NERC Case Notes: Reliability Standard TOP-001-1a | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard TOP-001-1a

NERC Case Notes: Reliability Standard TOP-001-1a

White & Case NERC Database

PacifiCorp, FERC Docket No. NP15-4-000 (October 30, 2014)

Reliability Standard: TOP-001-1a

Requirement: R3

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: PacifiCorp (PAC) self-reported that it did not follow a June 11, 2013 directive issued by its RC to trip 185 MW of generation in order to alleviate a Standard Operating Limit (SOL) exceedance on a major WECC path. Instead, a PAC operator concluded that tripping might lead to equipment damage and directed its generation dispatchers to curtail load to zero to alleviate the SOL exceedance, but did not immediately inform the RC of this decision.

Finding: WECC determined that the violation constituted a moderate risk to the BPS as it increased the risk of damaging BPS equipment, disrupting BPS operations or restoring BPS operations to normal conditions in the case of an emergency. However, PAC did take alternative actions to reduce overloading on the system and the SOL exceedance was alleviated after only thirteen minutes. The TOP-001-1a violation occurred on June 11, 2013. PAC agreed and stipulated to the facts of the violations. In approving the settlement agreement, the NERC BOTCC found that neither of the violations posed a serious or substantial threat to the BPS reliability. Both violations involved load shedding directives. In addition, PAC’s COM-002-2 violation represented its second violation of that Reliability Standard, which was considered an aggravating factor. But, PAC self-reported the TOP-001-1a violation, had a compliance program in place, was cooperative throughout the enforcement process, and did not conceal the violations.

Penalty: $60,000 (aggregate for 2 violations)

FERC Order: Issued November 28, 2014 (no further review)