Duke Energy will pay $40,000 to SERC Reliability for violations of NERC reliability standards at multiple renewable energy generators, according to two agreements reached between the utility and the regional entity last year.

NERC submitted the settlements to FERC on Nov. 30 in its final spreadsheet Notice of Penalty of 2023 (NP24-3). On Dec. 29, the commission said in a filing that it would not further review the agreements, leaving the penalties intact.

SERC sorted the Duke settlements into two overall violations, each carrying a $20,000 penalty. The first involved infringements of MOD-032-1 (Data for power system modeling and analysis) at eight Duke facilities:

• • Conetoe II Solar in North Carolina;
  • Cimarron Windpower II and Ironwood Windpower in Kansas;
  • Frontier Windpower I and II in Oklahoma;
  • North Allegheny Wind in Pennsylvania;
  • North Rosamond Solar in California; and
  • Top of the World Windpower in Wyoming.

Because the issues span the footprints of multiple regional entities, SERC will split the penalty with the Midwest Reliability Organization, ReliabilityFirst and WECC based on net energy load.

According to the settlement, Duke discovered while gathering evidence for an upcoming audit that the facilities in question had not submitted modeling data to their transmission planners and planning coordinators in some of the previous years, as required by the standard. Most of the facilities were missing their steady-state, dynamics and short-circuit data; Frontier 2 was missing only its dynamics data, SERC said.

After learning of the failure to submit the data, Duke conducted an extent-of-condition review across its other business areas. (The initial discoveries were all in the Duke Energy Renewables division.) No other MOD-032-1 infringements were discovered.

SERC and the other regions classified the violations as a minimal risk to grid reliability, noting that failing to submit required data “could have resulted in inaccurate data being used in planning models and studies” but adding that in nearly all cases, there were no changes in the relevant data during the period of noncompliance. The facilities’ mitigating activities included submitting the missing data; defining the roles and responsibilities of all those involved in producing and submitting MOD-032-1 data; and implementing a tool to track upcoming modeling requirements.

The second Duke settlement involved violations of MOD-025-2 (Verification and data reporting of generator real and reactive power capability and synchronous condenser reactive power capability). Conetoe II Solar also was involved in these infringements, along with the Los Vientos and Notrees wind facilities in Texas; SERC will split the fines with the Texas Reliability Entity.

Once again, Duke discovered the MOD-025-2 violations while gathering evidence for an upcoming audit. The facilities had failed to submit information when they performed their five-year staged verification of real and reactive power capabilities in 2021.

The REs determined that the root cause of the infringement was “an inadequate fleetwide compliance management approach to MOD-025-2.” According to the settlement, the staff responsible for overseeing compliance activities lacked training, and the utility’s MOD-025-2 procedure lacked clearly defined roles and responsibilities for all groups involved in producing and submitting the data.

Mitigating activities by the facilities included defining the responsibilities involved in the MOD-025-2 procedure and implementing an organizational approach for model data evidence that defines how the evidence is to be structured and named. The company also trained the impacted groups on updates to the procedure “to ensure new processes are understood and implemented.”