NERC Case Notes: Reliability Standard MOD-030-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard MOD-030-2

NERC Case Notes: Reliability Standard MOD-030-2

White & Case NERC Database

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.

Alcoa Power Generating, Inc. - Tapoco Division (APGI-Tapoco), Docket No. NP13-8-000, November 30, 2012

Reliability Standard: MOD-030-2

Requirement: R3; R3.2

Violation Risk Factor: (pending)

Violation Severity Level: Severe

Region: SERC

Issue: APGI-Tapoco, as a TOP, self-reported a violation of R3.2 when it failed to update daily values in its Transmission model on one day in 2011 due to an issue with the software password. The Transmission model to calculate Available Flowgate Capability (AFC) available to APGI-Tapoco's Transmission Service Provider (TSP) was therefore not updated at least once per day for days two through 30.

Finding: SERC determined that the R3 violation posed a minimal risk to the reliability of the BPS because in the event of missing values in the TOP's model, the TSP conducts AFC calculations with the previous day's values. With only minimal typical daily fluctuations in AFC, failing to update the values for one day would have a negligible impact on system reliability. SERC and APGI-Tapoco entered into a settlement agreement to resolve multiple violations, whereby APGI-Tapoco agreed to pay a penalty and to undertake other mitigation measures to come into compliance with R3. SERC considered Alcoa Inc's FERC Compliance Policy and Plan (which governs APGI-Tapoco) a mitigating factor in making its penalty determination. The duration of the violation was from July 21, 2011 and lasted one day. APGI-Tapoco neither admits nor denies the R3 violation.

Penalty: $11,000 (aggregate for 12 violations)

FERC Order: Issued December 28, 2012 (no further review)

Alcoa Power Generating, Inc. - Tapoco Division (APGI-Tapoco), Docket No. NP13-8-000, November 30, 2012

Reliability Standard: MOD-030-2

Requirement: R10

Violation Risk Factor: (pending)

Violation Severity Level: Severe

Region: SERC

Issue: APGI-Tapoco, as a TSP, self-reported a violation of R10 when it did not recalculate the hourly, daily and monthly Available Flowgate Capacity (AFC) values on one day in 2011 due to an issue with the software password on the TOP's system that uploaded the data to the TSP. Although the TSP's AFC calculation engine uses historical data in the event that new data from the TOP is not uploaded, APGI-Tapoco had not enabled the archiving function at the time of the violation was therefore unable to prove that daily AFC calculations had been performed between the date of its registration as a TSP until the date the archiving function as enabled.

Finding: SERC determined that the R10 violation posed a minimal risk to the reliability of the BPS because the entity that had been performing AFC calculations prior to the date of APGI-Tapoco's registration as a TSP continued to calculate AFC during the violation period. This same third party bought all of the power scheduled out of APGI-Tapoco during the violation period and such a sale would only have been possible if the AFC calculation demonstrated sufficient flow capacity. SERC and APGI-Tapoco entered into a settlement agreement to resolve multiple violations, whereby APGI-Tapoco agreed to pay a penalty and to undertake other mitigation measures to come into compliance with R10. SERC considered Alcoa Inc's FERC Compliance Policy and Plan (which governs APGI-Tapoco) a mitigating factor in making its penalty determination. The duration of the violation was from July 1,2011through August 9, 2011. APGI-Tapoco neither admits nor denies the R10 violation.

Penalty: $11,000 (aggregate for 12 violations)

FERC Order: Issued December 28, 2012 (no further review)

Alcoa Power Generating, Inc. - Yadkin Division (APGI-Yadkin), Docket No. NP13-8-000, November 30, 2012

Reliability Standard: MOD-030-2

Requirement: R3; R3.2

Violation Risk Factor: (pending)

Violation Severity Level: Severe

Region: SERC

Issue: APGI-Yadkin, as a TOP, self-reported a violation of R3 when its software program failed to upload updated system models on five days. The company self-reported an additional violation when its daily values were not updated on another occasion due to an issue with the software password. The Transmission model to calculate Available Flowgate Capability (AFC) available to APGI-Yadkin's Transmission Service Provider (TSP) was therefore not updated at least once per day for AFC calculations for intra-day, next day, and days 2 through 30.

Finding: SERC determined that the R3 violation posed a minimal risk to the reliability of the BPS because in the event of missing values in the TOP's model, the TSP conducts AFC calculations with the historical values. With only minimal typical daily fluctuations in AFC, failing to update the values for one day would have a negligible impact on system reliability. SERC and APGI- Yadkin entered into a settlement agreement to resolve multiple violations, whereby APGI-Yadkin agreed to pay a penalty and to undertake other mitigation measures to come into compliance with R3. SERC considered Alcoa Inc's FERC Compliance Policy and Plan (which governs APGI-Yadkin) a mitigating factor in making its penalty determination. The duration of the violation was from April 28, 2011through July 21, 2011. APGI-Yadkin neither admits nor denies the R3 violation.

Penalty: $13,000 (aggregate for 12 violations)

FERC Order: Issued December 28, 2012 (no further review)