NERC Case Notes: Reliability Standard MOD-012-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard MOD-012-0

NERC Case Notes: Reliability Standard MOD-012-0

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This page contains the NOP (Notice of Penalty) and ACP (Administrative Citation of Penalty) summaries. Click here to read the FFT (Find, Fix and Track) summaries.

Idaho Power Company, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: MOD-012-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In January 2008, Idaho Power Company (IPC) self-reported that after it installed and placed-in service a Power System Stabilizer (PSS) on the Twin Falls 46.8 MVA generating Unit #2, it found that, after the PSS was commissioned, the generator dynamic model report had not been updated and submitted to WECC as required.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system as the current dynamic models for the generator, excitation system, governor, and over-excitation limiter had been retested and certified in April 2006 and found to be correct. Other than the addition of the PSS to generator dynamic model report, everything else related to the unit construction or the unit control system was the same since the last time the unit was tested. The violation was self-reported and this was IPC’s first violation of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Madera Power, LLC (MADP), Docket No. NP12-47-000 (September 28, 2012)

Reliability Standard: MOD-012-0

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: High

Region: WECC

Issue: MADP self-reported that while conducting an internal compliance audit in September 2011 it found that, as a GO, it was in violation of MOD-012-0 R2 for its failure to provide updated dynamics system modeling and simulation to WECC and its TOP after replacing certain equipment.

Finding: The violation was deemed to pose minimal risk to BPS reliability because even though MADP did not provide updated equipment specifications to WECC and its TOP, the TOP did have modeling data for the facility. In addition, MADP is a small power production facility with limited impact on overall BPS operations. In determining the appropriate penalty, WECC considered MADP's internal compliance program as a mitigating factor. MADP agreed/stipulated to WECC's findings.

Penalty: $4,000 (aggregate for two penalties)

FERC Order: Issued October 26, 2012 (no further review)

Northern California Power Agency (NCPA), FERC Docket No. NP12-10 (December 30, 2011)

Reliability Standard: MOD-012-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: NCPA was conducting an internal review of its compliance with Reliability Standards and found it had violations of MOD-012-0 R1 and R2. NCPA, as a GO, discovered it had not given dynamic system modeling and simulation data to its RC, Pacific Gas and Electric (PG&E), because no procedure or process to ensure compliance was in place (R1). Regarding R2, the internal review disclosed that NCPA had not given full equipment characteristics and system data and review of data to PG&E for use in the WECC system-wide model. Therefore, NCPA self-reported non-compliance with MOD-012-0.

Finding: The violation constituted a minimal risk to BPS reliability because, although the equipment characteristics and data was not processed as required prior to sending it to the RC, NCPA’s system characteristics had no changes nor were there changes to the load data that would have caused the need to change NCPA’s network model. Not coordinating the reporting and data procedures with the RC had no affect on the reliability of the data submitted. The duration of the violation was June 18, 2007 through November 23, 2011. In determining the appropriate penalty, WECC considered NCPA’s compliance program, the fact that NCPA voluntarily took steps to ensure future compliance, and there was no evidence NCPA attempted to hide the violations. In addition, no aggravating factors were present.

Penalty: $1,000 (aggregate for four violations)

FERC Order: Issued January 27, 2012 (no further review)

Utah Associated Municipal Power Systems, FERC Docket No. NP10-36-000 (February 1, 2010)

Reliability Standard: MOD-012-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: Utah Associated Municipal Power Systems (UAMP) could not confirm that all of its members with behind-the-meter facilities were reporting their dynamics system data required by the standard. Consequently, UAMP and its Balancing Authority (PacifiCorp) could not confirm that the small generation facilities located behind-the-meter on the 10 MW or above netting criteria level were being modeled in the WECC modeling database.

Finding: Duration of the violations was from June 18, 2007, when the standard became enforceable, through December 29, 2008, when UAMP completed a mitigation plan. In reaching this determination, WECC considered the following mitigating factors: (1) there was a minimal risk to the reliability of the bulk power system because the generating facilities missing the required data were small in individual and total group capacity. UAMP failed to provide less than or equal to 25% of the appropriate equipment characteristics, system data, and existing and future Interchange Schedules in compliance with its respective Interconnection Regional steady-state modeling and simulation data requirements and reporting procedures as defined in the standard; (2) the violations constituted UAMP’s first occurrence of non-compliance with the applicable standard; (3) UAMP was cooperative throughout the enforcement process; and (4) there was no evidence that UAMP’s violations were intentional.

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

FERC Order: Issued March 3, 2010 (no further review)