NERC Case Notes: Reliability Standard IRO-005-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard IRO-005-1

NERC Case Notes: Reliability Standard IRO-005-1

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

Reliability Standard: IRO-005-1

Requirement: R7

Violation Risk Factor: High

Violation Severity Level: Severe

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 disseminate information within the Reliability Coordinator area as required, 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)

Grays Harbor County PUD, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: IRO-005-1

Requirement: R13

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007, Grays Harbor County PUD (Grays Harbor) self-reported that it was unable to produce documentation showing that it always operated its bulk electric system facilities to the most limiting parameter.

Finding: WECC found that the violation did not pose a serious or substantial risk to the bulk power system since Grays Harbor was actually operating its bulk electric system facilities to the most limiting parameter. In addition, this violation was primarily a documentation issue. The violation was self-reported and this was Grays Harbor's first violation of this Reliability Standard. Even though Grays Harbor completed its mitigation plan over 3 1/2 months late, no penalty was imposed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

USACE-Seattle District, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: IRO-005-1

Requirement: R13

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: WECC

Issue: In July 2008, USACE-Seattle District self-certified that it was unable to produce documentation showing that it always operated its bulk electric system to the most limiting parameter.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since USACE-Seattle District was actually operating its bulk electric system to the most limiting parameter. In addition, the violation was primarily a documentation issue. This was USACE-Seattle District's first violation of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Western Electricity Coordinating Council, FERC Docket No. NP11-259-000 (August 11, 2011)

Reliability Standard: IRO-005-1

Requirement: R9

Violation Risk Factor: High

Violation Severity Level: High

Region: NERC-Compliance Enforcement (NCEA)

Issue: On November 7, 2008, a fire at a key 500 kV line’s series capacitor bank at a substation caused a 500 KV line to undergo a forced scheduled outage, which caused a Category 2 disturbance. This outage caused excess stability and thermal System Operating Limits (SOL) on two Western Interconnection transfer paths, which led to load shedding. California-Mexico Reliability Coordinator (CMRC) and Rocky Mountain Desert Southwest Reliability Coordinator (RDRC), two of WECC’s predecessors, did not properly coordinate with two of the relevant Transmission Operators to enact plans to mitigate the Transmission Operators’ excess SOL that were caused by the fire.

Finding: NCEA and WECC entered into a settlement agreement to resolve multiple violations, whereby WECC agreed to pay a penalty of $100,000 and to undertake other mitigation measures. NCEA found that the IRO-005-1 violation constituted a moderate risk to bulk power system reliability. The load would still have needed to be shed even if the Reliability Coordinators took the required actions. But, prompt and decisive action by the Reliability Coordinators could have mitigated the results. The IRO-005-1 violation occurred on November 7, 2008. In approving the settlement agreement, NERC found that these were WECC’s first violations of the relevant Reliability Standards and WECC was cooperative during the enforcement process and did not conceal the violations. In addition, on February 14, 2008, another predecessor to WECC, Pacific Northwest Security Coordinator (PNSC), was involved in a separate event that led to a settlement for violations of, inter alia, Reliability Standards IRO-001-1 R3, IRO-005-1 R8 and COM-002-2 R2. NCEA evaluated the penalty, mitigation actions and preventative measures imposed in that settlement as part of this proceeding. WECC, which assumed the Reliability Coordinator role effective January 1, 2009, is responsible for the violations of its predecessors.

Penalty: $100,000 (aggregate for 4 violations)

FERC Order: Issued September 9, 2011 (no further review)

Western Electricity Coordinating Council, FERC Docket No. NP14-38 (March 31, 2014)

Reliability Standard: IRO-005-1

Requirement: 6

Violation Risk Factor: High

Violation Severity Level: Severe

Region: NPCC

Issue: The Western Electricity Coordinating Council (WECC) self-reported that it did not notify via its WECCNet message system two TOPs of relevant Geo-Magnetic Disturbance (GMD) forecast information. The two TOPs at issue were new to the Western Interconnection and WECC did not timely update its WECCNet messaging system to incorporate the new entities.

Finding: NPCC found that the IRO-005-1 violation constituted only a minimal risk to BPS reliability since the relevant TOPs were wind farms in Utah and Colorado and were less likely to be affected by GMD. The duration of the IRO-005-1 violation was from January 1, 2009 through August 20, 2013. WECC neither admitted nor denied the violations. In approving the settlement agreement, NERC BOTCC considered the fact that most of the violations constituted a serious or substantial risk to BPS reliability and NPCC concluded that, left unaddressed, the number and type of reliability violations represented a potential for serious risk to the reliable operation of the Western Interconnection. The violations also represented WECC’s second occurrence of violations for Reliability Standards COM-002, TOP-007 and IRO-005 (although it was not evaluated as an aggravating factor since the prior violations involved legacy procedures used by WECC’s predecessor). Ten of the violations were self-reported, which was viewed as a mitigating factor. WECC was also cooperative throughout the enforcement process and did not conceal the violations.

Total Penalty: $400,000 (aggregate for 19 violations)

FERC Order: Issued August 28, 2014 (no further review)

Midcontinent Independent System Operator, Inc. (MISO), FERC Docket No. NP15-14-000 (December 30, 2014)

Reliability Standard: IRO-005-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Lower

Region: ReliabilityFirst

Issue: MISO self-reported on March 16, 2012 issues with a control setting on its Network Model, utilized for sending alerts when voltage, thermal or stability post-contingent element conditions, exceeded defined thresholds on facilities in its RC area. The problem affected (1) seven transmission lines associated with one station; (2) six tie lines between the MISO and PJM Interconnection area; (3) fourteen three-winding transformers; (4) facilities where the Transmission Owner or Transmission Operator (TO or TOP) did not provide a Facility Rating and MISO assigned a default rating; and (5) facilities where voltage monitoring flags were incorrectly activated due to a coding discrepancy in the Network Model update script.

Finding: ReliabilityFirst determined that the violation posed a moderate risk to the BPS reliability as the facilities at issue were still being monitored by the TOs and TOPs, who operate the Bulk Electric System (BES) facilities; adjoining RCs, who monitor any post emergency conditions (e.g. voltage, thermal and stability limits); and MISO, who conducts real-time monitoring through its supervisory control and data acquisition (SCADA) and Inter-Control Center Communications Protocol system. Additionally, BPS Operators would have been able to alert MISO to any post-contingency issues based on the analysis of next-day reliability, by which MISO would have been able to implement mitigating actions. With the exception of the substation and transformer facilities, the TOs and TOPs found no evidence that the transmission system experienced any SOLs and the SOLs on the two facilities were not associated with any specified IROLs. MISO neither admitted nor denied the violations. In approving the settlement agreement, the NERC BOTCC found that issues related to MISO's Network Model were only associated with the monitoring of post-contingent element conditions and did not hinder MISO's ability to perform other monitoring functions. Moreover, the issues were not related, affected a small percentage of the facilities MISO monitors and were indicative of other technologies that depend on large amounts of data. This was MISO's first violation of the standard and none of the violations posed a serious or substantial threat to BPS reliability. While MISO self-reported the violations, they were delayed. But MISO did have an internal compliance program in place, which ReliabilityFirst considered a mitigating factor. MISO was cooperative throughout the duration of the violation and there was no evidence that it attempted to conceal the violations.

Penalty: $0 (aggregate for 4 violations)

FERC Order: Pending