NERC Case Notes: Reliability Standard EOP-009-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard EOP-009-0

NERC Case Notes: Reliability Standard EOP-009-0

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Great River Energy, FERC Docket No. NP11-77-000 (December 22, 2010)

Reliability Standard: EOP-009-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: Great River Energy (GRE) self reported a violation of EOP-009-0 R1 because it failed to test one-third of its blackstart units in calendar year 2009. A GRE operator tested the blackstart units on December 29, 2008 and mistakenly believed that the tests would satisfy the requirement that the units be tested in calendar year 2009.

Finding: The violation did not pose a serious or substantial threat to reliability of the bulk power system because if the GRE operator had conducted the tests just three days later then it would have not have been in violation of the Reliability Standard.

Penalty: $0

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

Idaho Power Company (IPCO), Docket No. NP13-8-000, November 30, 2012

Reliability Standard: EOP-009-0

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: WECC

Issue: IPCO, in its role as a GO and GOP, self-reported a violation of R2 after failing to submit its blackstart test data to WECC in both 2009 and 2010, despite having completed such testing.

Finding: WECC determined that the R2 violation posed a minimal risk to the reliability of the BPS because the lack of test reporting was limited to IPCO's blackstart units, and the units were actually tested even if the reports were not filed. IPCO also coordinated with other entities, such as its TOP, BA and RC, and its blackstart units were available in the event that a regional blackstart plan was needed. WECC and IPCO entered into a settlement agreement to resolve multiple violations, whereby IPCO agreed to pay a penalty and to undertake other mitigation measures to come into compliance with R2. WECC considered IPCO's internal compliance program a mitigating factor in making its penalty determination. The duration of the violation was from January 1, 2009 to December 13, 2011. IPCO agrees/stipulates to the R2 violation.

Penalty: $40,000 (aggregate for 4 violations)

FERC Order: Issued December 28, 2012 (no further review)