NERC FFT Reports: Reliability Standard MOD-008-1 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard MOD-008-1

NERC FFT Reports: Reliability Standard MOD-008-1

White & Case NERC Database

Orlando Utilities Commission (OUC), Docket No. RC13-10, June 27, 2013

Reliability Standard: MOD-008-1

Requirement: R1; R1.3.2; R1.3.3

Region: FRCC

Issue: Further to a Compliance Audit, FRCC found that OUC, as a TSP, had an issue with MOD-008-1 R1 because while OUC had prepared its Transmission Reliability Margin (TRM) Implementation Document, such document had not been kept current with accurate Available Transfer Capacity (ATC) figures, reflecting TRM subtracted from Total Transfer Capability (TTC). OUC also failed to document the process that had been implemented as no TRM was subtracted for days two through seven, no TRM was subtracted from the sum of the facility ratings segment, and no TRM was applied after April 30, 2012.

Finding: FRCC determined that the issue posed a minimal risk to the reliability of the BPS for three reasons: (1) OUC had three import and three export paths and no wheeling paths; (2) reservations would need to be made through both the sending and receiving Transmission Service Providers (TSPs) on the path, allowing the other TSP in the path to calculate ATC correctly and deny any firm ATC that was oversold by OUC; and (3) as the sum of the facility (line) ratings are typically larger than the calculated TTC value, the TTC value would not be a limiting factor even without TRM properly subtracted.

Seminole Electric Cooperative (SEC), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: MOD-008-1

Requirement: 1; 1.2

Region: FRCC

Issue: During an audit, FRCC found that SEC, as a TO, failed to comply with R1. SEC's Transmission Reliability Margin Implementation Document (TRMID) failed to include the methodology implemented to allocate TRM across SEC's Available Transfer Capability (ATC) Paths for the reserve sharing requirement. While SEC's response to the audit included a description of the method used, the description was not included in the TRMID (per R1).

Finding: FRCC found the issue posed a minimal to the reliability of the BPS since SEC was operating in accordance with to the methodology presented in the audit request, and all of the requirements were being met during the compliance period.

Western Area Power Administration - Rocky Mountain Region (WACM), FERC Docket No. RC13-5-000 (January 31, 2013)

Reliability Standard: MOD-008-1

Requirement: 1

Region: WECC

Issue: WECC conducted an on-site audit of WACM from August 20, 2012 to August 30, 2012, during which it found that WACM, as a TOP, violated R1.3 of MOD-008-1 in that WACM's Transmission Reliability Margin Implementation Document (TRMID) failed to show the TRM calculation utilized for operations for the time periods ("'Same day and real-time';'Day-ahead and pre-schedule';'Beyond day-ahead and pre-schedule, up to thirteen months ahead'") as mandated by R1.3.1 through R1.3.3. Instead, WACM's TRMID showed one TRM calculation, which it used for all three time periods, but that did not refer to any specific time period. The duration of the violation was found to be between April 1, 2010, the date that the standard went into effect, and October 5, 2012, the date on which WACM remediated the issue.

Finding: WECC found that the issue posed a minimal risk to the reliability of the bulk power system because despite the failure to provide three specific calculations, WACM did report the TRM calculation used in the TRMID. Additionally, WACM abided by R1.1 in that it identified components of uncertainty used in figuring out the TRM; it abided by R1.2 in that it described the process through which it appropriated TRM across Available Transfer Capability Paths; it abided by R3 and R5 in that it made its TRMID available to essential parties; it abided by R5 in that it came up with TRM values conforming to the TRMID at least once every 13 months.