Avista Corporation, FERC Docket No. NP10-26-000 (December 30, 2009)
Reliability Standard: TPL-002-0
Requirement: R1.2
Violation Risk Factor: Medium (TPL-002-0 R1 has a High Violation Risk Factor (VRF), but its sub-requirements only have a Medium VRF. In addition, the VRF for TPL-002-0 R1 was originally Medium, but, pursuant to a FERC-ordered modification, the High VFR for TPL-002-0 R1 became effective in August 2007.)
Violation Severity Level: Not provided
Region: WECC
Issue: WECC conducted a compliance audit and found that Avista had "fail[ed] to address stability studies for the loss of a single Bulk Power System (BPS) element for the longer-term planning horizon (years 6 through 10) in its annual assessment plan under Category B contingencies." Under Reliability Standard TPL-002-0, system simulations and related assessments must be performed periodically in order to ensure that reliable systems are developed that will meet specific performance requirements with sufficient lead time. These simulations and assessments must continue to be modified or upgraded as necessary to meet present and future system needs. Through interviews with Avista personnel, WECC discovered that although Avista had, in its assessment for 2007, performed both steady-state and dynamic studies for the near-term period, it had only conducted steady-state studies, not dynamic studies, for the longer-term period.
Findings: WECC and Avista entered into a settlement agreement to resolve all of the outstanding issues, where Avista neither admitted nor denied these alleged violations but agreed to pay a $30,000 penalty amount. The duration of the TPL-002-0 violation was determined to be from June 18, 2007 (when the standard became enforceable) until September 30, 2007 (when a mitigation plan was completed). Under its Mitigation Plan, Avista created longer term transient voltage and stability study cases that would cover critical system conditions. In determining the aggregate penalty amount for the multiple alleged violations, WECC considered the fact that this was one of the first enforcement proceedings to proceed through WECC since the Reliability Standards became mandatory, these were new requirements, Avista did not have any prior violations of the Reliability Standards, and Avista did not conceal any evidence and was cooperative during the entire enforcement process. And as the Avista system is surrounded by the Bonneville Power Administration system, these alleged violations did not appear to place the bulk power system at serious risk.
Penalty: $30,000 (aggregate for multiple violations)
FERC Order: Issued January 29, 2010 (no further review)
Reliability Standard: TPL-002-0
Requirement: R1, R2, R3
Violation Risk Factor: High with respect to R1, Medium for R2, and Lower for R3
Violation Severity Level: Not provided
Region: RFC
Issue: Cleveland Public Power (CPP) failed to demonstrate by valid assessment that its transmission system is planned such that the system can supply projected customer loads at all demand levels under certain Category B contingency conditions; failed to provide or maintain written record of a plan addressing scenarios in which its system simulations indicate an inability to respond as required; and failed to document its reliability assessments and corrective plans.
Finding: Duration of violation was from June 18, 2007 when the standard became enforceable through October 16, 2009. In reaching a settlement penalty, RFC considered (1) CPP self-reported the violations; (2) CPP was cooperative throughout the enforcement process; and (3) CPP committed substantial financial and personnel resources, compared to its size, in order to achieve compliance with the standard.
Penalty: $160,000 (aggregate for multiple violations)
FERC Order: Issued January 29, 2010 (no further review)
City of Columbia, MO, FERC Docket No. NP08-29-000 (June 5, 2008)
Reliability Standard: TPL-002-0
Requirement: R1.1
Violation Risk Factor: Medium
Violation Severity Level: Moderate
Region: SERC
Issue: After conducting an audit, SERC determined that the City of Columbia did not perform the required annual assessments needed to demonstrate that, when certain contingency conditions occur, its portion of the interconnected transmission system could be operated to supply projected customer demands and projected Firm Transmission Services at all Demand levels over the range of forecast system demands.
Finding: SERC declined to impose any penalty for multiple violations of the Reliability Standards since the violations occurred during the period of transition to mandatory standards and the violations were found not to have put bulk power system reliability at serious or substantial risk. Plus, no system disturbances occurred because of these violations. These multiple violations were the first by the City of Columbia, and the City of Columbia worked cooperative with SERC Reliability Corporation during the investigation. Also, the City of Columbia acted immediately to correct the problems and subsequently completed its Mitigation Plans to address the TPL violations and to ensure that reliability is maintained.
Penalty: $0
FERC Order: 124 FERC ¶ 61,015; https://www.nerc.com/pa/Stand/Reliability%20Standards/NoticeOfPenaltyOrder.pdf
Eugene Water & Electric Board, FERC Docket No. NP11-43-000 (November 30, 2010)
Reliability Standard: TPL-002-0
Requirement: R1, R2
Violation Risk Factor: High (R1), Medium (R2)
Violation Severity Level: Severe (R1, R2)
Region: WECC
Issue: Eugene Water & Electric Board ("EWEB") submitted a self-report for failing to perform required stability studies under the single element contingency conditions as defined in TPL-002-0 and consequently failing to provide a written summary of its system performance plans. EWEB was operating under the assumption that the Balancing Authority ("BA") was conducting the required studies on its behalf, but had not communicated with the BA to confirm this point to assure compliance.
Finding: This was EWEB's first violation of this Reliability Standard, EWEB self-reported the violation and was cooperative throughout the enforcement process, there was no evidence of any attempt or intent to conceal the violation, and the violation did not pose a serious or substantial risk to the bulk power system because EWEB's system is a small portion of a single BA, with a winter peak load of approximately 524 MW, and EWEB does not have any critical interconnection ties.
Penalty: $25,000 (aggregated for multiple violations)
FERC Order: Issued December 30, 2010 (no further review)
Florida Municipal Power Agency, FERC Docket No. NP10-2-000 (October 14, 2009)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Not provided
Region: FRCC
Issue: It was discovered in December 2007 that Florida Municipal Power Agency (FMPA) did not perform the mandated assessments and studies as required by the Reliability Standard in TPL-002-0 R1.
Finding: FRCC found that this violation did not involve a serious or substantial risk to bulk power system reliability since system planning was still being performed by FMPA's Planning Authority and the transmission planning working group (even though FMPA was not conducting the assessments and studies as required). This was FMPA's first violation of this Reliability Standard and it completed a mitigation plan.
Total Penalty: $0
FERC Order: Issued November 13, 2009 (no further review)
Florida Municipal Power Agency, FERC Docket No. NP10-2-000 (October 14, 2009)
Reliability Standard: TPL-002-0
Requirement: R2
Violation Risk Factor: Medium
Violation Severity Level: Not provided
Region: FRCC
Issue: It was discovered in December 2007 that Florida Municipal Power Agency (FMPA) did not perform the mandated assessments and studies as required by the Reliability Standard in TPL-002-0 R1 and therefore was also in violation of R2 of that standard.
Finding: FRCC found that this violation did not involve a serious or substantial risk to bulk power system reliability since system planning was still being performed by FMPA's Planning Authority and the transmission planning working group (even though FMPA was not conducting the assessments and studies as required). This was FMPA's first violation of this Reliability Standard and it completed a mitigation plan.
Total Penalty: $0
FERC Order: Issued November 13, 2009 (no further review)
Florida Municipal Power Agency, FERC Docket No. NP10-2-000 (October 14, 2009)
Reliability Standard: TPL-002-0
Requirement: R3
Violation Risk Factor: Lower
Violation Severity Level: Not provided
Region: FRCC
Issue: It was discovered in December 2007 that Florida Municipal Power Agency (FMPA) did not perform the mandated assessments and studies as required by the Reliability Standard in TPL-002-0 R1 and therefore was also in violation of R3 of that standard.
Finding: FRCC found that this violation did not involve a serious or substantial risk to bulk power system reliability since system planning was still being performed by FMPA's Planning Authority and the transmission planning working group (even though FMPA was not conducting the assessments and studies as required). This was FMPA's first violation of this Reliability Standard and it completed a mitigation plan.
Total Penalty: $0
FERC Order: Issued November 13, 2009 (no further review)
Merced Irrigation District, FERC Docket No. NP11-10-000 (November 5, 2010)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Severe
Region: WECC
Issue: Merced self-reported that it had failed to conduct Category B (single contingency) studies and therefore could not ensure its transmission system was planned in accordance with the reliability standards. The original violation occurred before the standards were mandatory, but became violations of the mandatory requirements when Merced failed to complete its mitigation plan in a timely fashion.
Finding: It was determined by WECC that the violation did not constitute a serious or substantial risk to the bulk power system because Merced did provide studies demonstrating that its system could serve its peak load conditions through 2017 under normal and single contingencies. The duration of violation was from June 18, 2007 through March 6, 2009.
Penalty: $8,000 (aggregate for multiple violations)
FERC Order: Issued December 3, 2010 (no further review)
Modesto Irrigation District, FERC Docket No. NP10-93-000 (March 31, 2010)
Reliability Standard: TPL-002-0
Requirement: R1, R2, R3
Violation Risk Factor: R1-High, R2-Medium, R3-Lower
Violation Severity Level: Not provided
Region: WECC
Issue: Modesto Irrigation District (MID) failed to perform the full range of "Category B" contingency studies and assessments required by TPL-002-0 R1, R2 and R3.
Finding: The alleged violations occurred from June 18, 2007, when the Standard became enforceable, until December 29, 2008, when MID completed a mitigation plan. Through settlement, no penalty was assessed and MID agreed to undertake a number of activities, including accelerating "Job Task Analysis" development for MID's operators and construction of a back-up control center. In reaching the agreement, WECC considered that it was MID's first violations of this Standard; the violations did not pose a serious or substantial risk to the reliability of the bulk power system; MID is a government entity and a small irrigation district; most violations were self-reported; MID did not attempt to conceal the violations; and the violations were not intentional.
Penalty: $0
FERC Order: Issued April 30, 2010 (no further review)
NERC Registered Entity, FERC Docket No. NP10-137-000 (July 6, 2010)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Not discussed
Region: WECC
Issue: The NERC Registered Entity failed to study multiple demand levels defined in Category B or produce an annual assessment.
Finding: The NERC Registered Entity was required to study multiple demands levels over the range of forecast system demands. In addition, it was required to provide an addendum to its annual assessment to include an analysis of winter (off-peak) conditions. If issues were identified in the winter assessment that required longer lead-time solutions, an analysis of off-peak conditions beyond the five-year horizon would be performed and reported on. If longer lead-time solutions were not identified in the winter assessment, the NERC Registered Entity would so indicate in the addendum and longer-term off-peak analysis would not be necessary. No further publicly available information was provided.
Penalty: $39,000 (aggregate for multiple violations)
FERC Order: Issued August 5, 2010 (no further review)
NERC Registered Entity, FERC Docket No. NP10-159-000 (July 30, 2010)
Reliability Standard: TPL-002-0
Requirement: R1, R2, R3
Violation Risk Factor: High for R1, Medium for R2, Lower for R3
Violation Severity Level: Not provided
Region: WECC
Issue: While the Registered Entity had completed necessary power flow studies, the Registered Entity failed to provide evidence that its assessments included a near-term summer study, nor current or past studies over the range of forecast system demand as required. Also, the Registered Entity did not have an adequate written summary of plans to achieve the required system performance throughout the planning horizon.
Finding: Duration of the violations was from June 18, 2007, when the Reliability Standard became enforceable, through March 30, 2009. The violations did not pose a serious risk to the reliability of the bulk power system because the violations were primarily documentation issues, and the Registered Entity is only a medium-sized entity in its balancing authority area. These were the Registered Entity's first violation of the Reliability Standard.
Penalty: $109,000 (aggregate for multiple violations)
FERC Order: Issued August 27, 2010 (no further review)
Nevada Power Company, FERC Docket No. NP10-54-000 (March 1, 2010)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Not provided
Region: WECC
Issue: Nevada Power analyzed its system only with respect to heavy summer load demand conditions, rather than selected demand levels over the range of forecast system demands, under the conditions defined in Category B.
Finding: Duration of violation was from June 18, 2007, when the standard became enforceable, through July 31, 2008. The violation was deemed not to pose a serious or substantial risk to bulk power system reliability because Nevada Power had studied its most heavy load condition.
Penalty: $52,000 (aggregate for multiple violations)
FERC Order: Issued March 31, 2010 (no further review)
PacifiCorp (PAC), Docket No. NP12-44-000 (August 31, 2012)
Reliability Standard: TPL-002-0
Requirement: 1
Violation Risk Factor: High
Violation Severity Level: Lower
Region: WECC
Issue: PAC self-reported in December 2008 that, as a Planning Authority (PA) and Transmission Planner (TP), it had not included electric system components below 200 kV in its assessment for system performance after the loss of a single Bulk Electric System (BES) element for its part of the interconnected transmission system.
Finding: The violation was deemed by WECC to pose minimal risk to BPS reliability because PAC could show that it had performed assessments of 200 kV+ systems as required by TPL-002-0 R1. PAC records showed that PAC had considered some systems operating at less than 200 kV in its assessment. In determining the appropriate penalty, WECC did not consider other violations that were the subject of an investigation as an aggravating factor. PAC did not contest WECC's findings.
Penalty: $0 (for 4 violations)
FERC Order: Issued September 28, 2012 (no further review)
Public Utility District No. 1 of Chelan County, FERC Docket No. NP10-2-000 (October 14, 2009)
Reliability Standard: TPL-002-0
Requirement: R1, R2, R3
Violation Risk Factor: High (R1, R3); Medium (R2)
Violation Severity Level: Not provided
Region: WECC
Issue: In July 2007, Public Utility District No. 1 of Chelan County (CHPD) self-reported that it had not demonstrated a valid assessment and therefore could not meet all of the requirements of TPL-002-0.
Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system due to the nature and location of CHPD’s system. In addition, CHPD had also historically conducted steady-state assessments on its portion of the interconnected transmission system. The violations were self-reported and were CHPD’s first violations of this Reliability Standard. A mitigation plan has been completed.
Penalty: $0
FERC Order: Issued November 13, 2009 (no further review)
Public Utility District No. 1 of Snohomish, FERC Docket No. NP11-135-000 (March 30, 2011)
Reliability Standard: TPL-002-0
Requirement: R1, R2
Violation Risk Factor: High (R1), Medium (R2)
Violation Severity Level: Severe
Region: WECC
Issue: Public Utility District No. 1 of Snohomish (SNPD), a Transmission Planner, failed to perform the required stability studies under the single element contingency conditions as defined in Category B of Table I to the Reliability in violation of TPL-002-0 R1. Further, SNPD was not able to provide a written summary of its system performance plans as required by TPL-002-0 R2.
Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a settlement agreement which included a penalty in the amount of $26,000 for these and other violations. In reaching this determination, the NERC BOTCC considered the following facts: the violations constituted SNPD’s first violations of the subject NERC Reliability Standard; SNPD self-reported the violations; SNPD cooperated during the compliance enforcement process; SNPD did not attempt to conceal a violation or intend to do so; the violations 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: $26,000 (aggregate for 8 violations)
FERC Order: Issued April 29, 2011 (no further review)
PUD No. 1 Douglas County, FERC Docket No. NP10-167-000 (September 30, 2010)
Reliability Standard: TPL-002-0
Requirement: R1, R2, R3
Violation Risk Factor: High (R1), Medium (R2), Lower (R3)
Violation Severity Level: Severe (R1, R2, R3)
Region: WECC
Issue: PUD No. 1 of Douglas County (DOPD), failed to maintain current studies in the near-term and long-term planning horizons. DOPD also failed to develop a valid assessment showing that DOPD’s portion of the interconnected transmission system was planned such that the Network could operate to supply projected customer demands, at all demand levels over the range of forecast system demands, under the contingency conditions as defined in Category B of Table I to the Standard. As such, DOPD was in violation of TPL-002-0 R1. In addition, DOPD could not provide a written summary of its system performance plans as required by R2. Further, DOPD could not produce such an assessment to WECC as required by R3.
Finding: WECC imposed a $70,000 penalty for these and other violations. In assessing the penalty, WECC determined the alleged violations did not create a serious or substantial risk to the bulk power system because, as DOPD conducts weekly operations reviews of system conditions, DOPD is aware of the real time and weekly system conditions. WECC also considered the fact that DOPD operates the Wells Hydroelectric Project, which consists of 10 generating units capable of producing approximately 840 MW of electricity, within a single Balancing Authority.
Penalty: $70,000
FERC Order: Issued October 29, 2010 (no further review)
Sacramento Municipal Utility District, FERC Docket No. NP10-29-000 (December 30, 2009)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Not provided
Region: WECC
Issue: SMUD studied adverse peak conditions only with respect to Category B contingency conditions, instead of addressing demand levels over a range of forecast system demands; moreover SMUD could not produce documentation to show it had conducted studies in accordance with this standard.
Finding: Duration of violation from June 18, 2007, when the standard became enforceable, through February 20, 2009. WECC determined the penalty justified because (1) the violation involved documentation failure only; (2) this was SMUD's first violation of this standard; and (3) there was no evidence SMUD attempted to conceal the violation.
Penalty: $65,000 (aggregate for multiple violations)
FERC Order: Issued January 29, 2010 (no further review)
Texas-New Mexico Power Co., Docket No. NP13-33 (April 30, 2013)
Reliability Standard: TPL-002-0
Requirement: 1/1.3/1.3.1/1.3.7/1.5
Violation Risk Factor: High
Violation Severity Level: Lower
Region: TRE
Issue: In July 2011, Texas-New Mexico Power Co. (TNMP), as a TP, self-certified that it did not perform a stability analysis in order to test system performance under defined conditions for all relevant contingencies.
Finding: TRE found that this violation constituted a moderate risk to BPS reliability since operating with SOLs that have not been validated by a stability analysis increases the risk of cascading outages or uncontrolled separation. But, TNMP did have established SOLs, and the problem was discovered and promptly addressed through TNMP’s internal controls. The duration of the violation was from June 28, 2007 through April 4, 2011. TNMP neither admitted nor denied the violation. TNMP’s internal compliance program was viewed as a mitigating factor, as well as the fact that TNMP engaged in measures above and beyond what was strictly required (such as adding a third transmission planner and additional engineers and increasing training).
Total Penalty: $7,000 (aggregate for 4 violations)
FERC Order: Issued May 30, 2013 (no further review)
Turlock Irrigation District, FERC Docket No. NP10-18-000 (November 13, 2009)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Not provided
Region: WECC
Issue: TID self-reported that it did not properly complete and distribute the required assessments of Category B conditions to neighboring entities.
Finding: Duration of the violation was from June 18, 2007, when the standard became enforceable, through October 25, 2008. WECC gave consideration to the fact that TID is a small entity with limited financial resources, it self-reported the violation, the violation resulted in a minimal to moderate impact to the reliability of the bulk power system, the violation was TID's first of this requirement, and TID provided evidence of a superlative compliance program.
Penalty: $80,000 (aggregate for multiple violations)
FERC Order: Order Denying Rehearing and Providing Clarification, issued June 21, 2012, 139 FERC ¶ 61,248 (2012); http://www.ferc.gov/whats-new/comm-meet/2012/062112/E-8.pdf
Unidentified Registered Entity, FERC Docket No. NP11-1-000 (October 7, 2010)
Reliability Standard: TPL-002-0
Requirement: R1, R2
Violation Risk Factor: R1, High; R2, Medium
Violation Severity Level: N/A
Region: WECC
Issue: WECC determined during an audit that an Unidentified Registered Entity (URE) did not undertake stability studies, the employees did not have the technical knowledge required to perform the stability studies, and the URE did not have an adequate corrective action plan to remedy a failure to meet performance criteria.
Finding: The violations did not pose a serious or substantial risk to the reliability of the bulk power system because of the URE's relative size and location and access to outside energy resources if needed for real-time operations. The violation only dealt with long-term planning.
Penalty: $106,000 (aggregate for multiple violations)
FERC Order: Issued November 5, 2010 (no further review)
Unidentified Registered Entity, FERC Docket No. NP11-124-000 (February 23, 2011)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Severe
Region: RFC
Issue: RFC found that the Unidentified Registered Entity (URE) failed to demonstrate system performance was within limits (system stable) via dynamic studies or simulations for Category B contingencies.
Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a settlement agreement which included a penalty in the amount of $100,000 for this and other violations. In reaching this determination, the NERC BOTCC considered the following facts, among others: the violation constituted the URE's first violation of the subject NERC Reliability Standard; the URE self-reported 11 of the 16 violations; the URE cooperated during the compliance enforcement process; the URE's compliance program; the URE 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: $100,000 (aggregate for multiple violations)
FERC Order: Issued March 25, 2011 (no further review)
Unidentified Registered Entity, FERC Docket No. NP11-128-000 (February 23, 2011)
Reliability Standard: TPL-002-0
Requirement: R1, R2
Violation Risk Factor: High (R1), Medium (R2)
Violation Severity Level: Not provided
Region: WECC
Issue: URE self-reported violations of R1 and R2 prior to the effective date of the Standard (June 18, 2007) because its annual planning studies and documentation did not cover all of the specified combinations of projected forecast system demands, required system upgrades and firm transfer levels, particularly beyond a five-year planning time-line as required by R1, and therefore URE could not provide a written summary of its plans to achieve the required system performance per R2.
Finding: WECC Enforcement determined URE had violated R1 and R2 because it failed to complete its Mitigation Plan by the time the Standard became effective. Specifically, URE’s assessment only contained studies under the heavy summer demand level and did not cover results of other demand levels. The violations posed a moderate risk to the bulk power system because, due to URE’s location and interconnections, the loss of its exports could have a significant impact. Moreover, Category A conditions specified in the Standard are the most fundamental to system planning. In determining the penalty amount, the NERC Board of Trustees Compliance Committee considered the following factors: this was URE’s first occurrence of this type of violation; URE was cooperative; and the number and nature of the violations.
Penalty: $450,000 (aggregated for multiple violations)
FERC Order: Issued March 25, 2011 (no further review)
Unidentified Registered Entity, FERC Docket No. NP11-269-000 (September 30, 2011)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Severe
Region: WECC
Issue: URE self-reported that it failed to finalize documentation of its annual assessment for 2009 until 2010.
Finding: WECC determined that the violation posed a minimal risk to the reliability of the BPS because the URE did not prepare the assessments that were required, but its portion of the interconnected transmission system is planned such that it can be operated to supply projected customer demands and projected Firm Transmission Services at all demand levels over the range of forecasted system demands. Duration of the violation was from the date the assessments were due through May 6, 2010. WECC and the NERC BOTCC took into consideration that URE had a compliance program as a particular mitigating factor as well as the self-report. WECC also exercised its discretion to assess a single aggregate penalty for the violations of TPL-001-0.1, TPL-002-0, TPL-003-0 and TPL-004-0 stemming from this one incident of non-compliance.
Penalty: $225,000 (aggregate for 11 violations)
FERC Order: Issued October 28, 2011 (no further review)
Utilities Commission of New Smyrna Beach, FERC Docket No. NP10-2-000 (October 14, 2009)
Reliability Standard: TPL-002-0
Requirement: R1
Violation Risk Factor: High
Violation Severity Level: Not provided
Region: FRCC
Issue: Utilities Commission of New Smyrna Beach (New Smyrna) failed to perform the assessments required by the standard.
Finding: Duration of the violation was from June 18, 2007, when the standard became enforceable, through June 12, 2009. Penalty was deemed appropriate because this was New Smyrna's first violation of this standard, and the violation did not pose a serious or substantial threat to the reliability of the bulk power system because the required assessments were being done by its Planning Authority and others.
Penalty: $0
FERC Order: Issued November 13, 2009 (no further review)
