NERC Case Notes: Reliability Standard VAR-STD-002a-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard VAR-STD-002a-1

NERC Case Notes: Reliability Standard VAR-STD-002a-1

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Avista Corporation, FERC Docket No. NP10-26-000 (December 30, 2009)

Reliability Standard: VAR-STD-002a-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: Not provided

Region: WECC

Issue: Avista self-reported violations of Regional Standard VAR-STD-002a-1 WR1 since it is a Generator Operator and it failed to have the AVR in service and capable of operating in automatic voltage control mode at all times. Through testing, Avista discovered that the AVR at its Boulder Park Generating Station (which has a total output of 30.8 MVA) did not possess the capability to operate in the voltage control mode. The facility is comprised of six units – which were designed as peaking plants that typically did not have voltage control capability (since they had multiple units connected to the same bus at the Boulder Substation). Although the AVR had been in service since the generating facility was energized in 2002, it had been operating in VAR control mode (not in voltage control mode) during that time.

Finding: Avista and WECC concluded a settlement agreement to resolve all outstanding issues. The duration of VAR-STD-002a-1 violation was determined to be from June 18, 2007 (when the Reliability Standard became enforceable) until July 7, 2008 (when Avista completed its Mitigation Plan for this standard). In determining the aggregate penalty amount for all of the reliability violations, WECC considered the fact that this was one of the first enforcement proceedings after the Reliability Standards became mandatory, Avista did not have any prior violations of the Reliability Standards, and that these violations did not appear to put the bulk power system at serious risk (especially as the Avista system is surrounded by the Bonneville Power Administration system). In addition, the VAR-STD-002a-1 violation was self-reported, Avista did not conceal evidence, and Avista was cooperative through the entire enforcement process. As part of its Mitigation Plan, Avista changed the settings on the AVR at the Boulder Park Generating Station to come into compliance with the standard. WECC verified that the "voltage drop" mode of the AVR responded to voltage deviations as required.

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

FERC Order: Issued January, 29, 2010 (no further review)

NAES Corporation – Tracy (NAES-TR), FERC Docket No. NP12-12 (January 31, 2012)

Reliability Standard: VAR-STD-002a-1

Requirement: WR1

Violation Risk Factor: Lower

Violation Severity Level: Level 4 Noncompliance

Region: WECC

Issue: It was determined that NAES-TR, as a GOP, did not operate its automatic control equipment in voltage control mode (VCM) for greater than 92% of the time its unit was on line for the reporting period Q4 2010 but rather operated in power control mode. NAES-TR’s operators believed that the TOP, Pacific Gas and Electric Company, had instructed it to operate in this mode, but the Standard does not allow the TOP to have the GOP operate in a mode other than VCM unless there are special conditions as set forth in the Standard, which was not the case here. Therefore, WECC reported that a violation of the Standard occurred by NAES-TR’s failure to operate its AVR in a VCM.

Finding: The violation was found to constitute only minimal risk to BPS reliability because, even though NAES-TR did not operate in the proper mode, the subject generator (the Thermal Energy Development Partnership) is a synchronous biomass facility with a rated capacity of 23 MW, which is connected to a 115 kV transmission system. WECC took into consideration the entity’s size and location noting that with such limited capacity it was unlikely to have any more than a minimal impact on BPS reliability. WECC also considered that no other aggravating factors were found.

Penalty: $500

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

Sacramento Municipal Utility District, FERC Docket No. NP10-160-000 (September 13, 2010)

Reliability Standard: VAR-STD-002a-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: Level 4 Non-Compliance

Region: WECC

Issue: In March 2008, Sacramento Municipal Utility District (SMUD) self-reported that it was not operating its nine generating units with the Automatic Voltage Regulator (AVR) operating in the automatic voltage control mode.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since the GE excitation systems were actually controlling voltage under all conditions – even when the AVR was placed in Power Factor (PF) or VAR control modes. The duration of the violation was from June 18, 2007 through February 29, 2008. But, WECC found that the violation occurred for three consecutive calendar quarters and that all nine of the generating units were not in automatic voltage control mode for all hours before February 29, 2008. In addition, the violation was self-reported and this was SMUD’s first violation of this Reliability Standard.

Penalty: $35,000

FERC Order: Issued October 13, 2010 (no further review)

Wheelabrator Lassen Inc., FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: VAR-STD-002a-1

Requirement: R1

Violation Risk Factor: N/A

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007, Wheelabrator Lassen Inc. (WL) self-reported that it had not been operating in automatic voltage control mode and did not get an exemption as required.

Finding: WECC found that the violation did not pose a serious or substantial risk to the bulk power system since WL's facility had been operating in power factor control mode without incident since it started up in 1983. The violation was self-reported and this was WL's first violation of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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