NERC FFT Reports: Reliability Standard TOP-002-2 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard TOP-002-2

NERC FFT Reports: Reliability Standard TOP-002-2

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This page contains the FFT (Find, Fix and Track) summaries. Click here to read the NOP (Notice of Penalty)/ACP (Administrative Citation of Penalty) summaries.

Independence Power & Light (Independence, Missouri) (INDN), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: TOP-002-2

Requirement: 11

Region: SPP RE

Issue: While conducting a Compliance Audit in March 2010, SPP audit staff found that INDN, a TOP, had not conducted its own current-day or next-day studies in calculating its System Operating Limits (SOLs) but instead used data compiled by the Reliability Coordinator (RC) for the Bulk Electric System generally. That data was available through the RC’s website, but INDN had no documented agreement with the RC to always make such data accessible. Also, INDN could not show that it had used the SPP RC system studies, but summer peak studies had been conducted pursuant to the Reliability Standard.

Finding: The issue was deemed by SPP RE to pose minimal risk to BPS reliability because INDN provided checklists from June 2007 onward that showed for each shift the system operator was required to review the SPP RC system studies and calculate the SOLs based on that data. The checklists included hyperlinks to the relevant SPP RC data. In addition, SPP RE considered that INDN is only a 315 MW facility which lessened any risk to overall BPS reliability.

Mesquite Wind, LLC (Mesquite), FERC Docket No. RC13-5-000 (January 31, 2013)

Reliability Standard: TOP-002-2

Requirement: 13

Region: TRE

Issue: Mesquite, as a GOP, self-reported a violation of R13 of TOP-002-2 to TRE on February 15, 2012, in that it failed to carry out reactive capability verification and report the results to the Balancing Authority (BA) or TOP. The August 18, 2009 Electric Reliability Council of Texas' (ERCOT) protocols mandate that the Generation Resource Entity perform such verification and report the results to ERCOT at the time of initial qualification and once every two years. While Mesquite did so upon initial qualification on November 29, 2007, it failed to do so until June 30, 2010. The duration of the violation was thus determined to be November 27, 2009 to June 30, 2010.

Finding: TRE found that the issue posed a minimal risk to the reliability of the bulk power system because the June 30, 2010 results reported to ERCOT were the same as those from November 29, 2009. Thus, there would be no impact on the BA's reactive capabilities management since the BA already knew about the reactive capabilities of the generation resource.

Mid Georgia Cogen L.P. (MidGa), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: TOP-002-2

Requirement: R18

Region: SERC

Issue: The SERC audit team found that MidGa, as a GOP, could not show that transmission line and equipment identifiers were consistent with the identifiers used by the interconnecting TOP, Georgia Power Company (GPC). In particular, GPC installed a substation to replace a simple tap point and updated the one-line diagram to reflect the change, however, MidGa did not update its one-line diagram which continued to show the old tie-point. Also, the one-line diagram did not show the switch numbers or breaker number as those used on the GPC one-line diagram.

Finding: The issue was found to pose minimal risk to BPS reliability because, first, MidGa did know the switches’ GPC numbers, but it did not know they were required to be included on MidGa’s one-line diagram. Second, GPC is responsible for the management of the transmission line and substation where the facilities interconnect. Third, outages are coordinated between the two companies, and fourth, MidGa had correctly performed clearances even though the one-line diagram used incorrect naming and numbering. Finally, any misoperation of a switch would affect only MidGa’s facility as it is radially connected to the BPS by way of GPC.

Midwest Energy Inc. (Midwest), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: TOP-002-2 (see Supplemental Filing)

Requirement: R11

Region: SPP

Issue: Midwest, in its roles as LSE and TOP, submitted a self-certification of non-compliance with TOP-002-2 R11 due to the fact that it had been relying on seasonal, next-day, and current-day studies performed by the Southwest Power Pool Reliability Coordinator (SPP RC) to determine its System Operating Limits (SOLs), without undertaking its own review of the studies. SPP stated that if the SPP RC was to perform the studies on behalf of Midwest, Midwest should secure an agreement with SPP stating so.

Finding: The issue was found to pose minimal risk to BPS reliability because other measures were in place during the violation period including evidence that Midwest was coordinating outages with both the SPP RC and adjacent TOPs. Also, in the event of an SOL problem, SPP RC would contact Midwest to come up with mitigation measures and to begin Transmission Loading Relief (TLR) procedures, if required. SPP found the size of the Midwest facility taken together with the fact that Midwest had coordinated outages with the appropriate parties lessened any risk to BPS operations due to Midwest’s failure to conduct its own studies.

Post Oak Wind, LLC (POW), FERC Docket No. RC13-5-000 (January 31, 2013)

Reliability Standard: TOP-002-2

Requirement: 13

Region: TRE

Issue: TRE conducted a compliance audit from June 7, 2011 through June 9, 2011, during which it found that POW failed to carryout reactive capability verification and report the results to the BA or the TOP. The August 18, 2009 Electric Reliability Council of Texas' (ERCOT) protocols mandate that the Generation Resource Entity perform such verification and report the results to ERCOT at the time of initial qualification and once every two years. While POW did so upon initial qualification on August 20, 2007, it failed to do so until June 30, 2010, making the duration of the violation from August 20, 2009 to June 30, 2010.

Finding: TRE found that the issue posed a minimal risk to the reliability of the bulk power system because the June 30, 2010 results reported were the same as those on August 20, 2007. Thus, there would be no impact on the BA's reactive capabilities management since the BA already knew about the reactive capabilities of the generation resource.

Sweetwater Wind 5 LLC (Sweetwater 5), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: TOP-002-2

Requirement: 13

Region: Texas RE

Issue: During an audit, Texas RE found that Sweetwater 5, as a GOP and wind generator in the ERCOT service region, did not perform reactive capability testing (per ERCOT Nodal Operating Guide 3.3.2.2); Texas RE determined that Sweetwater 5 had a remediated issue of R13. Sweetwater 5 failed to comply with the Standard until June 22, when ERCOT indicated Sweetwater 5 had "demonstrated" prospective reactive capability.

Finding: Texas RE found the issue posed a minimal risk to the reliability of the BPS because wind reactive capability testing had previously been the subject of a joint settlement between ERCOT and Sweetwater 5; Sweetwater 5 had conducted reactive capability testing in January of 2007 and annually thereafter, which ERCOT was informed of. Furthermore, the performance characteristics of the facility have not changed materially.

Western Farmers Electric Cooperative (WFEC), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: TOP-002-2 (see Supplemental Filing)

Requirement: R11

Region: SPP

Issue: WFEC, in its role as a TOP, submitted a self-report discussing an issue with TOP-002-1 R11 due to the fact that it had been relying on next-day and current-day Bulk Electric System (BES) studies performed by the Southwest Power Pool Reliability Coordinator (SPP RC) to determine its System Operating Limits (SOLs). SPP RC informed WFEC that its SOL studies were being undertaken based on SPP RC’s role as an RC. SPP stated that no agreement was in place stating that SPP RC would perform the studies on behalf of WFEC, and therefore, WFEC could not show that it would continue to receive data needed to perform correct next-day and current day BES analyses for determining SOLs. Subsequently, WFEC and SPP entered an agreement to provide next-day and current day studies so that WFEC could identify SOLs, and WFEC also began to undertake its own weekly studies.

Finding: The issue was found to pose minimal risk to BPS reliability because even though WFEC had no formal agreement with SPP that it would provide the relevant studies, WFEC system operators had been adequately identifying SOLs by using the SPP RC information. Also, WFEC’s EMS is set to raise an alarm in the event of an SOL violation, which lessened any BPS impact. WFEC staff also performs certain in-house studies that provided similar information as that provided by SPP RC.