NERC Case Notes: Reliability Standard BAL-001-0.1a | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard BAL-001-0.1a

NERC Case Notes: Reliability Standard BAL-001-0.1a

White & Case NERC Database

Lafayette Utilities System (LAFA), Docket No. NP13-12-000 (December 31, 2012)

Reliability Standard: BAL-001-0.1a

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: SPP RE

Issue: LAFA identified that it violated BAL-001-0.1a R2, in its capacity as Transmission Owner, Generation Owner and Distribution Provider, after it identified its Control Performance Standard 2 (CPS2) value for LAFA for June 2001 was at 85.6%. BAL-001-0.1a R2 requires a CPS2 of at least 90%. In three June 2010 reliability directives, SPP RC, LAFA’s Reliability Coordinator, directed LAFA to purchase power from Cleco’s Teche facility and reserve and schedule 90 MW of power for 19 days that month. 81% of LAFA’s 10-minute CPS2 violations occurred when it was scheduled to receive energy from Cleco. The violations occurred mainly because of a surplus, rather than shortage, of power within the LAFA balancing authority. LAFA also failed to inform SPP RC that it was unable to perform, keeping SPP RC from making alternate remedial actions.

Finding: SPP RE determined that the violation posed a moderate risk, but not a serious or substantial risk to BPS reliability. Because the noncompliance resulted from over- rather than under-generation, there was less potential for undue burden on neighboring systems. LAFA’s CPS2 value has stayed above 90% for each month following the violation. LAFA also reviews daily, as part of its TOP-002-2 compliance, the RC’s transmission studies that identify potential SOL violations. Finally, LAFA utilizes SCADA system alarms to alert operators and every LAFA transmission line has thermal overload protections. In determining the appropriate penalty, SPP RE considered the fact that LAFA convenes quarterly an Internal Compliance Committee (ICC) comprised of both LAFA employees and consultants, even though LAFA did not have a formal internal compliance program (ICP) at the time of the violation. Compliance is also handled by LAFA’s Electric Reliability Department, and through annual self-assessments and mock audits.

Total Penalty: $8,000 (aggregate for 3 violations)

FERC Order: Issued January 30, 2013 (no further review)