NERC Case Notes: Reliability Standard IRO-009-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard IRO-009-1

NERC Case Notes: Reliability Standard IRO-009-1

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Florida Reliability Coordinating Council, FERC Docket No. NP15-2-000 (October 30, 2014)

Reliability Standard: IRO-009-1

Requirement: R3

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: On July 29, 2012, a tree fell on the 230 kV Hopkins-Crawfordville line, which caused the line to relay and lock out. The line was not restored until approximately four hours later. In connection with this incident, the Florida Reliability Coordinating Council (FRCC), as the RC, self-reported that, when confronted with an assessment of actual or expected system conditions that predicted an Interconnection Reliability Operating Limit (IROL) exceedance in its RC Area if a specific contingency occurred, it did not timely follow its own reliability process for implementing processes, procedures or plans to prevent an IROL exceedance.

Finding: SERC determined that the violation constituted a serious or substantial risk to the BPS reliability as the identified 230 kV contingency could have resulted in line outages and islanding that would have affected two BAs and the loss of up to 274 MW in a localized area. Moreover, FRCC did not identify, pursuant to its System Operating Limit (SOL) methodology, the event as indicative of an IROL condition for more than an hour and did not take corrective action to minimize the duration and possibility of an at-risk condition that could have caused in an IROL exceedance. However, no actual harm to BPS reliability resulted as there was no IROL exceedance and any loss of load that would have occurred would have been confined to the local load-serving area. The violation occurred on July 29, 2012. FRCC neither admitted nor denied the violations. In approving the settlement agreement, the NERC BOTCC found that two of the violations posed a serious or substantial risk to BPS reliability. However, these were FRCC’s first violations of the Reliability Standards at issue and the violations were self-reported. FRCC took additional actions to mitigate the risk and it had an internal compliance program in place, which SERC considered as mitigating factors. FRCC also cooperated throughout the enforcement process and did not conceal the violations.

Penalty: $100,000 (aggregate for 6 violations)

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