NERC Case Notes: Reliability Standard IRO-008-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard IRO-008-1

NERC Case Notes: Reliability Standard IRO-008-1

White & Case NERC Database

Florida Reliability Coordinating Council, Inc. FERC Docket No. NP15-3-000 (October 30, 2014)

Reliability Standard: IRO-008-1

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: Florida Power & Light Company functions as the Florida Reliability Coordinating Council, Inc.’s (FRCC) agent for real-time and next-day planning RC functions. During August 8-9, 2012, a core router pair, which supported the communications network for the FRCC’s energy management system (EMS) at FPL’s primary control center, malfunctioned due to a buffer overrun. As a result, the EMS was rendered inaccessible from system operator consoles and FRCC was only able to fully access its EMS/Supervisory Control and Data Acquisition (SCADA) system three hours later. In connection with the incident, FRCC self-reported that it did not timely perform Real-Time Assessments to determine if any Interconnection Reliability Operating Limits (IROLs) were exceeded, or threatened to be exceeded, within its Wide Area.

Finding: SERC determined that the violation constituted a serious or substantial risk to the BPS reliability as it may have hampered FRCC’s ability to prevent instability, uncontrolled separation, or cascading outages. However, no actual harm to the BPS occurred as FRCC used other monitoring capabilities to maintain situational awareness during the incident. In addition, none of the FRCC BES elements were de-energized and no SOLs were exceeded during the incident. The IRO-008-1 violation occurred on August 8-9, 2012. FRCC neither admitted nor denied the violations. In approving the settlement agreement, the NERC BOTCC considered the fact that all of the violations constituted a serious or substantial risk to BPS reliability. However, these were FRCC’s first violation of the Reliability Standards at issue and the violations were self-reported. FRCC also had an internal compliance program in place, which SERC evaluated as a mitigating factor. In addition, FRCC was cooperative throughout the enforcement process and did not conceal the violations.

Penalty: $85,000 (aggregate for 4 violations)

FERC Order: Pending

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

Reliability Standard: IRO-008-1

Requirement: 2

Violation Risk Factor: High

Violation Severity Level: Severe

Region: NPCC

Issue: The Western Electricity Coordinating Council (WECC) self-reported that on August 21, 2012, its real-time state estimator tool (RTNET) was temporarily inoperable due to a software glitch, and WECC did not employ its backup monitoring system as mandated. As a result, WECC RC System Operator (RCSO) had trouble uploading the appropriate data into the Study Network Analysis application (STNET) and therefore WECC did not complete the STNET system assessment until 58 minutes after the last Real-Time Contingency Analysis (RTCA) assessment, which was outside of the required timeframe.

Finding: NPCC found that the IRO-008-1 violation constituted a serious or substantial risk to BPS reliability. WECC had limited real-time contingency tools to monitor and solve for contingencies, which placed the BPS at risk. If a contingency had occurred during the 58 minutes between assessments, WECC would not have had the needed post-contingency data available and the reliability of the contingency immediate area would have been threatened. The IRO-008-1 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)