NERC Case Notes: Reliability Standard BAL-003-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard BAL-003-0

NERC Case Notes: Reliability Standard BAL-003-0

White & Case NERC Database

City of Tallahassee, FERC Docket No. NP10-143-000 (July 30, 2010)

Reliability Standard: BAL-003-0

Requirement: R2.1

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: FRCC

Issue: In November 2008 while preparing for an audit, the City of Tallahassee (TAL) self-reported that, as a Balancing Authority, it could not produce documentation demonstrating that it had correctly calculated its Frequency Bias and it was operating within specified limits. From January 1, 2007 to May 8, 2008, TAL's Supervisory Control and Data Acquisition (SCADA) system had overridden the 4-second data used to determine the annual Bias calculation, and therefore TAL could not show that it reached its fixed Frequency Bias value by observing and averaging the Frequency Response for several disturbances.

Finding: FRCC and TAL entered into a settlement agreement to resolve multiple alleged violations, whereby TAL neither admitted nor denied the violations but agreed to pay a penalty of $5,000 and to undertake other mitigation measures. The duration of the alleged BAL-003-0 violation was from June 18, 2007 to November 20, 2008, when the mitigation was completed for this alleged violation. FRCC found that the alleged violation of BAL-003-0 did not create a serious or substantial risk to bulk power system reliability since TAL actually determined its Frequency Bias setting with historical data from before the period when the 4-second data was not retained. Also, while the minimum bias setting is 1.0, TAL was using a bias setting of 1.44. Furthermore, NERC considered the fact that the alleged violations were TAL's first violation of the relevant Reliability Standards; the alleged violations were self-reported; TAL was cooperative during the enforcement process and did not attempt to conceal the alleged violations; TAL had a positive compliance program; and there were no additional mitigating or aggravating factors.

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

FERC Order: Issued August 27, 2010 (no further review)

Michigan Electric Coordinated Systems, FERC Docket No. NP10-86-000 (March 31, 2010)

Reliability Standard: BAL-003-0

Requirement: R2.1

Violation Risk Factor: Lower

Violation Severity Level: Not provided

Region: RFC

Issue: Michigan Electric Coordinated Systems (MECS) used the "Fixed Frequency Bias Value" method for calculating the Frequency Bias component of Area Control Error as required by BAL-003-0, however, it failed to establish the fixed value bias by observing and averaging the Frequency Response for several disturbances during on-peak hours.

Finding: The alleged violation occurred from June 27, 2008, the date MECS was included on the NERC Compliance Registry, until October 29, 2008, when MECS completed a mitigation plan. Through settlement, a penalty of $5,000 was assessed (aggregate for multiple violations). In assessing the penalty, RFC considered: (1) MECS had no previous occurrence of alleged non-compliance with the relevant Reliability Standards; (2) MECS cooperated during the enforcement process; (3) there was no attempt to conceal a violation or evidence of intent; (4) the alleged violation did not pose a serious or substantial risk to the bulk power system; and (5) there were no aggravating circumstances.

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

FERC Order: Issued April 30, 2010 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-4-000 (October 7, 2010)

Reliability Standard: BAL-003-0

Requirement: R3

Violation Risk Factor: Medium

Violation Severity Level: N/A

Region: FRCC

Issue: An Unidentified Registered Entity (URE) self-reported possible non-compliance for operating its Automatic Generation Control (AGC) switched out of the Tie Line Frequency Bias (TLFB) in eight instances without first determining whether it would be adverse to the reliability of the bulk power system to operate in such a manner.

Finding: The violation did not pose a serious or substantial risk to the reliability of the bulk power system because most of the instances in which the URE failed to operate its AGC on TLFB lasted less than two minutes. Moreover, the BPS was not in an abnormal condition during these occurrences.

Penalty: $250,000 (aggregate for multiple violations)

FERC Order: Issued November 5, 2010 (no further review)