NERC Case Notes: Reliability Standard TOP-006-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard TOP-006-1

NERC Case Notes: Reliability Standard TOP-006-1

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

Arlington Valley, LLC - AVBA, FERC Docket No. NP13-9 (December 31, 2012)

Reliability Standard: TOP-006-1

Requirement: 3

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: AVBA self-certified, as a TOP, that it had not provided its operating personnel with the required technical information on its protective relays.

Finding: WECC found that the TOP-006-1 violation constituted a moderate/high risk to BPS reliability. Inadequate technical information and understanding by AVBA's technical personnel could potentially have a negative impact on AVBA's transmission and generation facilities. The duration of the TOP-006-1 violation was from November 5, 2007 through August 15, 2009. AVBA stipulated to the violations. In approving the settlement agreement, the NERC BOTCC considered the fact that these violations were AVBA's first violations of the relevant Reliability Standards; the violations were not intentional and were promptly mitigated once discovered; and AVBA was cooperative during the enforcement process and did not conceal the violations. In addition, all but one of AVBA's violations did not constitute a serious or substantial risk to BPS reliability.

Penalty: $60,000 (aggregate for 43 violations)

FERC Order: Issued January 30, 2013 (no further review)

EDF Trading North America, LLC, FERC Docket No. NP12-12 (January 31, 2012)

Reliability Standard: TOP-006-1

Requirement: R1/1.1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: TRE

Issue: On February 2, 2011, the Bayou Cogeneration Combustion Turbine No. 2 tripped and was offline for approximately 26 minutes. During the time period, EDF Trading, a GOP, did not show the unit status as “OFF” by way of the telemetering signal to ERCOT, EDF Trading’s Host BA and TOP. Failure to do so left ERCOT unaware of all generation resources available for use.

Finding: The violation posed only a moderate risk to BPS reliability because the offline unit, with a 75 MW nameplate rating, was unavailable for the 26 minutes whether or not ERCOT was aware and whether or not the Standard was violated, and not changing the status to “OFF” basically led to a failure in communication. Even though the unit was offline during a period of system stress, ERCOT had sufficient resources to draw from and the resource was unavailable regardless of what was happening to the system so knowing the unit’s status made no difference in terms of the system emergency. EDF Trading’s internal compliance program was considered a mitigating factor in determining the appropriate penalty.

Penalty: $21,000 (aggregate for two violations)

FERC Order: Order issued March 1, 2012 (no further review)

NAES Corporation-Tracy, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: TOP-006-1

Requirement: R1/1.1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: NAES Corporation-Tracy (NAES-Tracy) self-reported that it did not possess a documented procedure that would properly inform applicable entities of its available generation resources.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since NAES-Tracy knew the status of its generation resources and was able to provide the relevant information on request. The violation was primarily a documentation issue. Also, the violation was self-reported and was NAES-Tracy's first violation of this Reliability Standard. Even though the violation occurred before the Reliability Standards became mandatory, NAES-Tracy did not complete its mitigation plan in a timely manner, turning the violation into a post-June 18, 2007 violation. Even with the late completion of the mitigation plan, no penalty was imposed.

Penalty: $0

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

Platte River Power Authority, FERC Docket No. NP10-110-000 (June 2, 2010)

Reliability Standard: TOP-006-1

Requirement: R6

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: WECC

Issue: In January 2009, Platte River Power Authority (PRPA) self-reported that because of an out of range alarm set point, which was established below the Emergency Supervisory Control and Data Acquisition (SCADA) alarm point for some facilities, its scaling ranges might not have met the requirements of TOP-006-1 to promote accurate and timely monitoring of operating conditions on its transmission system. PRPA concluded that it had to adjust the scaling ranges at its Remote Terminal Unit and that it should have performed functional tests, from the meter through the SCADA, in order to verify the proper range.

Finding: WECC and PRPA entered into a settlement agreement to resolve the violation, whereby PRPA agreed to undertake mitigation measures and no penalty was imposed. WECC found that the violation did not create a serious or substantial risk to bulk power system reliability since the programming limits PRPA had in place were actually more restrictive than the ones established for the Emergency SCADA alarms. As some of the metering points used scaling results which were lower than the limits established by the Emergency SCADA alarm, the out of range alarm would be activated before the Emergency SCADA alarms would. PRPA self-reported the violation since it was concerned that it was not "accurately" monitoring the operating conditions. In addition, PRPA had access to multiple sources of information to monitor its transmission system and was able to notify operators of potential situations. In deciding not to impose a penalty, WECC considered that this was PRPA's first violation of this Reliability Standard; the violation was self-reported; PRPA was cooperative throughout the enforcement process and did not conceal the violation; and PRPA was found to have a effective compliance program. A mitigation plan has been completed.

Penalty: $0

FERC Order: Issued July 2, 2010 (no further review)

Public Utility District No. 1 of Clark County, FERC Docket No. NP12-5 (November 30, 2011)

Reliability Standard: TOP-006-1

Requirement: R7

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: In preparation for its registration with NERC as a TOP, in April 2009 CKPD self-reported non-compliance with TOP-006-1 R7. CKPD explained that its TOP, Bonneville Power Administration (BPA), informed it on April 6, 2009, that it would no longer function as CKPD’s TOP effective immediately. As a result, CKPD was required to register as a TOP and report non-compliance with the Standard. CKPD reported that the requirements of TOP-006-1 were new to CKPD because of its TOP registration, and at the time of registration, CKPD was not monitoring system frequency, as required by the Standard.

Finding: WECC determined the violation did not pose a serious or substantial risk to the reliability of the BPS because of the size of the facility and because it is not a BA nor does it have interchange schedules so not monitoring its system frequency would not have a significant impact on CKPD’s operations or the interconnected system. WECC recognized that at the time of its registration for the TOP function, CKPD was satisfying the requirements for its other functions as a TO, PSE, LSE, DP, GO and GOP. BPA performed tests on CKPD’s electric system during April 2009 which showed that it was not conducting TOP duties at the facility and the facility was not required to maintain system reliability. BPA also reported that CPKD employs experienced operators and also has internal maintenance procedures including a 24-hour dispatch center. WECC assessed no penalty for the violation based on the extenuating circumstances surrounding the non-compliance. In particular, BPA’s notice to CKPD that it would no longer operate as the TOP was unexpected and effective immediately. Consequently, CKPD was immediately responsible for registration and compliance with all applicable TOP standards. WECC also considered the following mitigating factors: the violations were self-reported, mitigation plans were quickly submitted and timely completed; the risk to the BPS was not serious or substantial; the violations were not repeat violations; and CKPD did not dispute the violations.

Penalty: $0 (for 33 violations)

FERC Order: Issued December 30, 2011 (no further review)

Public Utility District No. 1 of Snohomish County (SNPD), Docket No. NP12-22-000 (March 30, 2012)

Reliability Standard: TOP-006-1

Requirement: R3

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: SNPD registered as a TOP with NERC effective as of February 6, 2009, subsequently, SNPD submitted self-reports addressing non-compliance with NERC Reliability Standards. SNPD is located in the Bonneville Power Administration (BPA) Control Area. BPA was registered with NERC as the area TOP, and BPA had informed SNPD that it was not required to register as a TOP with NERC; however, after review of a FERC order discussing TOP compliance, on December 24, 2008, BPA notified SNPD that it would no longer serve as its TOP, effective immediately. SNPD then registered as a TOP and reported itself as non-compliant with applicable NERC Reliability Standards. SNPD underwent a WECC audit in January 2012 and no compliance violations were found.

Starting on February 6, 2009, the date SNPD registered as a TOP with NERC, SNPD was in violation of TOP-006-1 R3 because it had not documented the procedures for providing technical information concerning protective relay information to its operating personnel.

Finding: The violation posed no serious or substantial risk to BPS reliability. WECC considered that SNPD was new to the TOP role because of a registration issue. Although SNPD was not compliant with the Reliability Standard, risk was mitigated because SPND does provide the protective relay information to its operating personnel during the period it was formalizing policies and procedures. In addition, BPA conducted a technical assessment of SPND’s electrical system in determining whether it would act as SPND’s TOP, and the assessment results showed that BPA was not performing TOP duties in the first place, and second it did not need control of the SNPD system for BPS reliability. While SNPD was working towards TOP certification, BPA performed TOP duties such as coordinating outage plans, day-to-day routine real-time communications and notifications and any unplanned work forced by equipment failures, storms, etc. BPA assured the RC it would continue to communicate any planned and emergency outages and would work diligently with SNPD to obtain full TOP certification. At the time SNPD registered as a TOP, it was working on compliance with its other functions as Transmission Owner (TO), Transmission Provider (TP), Purchasing-Selling Entity (PSE), Load Serving Entity (LSE), Distribution Provider (DP), Generator Owner (GO) and Generator Operator (GOP).

WECC assessed no penalty due to the circumstances surrounding the non compliance. BPA unexpectedly notified SNPD that it would not be its TOP, effective immediately on December 24, 2008. SNPD then found itself immediately required to be NERC compliant. SNPD submitted its self reports in a timely manner and in addition submitted mitigation plans which were timely completed. The violations were not repeat violations and were not contested by SNPD.

Penalty: $0

FERC Order: Issued April 30, 2012 (no further review)

TransAlta Centralia Generation, LLC, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: TOP-006-1

Requirement: R1, R2, R3, R4, R5, R6, R7

Violation Risk Factor: Medium (R1, R3, R4, R5); High (R2, R6, R7)

Violation Severity Level: Not provided

Region: WECC

Issue: In May 2008, TransAlta Centralia Generation, LLC (TransAlta) self-reported that it did have not procedures in place to: (R1) inform its Host Balancing Authority, Reliability Coordinator, and affected Transmission Operators about the generation and transmission resources available for use; (R2) monitor transmission line status, real and reactive power flows, voltage, load-tap-changer settings, and the status of rotating and static reactive resources; (R3) provide technical information to its operating personnel regarding protective relays; (R4) gather information in order to predict the system's near-term load pattern; (R5) identify deviations in operating conditions, through the use of metering, and identify if corrective action is needed; (R6) ensure, through the use of metering, the accurate and timely monitoring of operating conditions in normal and emergency settings; or (R7) monitor system frequency.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since TransAlta was engaged in regular communications with its Balancing Authority and Transmission Operator. In addition, the Balancing Authority was performing the relevant activities or working with TransAlta on meeting the requirements of TOP-006-1. The violations were also primarily documentation issues. The violations were self-reported and were TransAlta's first violations of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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

Unidentified Registered Entity, FERC Docket No. NP12-2 (October 31, 2011)

Reliability Standard: TOP-006-1

Requirement: R6

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: URE self-reported that its EMS and SCADA had improper range settings (which generated inaccurate data), causing URE to be unable to perform timely monitoring of its operating conditions for normal or emergency situations.

Finding: WECC found that the violation constituted a minimal risk to BPS reliability since URE’s operators maintained real-time visibility of actual and predicted line flows and conducted hourly reviews in cooperation with its intertie neighbor. In addition, URE had a state estimator that conducted data checks and line flow verification, alerting URE’s operators of any data mismatches. URE also conducted contingency analysis studies to determine any upcoming reliability concerns and URE’s Balancing Authority monitored and analyzed URE’s transmission system. This was URE’s first violation of the relevant Reliability Standard. WECC evaluated URE’s compliance program as a mitigating factor.

Penalty: $37,000 (aggregate for 4 violations)

FERC Order: Issued November 30, 2011 (no further review).

Western Area Power Administration-Sierra Nevada Region, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: TOP-006-1

Requirement: R5

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Western Area Power Administration-Sierra Nevada Region (WASN) self-reported that it did not posses a documented procedure detailing the alarm capability of its EMS.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since WASN, as part of its annual emergency training program, did have a restoration plan in place and a dispatcher's drill covering restoration. In addition, the violation was primarily a documentation issue. The violation was self-reported and this was WASN's first violation of this Reliability Standard. Even though the violation occurred before the Reliability Standards became mandatory, WASN did not complete its mitigation plan in a timely manner. This delay turned the violation into a post-June 18, 2007 violation. Even with the late completion of the mitigation plan, no penalty was imposed.

Penalty: $0

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