NERC Case Notes: Reliability Standard FAC-011-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard FAC-011-1

NERC Case Notes: Reliability Standard FAC-011-1

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Florida Reliability Coordinating Council, FERC Docket No. NP15-2-000 (October 30, 2014)

Reliability Standard: FAC-011-1

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: On July 29, 2012, a tree fell on the 230 kV Hopkins-Crawfordville line, which caused the line to relay and lock out. The line was not restored until approximately four hours later. In connection with this incident, the Florida Reliability Coordinating Council (FRCC), as the RC, self-reported that its System Operating Limit (SOL) methodology did not adequately provide for BES performance consistent with the Reliability Standard.

Finding: SERC determined that the violation constituted a moderate risk to the BPS reliability as the insufficient SOL methodology could have resulted in certain SOL conditions, responses to SOL conditions impacting BPS reliability and contingency response plans going unaddressed. However, FRCC’s SOL methodology did include certain SOL contingency plans and conditions that require it, and other entities within the FRCC region, to respond when certain analyses indicated significant BES overloads. Furthermore, FRCC’s SOL methodology required it to continuously monitor real-time operations for out-of-limit conditions and to develop mitigating actions prior to contingencies occurring. The duration of the FAC-011-1 violation was from October 1, 2008 through May 2, 2013. FRCC neither admitted nor denied the violations. In approving the settlement agreement, the NERC BOTCC found that two of the violations posed a serious or substantial risk to BPS reliability. However, these were FRCC’s first violations of the Reliability Standards at issue and the violations were self-reported. FRCC took additional actions to mitigate the risk and it had an internal compliance program in place, which SERC considered as mitigating factors. FRCC also cooperated throughout the enforcement process and did not conceal the violations.

Penalty: $100,000 (aggregate for 6 violations)

FERC Order: Issued November 28, 2014 (no further review)

Florida Reliability Coordinating Council, FERC Docket No. NP15-2-000 (October 30, 2014)

Reliability Standard: FAC-011-1

Requirement: R3

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SERC

Issue: On July 29, 2012, a tree fell on the 230 kV Hopkins-Crawfordville line, which caused the line to relay and lock out. The line was not restored until approximately four hours later. In connection with this incident, the Florida Reliability Coordinating Council (FRCC), as the RC, self-reported that its System Operating Limit (SOL) methodology failed to include a list of criteria used to determine when violating a SOL would be considered an Interconnection Reliability Operating Limit (IROL) or to calculate maximum amounts of time for an IROL violation before the risk to the interconnection or other RC Area becomes unacceptable. Other areas that FRCC’s SOL methodology failed to address included: specifying that the study model account for the entire RC Area and certain critical modeling details from other RC Areas; determining the applicable stability limits for many contingencies; providing sufficiently detailed system model for calculating SOLs; and anticipating transmission system configuration, generation dispatch and load level.

Finding: SERC determined that the violation constituted a moderate risk to the BPS reliability as the failure to have an adequate SOL methodology could have resulted in FRCC overlooking certain SOL or IROL conditions and an inability to adequately plan for contingency responses or respond to SOL or IROL conditions. But, FRCC’s SOL methodology did include some contingency plans that addressed post-contingency voltages below 90% and line overloads that exceeded 140% as representative of an IROL condition. In addition, within its region and a significant portion of the BES within the adjacent RC Area, FRCC uses a Real-Time Contingency Analysis for monitoring and analyzing the BES. The duration of the violation was from October 1, 2008 through April 7, 2014. FRCC neither admitted nor denied the violations. In approving the settlement agreement, the NERC BOTCC found that two of the violations posed a serious or substantial risk to BPS reliability. However, these were FRCC’s first violations of the Reliability Standards at issue and the violations were self-reported. FRCC took additional actions to mitigate the risk and it had an internal compliance program in place, which SERC considered as mitigating factors. FRCC also cooperated throughout the enforcement process and did not conceal the violations.

Penalty: $100,000 (aggregate for 6 violations)

FERC Order: Issued November 28, 2014 (no further review)