NERC Case Notes: Reliability Standard IRO-005-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard IRO-005-2

NERC Case Notes: Reliability Standard IRO-005-2

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Unidentified Registered Entity, FERC Docket No. NP11-176-000 (April 29, 2011)

Reliability Standard: IRO-005-2

Requirement: R13

Violation Risk Factor: N/A

Violation Severity Level: Severe

Region: WECC

Issue: In May 2009, the Unidentified Registered Entity (URE) self-reported that it had been operating a 500 kV line beyond its System Operating Limits (SOL) and had not undertaken immediate action to decrease load in order to restore operations within the SOL. The URE had not been operating the line according to the most limiting parameter (when there was a difference with the derived limit).

Finding: WECC and the URE entered into a settlement agreement to resolve multiple violations, whereby the URE agreed to pay a penalty of $80,000 and to undertake other mitigation measures. WECC found that the violation of IRO-005-2 constituted a moderate risk to bulk power system reliability. But, the magnitude of the overload was only 3.7%, no Interconnection Reliability Operating Limits were implicated, and the operations on the line were appreciably lower than the emergency ratings of the transmission element. The duration of the IRO-005-2 violation was for three months and four days. In approving the settlement agreement and the penalty determination, NERC considered the fact that the violations were self-reported; the URE was cooperative during the enforcement process and did not conceal the violations; the URE had a compliance program in place (which was evaluated as a mitigating factor); the violations of IRO-005-2 R13 and TOP-004-2 R1 resulted from a single noncompliance occurrence; and there were no additional aggravating or mitigating factors.

Penalty: $80,000 (aggregate for 7 violations)

FERC Order: May 27, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-180-000 (April 29, 2011)

Reliability Standard: IRO-005-2

Requirement: R13

Violation Risk Factor: N/A

Violation Severity Level: Severe

Region: WECC

Issue: The Unidentified Registered Entity (URE) had not been operating a part of its transmission line according to the most limiting parameter, which resulted in that part of the line exceeding the System Operating Limit (SOL) by 65 MW for over 25 minutes.

Finding: WECC and the URE entered into a settlement agreement to resolve multiple violations, whereby the URE agreed to pay a penalty of $71,500 and to undertake other mitigation measures. WECC found that the violation of IRO-005-2 constituted a moderate risk to bulk power system reliability as the relevant part of the line was located along a critical transmission path. But, the URE was operating the line within its Transmission Operator’s ratings, and the SOL was only exceeded by 65 MW. The duration of the IRO-005-2 violation was 25 minutes. In approving the settlement agreement and the penalty determination, NERC considered the fact that the violations were the URE’s first violations of the relevant Reliability Standards; most of the violations were self-reported; the URE was cooperative during the enforcement process and did not conceal the violations; the URE had a compliance program in place (which was evaluated as a mitigating factor); the penalty for the violation of IRO-STD-006-0 WR1 was based on a specified Sanction Table; the violations of IRO-005-2 R13 and TOP-008-1 R2 resulted from a single noncompliance occurrence; and there were no additional aggravating or mitigating factors.

Penalty: $71,500 (aggregate for multiple violations)

FERC Order: May 27, 2011 (no further review)

WECC RC [California Mexico Reliability Coordinator OC], Docket No. NP10-160-000 (September 13, 2010)

Reliability Standard: IRO-005-2

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: NERC as Compliance Enforcement Authority (NCEA)

Issue: During the period from June 18, 2007 through January 1, 2009, the California Mexico Reliability Coordinator (CMRC) was not aware of each Interchange Transaction that wheeled through, sourced or sank in its Reliability Coordinator Area, and did not make that Interchange Transaction information available to all Reliability Coordinators in the Interconnection, as required by the Reliability Standard. Furthermore, CMRC was not using the proper tool to view dynamic schedules as required by R2.

Finding: The violation was the first violation of this Reliability Standard and it did not constitute a serious or substantial risk to the bulk power system. WECC was certified as the Reliability Coordinator on January 1, 2009 and assumed all further responsibilities. The violation was mitigated through the dissolution of the entity and NERC's certification of WECC as the new Reliability Coordinator for the region.

Penalty: $0

FERC Order: Issued October 13, 2010 (no further review)

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

Reliability Standard: IRO-005-2

Requirement: 15

Violation Risk Factor: High

Violation Severity Level: Severe

Region: NPCC

Issue: During a compliance audit, NPCC determined that, on March 30, 2010, the Western Electricity Coordinating Council (WECC) did not notify, as required, the impacted TOPs and BAs in the area of a System Operating Limit (SOL) violation of Path 27.

Finding: NPCC found that the IRO-005-2 violation constituted a serious or substantial risk to BPS reliability. As Path 27 was operating above its SOL, it risked damaging equipment or causing a significant impact on the BPS. As WECC did not disseminate the required information, the relevant TOPs and BAs did not have the needed information to take actions to address the SOL exceedance. The IRO-005-2 violation occurred on March 30, 2010. 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)