NERC Case Notes: Reliability Standard PER-004-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PER-004-1

NERC Case Notes: Reliability Standard PER-004-1

White & Case NERC Database

Electric Reliability Council of Texas, Inc., FERC Docket No. NP11-268-000 (September 30, 2011)

Reliability Standard: PER-004-1

Requirement: R1 and R3

Violation Risk Factor: High

Violation Severity Level: Severe (R1) and Lower (R3)

Region: Texas RE

Issue: On February 26, 2008, the Electric Reliability Council of Texas, Inc. (ERCOT) declared an Emergency Electric Curtailment Plan Step 2 (EECP2) event on its system due to an unexpected imbalance between generation and load, causing a reduction in system frequency to levels that were outside acceptance operational limits. The event lasted two hours, but did not reduce in involuntary customer load shedding. Through an audit, Texas RE determined that ERCOT did not adequately train its operating personnel concerning EECP procedures, and operators did not understand crucial differences between Energy Emergency Alerts and EECP, in violation of R1. In violation of R3, operational personnel did not have a comprehensive understanding of required interactions with Southwest Power Pool (SPP) regarding the event; the ERCOT operator did not identify the emergency level correctly when communicating to SPP, and voice logs demonstrated that the ERCOT operator did not understand the procedure for moving energy across the DC tie.

Finding: Texas RE determined that the violation posed a serious and substantial risk to the BPS because it put the Texas grid reliability at unnecessary and avoidable higher levels of risk than would otherwise have been the case, potentially leading to a wide spread and severe system disturbance. Duration of violation was February 26, 2008. Texas RE and the NERC BOTCC took into consideration that this was ERCOT's first violation of the Standard in reaching a penalty assessment, and also concluded that the serious and substantial risk to the BPS constituted an aggravating factor.

Penalty: $384,000 (aggregate for 15 violations)

FERC Order: Issued October 28, 2011 (no further review)

WECC RC [Rocky Mountain-Desert Southwest Reliability Coordinator] 2010

Reliability Standard: PER-004-1

Requirement: R1, R3, R4

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: NERC as Compliance Enforcement Authority (NCEA)

Issue: During the period from June 18, 2007 through January 1, 2009, the Rocky Mountain-Desert Southwest Reliability Coordinator (RDRC) did not have a documented training program in order to be staffed with adequately trained and NERC-certified Reliability Coordinator operators, as required by R1 of the Reliability Standard, nor did RDRC have a comprehensive understanding of the Reliability Coordinator Area and interactions with neighboring Reliability Coordinator Areas as required by R3. It was further discovered that RDRC did not have an extensive understanding of the Balancing Authorities, Transmission Operators, and Generation Operators within the Reliability Coordinator Area, including the operating staff, operating practices and procedures, restoration priorities and objectives, outage plans, equipment capabilities, and operational restrictions in violation of R4 of the Reliability Standard.

Finding: The violations were the first violations of this Reliability Standard and they did not constitute a serious or substantial risk to the bulk power system. WECC was certified as the Reliability Coordinator on January 1, 2009 and assumed all further responsibilities. The violation was mitigated through the dissolution of the entity and NERC's certification of WECC as the new Reliability Coordinator for the region.

Penalty: $0

FERC Order: Issued October 13, 2010 (no further review)