NERC Case Notes: Reliability Standard INT-004-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard INT-004-2

NERC Case Notes: Reliability Standard INT-004-2

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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.

Associated Electric Cooperative, Inc., FERC Docket No. NP11-50-000 (November 30, 2010)

Reliability Standard: INT-004-2

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: SERC

Issue: Associated Electric Cooperative, Inc. ("AEC") self-reported that in two instances it failed to update tags for its Dynamic Interchange Schedule from its generating resource into the applicable Balancing Authority. Usually AEC is not responsible for updating such tags, but pursuant to its agreement with another Purchasing-Selling Entity, AEC updates such tags on behalf of the other Purchasing-Selling Entity when its schedules involve transfers of 50 MW or less during any one hour.

Finding: It was determined by SERC that the violation did not pose a serious or substantial risk to the reliability of the bulk power system because the scheduled energy profile and the actual average energy profile were both significantly less than 250 MW in any hour, and the total energy transferred during the two periods in which the tags were not updated was only 196 MWh and 135 MWh, respectively, and the periods were of short duration. The duration of violation was from September 14, 2008 until September 15, 2008. The penalty was mitigated by the self-report.

Penalty: $0

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

DTE Energy Trading, Inc., FERC Docket No. NP10-153-000 (July 30, 2010)

Reliability Standard: INT-004-2

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: SERC

Issue: DTE Energy Trading, Inc. (DTE Energy Trading), as a Purchasing-Selling Entity, failed to update the Dynamic Interchange Schedule tag for the next available scheduling hour when the actual hourly integrated energy (0 MW) deviated from the hourly average energy profile indicated on the tag (47 MW) by more than 25 megawatt-hours.

Finding: The alleged violation occurred from November 10, 2009 until November 30, 2009. SERC did not impose a financial penalty for this violation. In determining no penalty was appropriate, SERC considered these factors: this was DTE Energy Trading's first alleged violation of this Reliability Standard; the violation was self-reported; DTE Energy Trading cooperated during the compliance enforcement process; DTE Energy Trading's compliance program; DTE Energy Trading did not attempt to conceal the violation or intend to do so; the alleged violation did not create a serious or substantial risk to the bulk power system; and there were no aggravating factors that would impact the penalty assessment.

Penalty: $0

FERC Order: Issued August 27, 2010 (no further review)

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

Reliability Standard: INT-004-2

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: SERC

Issue: Progress Energy Carolinas (PEC) self-reported that it did not update its Dynamic Transfer tags after exceeding the thresholds specified in the standard for 216 out of 17,328 hours.

Finding: SERC found that the violation did not constitute a serious or substantial risk to the bulk power system because the size of the Dynamic Transfers (800 MW) was small compared to PEC's system load and the most extreme deviation was only 547 MW; the actual transfers were within limits established for the reservation of firm transmission; and none of the deviations from the scheduled energy profile resulted in the issuance of transmission loading relief directives. Duration of violation was May 20, 2008 through August 2, 2010.

Penalty: $0

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

Tri-State Generation and Transmission Association, Inc. – Merchant (TSPMTS), FERC Docket No. NP10-113-000 (June 2, 2010)

Reliability Standard: INT-004-2

Requirement: R2.2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: MRO

Issue: In August 2009, Tri-State Generation and Transmission Association, Inc. – Merchant (TSPMTS) self-reported a tagging error, which it did not initially report as required. The tagging error was caused when a TSPMTS real time night shift operator revised the energy schedule for all future hours of the scheduling day of August 17, 2009 (but not the associated tag) in response to a lower than expected load served by the Dynamic Interchange Schedule on the night of August 16, 2009. This led to a "tagged load value" that was greater than +/- 25 MW for each hour during a 19-hour time period. After a call from the Nebraska Public Power District, TSPMTS fixed the tagging error for the next hour and the rest of the day.

Finding: MRO found that this violation did not pose a serious or substantial risk to the bulk power system since the Balancing Authorities actually used the direct electronic dynamic signal to regulate generation (instead of the tagged value). In addition, even though it did not modify the tag as required, TSPMTS did not receive any notices of reliability issues from its Reliability Coordinator, Transmission Operators or Balancing Authorities during the relevant time period. Even though this violation represented a second incident of non-compliance with INT-004-2, it was not considered an aggravating factor since the current violation occurred after the one-year reset period. In deciding not to impose a penalty, MRO also considered the fact that the violation was self-reported; TSPMTS undertook immediate action to correct the violation as soon it became aware of the issue; TSPMTS was cooperative during the enforcement process and did not conceal the violation; and TSPMTS has a positive compliance program. A mitigation plan has been completed.

Penalty: $0

FERC Order: Issued July 2, 2010 (no further review)