NERC Case Notes: Reliability Standard FAC-010-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard FAC-010-1

NERC Case Notes: Reliability Standard FAC-010-1

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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.

Colorado Springs Utilities, FERC Docket No. NP10-190-000 (September 30, 2010)

Reliability Standard: FAC-010-1

Requirement: R1, 2, 3 and 4

Violation Risk Factor: Lower for R1, 3 and 4; Medium for R2

Violation Severity Level: Not provided

Region: WECC

Issue: Colorado Springs self-reported that it could not determine its system’s response to multiple contingencies as required of a Planning Authority by R2. In addition, Colorado Springs did not have a documented system operating limit (SOL) methodology for use in developing SOLs within its Planning Authority Area. Lacking a SOL methodology, Colorado Springs did not have appropriate descriptions or reliability margins, and also did not issue it to the required persons in compliance with R1, R3 and R4.

Finding: It was determined by WECC that the violation did not constitute a serious or substantial risk to the bulk power system because Colorado Springs had studied a subset of contingencies on its system and determined that it would not have any system overloads. Duration of the violations was from July 1, 2008 through December 15, 2008. In determining the penalty amount, WECC also considered that this was Colorado Springs’ first violation of the standard, and that it had self-reported or self-certified 6 of the 9 violations that gave rise to the penalty.

Penalty: $31,000 (aggregate for multiple violations)

FERC Order: Issued October 29, 2010 (no further review)

PacifiCorp (PAC), Docket No. NP12-44-000 (August 31, 2012)

Reliability Standard: FAC-010-1

Requirement: 4

Violation Risk Factor: Lower

Violation Severity Level: N/A

Region: WECC

Issue: PAC self-reported in October 2008 that, as a Planning Authority (PA), it had not issued its System Operating Limit (SOL) Methodology to the parties listed in the R4 sub-requirement of the Reliability Standard. PAC issued its SOL Methodology approximately three months late.

Finding: The violation was deemed by WECC to pose minimal risk to BPS reliability because PAC had an SOL Methodology in place but merely overlooked distributing it after the compliance date to the appropriate parties set forth in the Reliability Standard. PAC did not contest WECC's findings.

Penalty: $0 (for 4 violations)

FERC Order: Issued September 28, 2012 (no further review)

Utilities Commission of New Smyrna Beach, Docket No. NP10-73-000 (March 31, 2010)

Reliability Standard: FAC-010-1

Requirement: R1

Violation Risk Factor: Lower

Violation Severity Level: Not provided

Region: FRCC

Issue: In December 2008, Utilities Commission of New Smyrna Beach (UCNSB) self-reported a possible violation of Reliability Standard FAC-010-1 R1 since UCNSB had not documented its System Operating Limits (SOLs) and the methodology it used to determine them. Instead, UCNSB was using the SOLs based on the manufacturer's ratings.

Finding: FRCC and UCNSB entered into a settlement agreement to resolve all issues related to the alleged violation, whereby UNCSB neither admitted nor denied the alleged violation but agreed to pay a penalty of $1,500 and to undertake other mitigation measures. FRCC found that the alleged violation did not create a serious or substantial risk to the bulk power system. In assessing the penalty, FRCC considered the fact that UCNSB was using and operating within the manufacturer's limits; this was UCNSB's first assessed violation of this Reliability Standard; and UCNSB self-reported the alleged violation and was cooperative during the compliance process. UCNSB has successfully completed its mitigation plan. In addition, UCNSB is a small municipal utility with only 72 MW of generation – which accounts for just 0.18% of FRCC's transmission grid.

Penalty: $1,500

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