak designation assigned is a function of hour of day, day of week, time zone, prevailing time (standard or daylight savings), and special holiday status.
Daylight saving time. The On-Peak to Off-Peak and Off-Peak to On-Peak boundary hours are unaffected by transitions to or from daylight savings time. If BALANCING AUTHORITIES remains on either standard or daylight savings time throughout the year, their inadvertent accounting practices shall use prevailing time.