NERC Case Notes: Reliability Standard BAL-003-0.1b | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard BAL-003-0.1b

NERC Case Notes: Reliability Standard BAL-003-0.1b

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Public Service Company of Colorado (PSCO), Docket No. NP12-26-000 (April 30, 2012)

Reliability Standard: BAL-003-0.1b

Requirement: R3 (two violations)

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: PSCO, as a BA, submitted two self-reports (February 2010 and November 2010) detailing violations of BAL-003-1.1b based upon its failure to operate its Automatic Generation Control (AGC) on Tie Line Frequency Bias when operating in a that mode would not be adverse to system or Interconnection reliability, as required by the Standard. In particular, the February report reported that PSCO found its Automatic Time Error Correction (ATEC) was disabled because the EMS operating mode had mistakenly changed from Tie Line Bias with ATEC to Flat Interchange Mode (Flat Tie). The ATEC was disabled for approximately 46 hours when operators realized the issue and switched to the correct operating mode. The November self-report reported an instance in which a PSCO operator was training a new employee as to what would be seen if the EMS was taken out of Tie Line Frequency Bias with ATEC mode. During the training, the operator changed the EMS mode to Flat Frequency mode in two instances to ensure the new employee knew how to toggle the EMS point. During both instances, operators knew the system condition and were ready to respond to any system events.

Finding: The violations were found to pose minimal risk to BPS reliability because PSCO’s contribution to the Interconnection frequency after a system event would be minimal due to PSCO’s limited capacity to provide frequency support. Also, the November instance was for a short time period and system operators knew the system condition and the training was done in a controlled environment. WECC found the training provided real experience to the trainee and system operators responsible for PSCO’s facilities. In determining the appropriate penalty, PSCO’s internal compliance program was considered a mitigating factor and credit was given for the self-report.

Penalty: $50,000 (aggregate for 5 violations)

FERC Order: Order issued May 30, 2012 (no further review)

Sunflower Electric Power Corporation, FERC Docket No. NP11-228-000 (June 30, 2011)

Reliability Standard: BAL-003-0.1b

Requirement: R1

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: SPP

Issue: In October 2010, Sunflower Electric Power Corporation (Sunflower) self-reported that it had not submitted, by January 1, 2010, its review and recalculation of its Frequency Bias Settings to SPP nor its method for calculating the settings. Sunflower submitted its Frequency Bias Settings on January 4, 2010 and its method for calculating the setting on November 10, 2010.

Finding: SPP found that the violation constituted only a minimal risk to bulk power system reliability since Sunflower’s Frequency Bias Settings were only submitted four days late and did not receive any requests for them from SPP or the NERC Operating Committee. The duration of the violation was from June 18, 2007 through December 9, 2010.

Penalty: $0 (aggregate for 2 violations)

FERC Order: Issued July 29, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-188-000 (May 26, 2011)

Reliability Standard: BAL-003-0.1b

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SPP

Issue: During a spot check, SPP discovered that the URE did not perform the calculations to determine the frequency response to its system using either of the two calculation methods outlined in R2.1 or R2.2 for 2009. Moreover, in 2008 URE did not perform any of the calculations to determine the frequency response required by R2. Duration of the violation was January 1, 2009 when the URE was required to review its Frequency Bias Settings through May 31, 2010 when the violation was mitigated.

Finding: SPP determined that the violation posed a minimal risk to the bulk power system because the frequency bias established by the URE was greater than the frequency bias determined by either of the methods required in the standard. The NERC BOTCC also considered that the URE self-reported certain of the violations, and this was the URE’s first occurrence of violations of the standards.

Penalty: $16,860 (aggregate for 7 violations)

FERC Order: Issued June 24, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-198-000 (May 26, 2011)

Reliability Standard: BAL-003-0.1b

Requirement: R2 (R2.1/R2.2)

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SPP

Issue: During a spot check, SPP discovered that the Unidentified Registered Entity (URE) had not conducted the calculations (using either of the mandated methodologies in the Reliability Standard) needed to establish the frequency response to its system.

Finding: SPP and the URE entered into a settlement agreement to resolve multiple violations, whereby the URE agreed to pay a penalty of $17,860 and to undertake other mitigation measures. SPP found that the BAL-003-0.1b violation only posed a minimal risk to bulk power system reliability since the frequency bias that was established by the URE was actually greater than the frequency bias that would have been established by the mandated methodologies (which resulted in the URE having an increased response to frequency excursions). The duration of the BAL-003-0.1b violation was from January 1, 2009 through May 31, 2010. In approving the settlement agreement, NERC found that these violations were the URE’s first violations of the relevant Reliability Standards; the PRC-005-1 violation was self-reported; the URE was cooperative during the enforcement process and did not conceal the violations; the URE had a compliance program in place when the violations occurred (which was evaluated as a mitigating factor); and there were no additional aggravating or mitigating factors.

Penalty: $17,860 (aggregate for 7 violations)

FERC Order: Issued June 24, 2011 (no further review)