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CHAPTER I

The July 13, 1977 Bulk Power Transmission Failureand Con Edison System Collapse

At 9229 p.m. on July 13, 1977 the bulk power transmissionsystem insoutheastern New York State failed and ceased delivering powerto the Con Edison system. Cut off from external sources of power, ConEdison did not achieve stable isolated operations and its system collapsedabout six minutes later. This Chapter of the Report describes the eventsbetween 8:37 p.m., when lightning struck a tower on a transmission lineabout 30 miles north of mid-Manhattan, and 9:36 p.m., when the ConEdison system collapsed.4

A. Fre-disturbance conditions

At 8:30 on the evening of July 13, the demand for electricityin Con Edison’s service territory totaled 5,866 megawatts (“rnw”), downfrom the day’s peak of 7,264 mw.5

Generation throughout the State was under the control of theNew York Power Pool (r,Pool” or !‘NYPP”) economic dispatch computer.This means that the Pool, at its control center in Guilderland, New York,controls the amount of generation at all major units in New York State andcoordinates imports of energy from neighboring power systems to meet allof the State’s power requirements in the most economic manner.

The summer peak on the Con Edison system in 1977 was 6,236 mw,which was about 500 mw below what Con Edison had forecast. Tes-timony of John E. Deegan, Jr., Con Edison Vice-President ofPlanning (“Con Edison testimony (Deegan)“), Hearings of the NewYork State Investigation into the New York City Blackout, July 13,1977 (Norman M. Clapp, Special Consultant in Charge) (“StateHearings”), p. 739.

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Unless otherwise indicated, all factual data is taken from Con Edisonreports on the July 13 blackout: Con Edison, First Phase Report,!hctern Rlacknut and W&em Restoration. Juv fm, I^“” T--‘-r Oc

--yen, Third Phase Report,I- Julv m-r971. Decems

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Because Con Edison’s in-City generating facilities use expen-sive low-sulphur oil and are on the average relatively older and less effi-cient than those available to other utilities, Con Edison normally pur-chases substantial amounts of power generated by others.6 In addition,Con Edison owns shares in two major generating facilities located outsideits service territory.7

Con Edison is connected with outside power systems throughfour distinct paths (see map in Appendix I). The largest of these is thenorthern path, which connects Con Edison with systems in upstate NewYork. The transmission lines in this path originate on both the east andwest sides of the Hudson River and converge in Westchester County toform a corridor containing five key 345 kilovolt (“kvl’) overhead lines,which are connected with Con Edison’s underground cable transmissionsystem. In one location, the overhead line corridor is as narrow as 250feet for a distance of 4,300 feet. 8 Con Edison% eastern transmission pathconsists of one 138 kv underground cable tie to Long Island Lighting Com-pany (“LILCO1$ which runs from Queens to Nassau County (the “Jamaicatie”). The southern path is one 230 kv overhead tie between Staten Islandand Linden, New Jersey (the “Linden tie”), connecting Con Edison andPublic Service Electric and Gas Company (“PSE&G% The western pathlinks these two companies with one 345 kv cable under the New Yorkharbor between New Jersey and Brooklyn (the fTHudson-Farragut tie*% Thiswestern tie was out of service on July 13.

On July 13 at 8:30 p.m., Con Edison was importing 2,860 mwof electricity into New York City to serve its customer load: 1,990 mwfrom generating units outside its service territory and 870 mw suppliedfrom Indian Point 3, a nuclear generator near the northern boundary ofCon Edison’s service territory owned by the Power Authority of the Stateof New York (“PASNY% The electric current flowing in the threeavailable paths at that time was approximately 2,800 mw into Con Edisonon the five Westchester lines, approximately 250 mw to LILCO on the

6 Con Edison Second Report, p. 3.- -7 These are the Roseton and Bowline PO& facilities located in Orange

and Rockland Counties, respectively, with generation capacities of480 mw and 800 mw.

a Con Edison Third Report, VoL V, p. 18.- - -

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Jamaica tie, and approximately 290 mw into Con Edison on the Lindentie.g

The import of 2,860 mw under automatic economic dispatchmeant that Con Edison’was receiving approximately 270 mw above thebasic schedule arranged in advance and in effect at 8:35 p.m.10 This hadtwo eff e&s. First, it increased the loadings on the lines through which ConEdison was importing power. Second, it reduced the amount of powerbeing generated in New York City.

The 600 mw capacity Astoria 6 plant owned by PASNY andlocated in New York City was out of service at 8:30 p.m. on July 13. ConEdison generation units which were unavailable included 493 mw of base-load units, 856 mw of peaking units and 1,331 mw of gas turbine units;among these outages were 606 mw of Con Edison’s reported 1,344mw of ten-minute reserve generation.11 Automatic reclosing equipmenton circuit 97 between the Buchanan andWestchester was also out of service.

B. The first lightning stroke

At 8:37:17 p.m. lightning struck a tower carrying the two 345kv transmission circuits linking the Buchanan and Millwood substations innorthern Westchester (see map and schematic diagram in Appendix I).Although transmission towers are designed to ground such Iightninstrokes, in this particular case both circuits (97 and 98) flashed over. IfsProtective relays sensed the flashover and triggered circuit breakers

Sprain Brook substations in

9 Con Edison First Report, Section A-I, Figure I-l. An additional 114mwwxwxinto the system over 138 kv lines south of PleasantValley.

10 NY PP Interchange end Generation Summary for July 13, 1977, StateHearings. Exhibit 50.

11 Con Edison Third Report: VoL V, pp. 70, 72. A “baseload unit”sFpti=wer on a continuous basis and may provide generationreserves; a”peaking unit” supplies power during peak demand periodsand may provide additional reserve generation; a “gas turbine” isnormally used to supply peak and reserve generation,

12 The “flashover~~ occurred when lightning increased the potential, of thetower to a point where an arc between the tower and the lineresulted. This arc established a path through which the line shortcircuited through the tower to the ground.

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which opened both circuits in order to isolate the fault from the rest ofthe system. The design of the substation at Buchanan is such that theopening of these circuit breakers also blocks all paths for the output ofthe Indian Point 3 nuclear generator. Protective equipment sensed thiscondition end automatically shut down Indian Point 3.

The lightning-induced faults on circuits 97 end 98 dissipatedin less than a second, but certain equipment and design problems keptthem out of service and spread the disruption further. Lines opened bylightning strokes sre designed to reclose automatically when the resultingflashover ceases. Circuit 98, however, failed to reclose because of in-adequate air pressure in a circuit breaker at the Millwood substation, theresult of a loose locking nut. Circuit 97 did not reclose because thereclosing circuit which is provided for most Con Edison lines had been-taken out of service pending the installation of a new reclosing systemdesigned to lessen the impact of reclosing on generators. This newequipment had already been provided for circuit 98. Circuit 88, a lineacross the Hudson River connecting the Ladentown and Buchanan sut>-stations, opened when an improperly designed breaker-failure timerincorrectly triggered a backup relay.

The lightning stroke and associated events described aboveresulted in the loss of 870 mw generated at Indian Point 3 and 427 mwcarried on line 88. This loss of 1,297 mw of input to the Con Edison sys-tem was immediately picked up by increased loadings on the remaininties. The resultant power surge caused the emergency transfer limit l!

13 AWansf er IimW specifies the amount of electricity that may safelypass through a specified group of transmission lines across a definedboundary. When an electric system is operated within %ormalwtransfer limits it has the capacity to withstand a specified event(such as the loss of a major transmission line) without causing theflow in any of the other lines in service to exceed their long timeemergency ratings; within “emergency” transfer limits, the flowwould not exceed the short time emergency rating following thespecified event. These specified events or “design criteria” includethe loss of a single or double circuit transmission facility or the lossof a generating facility. “New York Power Pool Design Standards forLong Range Planning and Studies of Short Range Operating Limits,”Con Edison Third Re ort, VoL V, Appendix I; Northeast Power Co-omnatlng me1 llNPCCw),-+-- “Basic Criteria for Design andOperation of Interconnected Power Systems,” id. See note 17 infrafor a discussion of long and short time emergeniy ratings. -

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between upstate New York and Con Edison to be exceeded.14

Following the lightning stroke the Con Edison System Operatoradjusted the Linden tie to decrease its loading by approximately 180 mw(according to the recorder chart in Appendix I of Con Edison’s Second~ozp~!p~ This also had the effect of increasing the flow in the northern

.

The Pool remained on automatic economic dispatch, and thegeneration lost at Indian Point 3 was replaced by statewide increasedgeneration which was transmitted to Con Edison over lines still in service.Within ten minutes after the lightning stroke, the Pool terminated thetransfer of power going through the Con Edison system from the NewEngland Power Exchange Pool to the Pennsylvania-New Jersey-MarylandPool (‘lPJM*l). At 8:45 the Pool inquired whether Con Edison was bringingup its generation, and at about the same time the Con Edison SystemOperator gave the alarm for fast pickup of generation. Although ConEdison believed that it had a ten-minute reserve of 738 mw (its reservereported to the Pool was 1,344 mw against a required reserve of 292 mw),generation was increased by only 397 mw between 8:45 and 8:55.

C. The second lightning stroke

At 8:55:53 p.m. a second lightning stroke hit a transmissiontower between the Millwood and Sprain Brook substations. The towercarried two 345 kv circuits (93 and 99) which flashed over simultaneouslyas a result of the stroke. Circuit 99 reclosed, but circuit 93 reclosed onlyat the Sprain Brook substation. The circuit breaker at the Buchanan Northsubstation remained open as a result of the operation of a relay designedto protect the Indian Point 2. nuclear generator even though that gener-ator had been out of service since July 1, 1977.15 The setting of the relayhad been adjusted in a way that prevented automatic reclosing under the

L 14 Testimony of Peter Zarakas, Con Edison Vice-President ofEngineering, Chairman of Board of Review cnCon Edison testimony(Zaraka&), State Hearin p. 443; testimony of Charles J. Durkin,Jr., Con Edison Chle System Operator (“Con Edison testimony-----+(Durkin)?, Hearing of the Special Commission of Inquiry into EnergyFailures &a M. Millstein, Chairman) (“City Hearing$l), August 31,1977, p. 499.

15 Indian Point 2 was out of service due to the need for work on a reactorcooling pump. Con Edison testimony (Zarakss), State Hearings, p.252.

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conditions of July 13. The Con Edison System Operator did not recognizethat circuit 93 was open.16

Following the opening of circuit 93 and the failure to recloseit, circuit 81, between the Millwood West and Pleasant Valley substations,became loaded above its short time emergency (?STElq) rating.17 Relaysshould not open lines automatically unless current substantially exceedsthe STE rating, but a damaged relay with contacts bent into a closedposition caused 81 to open improperly immediately after the opening of93 and 99. The 138 kv circuit between the Jamaica and Hudson Avenuesubstations (702) also opened due to a defective relay and was reclosedafter ten minutes.

The current flows in three major Con Edison transmissioncircuits exceeded their STE ratings by substantial amounts within secondsafter the second lightning stroke. The load on circuit 80 between theMillwood West and Pleasant Valley substations exceeded its STE rating bymore than 325 mw; the load in circuit 92 between the Pleasant Valley andLeeds substations exceeded its STE rating by more than 70 mw; and theload on the Linden tie exceeded its STE rating by more than 140 mw.

16 Con Edison Second Report, p. 42.- -17 Three ratings are in general use to describe the capacity of a

transmission line to carry electric power. The capacity is related tothe need to maintain the temperature of the line at a safe level.When a line carries power at or below its “normal” rating, it has thecapacity to carry such power on a continuous basis. At the long timeemergency @LTFo rating a line can carry such power continuouslyfor at least three hours. At the STE rating it can carry such powercontinuously for at least 15 minutes. Department of Public Service

to the Governor of the State of New- -

the lines. Their purpose is to provide a reference point for lineloading during emergency situations. When dire circumstances re-quire, even the STE rating can be exceeded without causing perma-nent damage to a line. Therefore, relays are not set to open a lineuntil current far exceeds the STE rating. On July 13 the Linden tieoperated substantially in excess of its STE rating for more than 13minutes, of which more than five minutes involved operation at170% of the STE rating, and circuits 80 and 92 were operated overtheir STE ratings for about 23 minutes before circuit 92 failed.

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Flows between Con Edison and LILCO and on a tie under the Long IslandSound between LILCO and Connecticut (the “Norwalk tie”) also changeddramatically, with the result that the load on the Norwalk tie exceededits STE rating by about 150 mw.

Following the second lightning stroke, the LILCO SystemOperator reduced the loading on the Norwalk tie to its STE rating. ThePool advised Con Edison to reduce the load on the Linden tie.18 By 9:04,the loading had been reduced through use of a regulating transformer (a“phase angle regulatorl’) by approximately 400 mw to a point more than200 mw below its STE rating. This had the effect of further increasingthe flows on circuits 80 and 92. The Con Edison System Operator hadrequested assistance from the Pool in unloading circuit 80 at 8:56. TheSenior Pool Dispatcher responded that he could not “pick anything upexcept from the north” and that Con Edison had “better shed some load”until it got “down below this thing.rr19 The substance of this conversationwas repeated at 9:02 and at 9:05.20 During this time, the Con Edison

18 “NYPP SPD [NYPP Senior Pool Dispatcher] : Bill, you’d better getthat Linden back or youll lose that baby too.

CE SO [Con Edison System Operator]: Yeah, I just lost 81.”

NYPP Senior Pool Dispatcher telephone tape transcript, July 13,1977 (“NYPP SPD Transcript”), reprinted in Con Edison SecondReport ,8:56:Om 6.

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19 I& 8:56:94, p. 7.

20 “CE SC: Look any better?NYPP SPD: No. You still got to get rid of about 400 Bill because

you’re 400 over the short time emergency on that 80line.

CESC: Yeah- that’s what Fm saying. Can you help me outwith that?

NYPP SPD: I can’t do nothing because it’s got to come from thelower part of the State, and there’s nothing there tohelp you with. You got to do it in.

CE SO: There’s no GT to put on because they went home.NYPP SPD: OK, then you’re going to have to shed load because

that’s the only way that thing is going to save you tilyou get them - things on because I told Long Islandto pick up everything he had and that’s the only placethat I can get into you.

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System Operator considered opening circuit 80, which would haveexacerbated the overload on the few other circuits still in service.21 Theoverloads on circuits 92 and 80 were not reduced after the second stroketo a level below their STE ratings.

At 8:56 the Con Edison Power Dispatcher ordered the 279 mwNarrows industrial gas turbines into service. These units take about 30minutes to reach maximum generation. Ten minutes later, he ordered the124 mw Astoria industrial gas turbines into service. The Pool asked LILCOto bring on its maximum generation at 9:04, and the Con Edison SystemOperator sounded the maximum generation alarm at 9~05.

Con Edison was directed by the Pool to initiate voltage re-duction at 9:09. It initiated such reduction at 9:13 and achieved 8% re-duction at 9:22. The Pool directed LILCO to reduce voltage by 5% at9:10, and this was achieved at 9:19. Con Edison did not attempt to dis-connect customer load prior to 9:19, although the Pool spoke to the ConEdison System Operator about such action on four occasions prior to thattime.

D. The loss of circuit 92

At 9:19:11 p.m. circuit 92 north of the Pleasant Valley sub-station in the Niagara Mohawk Power Corporation (“Niagara Mohawk”)service territory opened. Since circuit 92 is the northern extension ofcircuit 80, the opening of 92 resulted in the loss of circuit 80. Circuit 92had been operated above its STErating for approximately 23 minutes. Suchoperation causes lines to heat up, expand and sag toward the ground.Niagara Mohawk has since concluded that line 92 opened as a result of

* sagging into a tree. It was in the process of trimming trees under line 92

(cont.)NYPP SPD: There’s no way I can help you, see? OK Will?”ra, 9:02, pp. 9-10.

“CE SO: Dill, Tmgoing to cut feeder 80 - Pve no way of deloadingit right now.

NYPP SPD: Can’t you shed load and relieve it - if you cut feeder 80then you are really going to be in trouble.

CE SC: Fll see what I can do.NYPP SPD: Alright.”Id., 9:05, p. 11.

21 Id.

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during the week of July 13.22

The loss of circuit 92 severed Con Edison’s last 345 kv con-nection to the north and caused increased flows on the Linden tie comingin from the south, on the Jamaica tie to the east between Con Edison andLILCO and on the Norwalk tie between LILCO and Connecticut. Theincreased flows caused a transformer between the 345 and 138 kv systemsat Pleasant Valley to fail, which further aggravated loadings on the cir-cuits still in service. The loading on the Linden tie went more than 480mw over its STE rating to about 1,200 mw; the loading on the Jamaica tiewent well over its STE rating of 500 mw; and the loading on the Norwalktie went 100 mw over its STE rating to 350 mw.

At 9:22 LILCO opened the Jamaica tie with the approval ofthe Pool, thus further increasing the load on the Linden tie, which wasthen Con Edison’s one remaining major connection to outside powersources.

At 9:22 Con Edison made an unsuccessful attempt to reclosecircuit 81 by supervisory control from the Energy Control Center, ConEdison’s dispatch center in New York City. The Con Edison System Oper-ator has testified that he attempted to reduce consumer load by operatingthe 4 kv manual load shedding panel at 9t22.23 He completed the opera-tion at 9:27 with no impact on the load in the Con Edison system. ConEdison has re orted that he began to repeat the operation within the nexttwo minutes.%4 None of the other methods of manual load shedding wereattempted and no load was shed at this time.

E. The ?slandedrT Con Edison system

At 9:29:35 p.m. the loading on the Linden tie had reached 1,170mw, substantially in excess of its STE rating of 717 mw. This overload

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24

Testimony of Rudolph R. Schneider, Niagara Mohawk Vice-Presidentof Electric Production, State Hearin

----9pp. 1162-63. Niagara

Mohawk was unable to locate a burn mar which would indicate thepoint of flashover. It therefore cannot be conclusively determinedthat the flashover was due to the line touching a tree and, if so,whether the tree was one on which trimming had been completed.

7, p, 278 (deposition of William M.ator, read into the record).

State of New York Investigation

NEW YORK CITY BLACKOUTJULY 13, 1977

REPORT

Norman M. ClappSpecial Consultant in Charge of Investigation

Cleary, Gottlieb, Steen EC Charles P. Almon, Jr.,Hamilton, Special Counsel Technical Consultant

January, 1978

caused the failure of the circuit’s phase angle regulator, and the tieopened at 9:29:41. The resulting power flows over Con Edison’s remainingties to the outside world, two 138 kv circuits between the Pleasant Valleyand Millwood East Substations (11 and 161, quickly far exceeded the STBratings of these circuits, causing them to open. This resulted in the totalisolation of the Con Edison system from outside support - an island systemwith gross generation of 4,282 mw and gross load of 5,988 mw. Between8:36 and 9:29 Con Edison had brought on line 1,139 mw of its 2,021 mwtotal operating reserve that it expected to be available within the required30 minutes.

The critical events leading to the total collapse of the systemoccurred in the ten seconds following the loss of the Linden tie. Thegeneration deficiency on the Con Edison system of 1,706 mw caused thesystem frequency to decline rapidly.25 Ln less than three seconds, thesystem frequency decayed from 60.0 cycles per second (**hertz*’ or “Hz.~*)to approximately 57.8 Hz. This action triggered the automaticunder frequency relays designed to shed four predetermined blocks of loadat four distinct frequency levels in the event of frequency decline.26Because of the rapid frequency decay, the first three of the four blocks

25 System frequency declines when the disparity between load andgeneration in an isolated system slows the rotation of the generatorsserving the load.

26 The underfrequency relays are designed to shed the following per-centages of system load at the following frequency levels:

F r e q . (Hz.)Step IW.

1 59.52 59.33 58.84 58.35 57.8

CunulativeLoad Shed (%I Load Shed (%I

5 58 13

129 3”:

15 49

The first step at 59.5 Hz. causes sn 8% voltage reduction at areasubstations. This had already been accomplished manually. Theremaining steos disconnect load. Deoartment of Public Service StaffTask Force, Second Report to the-Governor of the State of NewYork on the Events Leadin to?&ConsolidatedEdino<prBlackoutaf xii-7& -d, Sesmber 15 , 197?FmdI?qzFiqp. - .

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were shed between two and three seconds after the opening of the Lindentie. While this

!reduced significant improvement in the balance of load

and generation, 7 it also resulted in a rapid rise in system voltage. Aseach block of load was shed, system voltage increased above the maximumpermissible levels (362 kv on the 345 kv system, 145 kv on the 138 kvsystem).

This voltage rise served to negate the beneficial effects of theload shedding. Just as frequency appeared to be nearing a return to 60 Hz.(a few seconds after the load was shed), the unacceptable voltage levelcaused Ravenswood 3 (generating 844 mw at 9229) to shut down at ap-proximately 9:29:48, seven seconds after the loss of the Linden tie.Ravenswood 3 was particularly vulnerable to the voltage increasesexperienced on the system and was the first generating unit to shutdown under isolated operation. 28 The loss of this generation was fatalto the stability of the system. Frequency on the system declined againcausin the last block of load to be shed by automatic underfrequencyrelays. 93 While this somewhat decreased the rate of frequency decline,the remaining generation on the system was insufficient to restorefrequency. 3o It continued to decline to between 54-55 Hz. over aperiod of four minutes. This soon caused protective relaying equipmentto shut down most of the remaining generating units in order to preventequipment damage. By 9:36, the entire Con Edison service territorywas blacked out,.

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Con Edison’s computer simulation indicates approximately 1,405 mwwere shed in the first three blocks. Con Edison Third Report, Vol.II, Table I, p. 23.

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Ravenswood 3 is connected to the 345 kv system rather than the 138kv system to which the majority of in-City generating units areconnected, and the 345 kv system experienced relatively highervoltage levels than the 138 kv system. Id., p. 37.

Con Edison’s computer simulation indicates that a total of 2140.6 mwof load was shed in the first ten seconds following the loss of theLinden tie. Id., Table I, p. 23.

After the trip of Ravenswood 3, there were 20 steam turbine gener-ators and 14 gas turbines remaining on line in the Con Edison system.I d , p . 6 . -

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CHAPTER II

The Events of September 26,1977

On September 26,1977, just 75 days following the blackout ofJuly 13, the Con Edison system again was faced with a major emergency asa result of repeated lightning strokes disrupting the bulk power trans-mission system. While in some ways this second episode was a more se-rious disturbance than that of July 13, total system collapse was averted.The events of September 26 demonstrated the usefulness of certain im-provements in the operation of the system instituted as a result of the July13 blackout, but also underscored many of the serious deficienciesremaining in the design and operation of the system.3l

A. Pre-disturbance conditions

At 2:20 on the afternoon of September 26, the load in the ConEdison system service territory was approximately 5,480 mw. Approxi-mately 2,760 mw was sup

52,720 mw was imported.$ed from in-City generation and approximately

Con Edison’s reported ten-minute reserveswere 325 mw and thirty-minute reserves were 1,581 mw.33 As on July 13,

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All data concerning the events of September 26 is derived from threesources: (1) a letter dated October 4, 1977 from Peter Zarakas toLester M. Stuzin of the Public Service Commission and an attackment setting forth Con Edison’s summary of the transmissionoperations, SItate Hearings, Exhibit 24 (“Se timber 26 Chronologyff);(2) testimoni Exhibits, State Hearings; and‘+fi transcript ofthe taped telephone communications at the Con Edison dispatchcenter prepared by Con Edison, State Hearings, Exhibit 48 (“September26 Telephone Transcript*% -

Pre-disturbance system conditions were very similar to those of July13:

Load if%GW w,6 mwIn-City generation 2,760 mw 3,008 mwImported power 2,720 mw 2,860 mw

Charles Durkin, Chief System Operator at Con Edison, agreed thatthe pre-disturbance conditions on July 13 and September 26 weresubstantially similar. Con Edison testimony (Durkin), StateHearings, pp. 523-24.

The reported reserves were not logged at the Con Edison dispatch

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the Hudson-Farragut tie was out of service. In addition, several Con Edisonand PASNY in-City generating units were not in service, including ArthurKill 2 (345 mw) and Astoria l(l73 mw), 2 (173 mw) and 6 (600 mw).

Since July 13, a number of improvements in operating proce-dures and equipment had been made by Con Edison in direct response tothe July 13 blackout experience.

(1) Stormwatch

Con Edison has developed a special **ThunderstormProcedurerfS4 for use when thunderstorms are approaching the Con Edisonsystem. Upon receiving a storm warning, a “Thunderstorm WatchRepresentative” reports to the dispatch center and assumes command.35Under the procedure the system is operated on the assumption that asingle circuit is already out of service. The system is then adjusted so thatthe loss of an additional double circuit will not cause flows over any othercircuit to exceed its LTE rating.36 If subsequent events cause loadingsabove LTE ratings, additional actions are prescribed: the bringing of allunits to their sustained ratings, the placing of gas turbines in service and,eventually, the selecting of areas for load shedding.37 The final step, ifSTE ratings are exceeded, is to institute load shedding to bring theoverloaded ties within their LTE ratings.38

(cont.)center. The quoted figures were calculated after September 26 fromreal time data in the operations computer. Con Edison letter datedDecember 7, 1977, State HearingIs, Exhibit 49.

34 Thunderstorm Procedure, Con Edison Operating Policy No. E-3-5,October 27, 1977 (“Thunderstorm Procedure”), State Hearings,Exhibit 50.

35 16, lf 2.1.

36 16, 114.0.

37 Id, 115.0.

38 Thunderstorm Procedure 116.0 states that if contingencies occur andSTE ratings are exceeded, Con Edison is to rl[pI roceed to go intoload shedding in order to bring the overloaded ties to within the LTErating.” Presumably, “load shedding” is to include voltage reduction,which is not otherwise mentioned in the procedure.

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(2) Additional oersonnel

After the July 13 blackout, the New York State Public ServiceCommission (**PSCtf or *Commissionfr) directed Con Edison to man keysubstations on a 240hour basis as an interim measure.39 Con Edisoncomplied40 and also began to man its gas turbine sites around the clock.41A new position had been added to the staff of the Con Edison dispatchcenter, that of Senior District Operator, with the duty to supervise andcoordinate reclosing and restoration operations.42 Finally, in contrastto July 13, the Chief System Operator was on duty and came to the floorof the dispatch center at about 3:26 to give assistance and direction.43

(3) Remote generation alarms

Fast load pickup and maximum generation alarms, which

39 Con Edison First Report, Introduction, p. 3.e-m40 Id Among the sites des@ated to be manned were the Ladentown and

Ramapo substations. Con Edison requested Orange and RocklandUtilities, Inc. to man those substations and agreed to reimburse itfor 100% of the cost of manning Ladentown and for the incrementalcost of manning Ramapo on weekends and in the 4:00 p.m. to 8:00 a.m.period during the week. Testimony of James J. McCarthy, Orangeand Rockland Assistant Vice-President of Engineering (“Orange andRockland testimony*‘), State Hearings, pp. 1054-56. The manning ofsubstations proved crit1-o the success of reclosing operations onSeptember 26. Con Edison testimony (Durkin), State Hearings, pp.547, 566; Orange and Rockland testimony, Statexings, p. 1071.

41 The ready availability of the gas turbines was an important factor inthe successful prevention of system collapse on September 26. ConEdison testimony (Durkin), State Hearings, p. 565. Because thedisturbance on September 2Gurred during the afternoon, at atime when most gas turbine sites were normally manned even priorto July 13, this change in operating procedure had little impact. Id.,pp. 545-46. However, the pre-July 13 manning schedule indicatesthat the Gowanus gas turbines (536 mw) would not have been mannedafter 3:00 and therefore would not have been available when light-ning struck at 3:21:56. PSC Second Report, p. III-18.e-

42 Con Edison testimony (Durkin), State Hearings, p. 546.

43 & pp. 514-15, 552.

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could be remotely Mggered from the dispatch center, had been installedat all gas turbine sites, and Con Edison had instituted monthly fast loadpickup tests.44

(4) Automatic reclosing on 97

Automatic reclosing equipment on circuit 97 was inservice on September 26.45

B. Chronology of events

At 2:20 p.m. on September 26, 1977, Con Edison’s weatherreporting service alerted the dispatch center to a heavy squall lineapproaching the Con Edison system. In accordance with the ThunderstormProcedure, the Con Edison System Operator increased in-City generationby approximately 100 mw and adjusted phase angle regulators to reduce theloadingson ties below normal transfer limits. It took the System Operatorapproximately 20 minutes to analyze and adjust the system.46

At 3:21:56 lightning struck the 230 kv Linden tie linking ConEdison to the PSE&G system in New Jersey. In order to protect the phaseangle regulator at the Goethals substation, this tie is not equipped withautomatic reclosing equipment. About ten seconds later, a secondlightning stroke caused a flashover on circuit 77, linking the Ramaposubstation of Orange and Rockland Utilities, Inc. (“Orange and RocklandTf)and the Rock Tavern substation of Central Hudson Gas and Electric Cor-poration (Ventral Hudson”). Protective relays operated to open circuitbreakers at both ends. Neither end reclcsed automatically. Less than aminute later lightning struck for a third time causing circuit 5018 betweenthe Ramapo substation and PSEhG’s Branchburg substation to flash over.The circuit breakers opened as designed, then closed successfully at theBranchburg end. However, the tie failed to reclose automatically atRamapo.

Despite the loss of three single circuit transmission lines, allother circuits on the system remained within their normal ratings and

44 I&, pp. 582-83.

45 Testimony of Frank E. Fischer, Con(“Con Edison testimony (Fischer)“),

Edison Chief Electrical EngineerState Hearings, p. 781.

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letter); Con Edison testimony

imports were approximately at normal transfer limits.47 At 3:26, ap-proximately four minutes after the initial lightning stroke, the SystemOperator signaled for fast load pickup.48

At 3:29:12 a fourth lightning stroke caused circuits 94 and 72,two 345 kv circuits on a common tower, to flash over simultaneously.Circuit 94 opened and reclosed automatically at both ends, Howeverautomatic reclosing was not successful for circuit 72. This fault on 94 and72 caused a voltage dip which triggered protective devices at Indian Point2 and 3, causing those generating units to shut down automatically.49Indian Point 2 shut down because protective circuits incorrectlyinterpreted the voltage dip as a loss of power.50 Although modificationshad already been made at Indian Point 3 to correct this problem, one ofthe instrumentation channels was out of service,

9lacing the unit in the

same status as Indian Point 2 and it too shut down. 1

The loss of Indian Point 2 and 3 caused circuit 81 to exceed itsnormal rating, circuit 80 to reach its normal rating, and the imports toexceed emergency transfer limits.52 At approximately 3:29, the SystemOperator called for maximumgeneration. It was at this point that he firstcontacted the Pool to request assistance and direction.53 At approxi-

47 Con Edison testimony (Durkin), State Hearings, p. 514.

48 September 26 Chronology, p. 1. Gas turbines had been started priorto the first hghtning stroke to replace some of the generation whichwas being provided by steam units as part of Con Edison’s reserverequirement. These steam units were needed to meet scheduled loadchanges later in the afternoon of September 26. Con Edison testi-mony (Durkin), State Hearin , pp. 528-32, 537-38. With the loss

----9lof three single circuit hnes, t e System Operator brought up thisgeneration from the gas turbines more quickly than normally bysignaling for fast load pickup. Id, pp. 548-49.

49 September 26 Chronolo---sir=

pp. l-2; Con Edison testimony (Durkin),State Hearings, p.

50 Con Edison testimony (Fischer), State Hearings, p. 761.

51 Id, pp. 763-64.

52 Con Edison testimony (Durkin), State Hearings, p. 515.

53 Id. p. 515. He apparently asked the Pool to request LILCO to go to35 voltage reduction. note 63, infra.

22

L

I:L

mately 3:31, the System Operator instituted a systemwide 8% voltagereduction, which reduced load by approximately 250 mw,54

The voltage dip that triggered the automatic shutdown ofIndian Point 2 and 3 also caused undervoltage relays at Bowline Point 2to shut down the plant’s circulating water pumps. To prevent pressurefrom building up in the condenser, the Orange and Rockland plant operatorshut down the unit manually at 3:32.55

The combined effect of the loss of Indian Point 2 and 3 andBowline Point 2 was to deprive the Con Edison system of approximately2,144 mw of generation or almost 40% of its load.56 Furthermore, theloss of Bowline Point 2 caused circuit 81 to exceed its STE rating’andcircuit 80 to exceed its normal rating.57 Reclosing efforts up to this timehad not proved effective. Circuits 72, 77 and 5018 all failed to recloseautomatically at Ramapo. Circuit 72 failed to reclose because of adamaged reclosing circuit. Circuit 5018 failed to reclose because of awiring error in a relay in the reclosing circuit.s8 Circuit 77 did not reclosebecause the recloeing circuits had been deactivated - the switch at theRamapo substation which places the reclosing system in service wasincorrectly in the “off” position. No explanation has been offered byOrange and Rockland for this circumstance.59 The Linden tie (which is not

54

55

56

57

58

59

September 26 Chronology, p. 2; Con Edison testimony (Durkin), StateHearings, p. 572.

Orange and Rockland testimony, State Hearings, p. 1076; Con Edisontestimony (Fischer), State Hearisp. 762.

Se tember 2s Telephone Transcript, p. 76; Con Edison testimony&&$-&ate H+ p. 556. Also, approximately 400 mw ofgeneration was su sequently lost when Astoria 4 shut down at 4:04during a routine switching operation, Se tember 26 Telephone

dTranscri t pp. 55, 83 (WZon Edison System Operator : I lost Indian9--7--

and 3, Bowline and Astoria 4. I lost 2659 megawatts ingeneration. That’s a lot.“); Con Edison testimony (Durkin), StateHearings, p. 520.

Id., pp. 516, 553, 559.

Orange and Rockland testimony, State Hearings, pp. 1060-63,llO4-06; Con Edison testimony (Fischermte Hearings, p. 770.

Orange and Rockland testimony, State Hearings, pp. 1060, 1064; ConEdison testimony (Fischer), Statexings, pp. 770-71.

23

equirii

ed with automatic reclosing) was energized from Linden at about3:51. However, supervisory controls for reclosing at Goethals apparentlydid not work6 1 Since the Goethals substation was not manned, reclosinghad to await the arrival of an operator and was not actually achieved untilover 25 minutes later.62

Maximum generation and voltage reduction on the Con Edisonand ULCO systems, which had been instituted at approximately 3:30,63failed to bring down the loading on circuit 81, which was still over its STErating. In fact, as load picked up because of the increasing darkness,the loading on 81 was actually increasing.64 At 3:37 an in-City gas turbine(158 mw) shut down because of a fault which occurred during an attemi; tobring the unit on line in response to the maximum generation alarm. Inlight of this, plus the fact that the thunderstorm was now approaching theimportant northern transmission corridor, the Con Edison Chief SystemOperator and System Operator decided that load shedding would be nec-essary to bring circuit 81 within its LTE rating.66

Consequently, at 3:40 the White Plains substation load sheddingequipment, which had recently been returned to service following

60

61

62

63

64

65

66

September 26 Telephone Transcript. p. 44.

ra, pp. 44-47.

& pp. 45, 64.

At Con Edison’s request, the Pool asked LILCO to go to 5% voltagereduction at about 3:32. Se tember 26 Tele hone flanscript, pi,

---!+-7- +---27, 29-30. Although Mr. Dur n test1 led t at it Droved unnecessarvfor LILCO to c&y out this request, the Pool appears to ha&reported to Con Edison at 4:03 that LILCO had achieved 5% voltagereduction. Con Edison testimony (Durkin), State Hearings, p. 55s;P-,--+-T-f;Se tember 26 Tele hone Ranscri t p. 53. =O also brought itsgeneration up qtuc ly, Increasing t e loading on the Jamaica tie toCon Edison. Con Edison testimony (Durkin), State Hearings, pp.557-58; September 26 Telephone Transcript, p. 29.

Con Edison testimony (Durkin), State Hearings, p. 517.

ra, p. 567.

Id., pp. 517, 567-68.

24

maintenance,67 was operated successfully using the 4 kv load sheddingpanel in the dispatch center.;zztQ;gUbstation.68

At 3:42 load was shed at the WashingtonThese steps, in addition to other measures already

reduced the loadings on 81 and 80, and by 3:46 i,mports werebelow emergency transfer limits. However, because of the storm’scontinued threat to the northern corridor and the potential loss of anotherdouble circuit line, another network at Pleasantville was shed at 3:50 asa precaution.7o In all, approximately 200 mw of load were shed throughdisconnection of customers.7l

An attempt was then made at 3:53 to reclose circuit 77 manu-ally. When the breaker at Ramapo closed, however, a defective voltagerelay at Rock Tavern operated, causing the breaker backup timer to sensea fault and trip both circuits 77 and 311.72 A few minutes later, at 3:56,circuit 5018 was successfully reclceed, providing an important path forpower into the system from PSE&G. This reclosure placed the system ina position to withstand the loss of a double circuit line in the Pleasant

67 September 26 Telephone Transcript, p. 17.

66 Se tember 26 Chronology, p. 2. Mr. Durkin testified that the choice--+----o areas for load shedding was made on the basis of which stationswere available for disconnection and happened to be in the first rowon the console. Con Edison testimony (Durkin), State Hearings, pp.570-71

69

70

71

4I!- 72

The actual ten-minute generation reserve response on September 26,at 3~40, was an increase of 468 mw compared with a 397 mw in-crease on July 13. Con Edison testimony (Durkin), State Hearings,p. 528. On September 26, unlike July 13, Con Edismhieved allof its expected ten-minute reserve. In fact, more than the expected325 mw was obtained due to the fact that gas turbines had beenstarted prior to the disturbance to meet scheduled changes. See note48, supra.

Con Edison testimony (Durkin), State Hearings, pp. 569-70, 590.

Idb pp. 57l-72. Additional load relief in an unknown amount may haveeen obtained through public appeals on radio and television and

requests made to large commercial customers. Con Edison testimony(Fischer), State Hearings, pp. 844-45.

Id, pp. 776-77, 780-81; Orange and Rockland testimony, StateHearings, p. 1063.

25

TABLE OF CONTENTS

Introduction

Chapter I. The July 13, 1977 Bulk Power TransmissionFailure and Con Edison System Collapse

A. Pre-disturbance conditionsB. The first lightning strokeC. The second lightning strokeD. The loss of circuit 92E. The %landed” Con Edison system

Chapter II. The Events of September 26, 1977 18

A. Pre-disturbance conditions 18B. Chronology of events 21

Chapter lII. Analysis and Conclusions 28

A. Facilities out of serviceB. Planning and design deficienciesC. Equipment failureD. Operation without an adequate safety marginE. Lack of coordination and direction in

meeting emergenciesF. Inability to maintain the isolated system

Chapter IV. Existing Administration of theBulk Power Transmission System

A. The New York State bulk power gridB. The utilitiesC. New York Power PoolD. Northeast Power Coordinating CouncilE. Public Service‘ CqmmissionF. Federal role

Chapter V. Recommendations 76

Page

1

7

79

111415

28313840

4557

62

626365676872

Valley right-of-way, and Con Edison felt that it obviated the need forfurther load shedding.73

At 3:58 a fifth lightning stroke caused circuit 97 to flash over.Because of the new reclcsing device which had been installed after July13, the relays cleared the fault and 97 was automatically restored toservice. At approximately 4:01 line 3ll was reclosed manually. At 4:14circuit 77 was reclosed manually at the Ramapo substation, approximately52 minutes after its initial loss. At 4:17 the Linden tie was successfullyreclosed manually at Con Edison’s Goethals substation, approximately 55minutes after it had first opened.74

By 4:22’Con Edison was able to begin restoring service to theareas which had been disconnected, and by 4:33 restoration of normalvoltage had begun. At 4:31 circuit 72, the last remaining circuit out ofservice, was reclosed manually at Ramapo, about one hour after it hadinitially opened.

At 4:34:48, just as the Linden tie began to carry substantialload into the Con Edison system, circuit 81 opened. The fault was stillpresent when automatic reclosing was attempted,75 but by 4:38 both ends

73 Con Edison testimony (Durkin), State Hearin@ p. 591.

74 At about 4:08, the Staten Island District Operator informed the ConEdison System Operator that he had given orders to nscopelt forsynchronization and cut in the Linden tie. September.26 TelephoneTranscript, p. 57. Eight minutes later the tie was still out of ser-vice. In view of the importance of the Linden tie and the lengthydelay which had already been caused by the necessity of dispatchinga man to the substation, the Con Edison System Operator orderedthat the tie be manually reclosed immediately, without checkingsynchronization. Id, p. 62. The tie recloeed at 4: 17 apparentlycarrying zero load. This confused both the Con Edison and PSE&Gsystem operators as to whether the line was actually in service. Id.,pp. 64-65, 68. By about 4:24, the monitoring equipment continuedto reveal only a minimal flow over the line, but within a few minutesthe readings began to climb and it became certain that the Lindentie had been successfully restored. Id., pp. 68-71.

75 It is unclear what caused the fault. Mr. Fischer testified that twocharacteristics of the fault on 81 indicated that it may not have beencaused by lightning: the occurrence of two separate faults on dif-ferent phases in a very short period of time and the fact that thefault was still present when reclosing was attempted. An alternate

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i

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had been reclcsed manually. At 5:33 yet another circuit (398) was hit bylightning. This line opened and reclosed successfully. At 5:34 circuit 81opened at Pleasant Valley but was reclosed by supervisory control fromthe dispatch center to continue carrying power into the City.16

(cont.1explanation is a tree limb or other debris blowing across the line.Con Edison testimony (Fischer), State Hearings, pp. 773-74, 776.

76 g+-----Se tember 26 Telephone Transcript, p. U; September 26-Chronology,

27

CHAPTER III

Analysis and Conclusions

This Chapter analyzes the events of July 13 under headingswhich reflect the major contributing causes of systemcollapse: (1) neededfacilities were out of service; (2) planning and design deficienciescompromised system reliability; (3) equipment failed to operate properly;(4) the operation of the system was not promptly adjusted to account forthe loss of transmission capacity and required safety margins were notmaintained; (5) coordinated responses to emergency conditions which couldhave prevented transmission collapse were not implemented; and (6) theCon Edison system failed to achieve stability after it became isolated. Theanalysis includes discussion of the events of September 26 insofar as theyshed light on these critical areas. The conclusions set forth with respectto each area seek to identify the key lessons to be learned from thedeficiencies revealed in the record.

A. Facilities out of service

When lightning struck at 8:37 on the evening of July 13, im-portant facilities were not in service - the system was not up to itsdesigned strength. The Hudson-Farragut connection between New YorkCity and PSE&G in New Jersey had been out of service since September4, 1976 due to the failure, for the third time, of a phase angleregulator.77 This tie is important both for its transmission capacity18 andbecause it provides a separate, or f’diversett path for the transfer of powerinto New York City. The automatic reclosing equipment on circuit 97,one of the high voltage circuits in Westchester County, was out of servicepending the installation of equipment of different design.lirg This equip-

77 Con Edison testimony (Zarakas), State Hearings, pp. 256-57.

78 .The Hudson-Farragut tie has a normal rating of 518 mw and a 1,043mw S’I’E rating.

79 Con Edison Second Report, p. 29. High speed automatic reclosingafterzximately one-third of a second is generally provided foroverhead lines in the Con Edison system. The main exception is linesthat terminate at generating stations. Although high speed reclosingwas installed on circuit 97, it was not in use because Con Edison feltthat such reclosing could damage generator shaft!?. Slow speedreclosing after ten seconds, which includes the use of a synchronouscheck relay, provides a means to reclose a line which terminates ata generating station with reduced risk of damage. On July 13 slow

28

ment is necessary promptly to return to service a line hit by lightning.Approximately 606 mw of Con Edison’s reported ten-minute reservegeneration of 1,344 mw was not in fact available.8O In the case of 44quick-start gas turbine units, this was because they were unmanned andno facilities had been provided for remote start.8l

Each of these outages significantly weakened the capacity ofthe system to withstand transmission emergencies. The availability of theHudson-Farragut tie alone would have prevented the collapse of thetransmission system 6n July 13.82 The availability of the gas turbine unitswould have permitted a greater and more rapid increase in in-City gen-eration after transmission difficulties made it necessary to reduce imports.This too would have averted the July 13 blackout.83 Automatic reclosingof circuit 97, while not sufficient in itself to have prevented the blackout,would have facilitated the restoration of an important transmission pathacross the Hudson River.

The critical impact that out-of-service facilities can have isunderscored by the events of September 26. Because an instrumentationchannel at PASNY’s Indian Point 3 was out of service, the system lostapproximately 850 mw of generation when that unit shut down during avoltage dip. The unavailability of automatic reclosing on circuit 77,

(cont.1speed reclcsing equipment had been installed on circuit 98 but hadnot yet been installed on circuit 97. Con Edison testimony (Fischer),State Hearings, pp. 305-09.

80 Con Edison Third Report, VoL V, pp. 72-73.- - -

81 & p. 85; Con Edison Second Report, Appendix Ill.- -82 If the Hudson-Farragut tie had been in service, it would have had the

capacity to carry a flow of 699 mw for at least three hours and aflow of 1,043 mw for at least 15 minutes. The utilization of thisadditional capacity would have reduced the flows in circuits whichremained in service after the two lightning strokes. This reductionwould have been sufficient to have kept both circuits 80 and 92 belowtheir STE ratings following the second stroke.

83 The 338 mw increase in generation which might have been obtained by8:55 if the Gowanus and Ravenswood quick-start gas turbines hadbeen manned (or connected for remote control) would have reduced -the flow on circuits 80 and 92 such that their STE ratings would havebeen exceeded for substantially less than 15 minutes, if at all.

29

simply because a switch incorrectly set in the f’off’* position deactivatedthe reclosing mechanism, deprived the system of a critical path for gen-eration.

In important respects, efforts to avoid or minimize theunavailability of facilities were lacking or inadequate; In the case of theHudson-Farragut tie, although the phase angle regulator had failed twicesince being placed in service ‘n December 1972, a spare was not ordereduntil after the third failure.8d At that time Con Edison did not attemptto repair the faulty transformer, even though a replacement was notexpected until May 1978.85 Subsequent to the events of July 13, ConEdison completed a program begun in the fall of 1975 (and originallyscheduled for completion in 19761 to reinforce underground cables, andcompletion of this program has allowed use of the Hudson-Farragut tiewithout the phase angle regulator.86

Most of the gas turbines would have been available had theybeen manned or had remote-start facilities been provided. In any event,there is no excuse for Con Edison’s incorrect representation of theavailability of these unmanned units when reporting its reserves to thePOOL87

There is also no apparent reason why Con Edison could notsooner have arranged to install the new reclosing equipment on circuit 97that had already been installed on circuit 98. Most extreme is thelack of justification or excuse for the disconnection of automatic reclosingfacilities at Orange and Rockland’s Ramapo substation on September 26.

Conclusions

1. While it is admittedly not possible to have all facilities availablefor service all of the time, the record indicates an unwarrantedcomplacency on the part of the operating utilities and the New YorkPower Pool with respect to the unavailability of critical facilities.Although the immediate offenders revealed when the system wastested by the events of July 13 and September 26 are Con Edison andOrange and Rockland, all the utilities sharing in the collective

84 Con Edison testimony (Zarakas), State Hearings, p. 268.

85 Id, pp. 256, 268.

86 Con Edison Third Report Vol. I, p. 5 1.m--87 Id, VoL V, pp. 72-73.

30

e

c-JI!-

.J

4li-

II.A-

88

89

90

91

92

management of the bulk transmission grid through the mechanismof the New York Power Pool must also share responsibility for thelack of a proper sense of urgency in maintaining all facilities of thesystem in a maximum state of readiness.

2. The reliability of the total system is jeopardized by the sub-standard level of performance of any of its parts. The inclinationand practice of the Pool to rely on the individual member utilitiesfor the maintenance of portions of the bulk transmission systemwithin their respective service areas tend to permit the poor per-formance of asingle utility to depreciate the reliability of the wholesystem.

B. Planning and design deficiencies

The events of July 13 and September 26 reveal importantplanning and design deficiencies. A key weakness is the reliance placedon a narrow transmission path running from New York City to the north.Approximately 80% of the transmission capacity to New York City islocated in this corridor.88 At one point in Westchester the five trans-mission circuits that constitute the northern transmission capacity are allwithin a corridor approximately 250 feet wide.8g Thus a single lightningstorm, local wind storm,g0 ice storm,gl aircraft accidentg2 or other such

The normal ratings of lines in the four main paths between the ConEdison system and outside sources of power are: northern path -1,590 mw (931, 1,135 mw (981, 1,305 mw (971, 825 mw (80) and 825mw (81); eastern path : 272 mw (Jamaica tie); southern path - 505mw (Linden tie); and western path - 518 mw (Hudson-Farragut tie).

Con Edison. Third Report, VoL V, p. 18.- - -

A local windstorm may have caused the loss of circuit 81 onSe~t;~ber 26. Con Edison testimony (Fischer), State Hearings, pp.

.

In March 1976, ice storms resulted in power outages of up to 11.5hours in the New York State Electric and Gas Corporation andNiagara Mohawk service territories. Federal Power Commission,Supplement to Staff Report on JI$ 13-14, 1977 Electric SystemDisturbance on t~o~~te~Edlsonipfiof New York, Inc.System, AufiT1977 (“FPC Supp. Report , p.- - - - - - + a - - -

On December 10, 1976, a National Guard helicopter crashed into aTennessee Valley Authority 161 kv transmission line west of

31

event can have a major effect on transmission.

Con Edison now plans to continue dependence on transmissioncapacity to the north of New York City. A program of northern trans-mission reinforcement is underway to provide, among other thin

5%transmission capacity for increased purchases of Hydra-Quebec power.Con Edison’s planned transmission additions outside New York Citythrough 1992 primarily involve reinforcement and undergrounding ofnorthern transmission, with the exception of a planned reinforcement ofthe Hudson-Farragut tie and a new 345 kv tie to Long Island.g4 In thewake of July 13, Con Edison has proposed still further northern trans-mission reinforcement as well as some widening of the northern corridor atits narrowest point.g5

Another weakness revealed by the July 13 events was theplanned shutdown of the Indian Point 3 unit following temporary trans-mission interruptions on the transmission line carrying circuits 97 and 98.Even if these circuits reclose following a lightning disturbance, substationand transmission design is such that it is necessary to halt an 873 mwcapacity generating unit that cannot be restarted for several hours. Thisshutdown occurs despite the availability of circuit 88 to carry the IndianPoint 3 output.

Related problems also played an important role in theSeptember 26 disturbance. On July 13 only Indian Point 3 shut down dueto transmission interruption. On September 26 both Indian Point 2 and 3,as well as the Bowline Point 2 generating unit, shut down followingtransmission outages west of Indian Point - outages which did not includelines between New York Cityand Indian Point or Bowline Point. This lossof approximately 2,100 mw of generation caused flows on transmission

(cant .)Chattanooga, Tennessee, which disrupted service on that line.

93 Con Edison testimony (Deegan), State Hearings, p. 717.

94 NYPP and Empire State Electric Energy Research Corporation, Re-port Pursuant to Article VIII Section 149-b of the Publid SerGeLaw (~~lpp.l& ~~pp.~l~5~2~KReinforcement of the Hudson-Farragut tie has been delayed bycontinuing negotiations between Con Edison and PSE&G over fi-nancial terms. Testimony of Charles F. Lute, Chairman of theBoard of Directors of Con Edison, City Hearings, August 30, 1977,pp. 358-60.

95 Con Edison Third- - Report, VoL I, p. 30.

32

di.!

lines to the north of Indian Point to increase above emergency limits andmade load shedding necessary.

The events of July 13 reveal other shortcomings in transmissionand switching design. Two circuits (94 and 88) cross the Hudson River intothe Buchanan substation. These two Hudson River crossings not onlyprovide the primary path to carry the output of the Bowline Point andRoseton generating units to New York City, but they are also New YorkCity’s link to the only direct interconnection between New York State andthe 500 kv Pennsylvania-New Jersey-Maryland grid. ‘Iwo transmissionlines (93 and the double circuit line 97/98) run out of Buchanan toward NewYork City. However, the circuit breaker configuration at Buchanan issuch that one or the other of the Hudson River crossings is taken out ofservice by the Ioss of either of the lines out of Buchanan toward New YorkCity.g6 This design also increases the number of circuits that will haveto be reclosed during emergencies.g7

Many of the design problems that played a role in the eventsof July 13 and September 26 were the result of intentional design com-promise. For example, a 1972 Con Edison-PSE&G study considered sixoptions for increasing transmission capacity in the New York/New Jerseyarea: five options for new PSE&G-Con Edison ties to the west or southof the City and one option for independent reinforcement by Con Edisonof the transmission corridor to the north.98 The independent reinforce-ment option was selected because it was said to be $18 million cheaper.99While Con Edison has recently conceded that this cost difference was

96

97

98

99

See diagram, Appendix-l. This condition means that there are aeter number of ways in which transmission outages can cuttransmission over the Hudson River. & designed, the loss of circuits(a) 94 and 88; (b) 93, 97 and 98; (cl 88 and 93; or (d) 94, 97 and 98would sever connection across the Hudson. If the lines in and out ofBuchanan were fully connected, only condition (a) or (b) would bringabout this result. )

On July 13 this meant that three circuits (88, 93 and either 97 or 98)instead of two (88 and any of 93, 97 or 98) had to be reclosed torestore transmission over both the northern Hudson River crossings.

Con Edison-PSEffi, “Joint Study, Additional Interconnection in the1975-1976 Period, Final Report” (March 19721, State Hearings~Exhibit 25.

Id, Table L

.

33

overstated by approximately $3.5 million,loO the important point forpresent purposes is that selection in 1972 of one of the more reliable,diverse path options would have prevented the July 13 blackout.101

Not only has the ability to transmit bulk power to New YorkCity been jeopardized by this lack of path diversity, but even the vitalnorthern corridor has been weakened by intentional design compromises.The factors which were considered in the design of transmission andswitching at Buchanan, for example, show both compromise and astraining of Pool reliability criteria to their limits or beyond. Despite theNYPP requirement that a transmission system be designed for the con-tingency of the loss of a double circuit transmission facility,162 ConEdison documents show that the Company WBS aware in 1973 that designingfor the loss of the double circuit line 97/98 out of Buchanan would resultin “inadequate import capability. ??lo3 The loss of circuits 97 and 98 fol-lowing a lightning stroke to the tower which carries both these circuits wasthe event which initiated the crisis of July 13. Con Edison did not designfor this contingency, and apparently felt that it had not thereby violatedthe NYPP design requirement, only because the towers which carry the345 IW circuits 97 and 98 outside the tower also carry two 138 kv circuitswithin the tower structure and the 97/98 circuits are thus not adjacent.l O4

100

101

102

103

104

Con Edison letter dated December 16, 1977, State Hearings, Exhibit49.

The impact of an additional $14.5 million investment in 1974 on thecoat of electricity to Con Edison consumers would have been lessthan one tenth of one percent of their bill - less than one cent ona $40 monthly electricity bill.

NYPP, “Design Standards for Long Range Planning and Studies ofShort Range Operating Limits,n Con Edison Third Report, VoL V,- - -Appendix I.

Memorandum dated September 25, 1973 from John E. Deegan, Jr.,Con Edison Planning Engineer, to Lawrence A. Kominiak, et aL,(“September 25, 1973 Memorandum”), State Hearings, Exhibit2c

Con Edison Third Report, VoL V, pp. 13, 26. The Pool requirementmaksTq= exception for non-adjacent double circuits. TheNPCC design criteria do specify “faults on different phases of. . .two adjacent transmission circuits on a multiple transmissioncircuit tower. . . .1’ See note 13, supra.

1.

34

Yet Con Edison studies show that the risk of a double circuit flashover onthese towers is of the same order of magnitude as on a typical doublecircuit t0wer.l O5 It thus appears that Con Edison and the Pool (becauseplanning is done on a Pool-wide basis) have planned for a transmissionsystem with inadequate strength to withstand foreseeable lightningdisturbances.

The refusal to plan for the loss of the 97/98 double circuittransmission line also led to the design compromise which requires IndianPoint 3 to be shut down following a temporary fault on circuits 97 and 98.Indeed Con Edison went so far as to modify the order in which circuits areconnected at Buchanan in order to avoid a reliability criterion which wouldhave required treating the loss of 97/98 as a design contingency.108 Thenew arrangement means, however, that the loss of the 97/98 line opens allavailable circuit breakers, thereby shutting down Indian Point 3.1°7 Thisis precisely what occurred on July 13. Had Con Edison kept withinestablished design criteria through transmission reinforcement and pro-vided a more reliable design at the Buchanan substation through the in-stallation of additional circuit breakers, the loss of Indian Point 3 wouldnot be a planned occurrence following a double circuit flashover on97/98.1°8

105

106

107

108

Con Edison has stated that based upon a design footing resistance often ohms, the probability of a double circuit flashover on the 97/98line is once in every 30-40 years, and on the conventional 93/99 lineit is once in every 15-20 years.30, 33.

Con Edison Third Report, VoL V, pp.- - -

The then existing configuration resulted in the loss of 97 and 98 as aconsequence of a fault on 97 or 98 followed by circuit breakerfailure. Design criteria require that the loss of a circuit followed bya breaker failure be treated as a design contingency. September 25,1973 Memorandum, supra note 103.

Con Edison Second Report, p. 9; Con Edison testimony (Fischer),State Hearings, pp. 315-16.

The documents submitted by Con Edison contain reliability studies fortwo switching configurations that were not used at Buchanan, butno reliability study for the switching configuration that is in fact inplace. See Con Edison study by Raymond C. Chan (assistantengineer),ctober 8, 1968 and Con Edison study by Eddie K. Chew(assistant engineer), May 2, 1969, State Hearings, Exhibit 25.

35

’ !

Appendix I: Maps and Diagram

Appendix II: Table and Charts

Appendix II& Comments on sections 541 and545 of H.R. 8444 (proposedNational Energy Act)

Appendix IV: List of Witnesses

Another example of compromise in the design of the switchingand transmission facilities in the northern corridor is the decision reachedby Con Edison in 1973 to avoid the overloading of circuit 97 or 98 followingthe loss of the other by intentionally opening circuit 88 across the HudsonRiver.log A letter dated September 29, 1975 from Robert F. Wolff, Man-ager of the Con Edison System Operation Department, to Rolland A.Merrill, Jr., Operating Manager of the New York Power Pool, states thatthis planned loss of circuit 88 will be necessary “at least until a strongparallel path to the RamapeMillwood area is constructed.“l1°

The loss of. transmission over the Hudson River as a result ofthe loss of a line out of Buchanan could have been avoided either by sub-station redesign coupled with transmission reinforcement betweenBuchanan and Millwoodlll or by the use of special equipment (seriesreactors) to balance line loadings. Use of this equipment was rejected in1970 when it was discovered that it would cost $8.9 million rather thanthe approximately $1 million that Con Edison had expected and that oneutility had not had good experience with this equipment.l12

The design deficiencies revealed by the events of September26 were also avoidable. The condition which caused Indian Point 2 to shutdown because of a voltage dip had been discovered approximately a yearearlier in connection with asimilar fau.lt.l13 Equipment which would haveadded an additional buffered power supply to prevent undesired response

109

110

111

112

113

Letter dated October 25, 1973 from Francis DeLea (Con EdisonDivision Engineer) to George D. Rockefeller (Con Edison AssistantProtection Engineer), State Hearings, Exhibit 25.

State Hearings, Exhibit 25.

See Con Edison Third Report, VoL V, p. 16.( T h e “ b r e a k e r a n d a h a l f ”configuration mxned by Con Edison would avoid the loss of cir-cuit 88 or 94 as a result of a loss of a line out of Buchanan.)

Memorandum dated October 2, 1970 from William J. Balet to RobertF. Wolff, State Hearings, Exhibit 25. Con Edison does not appearto have cased the use of this equipment on a standby basis topermit maximum availability of the Hudson River- crossings.

Con Edison testimony (Fischer), State Hearings, pp. 766-67.

36

to voltage fluctuations had not yet been installed.114 Similarly, Orangeand Rockland had not installed equipment which would have avoided theloss of Bowline Point 2 following a voltage dip. Orange and Rocklandapparently felt these improvements were not technically proven.115

Finally, while improved control facilities are not a panaceafor more basic system deficiencies, inadequacies in Con Edison, Orangeand Rockland and NYPP control room facilities do impede effective re-sponse to emergency conditions. The Con Edison System Operator’sunawareness on July 13 of the loss of circuit 93 was attributable in partto inadequate display of breaker status information. In 1975 fire destroyedOrange and Rockland’s dispatch center and that utility has had only askeleton control facility since that time.l16 More extensive supervisorycontrol equipment at Orange and Rockland could have facilitated meetingthe crises of both July 13 and September 26. The New York Power P&lhas a modern and in many ways model control facility. Still, there is noprovision for immediate calculation of necessary modifications to levelsof bulk power transfer following the loss of transmission facilities.l17 Thusthe Senior Pool Dispatcher was apparently unaware on July 13 that emer-gency transfer limits under the new operating conditions were beingexceeded following the first lightning stroke.

In 1974 the Boeing Company, which Con Edison had retainedto review the adequacy of control facilities, called attention to importantdeficiencies. The Boeing study concluded that Con Edison system opera-tors depended on “[pl ast experience and extensive exposure to varied loadsituations . . . to correct impending and actual problems1~l18 and that

“1 dl uring normal operating conditions the System Operator andDistrict Operators are provided with a minimum amount of

114 These modifications had already been made on the Indian Point 3 unit,and installation of similar equipment was planned for the Indian Point2 unit. la, p. 763.

115 Orange and Rockland testimony, State Hearings, pp. 1076-79.

116 Id, pp. 1080-82.

117 Testimony of RoIland A. Merrill, Jr., Operating Manager of NYPPtrlNYPP testimonyf$ State Hearings, p. 169.

118 Boeing Company, EnerReport), Februaryd

Control Center Lon Ran e Plan (Task II4,StateHearin@, %1&,5-36.

37

data to allow them to maintain cognizance of the system sta-tus. At times of overload, or transient change conditions, theoperators are not provided with sufficient data, in a readilyavailable form, to allow rapid and reliable decisions.wl19

Despite these conclusions, control room modernization was one of theprograms curtailed in Con Edison’s 1976 capital budget by reason of the

ally.1 20

3, The overall planning and design of the bulk transmission systemare compromised by the financial limitations of the individualutilities that build its components. The result has been a significantsacrifice of essential reliability. This is evident in the shaving orpostponing of important capital outlays and in the dangerous preoc-cupation of Con Edison with its transmission corridor to the northaimed in part at procuring larger amounts of what is presently lessexpensive Canadian hydroelectric power. A consequence of this hasbeen the neglect of a more diversified pattern of transmission tiesto the east, south and west.

4. The Pool has not enforced systemwide standards for reliability,planning and design. The Pool has tolerated design practices whichsubstantially impair the firm availability of transmission and gen-eration resources and appears to lack the incentive and authority toinject the overall system interest into the cost/reliability calcula-tions made by the individual members.

C. Equipment failure

Equipment failure played an important role in the events ofJuly 13 and September 26. On July 13 circuit 88 opened due to animproperly designed relay, circuit 81 opened because of a bent relaycontact, and circuit 702 opened because of a defective relay. Circuit 98did not reclose because of a loose locking nut on a circuit breaker. Circuit

119 Id. p. 58. In reaching these conclusions, Boeing noted that the ConFa’Leon System Operator did not have access to on-line interactiveload flow computations and that transfer limits were calculated bythe engineering department using off-line study programs. Id., p.36.

120 Con Edison testimony (Deegan), State Hearings, pp. 659-60.

38

93 did not reclose because a relay setting, since modified, preventedreclcs ure. On September 26, circuit 72 failed to recluse because of adefective coil in a time delay relay in the reclosing circuit and circuit 5018failed to reclose because of a wiring error in one of the interlocking relaysin the,reclosing circuit. When an attempt was made to reclose circuit 77manually at Ramapo, a defective voltage relay at Rock Tavern operatedcausing the breaker backup timer to sense a fault and open both circuits77 and 311.

A number of the equipment difficulties listed above should nothave occurred under proper testing and maintenance procedures. Had therelay that opened circuit 88 on July 13 been tested as a unit when it wasplaced in service, the design failure would have been discovered.121 Thebent relay contact which opened circuit 81 appears to have been the resultof mishandling of the relay, perhaps by manual closing of delicate contactsduring testing. In any event, a final visual check of relay contacts beforeplacing the relay back in service should have revealed this difficulty.Visual inspection should also have revealed the loose locking nut on circuit98. The defective equipment which prevented reclosing of circuits 72 and5018 on September 26 was the direct result of serious failures in inspectionand testing. The relay system on circuit 5018 apparently had not beentested after installation and most likely was not in operation at anytime.l22 The damaged relay equipment on circuit 72 at Ramapo shouldhave been detected had Orange and Rockland (which operates the Ramaposubstation) not violated the industry’s minimum relay maintenanceguidelines by not testing the relays in question for three years.l23 Whileconceding it is no excuse, Orange and Rockland has pleaded difficulties inscheduling relay testing and maintenance with the NYPP, a charge whichthe Pool denies.124 The Pool, however, did not monitor or enforce com-

pliance with maintenance and testing requirements.la5

The 1965 blackout occurred because relays were set so that

121 Con Edison testimony (Zarakas), State Hearings, pp. 287-88.

122 Orange and Rockland testimony, State Hearings, pp. 1061,1105-06.

123 Id., pp. 1064, 1106.

124 Id, pp. 1065-71; NYPP testimony, State Hearings2 p. 1467.

125 See note 207, infra.

39

they would open lines at loadings within the operating range.l26 In 1977the relay which prevented reclcsure of circuit 93 was set in accordancewith the manufacturer’s recommendation rather than in accordance withthe particular requirements of the equipment and transmission system towhich it was related.127 Since July 13 Con Edison has substantiallymodified the setting. 126 But even prior to July 13 a Con Edison study oftransmission in the Buchanan area had called attention to the seriousconsequences of the unavailability of circuit 93.129 These consequencesshould have been weighed against the risk of damage to the generator indeciding on the proper relay setting.

Conclusions

5. The testing and maintenance procedures used throughout theState must take account of the special need for reliable service toNew York City. As the events of July 13 and September 26 show,the failure of equipment outside one service territory can have adirect effect on the ability of another to receive power over the bulkpower transmission system.

6. The present testing and maintenance practices of the Pool and itsmembers are inadequate to meet essential standards of reliability inthe bulk transmission system. The Pool appears to have taken noeffective steps to police its members’ compliance with even theexisting standards.

D. Operation without an adequate safety margin

Prudent operation of a bulk power transmission systemrequiresthat operators never ignore the risk that transmission lines will be suddenlyremoved from service. While bad weather increases this risk, it is in fact

126 Federal Power Commission, Report to the President: NortheastPower Failure, November 9 and 10, n6rDecember 6, 1965, pp.4 ,

127 Con Edison testimony (Fischer), State Hearings, pp. 309-13,

128 & pp. 311-12.

129 Con Edison, “Buchanan-Millwood Right of Way Study” (1971), StateHearings, Exhibit 25, pp. 5-6.

40

ever present. Aircraft accidents,130 explosions,131 equipment faults,132broken shield wires133 and even kite flyingl34 can all open transmissionlines. To be able to respond to these contingencies without service in-terruption, the transmission system should not be operated at its fullcapacity - there should be a safety margin so that the system can con-tinue to operate after an unexpected event long enough for the systemoperator to take time-consuming corrective measures such as increasinglocal generation.1 35

This safety margin is as desirable after an unexpected eventas before it. The probability of another unexpected loss of transmissionremains essentially unchanged. Indeed, during a severe thunderstorm, ason July 13, the risk remains high. Without a continuous safety margin,the system is in the condition that a single event may bring about collapsebecause of insufficient time to implement corrective measures. At thevery least this means that following the loss of transmission facilities,local generation must be increased as quickly as possible to restore asafety margin under the new operating condition.

The operation of the bulk power transmission system on July13 did not comply with these principles. Prior to the first lightning strokeat 8:37, it was known that, due to the design deficiencies discussed above,the loss of the transmission line out of Buchanan carrying circuits 97 and

130

131

132

133

134

135

@ note 92, supra.

Explosions in 1973 and 1976 affecting transmission on the NiagaraMohawk and Municipal’Lighting Department of Plattsburgh, NewYork systems caused service outages of ten and five hours respec-tively.~ FPC Supp. Report, pp. 28-29.

There have been more than a dozen significant transmission outagesdue to equipment faults in the New York Power Pool area since 1967.Ict, pp. 26-30.

On October 16, 1977 a shield wire fell on two 138 kv transmissioncircuits in the City Public Service Board of San Antonio, Texassystem, which led to a blackout on that system,

Con Edison IfOperation Report - Protective Equipment,” October 14,1976, State Hearings, Exhibit 50.

While load shedding through customer disconnection can beimplemented quickly, it should be the last method for coping withemergency conditions.

41

c ’L-L J

INTRODUCTION

Twice within 12 years New York City and the adjacentcommunities of Westchester County have been subjected to the conse-quences of total electric power failure. In November of 1965 the blackoutwas part of a much larger cascading failure of the regional bulk powersystem, which originated in Canada and enveloped the entire northeasternregion of the United States. The second total power failure, whichoccurred on July 13, 1977, was limited to the service territory ofConsolidated Edison Company of New York, Inc. (“Con Edison*$ but thereit was just as complete as the first and of substantially longer duration.

The second failure was brought on by the compounding of manycauses triggered by a severe electrical storm. While it was lightning whichset the disastrous series of events in motion at 8:37 p.m., July 13, 1977,and prodded it along in the hour which followed, the root causes for theinability of the Con Edison system to withstand the impact of the stormand continue to function go much deeper than mere bad weather.

They are to be found in deficiencies of system planning anddesign, the unavailability of vital facilities, a lack of unified commandand coherent action under emergency conditions, mechanical failure andoperational error. They are to be found not only in the Con Edison systembut in the larger bulk power system serving all the major utilities of theState. They are the product of financial constraints, public pressures,divided responsibilities, organizational inertia and judgmental compro-mises. Some have long histories. Others are of more recent origin. Buton July 13, 1977, they added up to a complete failure of electrical servicein the Con Edison service area.

New York City and most of Westchester County were leftwithout power for a period of time ranging from two and one half hoursin some sections to as great as 25 hours in others. More than three millionhouseholds were affected, representing more than eight million people.Personal injury, loss of business income, property damage, as well aspersonal inconvenience and even hardship for countless New York citizenswere the tragic consequences - consequences severely aggravated by thelooting and arson which followed when the area was plunged into darkness.The economic losses alone from the blackout are incalculable.1 There is noway of even estimating the magnitude of the personal and social costssuffered by the people and communities affected.

1 The New York Times and the Wall Street Journal reported estimatesthat theseEe= of an orderof$ltude one billion dollars.New York Times, July 16, 1977, p. 1, COL 6; Wall Street Journal, July18,977,p. 5, COL 1. - -

Governor Hugh L. Carey immediately called upon the State ofNew York’s Public Service Commission to undertake a thorough investi-gation of the power failure for the purpose of identifying the causes anddeveloping recommendations for corrective action. The Commission, onthe night of the failure, designated a technical Staff Task Force of spe-cialists from its Power Division to commence the investigation. The StaffTask Force, under the direction of Lester M. Stuzin, the Division Direc-tor, consisted of James B. Keating, William E. Shaffer, Howard A.,Tarler, and S. A. Tilaro. It was assembled that night and began an on-the-spot review of the night’s events in the control centers of both theNew York Power Pool at Guilderland and Con Edison in New York City.

On July 22 Governor Carey supplemented his original requestwith Executive Order No. 54 requesting the then Acting Chairman of thePublic Service Commission to appoint Norman M. Clapp, a formerchairman of the Wisconsin Public Service Commission, as Special Con-sultant in Charge to conduct the State’s investigation.2 On July 25, Act-ing Chairman Edward Berlin so designated Mr. Clapp to conduct the in-vestigation and delegated to him the investigative powers of a Public

2 EXECUTIVE ORDER NO. 54

“WHEREAS, there occurred on July 13-14, 1977, a widespreadelectrical power failure in the New York City metropolitan area whichthreatened the health and safety of the residents of the area andwhich imposed economic hardship on many; and

WHEREAS, I requested the Public Service Commission, on July13, 1977, to undertake a thorough investigation into the cause of thepower failure and to provide me with recommendations which wouldensure that there would be no recurrence of any major power failurein this State;

NOW, THEREFORE, I, HUGH L. CAREY, Governor of theState of New York, do hereby request the Acting Chairman of thePublic Service Commission to exercise the powers granted him bysection 8 of the Public Service Law to appoint Norman Clapp to con-duct the investigation requested by me on July 13, 1977. I furtherrequest that Mr. Clapp be vested with all authority necessary toconduct that investigation, including the powers set forth insubdivision 11 of section 66 of the Public Service Law, and that he beinstructed to report his findings directly to me, as well as to thePublic Service Commission, and to make recommendations forwhatever action may be necessary to guarantee that there be norecurrence of any major power failure in this State.”

2

i Service Commissioner, including those specified in Sections 8 and 66(11)of the Public Service Law of the State of New York.

-I

4

Subsequently, the law firm of Cleary, Gottlieb, Steen ECHamilton of New York City was selected as Special Counsel for the in-vestigation. It has served in this capacity without compensation. Thefirm’s efforts have been supervised by two of its partners, Alan Appelbaumand Evan A. Davis. The preparation for hearings and examination ofwitnesses have been conducted by Mr. Davis and Lee R. Mitau, assisted byJeffrey N. Gordon, Steven E. Carlson and Kathleen L. Coles.

Charles P. Almon, Jr., former Chief of Power System Opera-tions for the Tennessee Valley Authority, former member of the AdvisoryPanel of the Federal Power Commission on its investigation of theNortheast Power Interruption of 1965 and Vice Chairman of the FederalPower Commission Advisory Committee on Reliability of Electric BulkPower Supply, was retained as Technical Consultant.

Although the Public Service Commission has supplied budgetaryand staff support as requested, the investigation has been conductedindependently of Commission control or direction. The conclusions andrecommendations reached in this Report are therefore to be taken strictlyas those of the Special Consultant in Charge and are in no way to beconstrued as indicating conclusions or recommendations of the Commis-SiOll.

Pursuant to the direction of Governor Carey’s Executive Order,this report with its recommendations is respectfully submitted to both theGovernor and the Public Service Commission.

In the investigation attention has been directed toward:

1. Review of the operations of Con Edison, the New YorkPower Pool and member utilities in the hour leading to the power failureon July 13, 1977 between 8:37 and 9:36 p.m. and their responses to theemergency of September 26, 1977, which had a similar potential for majorpower failure;

2. Analysis of the causal elements of breakdown on July 13 inthe further light of the September 26 emergency and identification of thespecific needs for corrective action to prevent, future major power failuresin the State of New York; and

3. Review of the level of reliability which can be expected ofthe other major electric utilities in New York State, with particularemphasis upon the adequacy of the ways and means for the planning,

i I

I

tI!I 1I’ I

1

.

1 I

design, maintenance and operation of the bulk power transmission grid.

It is not the purpose of this investigation to measure negligenceor suggest penalties for what has already happened. It has sought, rather,to determine the causes of the power failure and to recommend actionswhich will assure, so far as is humanly possible, that major power failuresin the State of New York will not recur in the future.

It has pursued this objective both through public hearings andsupplemental investigation. Under procedural guidelines announced at theoutset, patterned after the procedures of legislative investigativehearings, six full days of hearings were held, 33 witnesses were called andheard 1,545 pages of testimony were transcribed and 50 exhibits werefiled. 3

Witnesses came from Con Edison, the New York Power Pool,the Long Island Lighting Company, the Power Authority of the State ofNew York, the other major electric utilities in the State of New York,the Northeast Power Coordinating Council and the National Electric Re-liability Council.

To minimize the duplication of time, effort and expense ofother agencies conducting related investigations into the July blackout,they were invited to appear and share their data, records and recommen-dations as a part of the record of this investigation. The New York CitySpecial Commission of Inquiry represented by its chairman, Ira M.Millstein, Con Edison’s own Board of Review, the Federal Power Com-mission represented by Daniel Goldstein, Assistant Litigation Counsel,and the Public Service Commission’s Staff Task Force all responded to thisinvitation and contributed significantly to the data developed and itsanalytical evaluation, as did witnesses from the industry.

Expert testimony was also received from Lester H. Fink,Assistant Director for Systems Management and Structuring in the FederalEnergy Research and Development Administration, with respect to thetechnology of bulk power systems.

The Technical Consultant in this investigation made on-site personal inspection visits to the control centers of Con Edison andthe New York Power Pool as well as to the key Con Edison substationsinvolved in the events of July 13 and September 26.

3 The hearings were held in New York City on September 20 and 21 andOctober 25 and 26, and in Albany on November 15 and 16, 1977. Alist of witnesses is contained in Appendix IV of this Report.

4

Ld .J

55L

The Public Service Commission upon request of the SpecialConsultant in Charge authorized its Staff Task Force to meet with man-agement of each of the other seven member systems of the New YorkPower Pool to review the level of reliability of their respective systems inthe light of the experience of Con Edison. The results of these reviewswere the subject of the final two days of hearings on November 15 and 16.

This Report is based upon this total record of inquiry. In thechapters which follow it will cover:

1. A descriptive review of the critical events and actions onthe night of July 13, 1977 which culminated in the collapse of the ConEdison system at 9:36 p.m.;

2. Adescriptive reviewof the significant events and actions ofthe Con Edison system during the weather disturbance of September 26,which had striking similarities to the July 13 emergency but yielded adifferent outcome;

3. An analysis of the events and actions on both occasions,with a statement of the conclusions to be drawn from them as to thecauses of the July 13 blackout in the Con Edison service area;

4. A review of the institutional mechanisms for the develop-ment and operation of the bulk transmission system serving New YorkState as they relate to the critical issues of service reliability; and

5. The recommendations for corrective action to guard againstthe future recurrence of major electric power failures in the State of NewYork.

It is not the purpose of this Report to summarize all the evi-dence heard or reviewed. The record of the investigation, through thetranscript of the hearings and the exhibits received, speaks for itself.Rather it is the intended function of this Report to sort out the relevantfacts, to bring them into a clearer focus by the application of the bestexpert evaluation available to this investigation and thus to provide abetter public understanding of the need for the actions recommended toprotect the public interest in the reliability of electric service.

From these deliberations have emerged certain basic conclu-sions which appear to be self-evident but are worth identifying becausethey underlie the more specific conclusions and recommendations of theReport:

1. The New York City/Westchester County electric service

5

98 wouldnecessarily mean the loss of Indian Point 3 and circuit 88 carryingpower to New York City over the Hudson River. This should have beenthe starting point for fixing prudent import levels and these losses at 8:37should not have been an event in excess of design standards.136

After the first lightning stroke the system was operatedwithout a reasonable safety margin during the period from 8:37 until thesecond lightning stroke at 8:55. Power was being imported into New YorkCity at levels above emergency transfer limits, and this meant that theloss of a single circuit would cause one or more of the remaining circuitsto exceed its STE rating.137 As demonstrated in Appendix II, hadreestablishment of a safety margin been begun at 8:40 by increasing in-Citygeneration, the second lightning stroke could have been withstood withoutload shedding through adjustment of the Linden tie and voltage reduction.

Responsibility for the failure promptly to increase generationand decrease imports to reestablish a safety margin rests with the Pool,Con Edison and LILCO. Neither the Senior Pool Dispatcher nor the ConEdison System Operator treated operation without a safety margin and inexcess of emergency transfer limits as a major emergency. The SeniorPool Dispatcher did not use the emergency telephone hot line which ef-fects a simultaneous telephone connection between the Pool and the dis-patch centers of all its members - a point noted by the Niagara MohawkSystem Operator at about 8:49.138 He did not inform Con Edison thatenergy was being imported into New York City at levels above emergencytransfer limits. To the contrary, he reassured the Con Edison System

,’

136 Con Edison testimony (Zarakas), State Hearings, pp. 439-41.

137 See note 13, supra.

138 ‘“NM SO [Niagara Mohawk System Operator] :Yeah. You know, we lost a couple of minutes therethough, Bill. I think if he would have just jingledemergency just to call everyone’s attention to look -I didn’t even really see it for a minute or two here.Finally a guy from Albany called us and said, Hey, whathappened? Then I quick looked at the charts and thereit was.”

NYPP SPD Transcript, 8:49, p. 4.-m

42

.

Operator by noting that circuit 81 had not exceeded its LTE rating.139Despite emergency conditions, he did not terminate the economic dispatchprogram at 8:37 or promptly direct Con Edison to increase its own gener-ation as rapidly as possible. He did not request additional generation fromLILCO until 8:43 and led LILCO to believe that the problem was replacingIndian Point 3 generation, which LILCO thought to be merely a “routinerequest.“140 Although LILCO was reporting a ten-minute reserve of 324mw, by 9:00 it had increased generation by only 60 mw.141

The failure to terminate automatic economic dispatch wasparticularly CriticaL Under automatic poolwide dispatch, the Pool com-puter responded to the loss of Indian Point 3 by signaling the membercompanies to increase generation according to a schedule of participationfactors.l42 Lf the Pool had promptly ceased operating under automaticeconomic dispatch, following the initiation of area dispatch, Con Edisonwould have automatically begun increasing in-City generation and reducinits importation of power up to the full amount of its spinning reserve. 149Although a portion of this reserve was unavailable, the portion that wasavailable would, with the other actions mentioned above, have been suf-ficient had it been promptly brought into service.144

“NY PP SPD: Yeah - OK - you’re still below the long time. We’ve cutthe emergency [transfer of power from New England toPJMl so you should be getting some relief on it.”

NYPP SPD Transcript, 8:42:22, p. 3.- -

139

140

141

142

143

144

*

i

LILCO Memorandum to J.R. Gummersall, August 26, 1977, StateHearings, Exhibit 23 (XILCO Memorandum”), p. 2.

Testimony of John R. Gummersall, LILCO Senior Vice-President ofOperations (~*LILCO testimony”), State Hearings, p. 405.

Federal Power Commission, Stafftric System Disturbance in t

System, August4,m ffl

When Con Edison is not on automatic economic dispatch, it is on areadispatch, under which flows into the system are automaticallymonitored against scheduled imports and generation is automaticallyadjusted to correct deviations.

See Appendix II.

While the Pool failed to exercise leadership, the Con EdisonSystem Operator should not have needed direction. As it was, Con Edisondid not call for its ten-minute reserves until 8:45 the same time at whichthe Pool inquired about increased generation.

continuing automatic economic dispatch under emergency conditionstends to impair the restoration of safety margins by failing to makefull use of local generating reserves.

8. While the increased safety margin proposed by Con Edison forperiods of thunderstorm activity is a step in the right direction, itis far from being all that should be done to minimize the risk ofpower failure in New York City. To be reasonably certain of anadequate safety margin under existing system design it is necessaryto assume at all times that the 97/98 line, Indian Point 3 and circuit88 (or other more critical and equally vulnerable facilities) are outof service. The assumed loss of these facilities cannot be limitedto periods of adverse weather conditions since until designdeficiencies are corrected the availability of these facilities is atno time adequately secured,

E. Lack of coordination and direction inmeeting emergencies

Successful operation under emergency conditions requires cleardirection and coordination of action. One major purpose in establishingthe New York Power Pool was to provide a vehicle for such coordinationin emergencies.l 4g A plan of action, however, was never developed onJuly 13 and this failing was a major cause of the blackout.

1. Responding to the loss of circuits 97, 98,88 and Indian Point 3

A coordinated response to the first lightning stroke at 8:37required, as discussed above,‘termination of automatic economic dispatchand immediate pickup of the Con Edison and LILCO ten-minute reserves.Not only did these events not occur, Con Edison and the Pool did notpromptly confer as to the appropriate plan of action following the lossof transmission.

2, Responding to the loss of circuits 93 and 81

The need for a plan of action was even greater following thesecond lightning stroke at 8:55. The conditions that existed following thesecond stroke should never exist on a properly operated bulk powertransmission system. N-only was there no margin of safety, but four

149 New York Power Pool Agreement, dated April 4, 1977 (‘TNYPPAgreement?), State Hearings, Exhibit 17, p. 1.

45

lines were being operated at Ievels which can only be sustained for a shortperiod of time. The bulk transmission system was faced with imminentcollapse. 156

Thethe Pool, Constroke:

following plan of action could have been implemented byEdison and LILCO promptly after the second lightning

(1) Call up on a crisis basis additional Con Edison and LILCOgeneration.

(2) Adjust the Linden tie by phase angle regulation to either itsLTE or STE rating.

(8) Request LILCO to adjust the Norwalk tie to either its LTEor STE rating and maintain it there as its internal generation increased.

(4) Institute 8% voltage reduction in the Con Edison and LILCOservice territories. (Voltage reduction could also have been initiated in thePSE&G service territory if necessary to maintain the Linden tie at its LTErating.)

(5) Initiate the manual reclosing of all open circuits.

(6) Prepare to implement manual load disconnection in theevent of another contingency or the failure of corrective measures.

(7) Comply with Pool directives to disconnect load.

Based on the analysis set forth in Appendix II, prompt imple-mentation of steps (11, (2) and (4) would have averted the blackoutwithout disconnection of customers. Response (6) or (7) would have,averted the blackout with only relatively minor service interruptions.As it was, none of these responses was properly effected. Actualresponses were as follows:

(1) The first industrial gas turbine units were ordered intoservice at 8:56, but the thirtpminute reserve was not called for at ConEdison until 9:05. The Pool did not request LILCO to bring on maximumgeneration until 9:04. Con Edison data indicate that 236 mw of additionalgeneration could probably have been brought on line had it called for the

150 An equivalent emergency in generation terms would consist ofunderfrequency operation following the exhaustion of all operatingreserves and the outage of several base load units.

46

thirty-minute reserve five minutes earlier.l 5l

(2) The Pool did not direct Con Edison to implement voltagereduction until 9:09 and failed to specify that the reduction should be atthe 8% leveLls2 The Pool did not direct I&CO to go into 5% voltagereduction until 9:lO and never directed 8% voltage reduction.153 ConEdison did not initiate 5% voltage reduction until 9:13 or 8% voltage reduction until 9:18, and the 8% reduction was not effective until 9:22.L&CO did not achieve 5% voltage reduction until 9:19.

.(3) The Norwalk ti e was adjusted to its STE rating. However,as LILCO generation increased, the tiewas allowed to drop approximately190 mw below its STE rating thereby reducing LILCO’s ability to assist ConEdison by that amount.154

(4) The Linden tie was adjusted to 500 mw, a figure somewhatbelow its normal rating. The tie could have been adjusted to at least 680mw, its LTE rating, at which the line could have been safely operated forat least three hours. The responsibility for the failure to make full useof the Linden tie must be placed on the Pool, Con Edison and PSE&G. ThePool did not adequately impress on the PJM Interconnection Dispatcherthe severity of the crisis. The Senior Pool Dispatcher informed the PJMInterconnection Dispatcher at 8:58 that Con Edison was faced with a majoremergency.ls5 This understated the magnitude of the problem. At 9:07

151 Con Edison Third Report, VoL V, p. 77.m--152 “NY PP SPD: Bill, tell Bill [Con Edison System Operator, William

Jurith] to-go into voltage reduction immediately downthere - alright?”

NYPP SPD Transcript, 9:09, p. 13.- -153 NYPP SPD Transcript, 9:10-9:22, pp. ‘13-15; NYPP Pool Dispatcher

twoxtape transcript, July 13, 1977 (I’NYPP PD Transcri tn),reprinted in Con Edison Second Report, 9:lOw, pp. -1 .-+m-

154 See Chart 5, Appendix II.

155 “NYPP SPD: Yeah, I know that Linden’s up there. I already toldthem to try to get it down - he’s got a major emergencyover there and hers lost the 81 line, and hers lost theJamaica Valley Stream.

PJM ID [PJM Interconnection Dispatcher] : OK.NYPP SPD: I told him he’d better shed some load down there.PJM ID: Yeah, PS is going to open that Linden/ Goethals if they

47

the Con Edison Chief System Operator reco ized that the loading of theLinden tie should be increased to 700 mw. 56 At 9:lO he asked the ConPEdison System Operator to tell the Con Edison Power Dispatcher to callPSE&G and ask permission to increase the loading to about 600 mw be-cause Con Edison was “in danger of shutting down all of New Yorknls7The conversation between the Power Dispatcher and PSE&G occurred at9:lO. The Power Dispatcher failed to convey the seriousness of the prob-lem and said only: “we’re in jeopardy with our ties up north.n158 PSE&Gresponded that the Linden tie was “only good for 500.“159 This statementwas highly misleading in that under the emergency conditions that thenexisted the Linden tie was capable of carrying more than 700 mw.16O ThePower Dispatcher, who is required to know the ratings of all ties,lbl did

@ant .)

156

157

158

159

160

161

don’t do something about it.NYPP SPD: Yeah, I told him he’s going to have to get that thing

down somehow or other.PJM ID: Ok, fine.”NYPP SPD Transcript, 8:58:38, pp. 7-8.- -

“[CEI SO: And the Linden tie is way up there I had to back off, be-cause he was up to 900 Mw the guys down there are about500.

CSO [Chief System Operator] :- Ask him if he can take that up to 700, OK.

[CEI SO: Huh?cso: Let him ease that up to 700.”Con Edison System Operator telephone tape transcript, July 13,1977, reprinted in Con Edison Second Report, 9:07:39, p. 16.-.-Id, 9:10, p. 18.

Con Edison Power Dispatcher telephone tape transcript, July 13,1977, reprinted in Con Edison Second Report, 9:10:33, p. 13.- -Ib, 9:10:40, p. 13

Indeed, the Linden tie,operated at between 900 mw and l,200 mw forten minutes on July 13.

NPCC, Data on Coordinated Regional Bulk Power Supply Programs,FPC Order 383-4, Docket R-362, Appendix A-l, April 1, 1977, State

Exhibit 42, Item 9A, Vrocedure in a Major Emergency”,

48

not contradict this statement as he should have. Instead he agreed not toload the Linden tie above 500 mw, and the loading was maintained at thislevel until 9:19, when circuit 92 opened. Had the Linden tie been loadedto its LTE rating as part of the plan of action described above, the anal-ysis contained in Appendix II shows that circuit 92 would not have openedand system failure would have been avoided.ls2. . . .

(5) Cir&it 702 was reclosed at 9:06 but an attempt to reclose81 was not made until 9:22:47 (after the loss of circuit 92). No effortwas made to reclose circuit 93 because the Con Edison System Operatorwas unaware that it was open even though this information was availableto him and known to the Pool and the Westchester District Operator.While design deficiencies impeded the ability to reclose 93 since no pro-visions had been made for overriding the synchronous check relay by su-pervisory control,l63 circuit 93 could have been reclosed either at thebreaker or by manually disconnecting a wire at the breaker control board.The successful reclcsing of circuit 93 prior to 9:29 would have avertedsystem shutdown.l64

(6) No preparations were made to implement customer dii-connection, At any time from 8:55:53 onward, customer disconnectionwas an option that might have to be implemented on a moment’s notice.Personnel could have been assigned to stand by the load shedding panel,district supervisors could have been informed that disconnection mightoccur, and City officials could have been informed by the communications

(7) Con Edison failed to comply with a Pool directive to shedload. Responsibility for this failure, however, rests with both Con Edisonand the PooL The Pool spoke to Con Edison about shedding load on sevenseparate occasions between 8:55 and 9:29. The Senior Pool Dispatcher hastestified that on the first occasion the Pool was requesting that load be

162 In fact, circuit 92 would not have exceeded its STErating. See Chart2, Appendix It.

163 Con Edison has subsequently recommended that such provision bemade. Con Edison Third Report, VOL. V, p. 48.- - - .

164 After9:29 Con Edison needed to import approximately 1,200 mwovera northern circuit (see discussion below concerning the response toloss of circuit 92). The normal rating of circuit 93 is 1,590 mw andits STE rating is 1,952 mw.

49

shed and on the later occasions was directing that load be shed.165 Thewords used in each instance are set forth in the footnote.166 They do notsupport the distinction between request and directive which the Poolsuggests. On the other hand, it should have been obvious to the ConEdison System Operator that by 8:59 at the latest it was the Pool% judg-ment that load should be disconnected. This judgment should havegoverned even though load disconnection did not become an absolute im-perative until the loss of circuit 92 at 9:19: 11.

3. Responding to loss of circuit 92

Even after the loss of circuit 92 at 9:19:11 a coordinated re-sponse to the conditions that then existed would hav,e prevented total

165 Testimony of William B. Kennedy, NYPP Senior Pool Dispatcher,City Hearings, August 31, 1977, pp. 549-51, 553-54, 556-58.

166 8:56:54

8:59:15

9:02:22

9:05:08

9:20:34

9:22:20

9:27:08

“Bill, you better shed some load until you get down belowthis thing because I can’t pick anything up except fromthe north, see?” NYPP SPD Ranscri t p. 7.“Bill, I hate to bosyou, but your-4etter shed about400 MW of load or you’re going to lose everything downthere. . . . You’re trying to - all you have to do is hitthe button to shed it and then well worry about it af-terwards - but, you go[ tl to do something or they’regoing to open that Linden Tie on you.” Id. p. 8.“You still got to get rid of about 400 Bdecause you’re400 over theshort time emergency on that 80 line.” ICL,p. 9.Vantt you shed load and relieve it - if you cut feeder 80than [sic] you are really going to be in trouble.” Id., p.ll.“You got to shed load immediately or you’re going to goright down the pipe with everything you’ve lost that 80line there now. . . . Yeah - you’d better shed loadimmediately. . . . At least 600 MW anyway.John - will you shed load down there immediately. . . . Atleast 1000 MW or you’re going to go right down the pipe.”Id. p. 15.?a’K- Pmgoing to tell you one more time - if you don’t shedabout 600 MW of load immediately. . . . AU you got to dois punch-a button to get rid of it. . . . Shed 600 MWimmediately or youll lose that Linden and you’re out ofbusiness - that’s the only thing you have left John.” 16,p. 16.

50

system collapse. After the loss of circuit 92, it became virtually certainthat Con Edison would soon cease receiving power over the bulk powertransmission system unless substantial amounts of load were disconnectedimmediately. Con Edison’s gross generation was about 4,200 mw and itsgross load was about 6,100 mw, leaving an import requirement of 1,900mw. 167 The combined emergency capacity of the ties to New Jersey andLILCO, however, was about 1,250 mw, leaving a deficit of approximately650 mw. Moreover, to make full use of the Jamaica tie it would be nec-essary to open the Norwalk tie to prevent damage to both facilities.L68This would reduce power flows over the Jamaica tie until LILCO genera-tion could be increased.

There were two sets of responses to meet these conditions. Thefirst required maintaining the tie between ULCO and Con Edison, therebycreating a risk that both the LILCO and Con Edison systems would fail.The following actions would have been required:

(1) Open the Norwalk tie.

(2) Shed approximately 350 mw of LILCO load.

(3) Shed approximately 650 mw of Con Edison load.

The second set of responses would have isolated LILCO from Con Edison’sdifficulties through the following actions:

(I) Open the Jamaica tie.

(2) Shed approximately 1,200 mw of Con Edison load.,’Had either of these actions been taken in the ten minutes

between 9:19 and 9:29 system failure would have been averted. Actualresponses were as follows:

(1) LZCO shed 377 mw of load at 9:19 but did not open the

167 Charts 6 and 7, Appendix II.

168 At 9:19 the loss of circuit 92 caused an increase in flows fromConnecticut to Con Edison through the LILCO system. As a resultthe Norwalk tie and the Jamaica tie became overloaded. Chart 5,Appendix II. Further flows into the Con Edison system over theseties would have aggravated this overload condition.

Norwalk tie.169 As a result the Jamaica tie became loaded above its STErating and was opened by LILCO with Pool approval.170

(2) Con Edison attempted to shed load on the 4 kv network atapproximately 9:22. Had this attem t been successful approximately 770m w of load would have been shed. 181 Con Edison did not attempt to operate the 208 volt load shedding network or to drop area substations man-ually to shed the required additional 300 to 400 mw. The System Operatorwas unable to operate the 4 kv load shedding panel either because theequipment was defective or because he did not know how to operate it.l72No load was actually shed.

These events show lack of training and drill, and lack ofcoordination among the System Operator, the Power Dispatcher and theDistrict Operators. In the emergency that existed, alI should have actedto shed load. At 9:21 the Pool told Con Edison to shed 600 mw. AfterLILCO was authorized to open its tie to Con Edison, the amount of loadthat Con Edison had to shed increased, and at 9:22 the Pool directed that1,000 mw be shed. At this point it was necessary for Con Edison to operate the 4 kv and 208 volt load shedding equipment simultaneously in

169 LILCO Memorandum, su ra note 140, p. 3; LILCO testimony,,zgState Hearings, pp. 423-.

170 %I SO [Long Island System Operator] : Listen - they lost somethingelse.

NYPP PD [Pool Dispatcher] : Yeah, we know that.LI so: And Pm all overloaded on CLP quite a bit.NY PP PD: OK - starts backing it off. Hit everything you can.LI so: I11 have to start dropping load.NYPP PD: OK - shed load or separate.”t’zng TrETipt, 9:19:26, p. 10. See LILCO Memorandum,

“NYPP PD: Hello. Yeah, Kenny.LI so: Pm going to have to open that tie.NYPP PD: Go ahead - open it up - save your own system.”NYPP PD RI? 9:21:24, p. 11.- -

171 Con Edison Second Report, p. 57.- -172 Con Edison has been unable to determine the reason for the failure

to shed load on July 13. Id.

52

‘.

order to achieve the needed result. When the 4 kv panel failed to operate,in addition to simultaneous operation of the 208 volt network panel, ConEdison should have made use of three other means available to disconnect4 kv load, any one of which could have been delegated to a District Op-erator. These were load shedding through operation of (1) the dispatchcenter’s Quindar system, (2) its remote master controls or (3) throughorders to personnel at manned substations to open circuit breakers.

The Poolfs handling of the situation was also deficient. TheSenior Pool Dispatcher should have explained that the amount of loadshedding had to be ihcreased from 650 mw to 1,200 mw because theJamaica tie was being opened. The LILCO System Operator should nothave been told at 9:19 to “shed load or separate.“lr13 While these were thetwo options, the option chosen had a critical impact on the amount of loadwhich had to be shed by Con Edison. The separation option required ConEdison to shed load in New York City; if LILCO had shed load Con Edisonwould have had to shed load only in Westchester on the 4 kv network. Thechoice between these options should have been made by the Pool, and theconversationat 9:19 should not have ended without agreement with respectto LILCO*s course of action.

i

ii

Problems of coordination and communication continued onSeptember 26. There were several instances of confusion and difficultiesin coordinating responses during the crisis because of inconsistent infor-mation or interpretations of available data.l14 At times personnel

173 NYPP PD Transcript, 9:19, p. 10, quoted at note 170, supra.- -174 *I CCEI SO: How you making out with closing the breakers at Ramapo?

I see one of them is closed on 5018.O&R SO [Orange and Rockland System Operator] :

We’re not sure, but by the looks of the metering, the 5018is reopened.

[CEI SO: No, not here it hasn’t.O&R SO: It hasn’t?[Cti SO: No.O&R SO: Yours shows closed?[CE3 SO: Yeah.O&R SO: We show zero Bow.[CEl SO: No, one breaker shows dosed here whatever it is The 1502

- or 2500-2X. But, yeah, it shows like there’s a littleload going into Jersey on it.

O&R SO: Up here?”September 26 Telephone Transcript, 3:58:40, p. 49.

53

RECEIVER: Off course.[CE SO] : - off course for this area.RECEIVER: Yeah, right.ICE SO] : Well, you see that’s the - I don’t know - your pool

[PJMI doesn’t admit that. I don’t know why.RECEIVER: No, they didn’t.[CE SO] : No. Fmtrying to find- I’m trying to get them to realize

that that flow into PJM, into Branchburg, because ofthe generation you put on it. They said no, you didn’tput anything on.

RECEIVER: Bh. I told them that we had a thousand megawatts ingeneration because - we just dropped 150 on CT’s -

CCE SO] : Yeah.”Id.. after 4:5l, pp. 85-86.I

175 “[CE] SO:NYPP:[CEI SO:NY PP:ICE1 SO:NYPP=[CEI SO:NYPP:[CEI so:NYPP:

Oh, huh. Okay, Ill talk to you-What did we lose there now?Huh?We’ve just lost something else there now.Where?I don’t know. We just dropped about three, four hundredNaw, I don’t see anything.Anything in your system?Huh? ’

[CEI SO:

It went down into your system. You’d better see if youlost something else somewhere.Oh yeah. Yeah, we lost something in Astoria, sure ashell. Yep.”

misread or failed to notice important information.175 And, there were

(cant .)“[CE SO] : So you said you have a thousand megawatts of generation

on for -

September 26 Telephone Transcript, 4:04:16, p. 55;

‘WE Sol: Say, is 77-2Y and 72-2Y still open?UNKNOWN RECEIVER [Probably O&RI: Open? Everything is

[CE SO1 : Everything is closed at Ramapo?RECEIVERZ Y’es, as far as we know. Hold on just a minute. All

the lines are closed.[CE SO] : Yeah, the lines are closed, but I show two breakers

Open-RECEIVER: Well, hold on just a minute.[CE SO] : Sure.

54

frequent difficulties encountered in communication by telephone,176 aproblem which may have been exacerbated by a number of calls to the Con

(cont.)RECEIVER:[CE SO] :

Hold the line just a moment. Tll doublecheck the other.

?EL(To another person: Charlie, have you still got twobreakers open at Ramapo? (Yes, there is two breakersopen at Ramapo.)

RECEIVER: That’s the W72-2Y and 77-2X, huh?[CE SO]: Y e a h .RECEIVER: Okay.[CE SO]: Alllinesare-RECEIVER: All right. They’re going to close themup as soon as they

CM?ICE SO]: Right.”Ia, 5:01:04, pp. 93-94.

176 “[CE SOI: Zimmer.[ASTORIA] : Hill I can’t seem to get a hold of the D.O.[CE SO] : Uh, I’II-f~ETfo~l : Will you ring him and have him ring me?

Sure.*fSeptembk 2s Telephone Transcript, 2:28:3l, p. 13;

“[CE SO] : Yes, Dobrzyn, Do you have any problemin Rock Tavernon the 77 line?

[UNKNOWNRECEIVER]: (inaudible) Yeah, we’ve been trying to get them and

the damn line’s been busy.[CESOI : Y e a h . ”Id, 3:26:00, p. 24;

“[CE SO] :[UNKNOWN

What are 0 and R say Can they get the -

CALLER] : (inaudible) are closing in on 5018 and we’re working to

ECE SO]:feel that swing until we’re ready to close it.

[UNKNOWNWell, yeah, I can’t get through to him.

CALLER] : Right. So I told him to go ahead and close it.*’Id, 3:46:35, pp. 37-38.

Edison System Operator during the crisis to ask unnecessary questions177or to relay messages.178 It is noteworthy that just prior to the September26 crisis the Con Edison and Central Hudson system operators had a con-versation about Con Edison’s failure to follow Pool directives to shed loadon July 13 which reveals continued resistance to Pool directives.179

Conclusions

9. The lack of team discipline and advance preparation and drillprevented the formulation and execution of a plan of action whichwould have prevented system collapse. The instinctive reaction ofindividual operating personnel appears to focus on what is perceivedto be in the interests of their own companies in disregard of Pooldirectives based on the welfare of the system as a whole. Con Edisonhas not trained and drilled its control room and substation personnelin the attitude and specific measures necessary to meet emergencyconditions.

177 “[CE SO]: Dobson.[UNKNOWNCALLE RI : Yeah, Jerry, is that eight percent finished with now?[CE SO1 : Yes.[CALLER] :[CE SO1 :

As of what time do you make that?I don’t know; whatever time we shut it off.Sorry. For Christ sakes, there’s a thousand things happening here at once. Whatever time I shut it off.

[CALLER] : Okay, fine.[CE SO] : Right.[CALLERI : Thank YO&~Se tember 26 Telephone Transcript, 5:30:41, pp.L&m=7C

11 l-l 2; see alsoe-

178 16, 2:28:31, p. 13; 5:26:46, pp. 105-06.

179 fttCE SO1 : The only thing that made it bad was the pool telling themto shed load, you know.

[CH SO (Central Hudson System Operator)] : Yeah.ICE SOI: But sometimes the pool tells you what to do and it’s too

far off base, you know, and it’s not funny, you know.Oh, well, so what can you do?

[CH SO]: Yeah.. . .ttId., 2:06:56, p. 7.

56

10. The Pool has not exercised adequate overall control to assureemergency preparedness and to direct operations under emergencyconditions. Because overall responsibility is not fixed, emergencyoperations are unnecessarily confused and uncoordinated.

F. Inability to maintain the isolated system

The installation of automatic underfrequency load sheddingequipment capable of shedding approximately 50% of the Con Edison loadwas to have provided a last line of defense in the event the system becameisolated.180 The events of July 13 demonstrated that any comfort derivedfrom this protection was misplaced because large amounts of load couldnot be shed safely on the isolated Con Edison system. In fact, the oper-ation of the automatic relays not only failed to save the system, itaggravated the situation and contributed to its collapse.

The relays were triggered as designed when, after 9:29, thefrequency began rapidly to decline.l 8l Yet the sudden loss of approxi-mately 1,400 mw of load, together with associated loss of inductivereactance, produced unacceptably high voltages which caused the loss oflarge generating facilities at Ravenswood and Arthur Kill. This widenedthe gap between load and generation to such an extent that frequencydecline could not be arrested and total system collapse followed shortly.

180 Con Edison’s 50% automatic load shedding capability is significantlyin excess of NYPP and NPCC automatic load shedding guidelines,which recommend 25%,capability to be shed in the following manner:

Frequency (Hertz)NPCC NYPP

59.3 59.5-59.0

58.8 59.0-58.5FPC Report, p. 11.

Load Reduction Amount

10 %

15 %

181 Approximately 10% of the load subject to automatic load sheddingfailed to disconnect. Half this amount was due to equipment out ofservice for routine maintenance or repairs and the other half wasdue to defective equipment, improper programming or other un-known causes. Con Edison Third Report, VoL V, pp. 91, 93-94.- - -

._

”

Events have.. demonstrated that the automatic load sheddingsystem was inadequately planned for conditions on the Con Edisonsystem. Yet Con Edison was not wholly without analytical tools tostudy and prepare for the high voltage condition which occurred onJuly 13-l 82 The large amount of underground transmission and distributionfacilities that characterize the Con Edison system are known to presentspecial problems requiring the use of devices known as shunt reactors.l33On July 13, however, three of these reactors on the 345 kv systemls4were out of service. Had they been available they could have helpedto control the effects of the abrupt shedding of the first three blocksof load.195

In its Third Report, Con Edison has nowthat may alleviate some of these design deficiencies. 96 But even afterfroposed measures

these improvements are completed, there will be no sure basis for relianceon massive amounts of automatic load shedding as the ultimate protection

182

183

184

185

186

Although methods of analysis available at the time the automatic loadshedding equipment was installed would have made the computationmore difficult than today, they would have revealed the potentialproblems in the use of such equipment on the isolated Con Edisonsystem.

ffDue to the large amount of underground transmission and distributionfacilities utilized, charging current requirements must becompensated to an-acceptable degree through the application toshunt reactors. This characteristic requires exercise of care in thedispatch of real and reactive power under both normal and abnormalload conditions.” ‘Report, p. 19.

Two were at Sprain Brook (150 megavars (“MVARff) each) and one atGowanus (150 MVAR).

The 450 MVAR thereby unavailable would have meant that rather thanthe 867.6 MVAR lost in shedding the first 1405.2 mw of load,approximately 417.6 MVAR, or almost 50% less, would have beenlost. See Con Edison Third Report, VoL II, Table 1, p. 23.- - - -Con Edison now plans to maintain higher generator MVAR loading bymodifying operating procedures to keep 345 kv shunt reactors inservice, and to pn>vide for decreased capacitive reactance in orderto hold down voltage increases. It also plans to install additionalequipment to prevent the shutting down of Ravenswood 3 and ArthurKill-3 due to high system voltage, Con Edison Third Report, VoLp. 39. e--I I ,

58

for the islanded system. Con Edison’s Third Report states that too littleis known about the dynamics of islanded operations and points to the needto develop the requisite analytic tools.l87 Con Edison apparently hadsignificant difficulties in reconstructing and analyzing the events after9:29 on July 13.188

The inability to achieve stable isolated operation stems froma general failure to think through the problems that transmission lossescan create. For example, virtually no planning consideration has beengiven to the generation reserves needed in the event of transmission losses.Installed generation reserve capacit is determined solely with referenceto potential generation shortages. 8gfoperating reserve criterion,l go

Similarly, the Pool’s minimumtheoretically aimed at assuring poolwide

system integrity in emergency situations, is designed to meet generationshortages, not transmission losses. Indeed, it assumes sufficient transmis-sion exists to deliver the members’ minimum operating reserve capacity

187 ConEdison Third Report, VoL II, p. 38. In fact, asidefrominstallingeqtupment to minimize the high voltage condition and its effects,the only other recommendations made are for further study, testingand analysis of isolated operation. Id. pp. 39-40. Recognizing therisks of voltage fluctuations associatea’with isolated operations, ConEdison is also proposing a “semi-automatic” load shedding systemkeyed to tie line overloading to help avoid system separation. Td.,VOL v, pp. 91-92.

188 Con Edison Second Report, p. 1.- - -189 The Pool has established statewide capacity reserve requirements

based on a generation planning criterion that will assure that eachutility will have generation at least equal to its peak load at least99.96 15% of the time or, conversely, that the probability that it willnot have sufficient capacity will be one day in ten years. This hasresulted in a poolwide reserve margin of 22% of the statewide peak.This means that each individual utility, under the NYPP agreement,must maintain an installed generation capacity of at least 18% inexcess of its own system peak Ioad,

190 NYPP Operating Policy X2-7 (ITOP 2-7”), State Hearings, Exhibit 19.This policy provides for the computation availability of eachmember’s share of the Pool’s total ten-minute and thirty-minutereserves.

59

to the system suffering the shortage.191

Where disturbances on the bulk transmission system severelylimit the ability to transfer power, the POOPS existing reserve require-ments are inadequate. This was highlighted by the events of July 13 whenthe other members of the Pool were unable to come to Con Edison’s aidbecause of the loss of transfer capacity to the north. There was amplereserve capacity in the Pool that night - it simply could not be delivered.

That is why Con Edison’s assertions that, while its reserveperformance was disappointing, it at least met its minimum ten-minutereserve requirement under the POOPS operating policy, are beside thepoint. Con Edison needed its own in-City emergency reserve capacity tomeet its load when it could no longer receive aid from the rest of the Pool.Con Edison appears not to have carefully considered and studied the stepsit might have to take to achieve a balance between load and generationin such circumstances. It did not establish the safe level of load sheddingfor the Con Edison system or the amount of in-City generating reservesneeded to avoid load shedding in dangerously large amounts.

Conclusions

Il. Con Edison has inadequately studied the potential problems ofautomatic load shedding in light of the special conditions of itssystem and has failed to take steps to minimize these problems. Asa result, necessary equipment modifications were not made and

191 The Pool assumes adequate transmission in its generation capacityplanning: /’

“One of the more important of these assumptions is thatinternal NY PP transmission does not limit study results, i.e.,adequate transmission would be installed to prevent ‘bottled’generating capacity. Otherwise, either local load reliefmeasures would be required more frequently than shown in thestudy results or local generation reserves would have to beincreased”

State Hearings, Exhibit 44, (NYPP 1976 Submission under Rule149-b, VoL 2, Exhibit 3, “Generating Capacity Requirementsn), p 13.

The Pool Control Center has the responsibility to assure that theminimum operating reserves are not “bottled up” due to existing lineLimitations and scheduled line outages. OP 2-7, State Hearings>Exhibit 19, p. 2. This does not include considerationof potentialtransmission losses because of emergency disturbances.

60

needed equipment was out of service.

12. The Pool and Con Edison have not given sufficient attention tothe problems of isolated operation. The willingness to rely on abruptshedding of large amounts was not justified. No reserve requirementwas established to reduce reliance on unproved load shedding in largeamounts.

.

CHAPTER IV

Existing Administration of theBulk Power Transmission Svstem

The conclusions set forth in Chapter III of this Report, takentogether, point toward a single fundamental need: a complex bulk powertransmission system must in all its parts and at all times be planned,tested, maintained and operated with a high degree of discipline andvigilance under leadership with the authority, clear responsibility andundivided incentive to provide reliable transmission service.

This Chapter describes the New York State transmission gridand examines the existing organizational structure of the New York Statebulk power transmission system, focusing in turn on each of the principalparticipants in its operation and planning. It will briefly analyze the re-spective roles of the individual utilities, the New York Power Pool, theNortheast Power Coordinating Council, the Public Service Commissionand the Federal Energy Regulatory Commission (formerly the FederalPower Commission).

A. The New York State bulk power grid

The New York State bulk power transmission system is aninterconnected network of high voltage electric circuits (those 230 kv andabove) transporting electric energy from major generating facilities toload centers (see map in Appendix I). It consists of 2,789 miles ofoverhead and 165 miles of underground high voltage transmission lines.Through this network all utilities in the State are interconnected and areable to buy and sell power and to assist each other in times of emergency.The New York transmission system is interconnected with the transmissionsystems of neighboring states and regions. The total book investment ofthe State utilities in bulk transmission lines is $762,760,000.192

This bulk power system serves two important purposes affect-ing electric consumers throughout the State -reliability and economy.Reliability is enhanced because a utility facing an emergency resultingfrom aloss of generation or transmission, or from unanticipated load, mayobtain needed power from its neighbors. Economy is served in three ways.Fint, each utility must maintain installed and operating reserves to be

192 NYPP Letter dated December 9, 1977, State Hearings, Exhibit 49(private utilities: $637,800,000); PASNY Letter dated January 12,1978, State Hearings, Exhibit 49 (PASNY: $124,960,000).

62

prepared for temporary shortages of generation capacity, and the bulktransmission system allows for the calculation of these reserves on asystemwide basis. This diminishes each utility’s individual reserve re-quirement and thus its need to construct and operate expensive generatingfacilities.lg3 Second, the demand for power varies throughout the Stateon a seasonal basis. Some utilities, such as Con Edison which must powerNew York City’s air conditioners, face their greatest demands in thesummer; they are Wunmer-peaking”. Other utilities, such as NiagaraMohawk and New York State Electric and Gas Corporation (7fNYSEG”),are ltwinter-peaking”. Through power exchanges over the bulk powertransmission system this diversity can be exploited in a way that againminimizes the need to build additional generating facilities. Third, andrecently of increasing importance, the bulk power transmission systempromotes the use of the lowest cost generation to meet the energy needsof New York State.

Initially, reliability was the chief impetus for the inter-connection of utilities through transmission systems and the formation ofpower pools. Amajor recommendation of the report of the Federal PowerCommission on the 1965 blackout was to improve reliability throughincreased interconnections. Yet the economic impact of interconnectionhas since become very significant. Utilities in the NYPP area which for-merly relied chiefly on power generated within their service area havebegun to rely to a much greater extent on power supplied through the bulkpower system. Generation stations have been sited further away fromloadcenters for environmental reasons and to take advantage of more eco-nomical power sources. In light of such developments the reliability of thebulk power system becomes a matter of increasing importance.

B. The utilities II

The most important components in the current arrangement arethe major individual utilities - seven investor-owned companies andPASNY. Each of the seven private utilities has a geographic service ter-ritory in the State within which it is responsible for providing electricenergy. Each is individually responsible for the maintenance of lines andthe testing of relays and protective equipment located within its serviceterritory. The individual system operators and power dispatchers whooperate and control the flows within each system take or fail to take thesteps necessary to avoid failure of the bulk power transmission system.Each utility decides individually what transmission facilities it is preparedto finance and construct. As a practical matter, if no one utility or groupof utilities is prepared to build a line needed by the system as a whole,

193 @note 189, supra.

6 3

that line is not built.lg4

,

%

Each utility has unique characteristics depending on the natureof its service territory and generation resources. Niagara Mohawk, forexample, has access to hydro resources at Niagara Falls, along LakeOntario and in the Adirondacks and is a major seller of power to otherutilities. Nearly all of NYSEG’s generation is coal-fired and as a resultof the increasing prices of oil the company has also become an importantexporter of power. lg5 Orange and Rockland and Central Hudson are notheavy importers or exporters of electric power, although large powerflows pass through their territories en route to New York City.lg6PASNY, a State public authority, is a supplier of bulk power at wholesaleto other power systems, certain large industrial customers upstate andpublic entities in the New York City area. It has no service territoryas such, but owns substantial generation and transmission facilities

194 An example of this problem is the delay in the completion of theSouthern Tier Interconnection between Coopers Corners and RockTavern due to lack of agreement among the four interested utilitieson who will finance and construct it. This line has been the subjectof an Article VII Proceeding before the PSC (the Southern Tier Case,PSC Nos. 25845, 254711, in which the Commission approved theproposed line in January 1972. The line has not yet been completedbecause of this dispute. Orange and Rockland testimony, StateHearings? p. 1097.

195 Testimony of Jack H. Roskoz, NYSEGVice-President for Operations,State Hearings, pp. 1214,,. 1220.

196 Con Edison has an ownership interest in a number of these lines. ConEdison shares ownership with Orange and Rockland (2/3-l/3) in the345 kv double circuit line from Bowline Point (the generating stationthey own in the same ratio) to Ladentown. These two utilities alsoshare ownership (85%15%) in the two double circuit 345 kv linesfrom the center of the Hudson River to Ramapo. Con Edison alsoowns 100% of the 345 kv circuit from Ramapo to South Mahwah,New Jersey (although Orange and Rockland obtained transmissioncapacity of 400 mw in exchange for the right-of-way) and 100% ofthe 500 kv line from Ramapo to the New York/New Jersey state line.The 345 kv line from Ramapo to Rock Tavern, through CentralHudson and Orange and Rockland, is entirely owned by Con Edison.Orange and Rockland testimony, State Hearings, pp. 1096-97.

6 4

throughout the State.l97 The unique characteristics of Con Edison’s ser-vice territory and its heavy use of imported power have already beendescribed.

These differences produce different perceptions of the properbalance between reliability and economy among the New York Stateutilities. For an exporting company, transmission is one of the costs ofselling power, and a blackout in New York City is merely one day’s lost

For importers such as Con Edison, imports are used to servecustomers and a blackout means much more. Thus while both sending andreceiving companies receive important economic benefits through bulkpower sales, it is the receiving company that has the greatest stake inreliability. For many years the PSC has urged the utilities to agree on aformula for the allocation of transmission costs among the several utilitiesbenefiting from a particular line, but these efforts have beenunavailing.lg8 The absence of such a formula can impede constructionof facilities that are important for overall system reliability.

C. New York Power Pool

The New Y ork Power Pool is an organization established in 1966by the seven investor-owned utility companies in New York State andPASNYlg9 to obtain mutual benefits for all members through

“coordinated operation of their electric systems, includingincreased reliability of service and reduced capital costs madepossible by coordinated system planning and reduced operat-ing costs made possible by the interchange of electric energy

197 PASNY has a total installed generating capacity of about 6,000 mwand owns approximately 500 miles of 345 kv circuits and 250 miles of-230 kv circuits. Current plans call for PASNY to build and haveoperational in 1978, 155 miles of the State’s 765 kv network, whichwill provide the main transmission path for Con Edison% plannedimport of 600 mw of power from Hydro-Quebec.

198 Testimony of Lester M. St&n, Department of Public Service, Di-rector of Power Division (fTPSC testimony &zin)w), State Hearings,pp. 1011-12.

199 PASNY is a limited member of the Pool, participating in its coordi-nation of planning and operations but not in the purchase and saleof energy dispatched through the POOL

6 5

for economy purposes.~~200

Under the NYPP Agreement, the individual utilities havesurrendered very little of their sovereignty. The Pool is run by a series ofcommittees on which each utilit

201is represented.201 All committee action

requires unanimous consent. Although nearly 100 people work at thePool?s control center in Guilderland, the Pool itself has no employees. Itsstaff is employed by the member utilities and is loaned, sometimes on apermanent basis, to the POOL The Pool has no assets; the control center,which cost $5 million to build and equip, is owned by Niagara Mohawk inwhose service territory it is located. Indeed the Pool% bank account isadministered by Niagara Mohawk’s treasurer.963

At present the PoolTs most important function is to coordinatethe dispatch of power within the State’s bulk power system. From itscontrol center, a modern facility in Guilderland, the Pool monitors theflow over iransmission lines and coordinates the purchase and sale ofpower throughout the State. It maintains direct computer ties with eachutility. As part of its coordination function the Pool receives daily in-formation on generation reserves and schedules planned maintenance andtesting outages of generation and transmission. Despite the Pool’s superioroverview, actual control over the transmission lines rests with the dis-patch center of each utility. Although in emergencies the Pool dispatcheris authorized to give orders,904 lack of enforcement sanctions leaves itessentially within the discretion of utility system operators whether tofonow Pool directives.

200

201

202

203’

204

NYPP Agreement, State Hearings, Exhibit 17, p. 1.

There are Operating, Planning, Environmental and Public RelationsCommittees. Disagreements which cannot be resolved within thesecommittees are put to an Executive Committee.

NYPP Agreement, State Hearings, Exhibit 17, 52.06, p. 6.

Hearings before the Committee on Interstate and Foreign Commerce,Subcommittee on Energy and Power, House of Representatives. 95thGong., 1st Sess. (“Hou&Subcommittee Hear&f j(testimony of JohnR. Vogel, Jr., NYPPecutive Director), pp* 146-44.

NYPP Operating Policy #6-O, State Hearings, Exhibit 19, p. 1:“The Senior Pool Dispatcher have binding authority torequire load reduction or other adjustments under specificconditions. . . .”

66

In the case of transmission planning and construction, the Poolcoordinates, rather than directs, the actions of the individual utilitiessince any utility which does not wish to construct a facility need onlyexq2ise its veto power.

The Pool has promulgated a number ofYoperation of the bulk power transmission system.

licies dealingwith theOS These policies are

developed on an ad hoc basis and deal, for example, with each member’sobligations with respect to operating reserves, voltage reduction, emer-gency procedures in the cases of insufficient generation to meet load andsevere air pollution alerts. There are no detailed policies regarding thecritical areas of operator training, control center design, manning ofsubstations, facilities and procedures for remote reclosing of ties, stormwatch procedures, settings of synchronous check relays, reserves againstloss of transmission, right-of-way maintenance, transmission tower designand callup of operating reserves during transmission emergencies. Evenwhere policies or procedures do exist, neither the NYPP Agreement northe policies themselves provide sanctions for a member’s failure to comply.In the area of relay testing and maintenance, the members of the Poolsubscribe to the Northeast Power Coordinating Council minimum guide-lineq206 but the Pool does not monitor or enforce compliance by itsmembers and has no sanctions it might imand testing deficiencies are uncovered.20+)

ose in the event maintenanceThe events of September 26

have revealed that in at least one case the standards have beenviolated. 206

D. Northeast Power Coordinating Council

The source of the few general standards for the design andoperation of the State bulk power system is the Northeast PowerCoordinating Council, a voluntary association of utilities and power poolsin the Northeast and parts of Canada. The NPCC was formed after the1965 blackout in response to the policy of the Federal Power Commissionto encourage voluntary regional interconnection and cooperation. The

205 State Hearings, Exhibit 19.

206 Testimony of William E, Shaffer, Department of Public Service,Chief System Planner, State Hearings, pp. 972, 986-88.

207 Ia, pp. 972, 988; NYPP testimony, State Hearings, pp. 1466-67.

208 Orange and Rockland did not observe NPCC miminum relay mainte-nance guidelines. enote 123 and accompanying text, supra.

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NPCC, acting in cooperation with the National Electric Reliability Coun-cil (“NERC”) and the North American Power Systems InterconnectionCommittee (“NAPSIC$~O~ promulgates standards on automatic loadshedding, the general principles of setting electric relays, and the “singlecontingencyfT design criteria discussed in Chapter I above.210

The NPCC is not a planning body.or budget.2ll

It does not have a large staffIt does not seek to determine on a regional basis the design

of the transmission system, nor does it attempt to resolve disputes amongmembers over the planning, construction and operation of the regionaltransmission system. It does review transmission plans but lacks the powerto order changes. The NYPP and its member utilities have adopted NPCCcriteria for system design and relay testing on a voluntary basis.

E. Public Service Commission

Public oversight of the reliability, planning and overall ade-quacy of the State bulk power transmission system is principally the re-sponsibility of the Public Service Commission. The Public Service Lawgives the Commission extremely broad general power over the activities ofall private utilities.2l2 Section 66 provides that the Commission shall:

209

210

211

212

NAPSIC was formed in 1962 by the then interconnected utilities inthe United States and Canada to coordinate the operation of theexpanding interconnected system. As of today there are ten NAPSICoperating areas within three major interconnected systems in theUnited States and Canada. NAPSIC*s chief goals have been to co-ordinate frequency, operating criteria related to time error, andtie-line bias settings. The organization also publishes an OperatingManual with 22 “Operating Guides”. However, they are not explicitenough for actual system operation. FPC Supp. Report, p. 71.

& note 13, supra.

It has four full-time professional employees and an annual budget ofapproximately $800,000. Testimony of Julius Bleiweis, NPCC FX-ecutive Director, State Hearings, p. 1360. About 100 professionalemployees of the aer systems participate in the various NPCCtask forces and committees which review member systems’ plans.NPCC letter dated December 21, 1977, State Hearings, Exhibit 49.

N.Y. Pub. Serv. Law (McKinney

‘*l. Have general supervision of all . . . electric COP-porations having authority . . . to lay down, erect or main-tain wires, pipes, conduits, ducts or other fixtures in, overor under the streets, highways and public places of anymunicipality for the purpose. . . of furnishing or transmittingelectricity for light, heat or power, or maintaining under-ground conduits or ducts for electrical conductors, . . . andelectric plants owned, leased or operated by any . . . electriccorporation;

“2. .C. examine or investigate the methods employedby such persons, corporations and municipalities in manu- lfacturing, distributing and supplying . . . electricity forlight, heat or power and in transmitting the same, and havepower to order such reasonable improvements as will bestpromote the public interest, preserve the public health andprotect those using such . . . electricity and those employedin the manufacture and distribution thereof, and have powerto order reasonable improvements and extensions of the works,wires, poles, lines, conduits, ducts and other reasonabledevices, apparatus and property of . . . electric corporationsand municipalities. . . .” Public Service Law S66.

Section 72 provides that after a hearing the Commission mayorder an electric corporation to make

%uch improvement . . . in the manufacture, transmission orsupply of electricity, or in the methods employed by suchperson or corporation as will in its judgment be adequate, justand reasonable.” ,,

In sum, electric utilities are obliged to

“furnish and provide such service instrumentalities andfacilities as shall be safe and adequate and in all respects justand reasonable,w Public Service Law §65.

The Public Service Commission is the regulatory agency entrusted toenforce that obligation,. Public Service Law §§5, 66.

(cont.1mission lines proposed by PASNY to a consideration of environmentalimpact rather than need, which it must take as established. PublicService Law §126(lxg). Nor can the PSC review a facility subjectto exclusive or preemptive federal jurisdiction, id. §121(4)(c), whichcan include lines connecting PASNY’s hyrdoxctric generatingfacilities to the bulk power grid.

69

CI -

1. Transmission planning

Review by the PSC of transmission planning occurs in “ArticleVII Proceedings” (Public Service Law§§l20-30) in which new transmissionlines are examined in public hearings for fTenvironmental compatibility andpublic need”. Although environmental concerns were an important impetusfor passage of the law in 1970, Article VII directs the PSC to consider notonly the environmental impact of a proposed transmission facility but alsowhether

%uch facility conforms to a long-range plan for expansion of theelectric power grid of the electric systems serving this state andinterconnected utility systems, which will serve the interests ofelectric systemeconomy and reliability. . . .” Public Service Law§126(lXdX2).

Review of transmission planning of a more general sort occurspursuant to Public Service Law §149-b, which requires the utilities, as“members of the New York power pool,11 to prepare an annual submissionof a %ingle comprehensive long-range plan for future operations,fT in whichdemand, generating capacity and transmission capacity are projected overa ten-year period. The Commission holds public hearings to review theadequacy of these plans. It ultimately issues an opinion in which it maycomment on aspects of the plan and the form of submission, but it doesnot generally approve or reject the long-range plan as submitted.

2. Operation of the bulk power system

The PSC has, pursuant to the Public Service Law, broadstatutory authority to regulate each utility’s operations, including, ofcourse, operation of its transmission system. One hindrance to such reg-ulation is the limited staff resources available to the PSC generally. Forall of its regulatory duties the PSC relies on the Department of PublicService for staff support. The Department’s Power Division, which mustsupply staff engineering work for all phases of electric utility regulation,is authorized to employ 115 persons. Only 22 are assigned to the SystemPlanning Section, which has specific oversight duties regarding theutilities planning and operations.213 As is often the case with regulatoryagencies, the PSC staff responds to problems as they surface and leavesdaily management to the regulated entities. In addition, questions of

213 The Power Division is divided into four sections, each with the fol-lowing number of employees: Tariff Analysis, 11, Rat es and Valu-ation, 25, System Planning, 22, and Consumer Service, 52. PSCtestimony (Stuzin), City Hearings, October 14, 1977, pp. 361-64.

4.

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70

procedure and policy affecting reliabilty historically have been treated asbeing within the sphere of management discretion.

The PSC also has the power to order fTmanagement and opera-tions audiW. The law provides that

“[sl uch audits shall be performed at least once every five yearsfor combination gas and electric companies. . , . The audit shallinclude, but not belimited to, an investigation of the company’sconstruction program planning in relation to the needs of itscustomers for reliable service and an evaluation of the efficiencyof the company’s operations .I1 Public Service Law §66(19).

The Commission may use independent auditors if it chooses, supervisetheir work, and require the utility to pay the costs. The law also gives thePSC authority “to direct the company to implement any recommendationsresulting from such audits that it finds to be necessary and reasonable,”apparently without need for a regular Commission proceeding. The scopeand usefulness of this audit power has not been fully tested, as it wasadded only in 1976. Since then there have been two audits, an Arthur D.Little study of Con Edison and a PSC staff study of Orange and Rockland.The statutory language and legislative history suggest that theLegislature’s main concern was efficient utility operations214 -minimizing consumer costs - and the audits do not appear to have focusedon reliability issues.

The Commission has been cautious in the assertion of authorityover the Pool itself. In one case, which reviewed procedures for loadshedding, exchanges of power between utilities in times of shortage, andother emergency actions, the PSC did assert jurisdiction to review andrevise an official Pool operating procedure. However, the order effectingits opinion was issued against each utility, not the Pool itself.215 Other

214 See L. 1976, c. 556, §l (legislative findings) (reprinted in McKinney%$p. following Public Service Law §66(19)).

215 Some utilities challenged this regulation aa lacking authority underState law, violating the Commerce Clause of the United StateeConstitution as an undue burden on interstate commerce, and aspreempted by the Federal Power Act. The Commission rejected allof these challenges to its authority for the particular regulation andthe utilities did not press the matter in the courts. See PSC OpinionNo. 73-11 (Case No. 259371, April 20, 1973 (Opinizand Order onJurisdiction over Intercompany Transfers of Emergency ElectricPower); Fourth Interim Report (Case No. 25937), September 19,

71

Pool policies and indeed the basic NYPP Agreement have not been for-mally reviewed by the Commission. Nor has the Commission sought to

, require the Pool to adopt policies and procedures in areas where themembers have not taken the initiative.

F. Federal role

The Federal Power Act gives the Federal Power Commission(“FPCn) and its successors, the Department of Energy and the FederalEnergy Regulatory Commission (VFERCw), an independent regulatoryagency within the Department of Energy, a regulatory role in the inter-state transmission and wholesale marketing of electric power.2l6 His-torically, the main involvement of the FPC was in the economic regulationof electric utilities, primarily ratemaking for wholesale sales. But theFederal Power Act also contains certain regulatory authority in respectof the reliability of the bulk power transmission system.

Section 202(a) of the Act requires the division of the country-into regional districts “for the voluntary interconnection and coordinationof facilities for the generation, transmission, and sale of electric energy”and directs the Secretary of Energy “to promote and encourage suchinterconnection and coordination within each such district and betweensuch districts** (emphasis added). Section 202(b) authorizes FERC to orderinterconnection and the sale of power, and set the terms of the arrange-ment, but only upon petition of a state public service commission or autility and only if, after a hearing, it is determined that such action wouldnot require the enlargement of generating facilities or impair a utility’i

afe,service to its own customers.217 Section 202(c)

1972 (Commissioner J&sL

216 Federal Power Act §§201-319, 16 U.S.C. 6§82&25r (1970). The De-partment of Energy Organization Act, 42 U.S.C.A. §§7151, 7172(West Supp. 3 19771, transfers functions under the Federal Power Actto the Secretary of Energy and FERC. The Secretary has, in turn,delegated to FERC certain of the functions transferred to him.Delegation Order No. 0204-1, Department of Energy, 42 Fed. Reg.55,637 (Oct. 18, 1977). References in this Chapter are to the termsof the Federal Power Act as modified by these transfers anddelegations.

217 Section 207 is a parallel provision authorizing FERC, upon petitionof astate commission, to determine that a public utility is providing**inadequate” interstate service and to order corrective action,subject to the provisos of Section 202(b).

72

authorizes the Secretary to order “temporary connectiorW of generatingand transmission facilities during a war or an emergency resulting from (‘asudden increase in the demand for electric energy, or a shortage ofelectric energy” or of generating or transmission facilities. Section 311authorizes FERC and the Secretary to investigate virtually any aspect ofthe electric power industry throughout the country and directs that gen-eration and transmission capacity and costs be monitored.

Federal law thus gives FERC and the Secretary only a limitedmandate with respect to the reliability of the bulk power system. Neitherhas power to order, on its own motion, interconnections between utilities,and indeed the FPC never ordered two private utilities to do ~0.~1~ Thusneither FERC nor the Secretary could move sua sponte to resolve theimpasse regarding, for example, additional tia-tween Con Edison andPSE&G. The power to order temporary interconnection and transmissionof power in case of war or emergency has not been construed to giveauthority to prescribe procedures in case of a serious disruption on the bulkpower system.2lg And no federal body has power to adopt mandatorystandards for the design, construction, maintenance or operation of thebulk power transmission system.

The federal government’s chief effort on behalf of reliabilityhas been to encourage voluntary industry activity and cooperation. Im-mediately after the 1965 blackout the FPC began to promote the forma-tion of “regional reliability councils,” of which the NPCC was the first.22OThe FPC has requested, but not ordered, that its staff and the staffs ofstate commissions be allowed to participate in principal council meetingsand in important technical meetings. The regional councils are furtherrequested, not ordered, to file annual reports on reliability issues, such asmonthly peak loads projected two years in advance, long term projectionsof generating and transmission capacity, and load flow studies over the

218 Section 202(b) has been invoked by municipal power systems but notby state commissions or other utilities. Testimony of DanielGoldstein, FERC Assistant Litigation Counsel,93. See Gainesville Utilities Dep*t v. Florida515 (1911).

219 See, s, 18 C.F.R. 6§32.60-.62 (1977).

220 There are nine councils covering the 48 contiguous states andrepresenting 98% of alt generating capacity in the nation. They inturn are members of the NERC. Since 1971, NERC has publishedannual reports assessing the reliability and adequacy of bulk powersupply in North America.

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c

transmission network. Although the Bureau of Power of the Departmentof Energy may analyze and comment upon these reports, it has no powerto disapprove or order modifications in ~lani.~~~ It should also be notedthat the Bureau of Power has even more serious staffin problems thanthe PSC: only 25 employees for a nationwide mandate. 2&

In 1970 the FPC began a rule making proceeding to consider theadoption of rules, pursuant to its emergency powers, to deal with possibleshortages of electric energy by load relief and curtailment managementplanning. The result was an order issued in January 1972 that councils andutilities are fTencouraged to review existing mutual assistance and emer-gency condition operating proceduresfT and to make such plans public.223Since then regional councils have been requested to provide, as part oftheir annual submissions, information on practices such as load shedding,power facilities available for the startup of units in the event of a systemshut-down, and programs for the selection, setting and maintenance ofrelays that affect the overall reliability of the interconnected network.224

Conclusi or?

1. The New York Power Pool does not exercise effective respon-sibility for the reliability of the bulk power transmission systembecause of its institutional inadequacies. Its members have refusedto grant it adequate authority to develop and enforce basic reliabilitystandards. Its function is to serve the diverse individual interests ofthe State’s various member utilities rather than to serve solely theoverall reliability and economy objectives of the transmission sys-tem. Nor is the Pool an adequate focus for accountability. As amechanism for bringing coherent direction to the planning and operation of the bulk power transmission system, it is, in its presentform, unsatisfactory.

221

222

223

224

The regional reliability council program is described in FPC OrderNo. 383-4, 41 Fed, Reg. 55,174 (Dec. 17, 1976); see also FPC Supp.Report, p. 73. Pm-

House Subcommittee HearinChairman of FERC), p.-z3+

(testimony of Charles B. Curtis,

FX Order No. 445, 37 Fed. Reg. 782 (fan. 19, 1972).

18 C.F.R. 52.11, Appendix A-l (1977).

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2. Given the current absence of effective overall bulk transmissionsystem management, there is a special need for close regulatorysupervision. Neither the public nor the PSC can safely depend onthe judgments and initiative of management alone. Under thesecircumstances the PSC has not exercised sufficient initiative inregulating the bulk power transmission system.

3. Increased emphasis on bulk transmission reliability at the federallevel is desirable but cannot be a complete solution. There arepractical limits on the extent to which federal administrative ma-chinery can be used efficiently to monitor and supervise detailedquestions of design and day-to-day operation.remain an important component in thisconcern.229

State supervision mustarea of vital state

225 Comments on certain portions of proposed federal legislation tomodify the federal role are set forth in the letter dated October 20,1977 from Norman M. Clapp, Special Consultant in Charge, to theHon. John D. Dingell, Chairman of the Subcommittee on Energy andPower of the House Committee on Interstate and Foreign Commerce(State Hearings, Exhibit 341, attached to this Report as Appendixm,

7s

CHAPTER V

Recommendations

Governor Carey in his Executive Order of July 22 instructedthat recommendations be made “for whatever action may be necessary toguarantee that there be no recurrence of any major power failure in thisState.”

Based upon the conclusions reached in this Report, it istherefore recommended:

I. That the New York Public Service Commission, through thePower Division, immediately undertake a continuing publicreview and inspection of the planning, testing, operatingand maintenance procedures and practices of New York utili-ties relating to the reliability of the bulk transmission sys-tem (230 IW or greater) within the State of New York.

This undertaking wilI require budgetary support for additionaltechnical staff to handle the workload involved in such an ongoing as-signment, but the public interest and safety at stake in the reliability ofthe bulk transmission system are too great to be left to postmortem in-vestigation and correction. It should be an active ingredient in the day-to-day development and guidance of the system.

Such a program should include consultation by the Power Di-vision with all members of the New York Power Pool, including PASNY,on the planning considerations for future additions to the bulk system withparticular reference to reliability considerations.

It should include monthly reporting by Con Edison and the otherutilities on the implementation of planned improvements in equipment,operating and maintenance procedures, and testing, to audit the progressmade.

It should include special reporting and review of system per-formance by the Power Division whenever a circuit in the bulk systemsuffers loading in excess of its LTE rating to provide a continuing evalu-ation of operating performance, coordination and judgment.

It should include a responsibility on the part of the PowerDivision to report any current deficiencies noted to the Commission withrecommendations for whatever specific corrective action or enforcementlies within the power of the Commission.

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II. That the Public Service Commission immediately initiate arule making proceeding for the purpose of establishing neces-sary and enforceable reliability criteria and procedures forthe use, maintenance, design and operation of those portionsof the bulk transmission system under the control of ConEdison, including a contingency plan for isolated operation.

In the establishment of such criteria and procedures it isrecommended that the Commission require:

A. Automatic callup of in-City generation following loss oftransmission or generation

Until the impact of the loss of any major transmission facilityor generation facility serving New York City can be determined, in-Citygeneration should be increased automatically as a preventive measure. Ifcircumstances warrant, the callup of reserves can be canceled after con-sultation between Con Edison and the POOL To implement this policy,economic dispatch should automatically be discontinued following the lossof any major transmission or generation facility serving New York Cityso that in-City generation will be increased automatically under areadispatch.

B. Maintenance of in-City generating reserves available torespond to transmission losses

Ten-minute reserves within New York City should be adequateto assure that dangerous levels of load shedding will not be required in theevent the Con Edison system becomes isolated. In fixing the new level ofrequired reserves it will be necessary to determine how much load cansafely be shed on the Con Edison system. Generation located outside theCity and generation that cannot be brought on line automatically shouldnot be counted as part of this reserve. Standards for the regular auditingof the availability and response rate of these reserves should beestablished.

C, Limitation of automatic reductions in in-City generationunder economic dispatch

Under automatic economic dispatch, declining Pool-widegeneration requirements can result in automatic reductions in the levelof in-City generation. Procedures should be established so that in-Citygeneration will not automatically be reduced if, as a result, imports willexceed schedule by more than Con Edison’s ten-minute spinning reserve.Present equipment should be adjusted and automatic controls installed toidentify that portion of transfers over schedule attributable to economic

77

dispatch and automatically to place Con Edison on area rather than eco-nomic dispatch control in the event economic dispatch transfers exceedthe ten-minute spinning reserve. Following automatic transfer to areadispatch, immediate consultation between Con Edison and the Pool shouldbe required, and return to automatic economic dispatch should be effectedonly after such consultation.

D. Prompt return of key facilities to service

Major &City generating units and transmission lines whichprovide path diversity to the City, such as the Linden, Hudson-Farragutand Jamaica ties, are key facilities from the perspective of Con Edisonsystem reliability. Preventive maintenance of these facilities should bedone on an especially rigorous schedule; when outages occur, extraordinaryefforts should be made to return these facilities to service. Availabilitystandards should be established and outages of key facilities should beseparately reported to the Public Service Commission. Outage frequencyand duration in excess of standards should result in economic sanctionswhich cannot be passed on to the ratepayers.

E. Stricter safety margins on imports into New York City

Present transfer limits are based on maintaining stability andline loadings below emergency levels following events less severe than theworst credible event. Where transmission diversity, capacity or genera-tion reliability are marginal or inadequate, criteria for an increased safetymargin should be established under the assumption that the most criticaltransmission and generation loss has already occurred. It may be possibleto relax these criteria if transmission capacity and diversity are improvedand the output of the Indian Point units is made firmly deliverable to NewYork City.

F. More rigorous design criteria for Con Edison transmission

in the Buchanan area which Con Edison apparently believes do not violateexisting design criteria. New design criteria appropriate to the Con Edisonsystem should be developed including criteria for a reasonable level oftransmission path diversity.

III. That the Public Service Commission initiate a rule makingproceeding for the purpose of establishing necessary andenforceable reliability criteria and procedures, applicableto all utilities in the New York Power Pool under Commis-

78

sion jurisdiction, as to the use, maintenance, design andoperation of their respective portions of the bulk trans-mission system, including a contingency plan for opera-tion when cut off from external sources of power.

In the establishment of such criteria and procedures it isrecommended that the Commission require:

A. Strengthened protective equipment maintenance and testingprocedures

Existing standards for relay and circuit breaker testing andmaintenance should be strengthened in at least the following respects: (1)relay systems should be tested as a unit upon installation and after main-tenance; (2) relay contacts should be visually inspected and relay targetschecked following each automatic operation; (3) circuit breakers shouldbe opened and closed during tests; (4) a visual recheck of relays and circuitbreakers should be made following any maintenance or testing procedurebefore the device is placed in service; (5) manual closing of relay tripcontacts should be avoided; (6) each utility should file its testing, in-spection and maintenance schedule and develop a procedure fordetermining that all required maintenance, inspection and testing has beencarried out; (7) periodic compliance certificates should be prepared andfiled; and (8) any overhead transmission facility lacking automaticreclosing capability should be treated as if out of service for the purposesof determining transfer limits.

B, Improved manual reclosing capability

District supervisors and substation operators should be drilledin procedures to effect the manual reclosing of ties and these employeesshould be authorized to prepare for or even attempt reclosing on their owninitiative under prearranged conditions and guidelines. Lines which cannotbe reclosed promptly due to the lack of substation manning or supervisoryfacilities to effect reclcsing following relay lockout should be treated asif out of service for purposes of calculating transfer limits. Reliableconfirmation of breaker status should be available to permit rapid clearingof erroneous backup relay operations. Facilities to reset backup relaysshould be available to the operator responsible for confirming the status ofthe indicated stuck breaker.

C. Improved cooperation in meeting system emergencies

Any system disturbance which results in imports of powerabove normal transfer limits should be an event requiring immediate con-sultation between the affected utilities and the Pool to arrange a course of

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action, with the final decision being made by the Senior Pool Dispatcher.Alarms should be provided at dispatch centers, substations and generatingstations to alert operating system personnel to emergency conditions.Personnel should have clearly defined responsibilities to ascertain systemstatus and confirm the implementation of response measures such as theautomatic increase in generation.

D. Standards for right-of-way maintenance

Right-of-way maintenance schedules and compliance certif-icates should be filed periodically with the Commission. Clearance fromtrees should not be the limiting factor in line loadings, and trees shouldbe trimmed so that they do not preclude operation above STE ratings forat least 15 minutes. Criteriashould be established to determine when landunder transmission lines should be cleared of trees.

E. Standards and performance criteria for dispatch centerdesign

Uniform minimum requirements for dispatch center capabilityshould be established, including requirements for information display,communication, equipment redundancy, staffing, data logging, computerspeed and capacity, and remote supervisory control facilities.

F. Standards for operator training and qualifications

The Commission should establish procedures for review ofutility training programs and qualification requirements for transmissionsystem personneL Programs should be submitted by the utilities for Com-mission review. These programs should emphasize the development ofmanagement capability in system operators and drill in emergency action.

IV. That the State of New York establish a single entity to beresponsible for the planning, design, development, mainte-nance and operation of the bulk power transmission systemin the State of New York.

Such an entity, while necessarily expected to serve all utilitiestransferring power whether as sellers or buyers for distribution within theirrespective service areas, should be independent of their control,

It should be an entity fully responsive to the overriding publicinterest in the reliability as well as the economy of the system.

It should be able to provide a new source of capital funding for

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needed transmission facilities so that the distribution and generatingutilities are free to concentrate their capital resources on their own in-ternal needs. This will also mean that the planning and design of the bulktransmission system will not be limited or warped by the financiallimitations, or pressures, or conflicting economic interests whichcurrently shape the planning and management decisions of the variousindividual utilities.

Above all, it should provide coherent and unified direction tothe planning, design and operation of the total bulk transmission system.While active regulation can alleviate important problems there is nosubstitute for day-to-day control in the hands of responsible, accountableand independent management.

The exact form of such an entity is a policy decision for theState of New York as determined by the leadership of the Governor andthe Legislature. There are at least three general approaches to beconsidered:

A.

B.

c.

A private utility corporation set up for this purpose alone,subject to the active regulation of the Public ServiceCommission.

A private utility corporation set up for this purpose butadministered under the State’s police powers by publicofficials and employees responsible to the Governor andthe Legislature in a manner similar to the federal admin-istration of the aviation traffic control system.

A public corporation similar to PASNY, or PASNY itself.

Whatever pattern is used, the entity should have full powers toacquire, lease or enter into other arrangements for the operation ofexisting bulk power facilities as well as to provide and integrate all needednew facilities into the system.

81

. . ..r _-. .d.. -..t .,.

. . P’

APPENDIX I

Maps and Diagram

A. Map of New York State Bulk Power Transmission System, April 1977.

B. Map of Con Edison Transmission System, Summer 1977.

C. Simplified Schematic Diagram of Con Edison 345 kv ‘RansmissionSystem.

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APPENDIX II

This Appendix contains one table and seven charts relating tothe Con Edison system between 8:37 and 9:36 p.m. on July 13, 1977. Itcompares actual events with projected results if certain actions had beencarried out by Con Edison. Five of the charts are charts included initiallyin Con Edison’s Second Report, which have been modified as indicated forpurposes of comparison.

The projected effects of the following three actions werestudied:

1. Beginning fast load pickup of ten-minute reserve generationfive minutes earlier (at 8:40 rather than at 8:45 p.m.). Chart 7 shows theeffect of achieving five minutes earlier the generation increases actuallyobtained by Con Edison.

2. Loading the Linden tie at its LTE rating (680 mw) followingthe second lightning stroke rather than its normal rating of 500 mw. Chart3 modifies a Con Edison chart to show in the shaded area the additionalflow into New York City that would have resulted from this action. Al-though not included in the calculations, it would have been justifiableunder the extreme conditions that existed after 8:55 to load the Lindentie to its STE rating (717 mw).

3. Beginning voltage reduction at 9:OO and in the same manneras it was actually carried out at 9:13. Chart 6 modifies a Con Edison chartto compare the actual effect of voltage reduction with the result thatcould have been achieved. if initiated earlier.

The impact that these three actions would have had on July13, as expressed in megawatts, is summarized in Table I, from which thereconstructed loadings shown in Charts 1 and 2 have been derived. Hadthese actions been taken, Chart 2 shows that circuit 92 would not haveexceeded its STE rating and would only have exceeded its LTE rating forabout seven minutes. The loading on circuit 80 would have declined belowthe STE rating by 9:lS.

Had these actions been taken, the system would have beenunder control at 9:15. Con Edison and the New York Power Pool thencould have agreed on further action. The loading on the Norwalk tie at9:15 was approximately 150 mw below its STE rating (see Chart 5) and theloading on the Jamaica tie at 9:lS was far below its normal rating (seeChart 4). Thus, adjustment of the Norwalk tie by phase angle regulationcould have been used to bring circuit 80 well below its LTE rating.

1

Projected Effect of Certain Actions(in megawatts)

Adjustmentof Linden Vo 1 tage

Time Tie (1) Reduction (2)Additional

Generation (3)TotalRelief-

8:55

9:oo IO start

9:05 180 110

9:lO 190 60

9:15 170 0

160 160

200 210

50 340

0 250

130 300

(1) Loading tie. to its LTE rating (see Chart 3).

(2) Beginning voltage reduction at 9:OO and achievingthe same results as in Chart 6.

(3) ziri;g fast,,load pickup at 8:40 p.m. (see.

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EFFECT OF.‘40 LTAGEREDUCTION IF INSTITUTED

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*TELEMETERING DATA INCLUOES FLOWST O CARMEL AN0 MOHANSlC SUBSTATiONS

M MOOlFtCA’TlON TO ORffilbJAl CON’ EDISONCHART.6 0 1 0

(HWRS)

CON EDI SON GROSS GENERATION +k,JULY 13, 1977

(20:30 TO 21:29:41 HOURS)

4400 -

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A000 -

3800 -

3200/-

CHART 7

4+ FROM CON ED PHASE’II REPORT

(EASED ON SUM OF LOADS SHOWNON FIGS S-1, 5-2, 5-3)

E-EXAMPLE OF GAIN BYFASTER GENERATIONLOAD PICKUP

20:30 20:A0

(HOURS-I

21:29:41

APPENDIX III

October 20, 1977

The Hon. John D:- Dingel& ChairmanSubcommittee on Energy and Power of the

Committee on Interstate and Foreign Commerce+Room 3204 House Office Building Annex 2Washington, D. C. 20515

Dear Mr. Chairman:

When I appeared before your subcommittee on October 13, 1977, yourequested that I furnish the subcommittee with comments on Sections 541through 545 of H.R. 8444. My testimony was presented in my capacity asSpecial Consultant in Charge of the New York State investigation of thepower failure in New York City on July 13, 1977. My comments,therefore, are offered in the context. of that capacity. Because the in-vestigation that I am conducting is not yet complete, I am not now in theposition to provide comprehensive comments on these sections. I amprepared, however, to make the observations on Sections 541 and 5455,set forth below:.

1, Section 541(b)(2)(A) prohibits an interconnection, pooling or wheelingorder unless the Commission finds that such order will benefit consumersby “reducing co&P of supplying energy or assuring electric supplies with“greater economy.” While reduced c&s or improved economy are im-portant justification for such orders, my testimony focused on thedifferent problem of the need for interconnection to maintain adequatestandards of system reliability. There will,. no doubt, be instanceswhere interconnection for reliability purposes will be in the publicinterest despite the absence of cost savings. I suggest that the subparagraph541(aX2XA) be modified by the insertion of the words “or reliabilityafter “greater economy” in order to give the Commission clear authorityto deal with this situatiott.

2, The converse of the point made in the preceding paragraph is thatinterconnection which imposes no economic hardship, but which isdetrimental to system reliability is not in.the public interest. I recom--mend that the phrase “or deterioration of overaU reliability of theinterconnected systems” be inserted after “economic hardshipl* in Section541(b)(2XB)..

3. Section 541(b)(2) also contains a requirement that a utility makingapplication for interconnection or wheeling.demonstrate that it is ready,

willing, and able to provide reimbursement reasonably due for the costs(including capital or operating costs> incurred by the electric utility thatis requested to make physical connection or to wheel energy. I assumethat this requirement is not intended to undercut the Commission% au-thority to direct the apportionment of costs between the affected utilities(see Section 541 (b)(5)). To make this point clear, I suggest that the words“its. share of” be inserted after “reasonably due foP at line 5 of page 213of the proposed bill..

4, Section 541(b)(3) provides for Commission orders directing electricutilities to increase the transmission capacity of bulk power transmissionfacilities, As in the case of interconnection, it appears that economic andreliability considerations should be weighed by the Commission beforeissuing an order directing an increase in transmission capacity. Yet, aspresently drafted, 541(b)(3) contains no comparable provision to 541(b)(Z)requiring consideration of these factors. I suggest adding “upon thefindings specified in paragraph (2),” after “maylV in the sixth line of Section541(b)(3).

5. Section 541(b)(5) provides that the Commission may determine the’apportionment of costs and the compensation or reimbursement reasonablydue 9f the parties fail to agree to such terms and conditions.” Xn orderto make it clear that the Commission’s regulatory jurisdiction over theterms and conditions of interchange transactions is not defeated byagreement among the parties, I would suggest deletion of the conditionalphrase quoted above..

6. In certain respects, the provisions of Section 541 go so far as to assertFederal jurisdiction over- what would commonly be thought of as localdistribution or retail sales, For example, Section 541(b)(l) authorizes theCommission to direct interconnection with a qualified cogeneration fa-cility without specifying any. minimum capacity for such facility, andSection 541(c) exempts action under Sections 202(b) and 205(k) from theprovisions of Section 201(b) barring Federal jurisdiction over “facilitiesused in local distribution.~ Direct Federal responsibility for questions ofdistribution and retail sales at the local level raises in my mind substantialdoubt about the practical feasibility of efficiently and fairly resolvingthese local questions. through Federal administrative machinery. Absentsome compelling showing of a need for Federal control, it would, in myview, be unwise to endanger the administrative effectiveness of the Com-mission by expanding its regulatory scope beyond the critical area of bulkpower supply between electric utilities. I therefore. recommend the ad-dition of a statutory minimum capacity for a qualifying’ cogenerationfacility and conforming revision of Section 541(c).

7; Sections 541 and 545 require that Commission orders be preceded by anevidentiary hearing. While this traditional and salutary requirement willbe appropriate in many instances, evidentiary hearings are a wasteful and

.

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2

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unnecessary burden in instances where disputes can be resolved throughconciliation or where genuine issues of fact do not need to be resolved.Rather than an absolute evidentiary hearing requirement, I suggest thatthe three-step procedure of 1) an informal conference and staff inves-tigation with the utilities, pursuant to a Commission order of investiga-tion, looking to voluntary agreement on terms satisfactory to the Com-mission; 2) in the event such voluntary agreement is not reached, a Com-mission order to show cause why specified action should not be directedupon the staff findings recited in such order; and 3) an evidentiary hearingin the event an affected utility or interested party takes a material ex-ception to the staff findings recited in the order to show cause, and theCommission determines that an evident&y hearing is required to resolvegenuine questions of fact put in issue by such exception.

8. Section 545(a) provides for the promulgation by the Commission of“rules respecting electric utility reliability.” For the reasons set forth inparagraph 6 above, I do not believe that a case has been made for primaryFederal jurisdiction over all aspects of electric utility reliability including,for example, the reliability of local distribution networks. I thereforeurge that the conferees substitute Pules respecting the reliability of bulkpower transmission systems and pooling or wheeling arra.ngementY for thelanguage quoted above.

9. Section 545 appears to contemplate that the reliability rules to bepromulgated by the Commission will have the effect of preempting statejurisdiction over reliability. While Section 545(d) authorizes the Commis-sion to delegate certain limited implementation authority to any state,the legislation does not protect the power of a state to impose morestringent reliability criteria -where this come is believed to be requiredby local conditions.. To preserve state authority in this area of vital stateconcern, the following sentence should be added to the end of Section545(d):. “Any state regulatory authority may, to the extent provided bystate law, promulgate and enforce rules respecting electric utility reli-ability which do not-impair authority actually exercised by the Commissionunder this Section:Tf

Thank you for affording me an opportunity to comment on this proposedlegislation. As I testified before your Subcommittee, the failure .of theCon Ed system on July 13 and 14, 1977,. is, to my mind, strong evidenceof the need for Federal legislative action in the areas covered by thesecomments.

Very *uly yours,

Norman M. Clapp

3.

APPENDIX IV

LIST OFWITNESSES

(In the order in which they testified)

Lester M. Stuzin, Director, Power Division,Department of Public Service% Albany, New York

William i3. Shaffer, Chief System Planner,Department of Public Service, Albany, New York

Howard A. Tsrler, Chief, Management Audit Section,Department of Public Service, Albany, New York

James B. Keating, Principal System Planner,Department of Public Service, Albany, New York

S. A. Tilaro, Principal System Planner;Department of Public Service, Albany, New York

Daniei Goldstein, Assistant Litigation Counsel,Federal Energy Regulatory Commission,. Washington, D.C.

Ira M.. Millstein,‘ Chairman, New York City Special Commission of Inquiryinto Energy Failures

David K. Laniak,. Vice Chairman, New York Power Pool andSuperintendent of Electric System Planning and Operation,Rochester Gas and Electric Corporation *

Rolland A. M&ill, Jr., Operating Manager,New York Power Pool

Peter Zarakas, Vice-President of Engineering, Chairman of Hoard ofReview, Consolidated Edison Company

Frank E. Fischer, Chief ELectrical Engineer,Consolidated Edison Company

* Mr. Laniak testified for the New York Power Pool on September 20,1977 and for Rochester Gas end Electric Corporation on November 15,1977.

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A. Norman Terreri, Assistant Vice-President of nansmission Operations,Consolidated Edison Company

John R, Gummersall, Senior Vice-President of Operations,Long Island Lighting Company

Charles J. Durkin, Jr., Chief System Operator,Consolidated Edison Company

John E. Deegan, Jr., Vice-President of Planning;Consolid+ted Edison Company

F. J. DeLea, Chief Electric Planning Engineer,Consolidated Edison Company

Lester H. Fink, Assistant Director for Systems Management andStructuring of the Electric Energy Systems Division, Energy Research andDevelopment Administration, Department of Energy

James J. McCarthy, Assistant Vice-President of Engineering,Orange and Rockland Utilities, Inc.

Charles A. Bolz, Vice-President of Engineering and General Services,Central Hudson Gas and Electric Corporation

R. R,Schneider, Vice-President of EIectric Production,Niagara Mohawk Power Corporation

J. F. Aldrich, Manager,. System Power Control,Niagara Mohawk Power Corporation

P. D, Raymond, Jr., Manager, System Planning,Niagara Mohawk Power Corporation

E. J. Weiss, Manager, System Protection Engineering,Niagara Mohawk Power Corporation

Jack H. Roskoz, Vice-President of Operations;New York State Electric and Gas Corporation

Charbs J, Davis, Vice-President of Engineering,Long Island Lighting Company

Robert H. Hiney, Manager, Production and Marketing,Power Authority of the State of New York

H. Kenneth Haase, Principal System Planning Engineer,Power Authority of the State of New York

Eugene F. Bridler, System Operations Officer,Power Authority of the State of New York

John H. Phillips, Principal Operations Engineer,Power Authority of the State of New York

Julius Bleiweis, Executive Director,Northeast Power Coordinating Council

William J. Balet, Planning Manager,New York Power Pool

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Walter D. Brown, Executive Vice-President,

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