NERC Case Notes: Reliability Standard IRO-005-3a | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard IRO-005-3a

NERC Case Notes: Reliability Standard IRO-005-3a

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

Reliability Standard: IRO-005-3a

Requirement: 1.2/1.3, 4

Violation Risk Factor: High (1.2/1.3, 4)

Violation Severity Level: Moderate (1.2/1.3), Severe (4)

Region: NPCC

Issue: During a compliance audit, NPCC determined that, on March 1, 2012, the Western Electricity Coordinating Council (WECC) did not discover that a TOP operator had submitted incorrect System Operating Limits (SOL) for Path 3 for inclusion in the daily analysis performed by WECC’s Energy Management System (EMS) Real-Time Contingency Analysis (RTCA). WECC had numerous opportunities to discover that the SOL was incorrect, but the condition persisted for over 10 hours until the TOP operator notified WECC of the proper SOL. In addition, a SOL violation occurred on March 30, 2010, and WECC did not issue a directive until over an hour after the violation commenced.

Finding: NPCC found that the IRO-005-3a violations constituted a serious or substantial risk to BPS reliability. In regards to the March 1, 2012 event, WECC did not validate the SOL information submitted against the scheduled outages, resulting in WECC disseminating incorrect information and Path 3 operating above its SOL. WECC experienced an actual SOL exceedance on Path 3, which could have caused the loss of Path 3 or additional equipment or the loss of customer load. Outputting alarms were triggered, which should have warned WECC of the incorrect SOL for Path 3. WECC also had the correct outage information in its Coordinated Outage System (COS). In the March 30, 2010 instance, WECC did not provide timely notification within its RC area, and therefore other affected entities did not have the necessary information to formulate or take corrective action. The IRO-005-3a violations occurred on March 1, 2012 and 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)

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

Reliability Standard: IRO-005-3a

Requirement: 1/1.3

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: NPCC

Issue: In an August 21, 2012 incident, Western Electricity Coordinating Council (WECC) operators had difficulty loading the appropriate data into the Study Network Analysis application (STNET) and therefore WECC did not timely exercise its backup for its loss of the Real Time Network Analysis (RTNET) and Real-Time Contingency Analysis (RTCA) to identify potential System Operating Limits (SOL) and Interconnection Reliability Operating Limits (IROL) exceedances. During the incident, WECC self-reported that it was unable to monitor its RC area parameters as required.

Finding: NPCC found that the IRO-005-3a violation constituted a serious or substantial risk to BPS reliability. WECC was unable for 58 minutes (at which time the RTCA became operable again) to monitor SOL and IROL conditions within the Western Interconnection. During that time, WECC would not have had the needed real-time data available to solve potential contingencies. The IRO-005-3a violation occurred on August 21, 2012. 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)

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

Reliability Standard: IRO-005-3a

Requirement: 4

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: NPCC

Issue: The Western Electricity Coordinating Council (WECC) self-reported that, in response to a June 15, 2012 transformer relay issue impacting WECC’s West of McNary path, it did not timely send, as required, WECCNet notifications to entities located within WECC in order to inform them of the transformer relay issue and its impact on the West of McNary path and subsequent updates.

Finding: NPCC found that the IRO-005-3a violation constituted a serious or substantial risk to BPS reliability. As WECC did not timely issue WECCNet notifications (based on the mistaken belief that the transformer relay was an internal Bonneville Power Administration BA issue), affected entities did not know the reason behind the deviation of the Area Control Error and frequency and therefore could not undertake appropriate actions on their systems. The IRO-005-3a violation occurred on June 15, 2012. 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)

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

Reliability Standard: IRO-005-3a

Requirement: 5

Violation Risk Factor: High

Violation Severity Level: High

Region: NPCC

Issue: During a compliance audit, NPCC determined that, on August 17, 2011, the Western Electricity Coordinating Council (WECC), via the WECC Loveland RC (LRCC) operator, did not properly issue an Area Control Error (ACE) recovery directive, as the LRCC operator was not sufficiently specific when ordering the BA to shed load.

Finding: NPCC found that the IRO-005-3a violation constituted a serious or substantial risk to BPS reliability. Even which it was apparent that ACE was not going to be timely restored within 15 minutes, WECC did not direct rebalancing as required. The IRO-005-3a violation occurred on August 17, 2011. 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)

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

Reliability Standard: IRO-005-3a

Requirement: 6

Violation Risk Factor: High

Violation Severity Level: High

Region: NPCC

Issue: During a compliance audit, NPCC determined that, on November 4, 2010, the Western Electricity Coordinating Council (WECC) issued a directive to a receiver operator to shed firm load that was based on a wrong Path 20 System Operating Limit (SOL). The SOL was exceeded on Path 20 for more than 30 minutes. In addition, on March 1, 2012, WECC did not discover that a TOP operator had submitted an incorrect SOL for Path 3 for inclusion in the Real-Time Contingency Analysis (RTCA). WECC had numerous opportunities to discover that the SOL was incorrect, but the condition persisted for over 10 hours until the TOP operator notified WECC of the proper SOL.

Finding: NPCC found that the IRO-005-3a violation constituted a serious or substantial risk to BPS reliability. WECC did use its authority to ensure a SOL is mitigated, which caused the BPS to be in an unknown state and vulnerable to reliability problems and loss of load. In addition, on the November 4, 2010 event, a TOP also took a line out of service without WECC’s approval. The IRO-005-3a violation occurred on March 1, 2012 and November 4, 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)

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

Reliability Standard: IRO-005-3a

Requirement: 8

Violation Risk Factor: High

Violation Severity Level: Severe

Region: NPCC

Issue: The Western Electricity Coordinating Council (WECC) self-reported that, on June 15, 2012, as a result of a transformer relay issue and subsequent Bonneville Power Administration (BPA) schedule cuts that were negatively impacting the Area Control Error (ACE), WECC contacted BPA, but did not request complete information as to the corrective action that BPA was taking (such as the amount and names of scheduled curtailments) or evaluate whether the schedule cuts were appropriate or discuss other corrective actions with BPA.

Finding: NPCC found that the IRO-005-3a violation constituted a serious or substantial risk to BPS reliability. WECC did not evaluate in real-time the generation re-dispatch that BPA had initiated, even though the ACE at CAISO reach a -2,071 MW deficit and interconnection frequency exceeded its limits at both the BPA and CAISO areas. With such a high ACE, WECC’s response risked being too late to address the frequency deterioration. The IRO-005-3a violation occurred on June 15, 2012. 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)

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

Reliability Standard: IRO-005-3a

Requirement: 12

Violation Risk Factor: High

Violation Severity Level: Severe

Region: NPCC

Issue: The Western Electricity Coordinating Council (WECC) self-reported that, in response to a June 15, 2012 transformer relay issue impacting WECC’s West of McNary path, it did not timely send, as required, WECCNet notifications to entities located within WECC in order to inform them of the transformer relay issue and its impact on the West of McNary path and subsequent updates (including a frequency deviation caused by the Bonneville Power Administration (BPA) schedule cuts). WECC did not properly evaluate the issue or gather appropriate information.

Finding: NPCC found that the IRO-005-3a violation constituted a serious or substantial risk to BPS reliability. As WECC did not alert its BAs and TOPs of the frequency and Area Control Error (ACE) excursions caused by BPA, it constrained the ability of the adjacent TOPs and BAs to timely take responsive and protective actions within their system. The IRO-005-3a violation occurred on June 15, 2012. 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)