MUG: MOD-032-1 Manual Update (20210713)

The Rating designations in section 4.4.9 do not comport with the Rating definition used in operations

Section 4.4.9

• Rate 1=Normal
• Rate 2=STE (Emergency Rating, the rating used in contingency analysis)
• In Rate 3=LTE (Long-Term Emergency Rating, not required)  

In Operations Rate A is normal, Rate B is long-term emergency rating and Rate C is short-term emergency rating

Section 4.4 Level of Detail, Item 2, last 2 sentences:

“Units that have been retired are to be removed from MOD.  Units that have an approved Attachment Y but have not yet retired should remain in MOD until the retirement date.”

Comment/Question: Please clarify, should units with an approved Attachment Y have projects added to MOD to remove them from the models on their future retirement date?

Section 4.4.2.1 Profile Types, Device Profiles:

Comment/suggestion: Add the following sentence: “Unless transformer taps and settings are changed on a seasonal basis they should not be included in the Device Profile information and the Device Profile information is applied after the project data in the model creation process and can revert transformer setting back to their prior values if the data submitter were to post a MOD project that updates those values.” This practice will reduce the amount transformer errors created during the model building process.

Section 4.4.4.4 Energy Storage, Table 4-6

Please clarify the on-line status as well as the output for the different modes.  In particular, the question is should “SATOA**” energy storage be modeled online at zero % MW output but allowed to regulate voltage?

Section 4.4.5.4:

“DER machines and negative loads that are not represented adequately in this workbook shall be considered offline in base models. Non-zero marginal cost generation included as part of a negative Load will be treated as a non-Network resource and considered offline.”

Comment: As we have discussed by email after the 7/13/2021 MUG call, update/add text to the DER treatment in the Fuel-type Data Collection Workbook to call out the treatment or inclusion of the “As Is” option for the non-inverter based DER generation/Negative loads.  Also please define “not represented adequately in this workbook”.

Thanks,

Kerry Marinan

In section 4.4.5.2 delete the third bullet dealing with age of installations.

This data collection would require a major effort to collect and the benefits would be minimal,  With the large growth in DER, especially rooftop PV, since 2018, the percentage of pre-IEEE1547-2018 installations grows ever smaller.  This massive data collection effort is not necessary for the small improvement in model accuracy. 

For Generation and Transmission Electric Cooperatives the problem is compound that this data would have to be collected by each member distribution cooperative served by the G&T.  This would require a great amount of coordination and effort.

During the TPL-001-5 preparation effort under the TOCTT run by Joe Reddoch it was discovered that there is a compliance gap regarding Single Point of Failure (SPF) responsibility.  TPL-001-5 P5 contingencies and footnote 13 SPF compliance obligations rests solely with the TP and not the Protection System Owner (TO and GO).   There are no NERC standards where this obligation is established.   This is only a problem for the transmission and generation assets not owned by the TP’s compliance.  

This gap can be closed with some small additions to the MOD-032 User’s Guide responsibility section for TO and GO to identify protection system SPF .  By adding these two additional responsibilities, TOs and GOs will have a MOD-032 R2 compliance responsibility to identify SPF locations and develop the contingency definitions, including the complicated dynamic contingency sequencing for remote clearing.

Likewise, an addition to Section 4.2.2.5 Protective Systems (pg 30) should be added to clarify that the modeling of protection system operation for SPF rest with the TO and GO.   Also, Section 4.4 Schedule clarifies that the SPF contingency definition are dues with the dynamic model data.

I appreciate consideration of these changes.