NERC Case Notes: Reliability Standard IRO-002-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard IRO-002-1

NERC Case Notes: Reliability Standard IRO-002-1

White & Case NERC Database

Electric Reliability Council of Texas, Inc., FERC Docket No. NP11-268-000 (September 30, 2011)

Reliability Standard: IRO-002-1

Requirement: R4

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: Texas RE

Issue: On February 26, 2008, the Electric Reliability Council of Texas, Inc. (ERCOT) declared an Emergency Electric Curtailment Plan Step 2 (EECP2) event on its system due to an unexpected imbalance between generation and load, causing a reduction in system frequency to levels that were outside acceptance operational limits. The event lasted two hours, but did not reduce in involuntary customer load shedding. Through an audit, Texas RE determined that ERCOT failed to have communication capabilities to meet reliability needs at the time of the event, since its hotline call to declare the emergency event did not reach the Austin Control Center, which was responsible for certain Balancing Authority functions during the emergency, until about ten minutes after the emergency event was declared.

Finding: Texas RE determined that the violation posed a serious and substantial risk to the BPS because it put the Texas grid reliability at unnecessary and avoidable higher levels of risk than would otherwise have been the case, potentially leading to a wide spread and severe system disturbance. Duration of violation was February 26, 2008. Texas RE and the NERC BOTCC took into consideration that this was ERCOT's first violation of the Standard in reaching a penalty assessment, and also concluded that the serious and substantial risk to the BPS constituted an aggravating factor.

Penalty: $384,000 (aggregate for 15 violations)

FERC Order: Issued October 28, 2011 (no further review)