NERC Case Notes: Reliability Standard INT-006-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard INT-006-2

NERC Case Notes: Reliability Standard INT-006-2

White & Case NERC Database

Los Angeles Department of Water and Power, FERC Docket No. NP10-141-000 (July 6, 2010)

Reliability Standard: INT-006-1

Requirement: R1

Violation Risk Factor: Lower

Violation Severity Level: Not provided

Region: WECC

Issue: LADWP self-reported that it had failed to approve 25 e-tag transactions as required by the standard. LADWP noted that procedural and software problems had impeded its compliance with the standard in these cases.

Finding: Duration of the violation was from June 18, 2007, when the standard became enforceable, through March 3, 2008. The violation was deemed to begin on June 18, 2007, rather than the date of the first failure to approve an e-tag transaction, because LADWP stated that procedural and software problems had impeded its compliance. The violation did not pose a serious or substantial risk to the reliability of the bulk power system because only commercial transactions, not reliability transactions, were affected by the violation. LADWP received credit for self-reporting the violation.

Penalty: $225,000 (aggregate for multiple violations)

FERC Order: Issued Oct. 8, 2010 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-137-000 (March 30, 2011)

Reliability Standard: INT-006-1/INT-006-2

Requirement: R1

Violation Risk Factor: Lower

Violation Severity Level: N/A

Region: WECC

Issue: URE self-reported two violations of INT-006-1 and two violations of INT-006-2, all with respect to R1. URE reported that on April 25, 2008 it had failed to respond to a Request for Interchange within the assessment period required by the Standard in violation of R1, and also failed to respond to a tag when its vendor’s system shut down briefly on August 12, 2008. URE further reported a violation of R1 on October 19, 2008 because it failed to respond to a tag when its system did not recognize a valid acronym due to its etag vendor failing to properly update its software. Finally, URE reported that on February 21, 2009 it discovered an expired tag number caused by failure of a proxy server used to route eTagging traffic to the management system servers. Duration of the first two violations was April 25, 2008 through October 8, 2008, when the violations were mitigated. Duration of the third violation was October 19, 2008 through October 28, 2008, when the violations were mitigated. Duration of the fourth violation was February 21, 2009 through May 12, 2009, when the violations were mitigated.

Finding: WECC Enforcement determined that the violation did not pose a serious or substantial risk to the bulk power system because in each case, the pertinent tags were reissued, approved and implemented and the violations were related to routine daily commercial interchange transactions. Further, the NERC BOTCC concluded the penalty appropriate because this was URE’s first violation of most of the Standards involved, URE self-reported 28 of 30 violations, and URE was cooperative during the investigation.

Penalty: $106,000 (aggregate for 30 violations)

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