NERC Case Notes: Reliability Standard PRC-001-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-001-1

NERC Case Notes: Reliability Standard PRC-001-1

White & Case NERC Database

This page contains the NOP (Notice of Penalty) and ACP (Administrative Citation of Penalty) summaries. Click here to read the FFT (Find, Fix and Track) summaries.

American Electric Power Service Corporation and PJM Interconnection, LLC, FERC Docket No. NP14-28 (January 30, 2014)

Reliability Standard: PRC-001-1

Requirement: 3.2

Violation Risk Factor: High

Violation Severity Level: Lower

Region: RFC

Issue: American Electric Power Service Corporation (AEP) changed the relay settings for line relaying on its Fostoria Central-Lemoyne 345 kV transmission line (which serves as an interconnection between AEP and FirstEnergy Corporation (FirstEnergy)), but did not inform FirstEnergy of the revised settings. This resulted in a May 29, 2012 misoperation on the Lemoyne terminal at Fostoria Central station. Based upon a request by PJM Interconnection, LLC (PJM), RFC found that AEP did not abide by the PJM Consolidated Transmission Owners Agreement, including the PJM Compliance Bulletin for Reliability Standard PRC-001-1 which required coordination when a modification is made to a protection system that changes it performance. AEP did not coordinate with its neighboring entities as required when it changed the reach of a distance relay. PJM, as the TOP, had a violation of PRC-001-1 3.2 as a result of AEP’s lack of coordination of protective system changes with a neighboring TOP.

Finding: RFC found that the PRC-001-1 violation constituted a moderate risk to BPS reliability as the lack of coordination between AEP and FirstEnergy regarding the protection system changes caused a misoperation. But, BPS stability was not affected as a result of the misoperation since the Fostoria Central breakers successfully reclosed within 10 seconds after the overreaching trip. The duration of the violation was from March 15, 2012 through July 20, 2012. AEP and PJM agree and stipulate to the terms of the settlement agreement. In approving the settlement agreement, NERC BOTCC considered the fact that the violation was self-reported and represented the first violation of the relevant Reliability Standard. RFC did not seek to impose a monetary penalty as it wants to incentivize strong compliance programs and internal controls, and AEP and PJM displayed commitment to strengthening their internal controls and preventing reoccurrence of the violation. AEP and PJM were also cooperative during the enforcement process and did not conceal the violation.

Total Penalty: $0

FERC Order: Issued February 28, 2014 (no further review)

American Transmission Co. LLC, Docket No. NP12-13 (January 31, 2012)

Reliability Standard: PRC-001-1

Requirement: R6

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: American Transmission Co. LLC (ATC) submitted a self-report on January 14, 2011 stating that it had failed to monitor the status of its Plains Power Swing Relay Special Protection System (“Plains SPS”) and failed to provide notice regarding a change in status of the Plains SPS to affected TOPs and BAs in violation of PRC-001-1 R6. ATC discovered that in the process of upgrading the Plains SPS, it did not install the new Direct Transfer Trip (DTT) correctly, preventing the Plains SPS from performing accurately. ATC was not aware of the issue and, therefore, did not provide the requisite notice. The duration of the violation was from August 21, 2009 to December 17, 2010.

Finding: RFC determined that the violation posed a moderate risk, but did not pose a serious or substantial risk, to the reliability of the BPS because, based on simulations, it was found that cascading outages could not occur as a result of the defective DTT installation. ATC would have been able to successfully separate any unstable portions of its transmission system from the rest of its system.

Penalty: $35,000

FERC Order: Issued March 1, 2012 (no further review)

Arlington Valley, LLC - AVBA, FERC Docket No. NP13-9 (December 31, 2012)

Reliability Standard: PRC-001-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: AVBA self-reported, as a TOP, that its operating personnel were not adequately familiar with the transmission Protection System schemes used in the area, especially the purposes and limitations of those Protection Systems.

Finding: WECC found that the PRC-001-1 violation constituted a moderate risk to BPS reliability. In regards to the PRC-001-1 violation, it is necessary for operating personnel to know the neighboring transmission Protection System schemes in order to prevent potential misoperations and misunderstandings from occurring. Arlington Valley's operating personnel did have some knowledge of the transmission Protection System schemes, even though they had not received formal training on them. The duration of the PRC-001-1 R1 violation was from November 5, 2007 through August 9, 2009. Arlington Valley stipulated to the violations. In approving the settlement agreement, the NERC BOTCC considered the fact that these violations were Arlington Valley's first violations of the relevant Reliability Standards; the violations were not intentional and were promptly mitigated once discovered; and Arlington Valley was cooperative during the enforcement process and did not conceal the violations. In addition, all but one of Arlington Valley's violations did not constitute a serious or substantial risk to BPS reliability.

Penalty: $60,000 (aggregate for 43 violations)

FERC Order: Issued January 30, 2013 (no further review)

Calpine Corporation and Calpine Power Management, LP, Docket No. NP12-32-000, June 29, 2012

Reliability Standard: PRC-001-1

Requirement: R2, R3.1

Violation Risk Factor: High

Violation Severity Level: Severe (R2); High (R3.1)

Region: TRE

Issue: TRE initiated a Spot Check of Calpine Corporation (“Calpine Corp.”) and its subsidiary, Calpine Power Management, LP (“CPM”) (collectively, “Calpine”), on August 20, 2010 and found violations of R2 and R3.1. Specifically, TRE found that there was no evidence that the TOP and host BA were notified of a relay failure at a generating unit (Citgo North Oak Park Unit 3) on May 8, 2009 in violation of R2. Moreover, TRE determined that although Calpine notified the TOP/BA of an earlier, similar relay failure that occurred in October 2008, Calpine did not report why the relay failed and did not take prompt action to rectify the failure following the October 2008 event, as evidenced by the May 8, 2009 event and three other similar events. With respect to the violation of R3, TRE found that following the October 2008 misoperation, Protection System changes were implemented on November 3, 2008 in an attempt to remedy the issue, but that such changes were made without the requisite coordination with the relevant TOP/BA and TO. The duration of the violations was from November 3, 2008, the date inadequate protection system changes were implemented without prior coordination, until May 9, 2009, the date adequate Protection System changes were implemented and the TOP/BA was notified of the changes.

Finding: TRE determined that the violations posed a moderate risk to the reliability of the BPS because the incorrect CAP resulted in additional misoperations that could have been avoided. The violation was mitigated by the following factors: replacement capacity was available to cover the temporary loss of the BPS generation capacity associated with the tripped unit and the misoperations did not result in a state of Energy Emergency Alert; the unit was only generating approximately 62 MW output to the BPS at the time of the incidents; there was no loss of customer load; and the unit was quickly re-synchronized following each misoperation. In addition, although R3 requires coordination for the implementation of new protection system changes, the changes that were implemented on November 3, 2008 did not hinge on any special actions by either the TOP or BA.

Penalty: $100,000 (aggregate for four violations between Calpine Corp. and its subsidiary, Calpine Power Management, LP)

FERC Order: Issued July 27, 2012 (no further review)

Castleton Power, LLC, FERC Docket No. NP11-82-000 (January 31, 2011)

Reliability Standard: PRC-001-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: NPCC

Issue: In May 2009, Castleton Energy Center (CSP) acquired the equity interests in EPCOR (Power) Castleton LLC n/k/a CSP. CSP conducted a self-audit and found that, due to the new ownership, it did not have documentation showing that its facility personnel were familiar with the purpose and limitations of protection system schemes applied in its area as required by the Reliability Standard.

Finding: NPCC Enforcement determined that the violation did not create a serious or substantial risk to the bulk power system because protective relay circuits (except for current transformer (CT) and potential transformer (PT) circuits) were being tested. NPCC Enforcement further found that although CSP did not have formal documents showing it was familiar with protection system schemes, it had a general familiarity with the protection system schemes as evidenced by the fact that CSP was performing maintenance and testing on all of its generators and associated equipment, except for the CT and PT testing, which subsequently tested satisfactorily. The NERC Board of Trustees Compliance Committee (BOTCC) assessed a $10,000 penalty for the violation of PRC-001-1 and violations of PRC-005-1. In reaching its determination, the NERC BOTCC considered that the subject violation was CSP's first occurrence of a violation of the subject Reliability Standard; CSP cooperated during the compliance enforcement process; CSP had an internal compliance program; and there was no evidence CPS attempted to conceal the violation.

Penalty: $10,000 (aggregate for multiple violations)

FERC Order: Issued March 2, 2011 (no further review)

Duke Energy Carolinas (DEC), Docket No. NP13-20 (December 31, 2012)

Reliability Standard: PRC-001-1

Requirement: 1, 4

Violation Risk Factor: High

Violation Severity Level: High (R1); Lower (R4)

Region: SERC

Issue: On August 25, 2007, a disturbance occurred on DEC’s portion of the BPS that ultimately resulted in the tripping offline of about 900 MW of generation and the temporary outage of five 230 kV transmission lines. The disturbance was exacerbated due to the failure of Protection System design. As a result of an investigation into the causes of the disturbance, SERC concluded that DEC was not familiar with the limitations of the generation station Protection Systems connected to its system, which is required by R1, and therefore did not design its Protection Systems appropriately. It was also discovered that six other generation stations within DEC’s system had similar design failures (though no disturbance occurred with respect to them on August 25, 2007). In addition, DEC did not coordinate specific relay functions when it installed Protection Systems at a particular generating station as required by R4.

Finding: SERC decided the violations of R1 and R4 posted a moderate risk to the reliability of the BPS because DEC’s unfamiliarity with the Protection Systems in its part of the BPS could lead to significant design or operational mistakes. DEC’s previous violations of the same or similar standards were not considered aggravating factors because the facts and circumstances of the prior violations were not related to the current violation. The duration of the R1 and R4 violations was from June 18, 2007 through June 1, 2014.

Total Penalty: $17,000 (aggregate for 3 violations)

FERC Order: Issued January 30, 2013 (no further review)

EcoGrove Wind LLC (EcoGrove), Docket No. NP12-26-000 (April 30, 2012)

Reliability Standard: PRC-001-1

Requirement: R3/3.1

Violation Risk Factor: High

Violation Severity Level: Lower

Region: RFC

Issue: During a Compliance Audit in May 2011, RFC determined that EcoGrove, as a GOP, was in violation of PRC-001-1 R3.1 based upon its failure to produce evidence that it coordinated protective system changes with its TOP and BA. Specifically, in June 2009, EcoGrove had a misoperation caused by a relay set point being set less than the total amount of flow out of the generators, leaving EcoGrove unable to ensure that 8.28 MW of its available generating capacity (100.5 MW) reached the interconnection point. To correct the cause of the misoperation, EcoGrove changed the settings on six of its overcurrent relays. EcoGrove could not show that the changes were coordinated with its TOP and BA.

Finding: The violation was determined to pose a minimal risk to BPS reliability because even though EcoGrove did not coordinate the changes, its BA was aware of the change which allowed pre-coordinated generation to reach the interconnection point. The 8.28 MW of generation was agreed upon among EcoGrove, the interconnecting utility and the BA, so the 8.28 MW did not cause the maximum amount of generation expected to be exceeded. Also, EcoGrove supplies its BA with five-day production forecasts each day, so the BA knew of the generating capability by way of those reports. In determining the appropriate penalty, RFC considered EcoGrove’s internal compliance program in effect during the violation period to be a mitigating factor. RFC considered that the violations were all discovered during a Compliance Audit and not through self-reports so no mitigating credit was applied. Further mitigating factors were EcoGrove’s cooperation and timely submittal of a Mitigation Plan.

Penalty: $2,000 (aggregate for 3 violations)

FERC Order: Order issued May 30, 2012 (no further review)

Indianapolis Power & Light Company, FERC Docket No. NP11-210-000 (June 29, 2011)

Reliability Standard: PRC-001-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: During a compliance audit in March 2010, RFC found that Indianapolis Power & Light Company (IPL), as a Balancing Authority, Generator Owner and Transmission Operator, did not possess adequate documentation showing that all of its operating personnel were sufficiently familiar with the purpose and limitation of protection system schemes used in the IPL area.

Finding: RFC and IPL entered into a settlement agreement to resolve multiple violations, whereby IPL agreed to pay a penalty of $70,000 and to undertake other mitigation measures. RFC found that the PRC-001-1 violation did not constitute a serious or substantial risk to bulk power system reliability since the protection systems that IPL uses are standard in the industry and all of the relevant IPL personnel are NERC-certified operators (who received training on protection systems). The duration of the PRC-001-1 violation was from June 18, 2007 through May 31, 2011. In approving the settlement agreement, NERC found that these were IPL’s first violations of the relevant Reliability Standards; IPL was cooperative during the enforcement proceeding and did not conceal the violations; there was a compliance program in place (which was evaluated as a mitigating factor); and there were no additional aggravating or mitigating factors.

Penalty: $70,000 (aggregate for 11 violations)

FERC Order: Issued July 29, 2011 (no further review)

Madera Power, LLC (MADP), Docket No. NP12-47-000 (September 28, 2012)

Reliability Standard: PRC-001-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: High

Region: WECC

Issue: MADP self-reported that while conducting an internal compliance audit in September 2011 it found that, as a GOP, it was in violation of PRC-001-1 R1 for its failure to have an adequate training program for its operators in the purpose and limitation on protection system schemes.

Finding: The violation was deemed to pose minimal risk to BPS reliability. MADP did have a training program in place; however, upon testing its operators, it determined the program was not sufficient enough to properly train its operators on protection system schemes. In determining the appropriate penalty, WECC considered MADP's internal compliance program as a mitigating factor; however, MADP's compliance history was considered an aggravating factor. MADP agreed/stipulated to WECC's findings.

Penalty: $4,000 (aggregate for two penalties)

FERC Order: Issued October 26, 2012 (no further review)

Naniwa Energy LLC, FERC Docket No. NP11-57-000 (November 30, 2010)

Reliability Standard: PRC-001-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: High

Region: WECC

Issue: Naniwa self-reported that it could not confirm that a plant manager was familiar with protection schemes outside of the generating plant itself, in particular protection schemes related to its Transmission Operator.

Finding: It was determined by WECC that the violation did not pose a serious or substantial risk to the reliability of the bulk power system because Naniwa's plant manager was in contact with the Transmission Operator on a regular basis and therefore would have been notified of any significant events affecting protection schemes beyond the Naniwa plant itself. The duration of violation was June 18, 2007, when the Reliability Standard became mandatory, through June 30, 2009, when Naniwa's mitigation plan was completed. In determining the penalty, consideration was given to the fact that Naniwa self-reported the violation, and this was Naniwa's first occurrence of violation of this Reliability Standard.

Penalty: $27,000 (aggregated for multiple violations)

FERC Order: Issued December 30, 2010 (no further review)

New Harquahala Generating Company, LLC, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-001-1

Requirement: R4

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: WECC

Issue: New Harquahala Generating Company, LLC (New Harquahala) self-reported that it was unable to produce documentation showing that it was coordinating the protection systems for its major transmission lines and interconnections with its neighboring Generator Operators, Transmission Operators, and Balancing Authorities.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since New Harquahala was actually coordinating the protection systems on its major transmission lines and interconnections with its neighboring Generator Operators, Transmission Operators, and Balancing Authorities. The violation was primarily a documentation issue. Also, the violation was self-reported and was New Harquahala's first violation of this Reliability Standard. Even though the violation occurred before the Reliability Standards became mandatory, New Harquahala did not complete its mitigation plan in a timely manner. This delayed completion turned the violation into a post-June 18, 2007 violation. Even though the mitigation plan was completed late, no penalty was imposed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

NextEra Energy Resources, LLC, FERC Docket No. NP11-244-000 (July 28, 2011)

Reliability Standard: PRC-001-1

Requirement: R3.1

Violation Risk Factor: High

Violation Severity Level: High

Region: RFC

Issue: RFC found that in three instances NextEra Energy Resources, LLC (NextEra) had implemented protective system changes at its Point Beach Nuclear Plant, but had not coordinated those changes with its Transmission Operator and/or its Host Balancing Authority.

Finding: RFC and NextEra entered into a settlement agreement to resolve multiple violations, whereby NextEra agreed to pay a penalty of $60,000 and to undertake other mitigation measures. RFC found that the PRC-001-1 violation did not constitute a serious or substantial risk to bulk power system reliability since the Transmission Operator was involved in coordinating the protective system changes in two of the relevant instances. In addition, the Transmission Operator and Host Balancing Authority confirmed that the protection provided by NextEra’s protective systems was sufficient at all times. The duration of the PRC-001-1 violation was from May 12, 2008 through October 14, 2010. In approving the settlement agreement, NERC found that this was NextEra’s first violation of PRC-001-1 R3.1 (even though it had previous violations of PRC-005-1 R1.1 and R2.1); one of the violations was self-reported; NextEra was cooperative during the enforcement process and did not conceal the violations; NextEra had a compliance program in place (which was evaluated as a mitigating factor); and there were no additional aggravating or mitigating factors.

Penalty: $60,000 (aggregate for multiple violations)

FERC Order: Issued August 29, 2011 (no further review)

Panda Brandywine LP, Docket No. NP11-270 (September 30, 2011)

Reliability Standard: PRC-001-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: During a compliance audit, RFC determined that Panda Brandywine LP (Panda) violated R1 because Panda failed to provide sufficient evidence that its operations personnel were familiar with the purpose and limitations of relevant protection system schemes.

Finding: RFC determined that the violation posed a moderate risk to the reliability of the BPS, but did not pose a serious or substantial risk to the reliability of the BPS, because Panda’s training program covered fundamental aspects of relay protection systems and other electrical components, switching and electrical systems, and Panda represented that it provides on-the-job training on relay protection system schemes specific to Panda’s facility. The violation lasted from February 25, 2008 to December 15, 2010.

Penalty: $50,000 (aggregate for 4 violations)

FERC Order: Issued October 28, 2011 (no further review)

PJM Interconnection, LLC, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-001-1

Requirement: R1, R3.2, R4

Violation Risk Factor: High (R1, R3.2, R4)

Violation Severity Level: Severe (R1), Lower (R3.2, R4)

Region: RFC

Issue: During a compliance investigation into system disturbances when the Fort Martin generating station tripped offline, RFC determined that PJM Interconnection, LLC (PJM), as the TOP and BA, did not possess complete information on the settings and operating characteristics of the Fort Martin protection system schemes and the changes that were made to those schemes. The FirstEnergy Utilities had replaced two relays at the Fort Martin substation, but did not notify PJM. Therefore, PJM was not sufficiently familiar with the purposes and limitations of the protection system scheme at the Fort Martin substation (R1). PJM also did not coordinate the protection system changes at the Fort Martin substation with neighboring GOPs, TOPs and BAs (R3.2, R4).

Finding: To prevent future violations, PJM updated its reporting requirements for its member TOs concerning relay protection system changes and changed its manual to cover protection systems. PJM also evaluated the specific change to the Fort Martin protection system in order to determine if additional modeling was needed. The duration of the PRC-001-1 violations was from October 14, 2008 through December 18, 2009. RFC evaluated as mitigating factors certain aspects of PJM’s compliance program and its cooperation with RFC. As all the PRC-001-1 violations arose from the same set of circumstances, it was not considered to be a repeat violation.

Penalty: $10,000 (aggregate for 4 violations)

FERC Order: Order issued June 29, 2012 (no further review)

Portland General Electric Co. (PGE), FERC Docket No. NP15-28-000 (April 30, 2015)

Reliability Standard: PRC-001-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: PGE self-reported that it "failed to be familiar with the purpose and limitations of protection system schemes applied in its area." PGE placed two Local Area Protection Schemes (LAPS) into service without identifying them as Special Protection Schemes (SPS). The violation occurred for approximately five years.

Finding: WECC found that this issue posed a minimal, but not a serious or substantial, risk to BPS reliability. Misoperation of the SPSs could have resulted in exposure of local 115kV facilities to low-voltage, removal of equipment and generation from service, and damage to transmission lines from overload. However, PGE continuously monitored the SPSs’ relays, regularly maintained and tested the equipment, and one of the SPSs had been operated successfully. WECC also considered PGE’s internal compliance program for meeting reliability standards as a factor that mitigated the penalty determination. In order to further mitigate this violation, PGE (1) trained appropriate personnel to identify SPSs, (2) trained TOPs, BA, and GOPs on the SPSs at issue, (3) implemented a test plan and schedule for one SPS, and (4) disabled the other SPS.

Penalty: $97,000 (aggregate for 8 violations)

FERC Order: FERC approved the settlement on May 29, 2015.

Portland General Electric Co., FERC Docket No. NP15-28-000 (April 30, 2015)

Reliability Standard: PRC-001-1

Requirement: R3

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: WECC

Issue: PGE self-reported that it failed to coordinate new protective systems with its TOP and Host BA when it placed two Local Area Protection Schemes (LAPS) into service. PGE did not identify the LAPS as special protection schemes (SPS) and therefore PGE failed to appropriately coordinate the systems. The violation occurred for approximately five years.

Finding: WECC found that this issue posed a minimal, but not a serious or substantial, risk to BPS reliability. Misoperation of the SPSs could have resulted in exposure of local 115kV facilities to low-voltage, removal of equipment and generation from service, and damage to transmission lines from overload. However, PGE continuously monitored the SPSs’ relays and regularly maintained and tested the equipment, which made PGE able to notify its TOP and Host BA of any changes. WECC also considered PGE’s internal compliance program for meeting reliability standards as a factor that mitigated the penalty determination. To further mitigate this violation, PGE (1) trained appropriate personnel to identify SPSs, (2) trained the TOPs, BA, and GOPs on the SPSs at issue, (3) submitted a list of SPSs to the Remedial Action Scheme Reliability Subcommittee, (4) implemented a test plan and schedule for one SPS, and (5) disabled the other SPS.

Penalty: $97,000 (aggregate for 8 violations)

FERC Order: The NERC did not further review the settlement and the settlement entered into effect on May 29th, 2015.

Portland General Electric Co., FERC Docket No. NP15-28-000 (April 30, 2015)

Reliability Standard: PRC-001-1

Requirement: R6

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: PGE self-reported that it failed to properly monitor two Special Protection Schemes (SPS) and did not inform the affected TOPs and BAs of the schemes’ status changes. PGE placed two Local Area Protection Schemes (LAPS) into service without identifying them as SPSs. The violation occurred for approximately five years.

Finding: WECC found that this issue posed a minimal, but not a serious or substantial, risk to BPS reliability. During the operations of one SPS, surrounding utilities did not know the reason for generation curtailment, and misoperation of the SPSs could have resulted in exposure of local 115kV facilities to low-voltage, removal of equipment and generation from service, and damage to transmission lines from overload. However, PGE continuously monitored the SPSs’ relays and regularly maintained and tested the equipment. WECC also considered PGE’s internal compliance program for meeting reliability standards as a factor that mitigated the penalty determination. In order to further mitigate this violation, PGE (1) trained appropriate personnel to identify SPSs, (2) trained TOPs, BA, and GOPs on the SPSs at issue, (3) submitted a list of SPSs to the Remedial Action Scheme Reliability Subcommittee, (4) implemented a test plan and schedule for one SPS, and (5) disabled the other SPS.

Penalty: $97,000 (aggregate for 8 violations)

FERC Order: FERC approved the settlement on May 29, 2015.

PPG Industries, Inc., FERC Docket No. NP11-122-000 (February 23, 2011)

Reliability Standard: PRC-001-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: During the compliance audit of PPG Industries, Inc. (PPG) in July 2009, SERC found that PPG could not demonstrate that its operators were properly knowledgeable about the purpose and limitations of the Protection System schemes used in the area, as required.

Finding: SERC and PPG entered into a settlement agreement to resolve multiple violations, whereby PPG agreed to pay a penalty of $10,000 and to undertake other mitigation measures to resolve multiple violations. SERC found that the PRC-001-1 violation only constituted a minimal risk to bulk power system reliability since PPG affirmed that supervisors, who were available on an on-call basis, possessed sufficient familiarity about the purpose and limitations of the relevant Protection System schemes. In addition, PPG includes relay function training in its operator's development program. The duration of the PRC-001-1 violation was from July 20, 2007 through May 31, 2010. In approving the settlement agreement, NERC considered the fact that this was PPG’s second violation of PRC-005-1 R1 (even though that was not considered to be an aggravating factor); one of the violations was self-reported (even though it was submitted in anticipation of an audit); PPG was cooperative during the enforcement process and did not conceal the violations; and there were no additional mitigating or aggravating factors.

Penalty: $10,000 (aggregate for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

Progress Energy Florida, FERC Docket No. NP12-2 (October 31, 2011)

Reliability Standard: PRC-001-1

Requirement: R3/3.2, R4

Violation Risk Factor: High (R3/3.2, R4)

Violation Severity Level: Severe (R3/3.2), High (R4)

Region: FRCC

Issue: Progress Energy Florida (PEF), as a TOP, self-reported that in two instances it had not coordinated changes to its protection systems with three neighboring BAs and TOPs (R3/3.2). FEP also self-reported that it did not possess sufficient documentation in 17 instances demonstrating that it had coordinated its protection systems with interconnected neighboring GOPs, BAs, and TOPs.

Finding: FRCC found that the violations constituted only a minimal risk to BPS reliability. In terms of the R3/3.2 violation, PEF did not make any changes, in the two instances, to the settings values of the newly installed relays, and the interconnected entity did not have to undertake any changes to accommodate the newly installed relays. In terms of the R4 violation, PEF confirmed that its usual business practice is to coordinate its relay settings and PEF the settings were coordinated, but it could not produce documentation to show such coordination. The duration of the violations was from October 9, 2008 through December 22, 2010 (R3/3.2) and September 13, 2007 and December 22, 2010 (R4). PEF had a compliance program in place, but it was only evaluated as a neutral factor.

Penalty: $75,000 (aggregate for 4 violations)

FERC Order: Issued November 30, 2011 (no further review)

Public Service Company of New Mexico, FERC Docket No. NP10-160-000 (September 13, 2010)

Reliability Standard: PRC-001-1

Requirement: R4

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: WECC

Issue: The Public Service Company of New Mexico (PNM) self-reported that it had not coordinated its protection systems on major transmission lines and interconnections with its neighboring Generator Operators, Transmission Operators, and Balancing Authorities.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since PNM was actually engaged in communications with its Generator Operators, Transmission Operators, and Balancing Authorities (even though not as required by the Reliability Standard). The duration of the violation was from June 18, 2007 to March 31, 2009. The violation was self-reported and this was PNM’s first violation of this Reliability Standard. Even though the violation occurred before the Reliability Standards became mandatory, PNM did not timely complete an acceptable mitigation plan. Even though PNM completed its mitigation plan late, WECC decided not to impose a penalty.

Penalty: $0

FERC Order: Issued October 13, 2010 (no further review)

Public Service Company of New Mexico (PNM), Docket No. NP12-47-000 (September 28, 2012)

Reliability Standard: PRC-001-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: After receiving a Notice of On-site Compliance Audit, PNM, as a GOP, submitted a self-report of non-compliance with PRC-001-1. Subsequently, the Audit Team confirmed the following violations: (1) PNM could not show that GOPs were familiar with the purpose and limitations of Protection System schemes. WECC did find that TOP and BA personnel were familiar with the purpose and limitations of Protection System schemes. WECC determined that the scope of the violation is limited to PNM's GOP function.

Finding: The violation was deemed to pose minimal risk to BPS reliability which was mitigated because the violation is limited to PNM's failure to provide documentation evidencing compliance with R1, instead of PNM not familiarizing operators with Protection System limits and purpose. WECC determined that operators were familiar with the risk to the Protection System. And, the scope of the violation is limited to the GOP function. In its capacity as a TOP and BA, PNM provided evidence of familiarity with Protection System purposes and limits pursuant to R1. In determining the appropriate penalty, WECC considered PNM's internal compliance program as a mitigating factor and the repeat violation of BAL-004-WECC-01 as an aggravating factor. PNM agreed/stipulated to WECC's findings.

Penalty: $79,000 (aggregate for nine penalties)

FERC Order: Issued October 26, 2012 (no further review)

Seminole Electric Cooperative (SEC), Docket No. NP12-18 (February 29, 2012)

Reliability Standard: PRC-001-1

Requirement: R6

Violation Risk Factor: High

Violation Severity Level: High

Region: FRCC

Issue: During an audit, FRCC discovered that on August 11, 2008, SEC, in its role as a BA and a TOP, disabled its Special Protection System (SPS), Black Creek Out Step Tripping (OST) Scheme for one hour in order to perform relay maintenance. SEC did not alert the EMCC of the planned outage during which time the SPS would have a temporary status change as required by the Standard.

Finding: FRCC determined the violation posed a minimal risk to BPS reliability because of the short time period the SPS was out of service. Upon review of system conditions and data, FRCC found that there was no such condition requiring the SPS to be armed or triggered. In determining the appropriate penalty, FRCC considered SEC’s strong compliance program as a mitigating factor.

Penalty: $12,000 (aggregate for 3 violations)

FERC Order: Issued March 30, 2012 (no further review)

Tri-State Generation and Transmission Association, Inc-Reliability, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-001-1

Requirement: R2, R3, R4, R5, R6

Violation Risk Factor: High (for R2, R3, R4, R5, R6)

Violation Severity Level: Not provided

Region: WECC

Issue: Tri-State Generation and Transmission Association, Inc-Reliability (TSGT) self-reported that it had not: (R2) notified the Reliability Entities of its relay or equipment failures; (R3) coordinated the changes to its protection systems; (R4) coordinated the protection systems for its major transmission lines and interconnections with its neighboring Generator Operators, Transmission Operators, and Balancing Authorities; (R5) coordinated the changes in generation, transmission, load, or operating conditions which could require changes in the protection systems of third parties; or (R6) monitored the status of each special protection system in its area and notified the affected Transmission Operators and Balancing Authorities of the changes in status.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since TSGT was able to provide the relevant information on request (for R2, R4, R5, R6). In addition, for R3, TSGT was actually coordinating its protection systems with its Generator Operators, Transmission Operators, and Balancing Authorities (even though not by the methods specified in PRC-001-1). The violations were self-reported and they were TSGT's first violations of this Reliability Standard. Even though the violation occurred before the Reliability Standards became mandatory, TSGT did not complete its mitigation plan in a timely manner, turning the violations into post-June 18, 2007 violations. Even though the mitigation plan was completed late, no penalty was imposed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Unidentified Registered Entity, Docket No. NP11-270-000 (September 30, 2011)

Reliability Standard: PRC-001-1

Requirement: R1, R3

Violation Risk Factor: High (R1, R3)

Violation Severity Level: Severe (R1, R3)

Region: WECC

Issue: Based on WECC_URE1’s failure to respond to audit notices, WECC found that WECC_URE1 did not show that its operating personnel knew the purpose and limitations of the protection system schemes that apply in WECC_URE1’s area (R1) or that it had coordinated its new protection systems and protection system changes with its Transmission Operator and Host Balancing Authority (R3).

Finding: WECC found that the PRC-001-1 violations constituted a moderate risk to bulk power system reliability. In terms of R1, since WECC_URE1 operates a facility with a nameplate capacity of less than 30 MW (with only one interconnection to the bulk power system), an unintended trip (or a failure to trip) would only impact WECC_URE1’s equipment and would not have a broader impact on the bulk power system. In terms of R3, WECC_URE1 did not have any changes to its protection system that would necessitate changes in the protection systems of other entities. WECC_URE1 developed a compliance program to manage its future compliance efforts (which was evaluated as a mitigating factor). However, WECC_URE1 was not cooperative during the compliance audit process and did not timely complete the required self-certifications (which were evaluated as aggravating factors).

Penalty: $90,000 (aggregate for 14 violations)

FERC Order: Issued October 28, 2011 (no further review)

USACE – Little Rock District, FERC Docket No. NP11-19-000 (November 5, 2010)

Reliability Standard: PRC-001-1

Requirement: R2, R3

Violation Risk Factor: High (R2 and R3)

Violation Severity Level: Not provided

Region: SPP

Issue: In March 2008, USACE – Little Rock (USACE-LR) self-certified that it did not possess a formal policy requiring it to notify its Transmission Operator and Host Balancing Authority when there was a relay or equipment failure that reduced bulk power system reliability. USACE-LR also self-certified that it did not possess a formal policy regarding coordinating new protection systems with its Transmission Operator and Host Balancing Authority.

Finding: SPP found that these violations did not constitute a serious or substantial risk to the bulk power system since USACE-LR’s Transmission Provider, Southwest Power Administration (SWPA), coordinates USACE-LR’s sale and delivery of power, and therefore USACE-LR is required to notify SWPA when its equipment failures would affect the output of its hydroelectric generating facilities. Furthermore, USACE-LR coordinates changes in its protective systems with SWPA. The duration of the violations was from July 10, 2007 through October 13, 2009. In deciding not to impose a penalty for multiple violations, SPP considered the fact that the violations represented USACE-LR’s first violations of the relevant Reliability Standards; the violations were caused by USACE-LR not having formal procedures and policies in place; and USACE-LR did not attempt to conceal the violations. In addition, the violations were self-certified.

Penalty: $0

FERC Order: Issued December 3, 2010 (no further review)

USACE – Tulsa District, FERC Docket No. NP10-160-000 (September 13, 2010)

Reliability Standard: PRC-001-1

Requirement: R2, R3

Violation Risk Factor: High for R2, Not provided for R3

Violation Severity Level: Not provided

Region: SPP

Issue: PRC-001-1, R2 requires an entity to have a formal policy to notify its Transmission Operator and Host Balancing Authority if protective relay or equipment failures reduced system reliability and R3 requires the entity to coordinate new protective systems and all protective system changes with its Transmission Operator and Host Balancing Authority. USACE-Tulsa self-certified it was not compliant with these requirements.

Finding: As determined by SPP, the violations did not create a serious or substantial risk to the bulk power system because, USACE-Tulsa did notify its Transmission Operator and Balancing Authority of equipment failures affecting the output of its generating facilities, despite not having a written policy for its operators regarding notification of equipment errors. SPP further noted that although USACE-Tulsa did not have a written policy requiring coordination of all new Protection Systems and all Protection System changes with this Transmission Operation and Balancing Authority, USACE-Tulsa was coordinating all new Protection Systems and all Protection System Changes with its Transmission Operator and Balancing Authority. The duration of the violations was July 10, 2007 through August 28, 2009. Additional factors for the determination of no penalty amount included that that the violations were documentation issues and were the first violations of this Reliability Standard. USACE-Tulsa completed a mitigation plan.

Penalty: $0

FERC Order: Issued December 16, 2010, 133 FERC ¶ 61,214 (2010), reh'g denied 137, FERC ¶ 61,044 (2010)

Western Area Power Administration – Upper Great Plains Region and Western Area Power Administration – Upper Great Plains East (WAUE), FERC Docket No. NP14-33 (February 27, 2014)

Reliability Standard: PRC-001-1

Requirement: 2

Violation Risk Factor: High

Violation Severity Level: Severe

Region: MRO

Issue: After the June 17, 2010 Eastern Montana-Western North Dakota Disturbance, WAUE self-reported that it did not properly review and respond to alarms related to lightning strikes and delayed for over two and a half hours in isolating the section of the transmission line related to failed protective relay equipment. MRO found that if WAUE had recognized and responded to the alarms on a timely basis, it was likely that the Charlie Creek-Belfield line would have been removed from service earlier and therefore the backup relay action would not have tripped 14 Bulk Electric System (BES) elements.

Finding: MRO found that the PRC-001-1 R2 violation constituted a serious or substantial risk to BPS reliability. Since WAUE did not appropriately respond to the alarms and take the necessary corrective actions, the Charlie Creek-Belfield line stayed in service longer than it should have, which resulted in a fault developing and the backup relays causing 14 BES elements on the WAUE system to trip. The duration of the PRC-001-1 R2 violation was from June 17, 2010 through December 16, 2011. WAPA-UGPR admits the violations. In approving the settlement agreement, NERC BOTCC considered the fact that WAPA-UGPR engaged in above and beyond mitigation activities (such as training system operators, hiring additional compliance staff and replacing relays at a substation) and other actions to facilitate future compliance with the Reliability Standards. In addition, these were WAPA-UGPR’s first violations of the relevant Reliability Standards and WAPA-UGPR conducted a compliance assessment after the June 17, 2010 Eastern Montana-Western North Dakota Disturbance. WAPA-UGPR has a compliance program in place, which was evaluated as a mitigating factor. WAPA-UGPR was also cooperative during the enforcement process and did not conceal the violations. Certain of the violations constituted a serious or substantial risk to BPS reliability. In addition, although it lost multiple BES elements during the Eastern Montana-Western North Dakota Disturbance, it did not lose any generation or customer load as a result of the PRC-001-1 R2 violation.

Total Penalty: $0

FERC Order: Issued March 28, 2014 (no further review)

Whiting Clean Energy, Inc. (WCE), Docket No. NP14-8 (Nov. 27, 2013)

Reliability Standard: PRC-001-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: While conducting a Compliance Audit, WCE, as a GOP, was found to be in violation of PRC-005-1 due to its failure to provide evidence of operator training on protection system schemes. RFC found the violation time period to be July 9, 2008, the date WCE registered as a GOP, until December 12, 2012, the date mitigation actions were completed.

Finding: This violation was deemed to pose minimal risk to reliable BPS operations, but not serious or substantial risk. WCE maintained that operators had been trained by an outside contractor and in accordance with NERC’s documents on Protection System devices, but WCE could not show evidence of the training. Under a new management team at WCE, all training was provided and recorded. In determining the appropriate penalty, RFC considered several factors, including that these violations were the first by WCE of the subject Reliability Standards; one violation was self-reported; WCE cooperated during the compliance enforcement process; and WCE has a compliance program in place and certain aspects were considered a mitigating factor by RFC. However, RFC determined that WCE’s performance during the Compliance Audit was an aggravating factor as WCE did not fully understand its responsibilities under NERC’s Reliability Standards nor even its own processes and procedures.

Total Penalty: $35,000 (aggregate for 7 violations)

FERC Order: Issued December 27, 2013 (no further review)