NERC Case Notes: Reliability Standard INT-001-3 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard INT-001-3

NERC Case Notes: Reliability Standard INT-001-3

White & Case NERC Database

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.

Progress Energy Carolinas, FERC Docket No. NP11-266-000 (August 31, 2011)

Reliability Standard: INT-001-3

Requirement: R1

Violation Risk Factor: Lower

Violation Severity Level: Moderate

Region: SERC

Issue: Progress Energy Carolinas (PEC) self-reported that it did not submit Dynamic Schedules to its Interchange Authority on four individual occasions between October 2007 and September 2009.

Finding: SERC found that the violation did not constitute a serious or substantial risk to the bulk power system because the contract resources for the wholesale customer are dynamically scheduled based on metered load such that the schedule always matches the load, and other interchange information was agreed upon prior to the Dynamic Schedule implementation; and PEC's Balancing Authority includes the wholesale customer hourly integrated Dynamic Schedule in its schedule checkout process. Duration of violation was October 1, 2007 through September 14, 2009.

Penalty: $0

FERC Order: Issued September 30, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-218-000 (June 29, 2011)

Reliability Standard: INT-001-3

Requirement: R1

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: WECC

Issue: WECC found that the Registered Entity had six tagged transactions, scheduled from one of its generation facilities, where it had submitted dynamic schedules above its expected average MW profile, as opposed to submitting dynamic schedules at the expected average MW profile for each hour as required.

Finding: WECC and the Registered Entity entered into a settlement agreement to resolve multiple violations, whereby the Registered Entity agreed to pay a penalty of $130,000 and to undertake other mitigation measures. WECC found that the INT-001-3 violation constituted only a minimal risk to bulk power system reliability since the Registered Entity’s implemented values only deviated by less than 3% from the expected values (which is consider by WECC to be a minor inaccuracy in scheduling information). In addition, these deviations did not affect the calculations done by WECC’s reliability analysis services. The duration of the INT-001-3 violation was from August 28, 2008 through July 1, 2010. In approving the settlement agreement, NERC found that there were three instances of noncompliance with Regional Reliability Standard PRC-STD-005-1 WR1 (which was evaluated as an aggravating factor); some of the violations were self-reported; the Registered Entity was cooperative during the enforcement process and did not conceal the violations; the Registered Entity had a compliance program in place (which was evaluated as a mitigating factor); the penalties for the violations of Reliability Standards EOP-001-0 R6 and EOP-005-1 R2 were aggregated since both penalties were based on a single act of noncompliance; the penalties for the violations of Reliability Standards PRC-STD-005-1 WR1 and VAR-STD-002b-1 WR1 were based on the respective Sanction Tables; and there were no additional aggravating or mitigating factors.

Penalty: $130,000 (aggregate for 27 violations)

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