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

NERC Case Notes: Reliability Standard TOP-STD-007-0

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Arizona Public Service Company, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: TOP-STD-007-0

Requirement: R1

Violation Risk Factor: N/A

Violation Severity Level: Not provided

Region: WECC

Issue: In January 2008, Arizona Public Service Company (APSC) self-reported that it had exceeded the maximum amount of power that is allowed over the Operating Transfer Capability for 50 minutes on November 7, 2007.

Finding: WECC found that this violation did not constitute a serious or substantial risk to bulk power system reliability since APSC and its Reliability Coordination stayed in contact throughout the incident and APSC worked with the Reliability Coordinator in order to restore its system back within normal operating limits. APSC also took actions during those 50 minutes to reduce its load. In addition, APSC self-reported the violation; this was APSC's first violation of this Reliability Standard; and it completed a mitigation plan.

Penalty: $0

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

Arizona Public Service Company (APS), Docket No. NP13-15 (December 31, 2012)

Reliability Standard: TOP-STD-007-0

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: NERC Compliance Enforcement Authority

Issue: On November 7, 2008, the Western Interconnection experienced a Category 2 disturbance caused by a forced outage of a San Diego Gas and Electric Company 500 kV transmission line. Loss of this line caused APS to immediately re-rate Path 49 and distribute a WECC-Net message to notify pertinent entities of the new Operating Transfer Capability Limit (OTC) on the path. It also directed certain generation to back down in order to relieve the affected lines and communicated with various entities during the disturbance. APS violated WR1 because it failed to take all necessary actions to bring loading on Path 49 under its OTC within the required 30-minute period.

Finding: NERC determined that the violation posted a serious and substantial risk to the reliability of the BPS because the operating limit was exceeded by 780 MW for a total of 47 minutes, allowing a condition to persist that could have led to instability, uncontrolled separation, or cascading outages. Duration of the violation was one day, November 7, 2008.

Total Penalty: $250,000 (aggregate for 2 violations)

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

California Independent System Operator (CAISO), Docket No. NP13-56-000 (Sept. 30, 2013)

Reliability Standard: TOP-STD-007-0

Requirement: WR1

Violation Risk Factor: NA

Violation Severity Level: NA

Region: WECC

Issue: Pursuant to a Settlement Agreement entered into between the parties, CAISO was found to be in violation of multiple Reliability Standards with respect to a forced outage experienced by the Western Interconnection Bulk Electric System of the San Diego Gas & Electric (SDG&E) TL 50001 transmission line between SDG&E’s Imperial Valley and Miguel Substations, which was itself caused by a fire in a series capacitor bank. Among other violations, CAISO, in its function as TOP, was found to violate TOP-STD-007-0 WR1. CAISO is the path operator of the Southern California Import Transmission (SCIT) nomogram. The SCIT nomogram exceeded system operation limits (SOL) and was not fully relieved until 24 minutes after the occurrence of the exceedance. TOP-007-0 WR1 mandates elimination within 20 minutes.

Finding: The violation was deemed to pose a moderate, but not a serious or substantial, risk to BPS reliability, as the limit was exceeded for only four minutes over the regional standard’s time limit. Further, CAISO did immediately react as soon as smoke was reported at the series capacitor bank. In determining the appropriate penalty, NERC considered the following: (1) CAISO had not previously been subject to NERC Reliability Standards violations; (2) CAISO self-reported violations; (3) CAISO was cooperative in the enforcement process; (4) CAISO maintained a compliance program at the time of the event; (5) CAISO did not appear to hide or cover up any violation; and (6) CAISO voluntarily took additional mitigating activities which included significant investment to improve its operations and avoid future violations.

Total Penalty: $120,000 (aggregate for 6 violations)

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

El Paso Electric Company, FERC Docket No. NP11-138-000 (March 30, 2011)

Reliability Standard: TOP-STD-007-0

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: WECC

Issue: El Paso Electric Company (EPE), a Transmission Operator, failed to restore Path 47 to its Operating Transfer Capability Limit within 20 minutes, as required by the Reliability Standard.

Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a penalty in the amount of $0 for this violation. In reaching this determination, the NERC BOTCC considered the following facts, among others: the violation constituted EPE’s first violation of the subject NERC Reliability Standard; EPE cooperated during the compliance enforcement process; EPE’s compliance program; EPE 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: $0

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

Unidentified Registered Entity, FERC Docket No. NP11-63-000 (December 22, 2010)

Reliability Standard: TOP-STD-007-0

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: Not discussed

Region: WECC

Issue: Unidentified Registered Entity’s (URE) system operator monitored actual power flow on the transmission line, however, URE failed to take immediate action to reduce schedules to ensure the net schedule over the path did not exceed the Operating Transfer Capability Limits (OTC), and WECC determined that scheduled flows exceeded the OTC for 3 hours in violation of the subject Reliability Standard.

Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a penalty in the amount of $80,000 for this and other Reliability Standards violations. In reaching this determination, the NERC BOTCC considered the following facts: the violation constituted URE’s first violation of the subject Reliability Standard; URE self-reported the violation; URE cooperated during the compliance enforcement process; URE’s compliance program; URE did not attempt to conceal a violation or intend to do so; and the violation did not create a serious or substantial risk to the bulk power system.

Penalty: $80,000 (aggregate for multiple violations)

FERC Order: Issued January 21, 2011 (no further review)