NERC Case Notes: Reliability Standard PRC-007-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-007-0

NERC Case Notes: Reliability Standard PRC-007-0

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City of Healdsburg, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-007-0

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Not provided

Region: WECC

Issue: The City of Healdsburg self-reported in August 2007 that it had not provided its annual underfrequency data as required.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the City of Healdsburg did have an underfrequency load shedding (UFLS) program in place. The City of Healdsburg self-reported the violation; this was the City of Healdsburg’s first violation of this Reliability Standard; and a mitigation plan was completed.

Penalty: $0

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

City of Healdsburg, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-007-0

Requirement: R3

Violation Risk Factor: Lower

Violation Severity Level: Not provided 

Region: WECC

Issue: The City of Healdsburg self-reported in August 2007 that it had not provided sufficient documentation to its Regional Entity for its under frequency load shedding (UFLS) program as required.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the City of Healdsburg did have an UFLS program in place. The City of Healdsburg self-reported the violation; this was the City of Healdsburg’s first violation of this Reliability Standard; and a mitigation plan was completed.

Penalty: $0

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

 

City of Santa Clara d/b/a Silicon Valley Power, FERC Docket No. NP11-130-000 (February 28, 2011)

Reliability Standard: PRC-007-0

Requirement: R2, R3

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: WECC

Issue: During an off-site compliance audit, Silicon Valley Power (SVP) failed to provide evidence of annual updates to its underfrequency data for WECC’s underfrequency load shedding program database as required by R2, and it failed to document its underfrequency load shedding program within 30 days of WECC’s request as required by R3. Duration of violation was June 18, 2007, when the Standard became enforceable, through September 15, 2008, when the violations were mitigated.

Finding: WECC Enforcement determined that the violations did not pose a serious or substantial risk to the bulk power system because SVP had an underfrequency load shedding program, though it was not compliant with requirements, and in the event of an underfrequency event, the California ISO would provide greater flexibility as it coordinates large utilities with sufficient generation to mitigate such an event. Further, the NERC BOTCC concluded the penalty appropriate because this was SVP’s first violation of the Standard, about half of the aggregate violations found were documentation issues, and SVP was cooperative during the investigation.

Penalty: $94,000 (aggregate for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

City of Ukiah, FERC Docket No. NP10-160-000 (September 13, 2010)

Reliability Standard: PRC-007-0

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Not provided

Region: WECC

Issue: In November 2007, the City of Ukiah (CYUK) self-reported that it had not annually updated its Underfrequency Load Shedding (UFLS) data and did not have a procedure in place to report and update information in a UFLS program database. And since CYUK did not have a documented operations setting related to the UFLS system, it was unable to ensure that its UFLS system satisfied the WECC criteria.

Finding: WECC found that this violation did not constitute a serious or substantial risk to the bulk power system since CYUK was only connected to the bulk power system by a single 115 kV single circuit transmission line which served CYUK’s system. CYUK is a small load (only 34 MW) within a larger entity’s footprint and any inconsistencies within CYUK’s UFLS program would have a small effect in CYUK’s area (especially as the larger entity later removed CYUK from the area’s UFLS program). The duration of the violation was from August 10, 2007 through June 10, 2008. Furthermore, the violation was self-reported and it was CYUK’s first violation of this Reliability Standard. Even though CYUK completed its mitigation plan late, WECC decided not to impose a penalty.

Penalty: $0

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

Jersey Central Power & Light Company, FERC Docket No. NP12-6 (December 30, 2011)

Reliability Standard: PRC-007-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Moderate

Region: RFC

Issue: In December 2010, Jersey Central Power & Light Company (Jersey Central), a DP and TO, self-reported that it had incorrectly included nine UFLS relays in its UFLS program and that without those nine relays it would not have been able to satisfy the load shed levels for two frequency set points mandated by RFC. Those two frequency set points are the ability to shed 10.0% of estimated peak system load at 59.3 Hz and 10.0% of estimated peak system load at 58.5 Hz, with Jersey Central only able to shed 9.1% at 59.3 Hz and 9.8% at 58.5 Hz. Therefore, Jersey Central’s UFLS program was not consistent with RFC’s UFLS mandates.

Finding: RFC found that the violation constituted a moderate risk to BPS reliability as Jersey Central’s failure to shed the required amount of peak load at the 59.3 Hz step increased the chance that the frequency would have had to dip even lower and reduced the chance of arresting frequency decline. Jersey Central also did not have any automatic alarms on the UFLS relays (even though the TOP was monitoring the system and would be able to respond). The violation only involved 26 MW of load that Jersey Central was supposed to be able to shed (representing only 1.3% of Jersey Central’s load shed requirement), which is within the estimation-error rate for an electric utility’s load forecasts. Furthermore, Jersey Central’s load shed capabilities at the 58.9 Hz step exceed the 10.0% requirement, meaning that Jersey Central is capable of shedding an additional 50 MW of load. The duration of the violation was from June 18, 2007 through December 7, 2010. In determining the aggregate penalty amount, NERC BOTCC considered the fact that this was Jersey Central’s first violation of the relevant Reliability Standard; the violation was self-reported; Jersey Central was cooperative during the enforcement process and did not conceal the violation; Jersey Central had a compliance program in place (which was evaluated as a mitigating factor); the violation did not pose a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.

Penalty: $37,000

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

National Nuclear Security Administration-Los Alamos National Laboratory, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-007-0

Requirement: R2, R3

Violation Risk Factor: Lower (for R2, R3)

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007, the National Nuclear Security Administration-Los Alamos National Laboratory (NNSAL) self-reported that it was unable to demonstrate that it was annually updating its underfrequency data and that it had not documented its Underfrequency Load Shedding (UFLS) program.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since NNSAL was able to provide the relevant data on request and did actually have a UFLS program in place. The violations were self-reported and they were NNSAL's first violations of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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

Port of Oakland, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-007-0

Requirement: R2, R3

Violation Risk Factor: Lower (for R2, R3)

Violation Severity Level: Not provided

Region: WECC

Issue: In December 2007, the Port of Oakland self-reported that it had not documented its Underfrequency Load Shedding (UFLS) program and was not providing its underfrequency data as required. Therefore, the Port of Oakland was also unable to provide documentation of its UFLS program to its Regional Entity.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since the Port of Oakland did actually have a UFLS program. The violations were self-reported and they were the Port of Oakland's first violations of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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

Public Utility District No. 1 of Benton County, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-007-0

Requirement: R2, R3

Violation Risk Factor: Lower (for R2, R3)

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007, Public Utility District No. 1 of Benton County (Benton) self-reported that it was not providing its underfrequency data annually and had not provided annual documentation of its UFLS program to its Regional Entity.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since Benton did actually have a UFLS program. The violations were self-reported and they were Benton's first violations of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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

 

Public Utility District No. 1 of Snohomish County, FERC Docket No. NP11-135-000 (March 30, 2011)

Reliability Standard: PRC-007-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: High

Region: WECC

Issue: Public Utility District No. 1 of Snohomish County (SNPD), a Distribution Provider and Transmission Owner, did not include sufficient blocks of load in its Under Frequency Load Shedding (UFLS) program because SNPD misinterpreted the quantities required by the WECC UFLS plan to be included in each frequency block and in the total program. Also, SNPD’s UFLS program was inconsistent with the WECC Off-Nominal Frequency Load Shedding and Restoration Plan and that the amount of load to be dropped within a maximum delay of 14 cycles was deficient by three percent.

Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a settlement agreement which included a penalty of $26,000 for this and other violations. In reaching this determination, the NERC BOTCC considered the following facts: the violation constituted SNPD’s first violation of the subject NERC Reliability Standard; SNPD self-reported the violation; SNPD cooperated during the compliance enforcement process; SNPD did not attempt to conceal a violation or intend to do so; the violation did not create a serious or substantial risk to the bulk power system; and there were no other mitigating or aggravating factors or extenuating circumstances.

Penalty: $26,000 (aggregate for 8 violations)

FERC Order: Issued April 29, 2011 (no further review)

West Penn Power Company, Monongahela Power, and The Potomac Edison Company, FERC Docket No. NP12-7 (December 30, 2011)

Reliability Standard: PRC-007-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Moderate

Region: RFC

Issue: In November 2010, West Penn Power Company, Monongahela Power, and the Potomac Edison Company (WP/MP/PE), a DP and TO, self-reported that as two of its UFLS relays were set below one of the frequency trip points required by RFC (59.5 Hz), it would only be able to shed 4.7% of the peak system load at that step (instead of the 5.0% required). In addition, in early 2011, WP/MP/PE found that its UFLS program improperly included one of its UFLS relays that was removed from service in 2005 and one UFLS relay that would have failed to trip a particular transformer breaker, leading to WP/MP/PE only being able to shed 4.6% of the peak system loads at the 58.9 Hz step (29 MW below the required amount). Therefore, WP/MP/PE’s UFLS program was not consistent with RFC’s UFLS program requirements as required.

Finding: RFC found that the PRC-007-0 violation constituted a moderate risk to BPS reliability as WP/MP/PE’s failure to shed the required amount of peak load at 59.95 Hz increased the chance that the frequency would have had to dip even lower (which would require other entities to shed more load). But, WP/MP/PE did have excess load shed amounts available in other frequency steps of the UFLS program (with WP/MP/PE’s total UFLS capability equaling 105.6% of the total load shed requirement), which mitigated this risk. In addition, no UFLS events occurred during the violation. The duration of the PRC-007-0 violation was from June 18, 2007 through April 29, 2011. In determining the aggregate penalty amount, NERC BOTCC considered the fact that the violations were self-reported; WP/MP/PE was cooperative during the enforcement process and did not conceal the violations; WP/MP/PE 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: $40,000 (aggregate for 2 violations)

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