NERC Case Notes: Reliability Standard BAL-002-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard BAL-002-0

NERC Case Notes: Reliability Standard BAL-002-0

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This page contains the NOP (Notice of Penalty) and ACP (Administrative Citation of Penalty) summaries. Click here to read the FFT (Find, Fix and Track) summaries.

Electric Energy, Inc., FERC Docket No. NP10-46-000 (February 1, 2010)

Reliability Standard: BAL-002-0

Requirement: R4

Violation Risk Factor: Medium

Violation Severity Level: Not discussed

Region: WECC

Issue: Electric Energy, Inc. (EEI) self-reported that it had four DCS Reportable Disturbance events during the third quarter of 2008 and did not reach 100% recovery within the required time frame for one event (though it reached 93% recovery within the required time frame).

Finding: The penalty was deemed appropriate because it was EEI's first violation of this standard, EEI self-reported the violation, and the violation did not create a serious or substantial risk to the bulk power system reliability.

Penalty: $5,000 (aggregate for multiple violations)

FERC Order: Issued March 3, 2010 (no further review)

ISO New England, Inc., FERC Docket No. NP13-52 (September 30, 2013)

Reliability Standard: BAL-002-0

Requirement: 4.1/4.2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: NPCC

Issue: At approximately 1:09 pm on September 2, 2010, Mystic station power plant units 8 and 9 tripped off line as a result of a loss of gas supply, which caused a loss of 1372 MW of real-time generation and constituted a Reportable Disturbance. ISO New England, Inc. (ISO-NE) undertook corrective actions to compensate for the loss of the Mystic units, but was unable to return the Area Control Error (ACE) to its pre-disturbance value within 15 minutes as required by the Reliability Standard. ISO-NE approved a contingency dispatch (CP-SPD) cast, requesting 1800 MW of generation, and requested 50 MW of Shared Activation Reserves from the New Brunswick System Operator. As ISO-NE had recently replaced its dispatch communication system to send Desired Dispatch Points (DDPs) to its generator operators, some generators were unable to fully respond to ISO-NE’s dispatch as they did not have their system properly set up to receive dispatches. ISO-NE was able to recover its ACE within 23 minutes.

Finding: NPCC found that the violation constituted a moderate risk to BPS reliability since, if another disturbance had occurred, ISO-NE may have been forced to institute emergency actions in order to restore its ACE to the pre-disturbance value (e.g., curtailing contracts, implementing emergency operating conditions, or shedding load). But, ISO-NE’s control room operators were already responding to the loss of the most severe single contingency. ISO-NE was able to recover the system frequency within nearly six minutes. The violation lasted for eight minutes on September 2, 2010. ISO-NE admitted the violation. In approving the settlement agreement, NERC BOTCC considered the fact that the violation was ISO-NE’s first violation of this Reliability Standard, the violation was self-reported within hours of the incident and ISO-NE had a compliance program in place when the violation occurred (which was evaluated as a mitigating factor). In addition, ISO-NE’s cooperation during the enforcement process was considered exemplary, as it participated in a NERC pilot program on event analysis and willingly discussed and provided detailed information on the violation. ISO-NE also developed training programs for market participant generator operators and gave a presentation to NPCC compliance staff and New England Power Pool regarding how the generators responded to the dispatch.

Total Penalty: $5,000

FERC Order: Issued October 30, 3013 (no further review)

Los Angeles Department of Water and Power (LADWP), Docket No. NP12-40 (July 31, 2012)

Reliability Standard: BAL-002-0

Requirement: R4/4.1/4.2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: WECC found that LADWP, as a BA, was in violation of BAL-002-0 R4 because LADWP failed to meet its Disturbance Recovery Criterion within the Disturbance Recovery Period for 100% of LADWP’s Reportable Disturbances. On October 8, 2010, LADWP submitted a Periodic Data Submittal covering the third quarter of 2010. WECC reviewed the submission during an on-site Compliance Audit between January 17, 2011 and January 28, 2011 and determined the only instance of noncompliance took place during the third quarter of 2010. The instance at issue resulted from LADWP calculating its disturbance control performance to determine its Disturbance Recovery Criterion for 3Q 2010. In that calculation, LADWP reported it had three disturbances, after two of which it returned its Area Control Error (ACE) to pre-disturbance levels within the designated fifteen-minute timeframe. After the third disturbance, which took place on July 17, 2010, LADWP did not return the ACE to its pre-disturbance level within the required time frame. Instead, after the Hynes Generating Station Unit 5 tripped off from the system, creating a 282 MW loss, the LADWP took 26 minutes to return its ACE to zero. As a result, LADWP’s average recovery was 95.44% instead of the required 100%, which resulted in LADWP having only a 96.51% average recovery for the third quarter of 2010.

Finding: This violation posed only a minimal risk to BPS reliability because the Disturbance Control Standard is limited to the loss of supply and does not apply to the loss of load. During the violation, LADWP lost 277 net MW of generating capability, but LADWP had sufficient contingency reserves, more than 1,000 MW, to cover the generating loss. Further, LADWP recovered 212 MW within five minutes of the disturbance, leaving a deficit of only 6 MW to get its ACE back to zero. The risk posed by this small deficit was further minimized by the fact that LADWP is a single municipal system mostly located within an ISO. Consequently, the loss of generating capability from the third disturbance represents only a fraction of the generation available to LADWP and does not present a challenge to the transmission lines feeding the LADWP system. LADWP agreed/stipulated to WECC’s determinations. In determining the appropriate penalty, WECC considered LADWP’s internal compliance program as a mitigating factor.

Penalty: $60,000 (aggregate for five violations)

FERC Order: Issued August 30, 2012 (no further review)

Northwest Power Pool Reserve Sharing Group, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: BAL-002-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In February 2008, it was determined that Northwest Power Pool Reserve Sharing Group (NWPP) had not specified its Contingency Reserve policies as required.

Finding: WECC found that this violation did not create a serious or substantial risk to the bulk power system since NWPP did actually maintain Contingency Reserves and had a Contingency Reserves policy in place (even though the policy did not conform with the requirements of BAL-002-0). This was NWPP's first violation of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

PacifiCorp, FERC Docket No. IN11-6 (December 1, 2011)

Reliability Standard: BAL-002-0

Requirement: R4, R6

Issue: On February 14, 2008, a short circuit occurred on a transformer at PacifiCorp’s Huntington generation plant in Utah, which triggered an immediate loss of approximately 2800 MW of generation across PacifiCorp’s East Balancing Authority Area (“PacifiCorp East” – which consists of Utah, southeast Idaho and western Wyoming) and the shedding of approximately 183 MW of firm load in Utah. Immediately after the disturbance occurred at 9:16 am, PacifiCorp’s Area Control Error (“ACE”) went from approximately 70 MW to approximately -2371 MW. At 10:00 am, as a result of receiving of purchased power deliveries arriving into the system, PacifiCorp was able to return its ACE to zero. When the reserve sharing support (which accounted for deliveries of 1001 MW) ended automatically at 10:15 am, PacifiCorp’s ACE decreased from zero to -515 MW and then later to -752 MW. At 10:43 am, PacifiCorp started shedding firm load, which helped to restore PacifiCorp’s ACE at 10:57 am (R4). In addition, PacifiCorp did not restore its contingency reserves by 11:00 am as required and in fact had zero contingency reserves at that time (R6).

Finding: On December 1, 2011, FERC approved a Stipulation and Consent Agreement between FERC Office of Enforcement (“Enforcement”), NERC and PacifiCorp regarding PacifiCorp’s actions as a BA and TOP surrounding the February 14, 2008 disturbance. In terms of the BAL-002-0 R4 violation, Enforcement and NERC determined that it initially took PacifiCorp approximately 45 minutes to restore its ACE after the Reportable Disturbance (and not within 15 minutes as required) and, during that time, PacifiCorp was leaning on the Interconnection by using resources from other BAs to maintain its own operations. Enforcement and NERC found that PacifiCorp should have take additional actions, such as obtaining more resources or, as a last resort, shedding firm load in the hour ending at 10:00 am. In terms of the BAL-002-0 R6 violation, PacifiCorp did not restore its contingency reserves within the mandated Contingency Reserve Restoration Period (which is 90 minutes after the end of the 15-minute Disturbance Recovery Period).

Penalty: $3,925,000 (aggregate for 23 violations)

FERC Order: http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=12829507

Rocky Mountain Reserve Group, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: BAL-002-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In July 2008, it was determined that Rocky Mountain Reserve Group's (RMRG) Contingency Reserve Policy did not specify that the same portion of resource capacity could not be counted as Contingency Reserve more than once by multiple Balancing Authorities.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since RMRG was actually conducting monthly audits to verify that the same reserves were not being counted more than once by the members of the reserve sharing group (even though its policy statement did not contain the specific language as required). The violation was primarily a documentation issue and this was RMRG's first violation of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Sacramento Municipal Utility District, FERC Docket NP10-106-000 (May 3, 2010)

Reliability Standard: BAL-002-0

Requirement: R4

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Sacramento Municipal Utility District (SMUD) self-reported that a reportable disturbance occurred on November 27, 2008 where SMUD required 22 minutes to return its Area Control Error value to zero.

Finding: Duration of violation was from November 27, 2008 through May 1, 2009 when SMUD completed a mitigation plan. The violation did not pose a serious or substantial risk to the bulk power system because the issue pertained to a loss of supply rather than a loss of load, and SMUD had sufficient contingency reserves to address the loss of supply involved in the violation. In addition, this was SMUD's first violation of this standard.

Penalty: $9,900 (aggregate for multiple violations)

FERC Order: Issued May 28, 2010 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-180-000 (April 29, 2011)

Reliability Standard: BAL-002-0

Requirement: R4

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: In April 2008, the Unidentified Registered Entity (URE) self-reported that it had not satisfied the Disturbance Recovery Criterion within the Disturbance Recovery period for all of its Reportable Disturbances in the first quarter of 2008, since on one day the URE was unable to recover its Area Control Error within 15 minutes as required.

Finding: WECC and the URE entered into a settlement agreement to resolve multiple violations, whereby the URE agreed to pay a penalty of $71,500 and to undertake other mitigation measures. WECC found that the violation of BAL-002-0 only constituted a minimal risk to bulk power system reliability since the URE had actually dispatched sufficient reserves in order to recover its Area Control Error (even though it had a software bug). There was only one Reportable Disturbance during the first quarter of 2008. The duration of the BAL-002-0 violation was one day. In approving the settlement agreement and the penalty determination, NERC considered the fact that the violations were the URE’s first violations of the relevant Reliability Standards; most of the violations were self-reported; the URE was cooperative during the enforcement process and did not conceal the violations; the URE had a compliance program in place (which was evaluated as a mitigating factor); the penalty for the violation of IRO-STD-006-0 WR1 was based on a specified Sanction Table; the violations of IRO-005-2 R13 and TOP-008-1 R2 resulted from a single noncompliance occurrence; and there were no additional aggravating or mitigating factors.

Penalty: $71,500 (aggregate for 9 violations)

FERC Order: May 27, 2011 (no further review)