Reliability Standard: BAL-006-1.1
Violation Risk Factor: Lower
Violation Severity Level: High
Issue: URE self-reported that a defect in its Physical Scheduling System (PSS) software caused its operators to be unable to act upon schedule adjustments in situations when multiple adjustments to the same e-Tag were issued concurrently or successively. URE had developed manual fixes to address the software problem, but these manual fixes were not always effective as not all of the adjustments to the same e-Tag were reflected in URE’s PSS or calculated Net Scheduled Interchange (NSI). Therefore, as a result of the problems with the manual fixes, URE was not operating to a common NSI as required.
Finding: RFC found that the BAL-006-1.1 violation constituted a moderate risk to BPS reliability. When there were multiple schedule adjustment requests for the same e-Tag, URE employed successfully approved subsequent curtailment or adjustment requests. In addition, inadvertent interchange, which is caused by not operating a common NSI, does not generally affect the real-time operations of the BPS and does not pose immediate threats to reliability. In determining the aggregate penalty amount, NERC BOTCC considered the fact that certain of the violations were self-reported; URE was cooperative during the enforcement process and did not conceal the violations; URE had a compliance program in place (which was evaluated as a mitigating factor); URE adopted additional efforts to improve reliability (such as updates to its software for effective CA access management) that went beyond the requirements in the mitigation plan; the violations did not pose a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.
Penalty: $60,000 (aggregate for 6 violations)
FERC Order: Issued January 27, 2012 (no further review)