NERC Case Notes: Reliability Standard TOP-008-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard TOP-008-1

NERC Case Notes: Reliability Standard TOP-008-1

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Entergy, FERC Docket No. NP14-36-000 (March 31, 2014)

Reliability Standard: TOP-008-1

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: During a compliance investigation related to a December 27, 2010 load shed event in the Acadiana Load Pocket, SERC determined that Entergy, as a TOP, failed to operate its system to prevent the likelihood that an action would cause a System Operating Limit (SOL) violation in its area or another area of the interconnection. During the December 27, 2010 incident, Entergy ordered the closing of a normally open breaker (to relieve the overload condition on the North Crowley-Scott line), which resulted in a maximum 11% overload of the Richard-Colonial 138 kV line over its thermal rating for an average of 35 minutes.

Finding: SERC found that the violation constituted a moderate risk to BPS reliability since it could have caused additional SOL violations and operating above the SOLs can result in switching, re-dispatching generation and/or shedding load in order to realign the transmission system configuration. However, Entergy has procedures for monitoring and resolving SOLs and Interconnection Reliability Operating Limits (IROLs), and IROLs were not exceeded during the December 27, 2010 incident. Entergy neither admitted nor denied the violations. In approving the settlement agreement, the NERC BOTCC found that the violations constituted a moderate risk to BPS reliability, and not a serious or substantial risk. Entergy violated the same Reliability Standards in the past, but this compliance history was not considered to be an aggravating factor. But, the violations occurred while the system was stressed, which was viewed as an aggravating factor even thoug the violations did not contribute to the load loss. Entergy did have an internal compliance program in place, which was evaluated as a mitigating factor. Entergy also cooperated throughout the enforcement process and did not conceal the violations.

Penalty: $30,000 (aggregate for 4 violations)

FERC Order: Issued April 30, 2014 (no further review)

KCPL – Greater Missouri Operations, FERC Docket No. NP12-15 (February 29, 2012)

Reliability Standard: TOP-008-1

Requirement: R2, R4

Violation Risk Factor: High (R2), Medium (R4) Violation Severity Level: Severe (R2, R4)

Region: SPP

Issue: On June 17, 2009 at 9:54 am, KCPL – Greater Missouri Operations (“KCPL-GMO”) suffered a transmission system outage that caused all of KCPL-GMO’s customers in the greater St. Joseph area to lose service. KCPL-GMO lost 84 MW of generating capacity and 258 MW of firm load (which represents approximately 48,000 customers), with power being restored to KCPL-GMO customers by 11:22 am that day and the relevant generator returning to service at 12:54 pm that day. KCPL-GMO’s transmission system outage was limited to the St. Joseph, Missouri area and did not impact any other transmission system. During a compliance audit related to the outage, SPP found that on the day of the outage, KCPL-GMO’s system operators had not been operating the system in a way as to prevent the likelihood that a disturbance, action or inaction would cause an IROL or SOL violations (R2). SPP also found that KCPL-GMO did not conduct the required next-day and current-day studies. Therefore, KCPL-GMO’s system operators did not have (or effectively use) the information that was needed to determine the causes of the SOL violations in all operating timeframes for the planned outage (R4).

Finding: SPP found that KCPL-GMO’s violations constituted a serious or substantial risk to BPS reliability. The lack of an accurate next-day or current-day study posed a serious and substantial risk to the 161 kV BPS that served the St. Joseph load pocket. SPP determined that if KCPL-GMO had conducted current-day and next-day studies, it would have known about potential problems (and the operator may have cancelled the planned outage). In approving the penalty amount, NERC BOTCC evaluated the fact that the violations resulted in a loss of load (which increased the severity of the relevant violations); these were the first violations of the relevant Reliability Standards; KCPL-GMO cooperated during the enforcement process and did not conceal the violations; and KCPL-GMO had an internal compliance program in place (which was evaluated as a mitigating factor). KCPL-GMO also implemented additional voluntary actions in order to prevent future violations.

Penalty: $400,000 (aggregate for 7 violations)

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

Puget Sound Energy, Inc., FERC Docket No. NP14-1 (October 30, 2013)

Reliability Standard: TOP-008-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: On 9/26/2012, one of Puget Sound Energy, Inc.’s (PSE) 115 kV lines (which connected Sumas Transmission Station to Bellingham Transmission Station) tripped as a result of a fault caused by a tree, which resulted in the Sumas-Lynden line being the only line carrying the Sumas Transmission Station’s output and the line exceeding its SOL. As the trip on the line occurred while PSE was performing an energy management system failover (which produced false alarms), PSE’s power system dispatchers did not immediately discover that the line had tripped. PSE self-reported that, that the Sumas-Lynden line was loaded to 128.5 MVA (which is 117% of its SOL rating of 110 MVA) for 41 minutes on 9/26/2012. PSE found that its power system dispatchers did not fully understand the WECC Reliability Coordinator’s revised SOL Methodology and the requirement that power dispatchers respond immediately to line loading that exceeds the seasonal rating in effect and communicated to the Reliability Coordinator. Also, PSE’s operations staff and power dispatchers incorrectly assumed that there was an automatic runback scheme protecting against an SOL violation on the Sumas-Lynden line.

Finding: WECC found that the TOP-008-1 violation constituted a moderate risk to BPS reliability since an appropriate response to the SOL violation and line trip was delayed as a result of PSE’s actions. In addition to the confusion on clearing the alarms during the failover, PSE had not conducted the needed operational training and there was a lack of knowledge regarding WECC’s Reliability Coordinator SOL Methodology and the lines that had an automatic runback scheme in place. The lack of training and knowledge on the SOL Methodology could have resulted in PSE not being able to take immediate action to respond to more serious SOL conditions. But, the generation facility at the Sumas Transmission Station accounted for only 4% of PSE’s generation capacity, and PSE had 844 MW of reserve available, including 261 MW of spinning reserve, which would have completely covered the Sumas Transmission Station’s generation capacity. The TOP-008-1 violation lasted for approximately 41 minutes on September 26, 2012. PSE agreed and stipulated to the violations. In approving the settlement agreement, NERC BOTCC considered the fact that the violations were PSE’s first violations of the relevant Reliability Standards and that the violations were self-reported. PSE also had a compliance program in place and PSE engaged in voluntary corrective action to remediate the violations. PSE also improved its SOL Rating Precision and Protection System Training. The violations did not constitute a serious or substantial risk to BPS reliability.

Total Penalty: $50,000 (aggregate for 2 violations)

FERC Order: Issued November 29, 2013 (no further review)

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

Reliability Standard: TOP-008-1

Requirement: R1, R2, R3, R4

Violation Risk Factor: High (for R1, R2, R3); Medium (R4)

Violation Severity Level: Not provided

Region: WECC

Issue: In May 2008, TransAlta Centralia Generation LLC (TransAlta) self-reported that it did not have procedures in place: (R1) to take immediate actions to relieve the condition in response to a System Operating Limit (SOL) violation; (R2) to prevent the chance of a disturbance, action, or inaction that would lead to a SOL violation in its area or another area of the Interconnection; (R3) to disconnect the affected facility if the equipment became endangered through the persistence of the overload, abnormal voltage, or reactive condition; or (R4) to perform analyses in order to determine the cause of the SOL violations in all operating timeframes.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system because, under an April 2000 agreement between TransAlta and its Balancing Authority, TransAlta and the Balancing Authority would take actions to relive the condition that caused the SOL violation. In addition, the April 2000 agreement ensured that there were relevant procedures in place to address the requirements of TOP-008-1. The violations were primarily documentation issues. Also, 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. NP11-180-000 (April 29, 2011)

Reliability Standard: TOP-008-1

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: WECC

Issue: The Unidentified Registered Entity (URE) had not been operating a part of its transmission line according to the most limiting parameter, which resulted in that part of the line exceeding the System Operating Limit (SOL) by 65 MW for over 25 minutes.

Finding: WECC and the URE entered into a settlement agreement to resolve multiple violations, whereby the URE agreed to pay a penalty of $71,500 and to undertake other mitigation measures. WECC found that the violation of IRO-005-2 constituted a moderate risk to bulk power system reliability as the relevant part of the line was located along a critical transmission path. But, the URE was operating the line within its Transmission Operator’s ratings and the SOL was only exceeded by 65 MW. The duration of the TOP-008-1 violation was 25 minutes. In approving the settlement agreement and the penalty determination, NERC considered the fact that the violations were the URE’s first violations of the relevant Reliability Standards; most of the violations were self-reported; the URE was cooperative during the enforcement process and did not conceal the violations; the URE had a compliance program in place (which was evaluated as a mitigating factor); the penalty for the violation of IRO-STD-006-0 WR1 was based on a specified Sanction Table; the violations of IRO-005-2 R13 and TOP-008-1 R2 resulted from a single noncompliance occurrence; and there were no additional aggravating or mitigating factors.

Penalty: $71,500 (aggregate for 9 violations)

FERC Order: May 27, 2011 (no further review)