NERC Case Notes: Reliability Standard INT-003-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard INT-003-2

NERC Case Notes: Reliability Standard INT-003-2

White & Case NERC Database

Unidentified Registered Entity, FERC Docket No. NP11-128-000 (February 23, 2011)

Reliability Standard: INT-003-2

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Following a compliance audit, WECC determined Unidentified Registered Entity (URE) did not provide sufficient evidence to show it was contacting or communicating with neighboring Balancing Authorities to confirm interchange schedules. URE provided a procedure with an effective date that was during the audit, so it could not serve as evidence.

Finding: WECC Enforcement determined the violation posed a moderate risk to the bulk power system because URE is located among larger Balancing Authorities and receives generation from outside its service territory. Correct calculation of the Area Control Error is essential to balanced operation of the interconnected grid, and therefore it is important for URE to coordinate its interchange schedules with adjacent Balancing Authorities. In determining the penalty amount, the NERC Board of Trustees Compliance Committee considered the following factors: this was URE’s first occurrence of this type of violation; URE was cooperative; and the number and nature of the violations.

Penalty: $450,000 (aggregated for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP12-9 (December 30, 2011)

Reliability Standard: INT-003-2

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: RFC

Issue: URE self-reported that while it was performing maintenance on its RSA database (which authenticates users for URE’s Physical Scheduling System (PSS)), it lost connectivity to the RSA database, which terminated access to the PSS. Since URE’s operators could not access the PSS and the e-Tag system, schedule adjustment requests were passively denied (since they were not acted upon in a timely manner). A URE operator made manual adjustments to the Net Scheduled Interchange (NSI) component of the Automatic Generation Control, but reversed the manual adjustments upon receiving notice that the PSS was unable to be reconnected and the scheduled adjustments had not been confirmed. Therefore, URE was unable to confirm Interchange Schedules with the sending BA before implementing the BA’s ACE equation.

Finding: RFC found that the INT-003-2 violation constituted a moderate risk to BPS reliability. But, the duration of the violation only lasted for nine minutes on one day. URE had promptly recognized and corrected the error and there were no resulting adverse impacts to the BPS. In determining the aggregate penalty amount, NERC BOTCC considered the fact that certain of the violations were self-reported; URE was cooperative during the enforcement process and did not conceal the violations; URE had a compliance program in place (which was evaluated as a mitigating factor); URE adopted additional efforts to improve reliability (such as updates to its software for effective CA access management) that went beyond the requirements in the mitigation plan; the violations did not pose a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.

Penalty: $60,000 (aggregate for 6 violations)

FERC Order: Issued January 27, 2012 (no further review)