NERC Case Notes: Reliability Standard PER-002-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PER-002-2

NERC Case Notes: Reliability Standard PER-002-2

White & Case NERC Database

Sacramento Municipal Utility District, FERC Docket No. NP12-8 (December 30, 2011)

Reliability Standard: PER-002-2

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Lower

Region: NCEA

Issue: During a compliance investigation regarding a December 26, 2008 incident where Sacramento Municipal Utility District (SMUD) lost substation DC control voltage supply at its Orangevale (ORV) substation, NCEA determined that the SMUD Power System Operator (PSO), functioning as a TOP, had inadequate knowledge and understanding of SMUD’s standard circuit breaker supervisory control switching and indicator scheme on its Energy Management System (EMS) SCADA control scheme. The SCADA control schemes are material to the control and operation of BPS equipment and facilities.

Finding: NCEA found that the PER-002-2 violation constituted only a minimal risk to BPS reliability since SMUD’s substations and transmission lines (consisting of 230 kV or lower voltage) represent only a small portion of the Western Interconnection in the vicinity of SMUD’s BPS facilities (and any impact would likely be limited to the local vicinity of SMUD’s own system facilities and would not spread throughout the Western Interconnection). The duration of the PER-002-2 violation was from June 18, 2007 through March 25, 2009. SMUD has also invested over $1.17 million to install redundant measures in its backup systems in a number of its substations. In determining the aggregate penalty amount, NERC BOTCC considered the fact that these violations were SMUD’s first violations of the relevant Reliability Standards; one of the violations was self-reported; SMUD was cooperative during the enforcement process and did not conceal the violations; SMUD had a compliance program in place (which was evaluated as a mitigating factor); the violations did not pose a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.

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

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