NERC Case Notes: Reliability Standard PRC-005-1a | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-005-1a

NERC Case Notes: Reliability Standard PRC-005-1a

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.

CCI Signal Hill LLC (CCI SH), FERC Docket No. NP15-29-000 (May 28, 2015)

Reliability Standard: PRC-005-1a

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: High

Region: Texas RE

Issue: Texas RE, during a compliance audit, found that CCI SH's Protection System maintenance and testing program failed to include 40.9% of Protection System devices by excluding 116 potential transformers and current transformers. The Protection System maintenance and testing program also failed to include maintenance and testing intervals and a summary of maintenance and testing procedures for devices that sense voltage and current.

Finding: Texas RE found that this issue posed a moderate, but not a serious or substantial, risk to BPS reliability. Two of the plant's four units were Blackstart resources, and failures in the maintenance of Protection System equipment could have led to the failure of the Blackstart units and to relay misoperations. This could have delayed restoration of firm load. However, the plant's two other units had the ability to support the Blackstart and CCI SH was contracted to supply only 3.4% of ERCOT's primary Blackstart capability. To mitigate the violation, CCI SH (1) hired a consultant to identify devices that sense voltage and current, (2) updated its Protection System maintenance and testing program to include appropriate devices and to comply with PRC-005-2, and (3) hired a consultant to review CCI SH's internal compliance program.

Penalty: $50,000 (aggregate for 6 violations)

FERC Order: FERC approved the settlement on June 26th, 2015.

Covanta York Renewable Energy, LLC, Docket No. NP13-33 (April 30, 2013)

Reliability Standard: PRC-005-1.a

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: During a compliance audit, RFC determined that Covanta York Renewable Energy, LLC (Covanta York), as a GO, did not include in its Protection System maintenance and testing program the maintenance and testing intervals and their bases and a summary of the maintenance and testing procedures for current and potential sensing devices and DC control circuitry.

Finding: RFC found that the violation only constituted a minimal risk to BPS reliability. Covanta York performed all of the required testing on its protective system devices during the three-year relay calibration testing cycle and found no misoperations or faulty conditions. Covanta York also has a real-time alert system that monitors its protection system devices. The duration of the violation was from December 28, 2011 through February 24, 2013. Covanta York admitted the violation. Covanta York and its affiliates’ compliance program and cooperation were viewed as mitigating factors, while the compliance history was evaluated as an aggravating factor.

Total Penalty: $0

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

Public Utility District No. 2 of Grant County (GCPD), Docket No. NP12-40 (July 31, 2012)

Reliability Standard: PRC-005-1a

Requirement: R2; R2.1

Violation Risk Factor: High

Violation Severity Level: Lower

Region: WECC

Issue: WECC reviewed GCPD’s Self-Certification, submitted on January 19, 2012, and determined that GCPD violated PRC-005-1a R2.1 because it failed to maintain and test the battery bank at its Wanapum Station during the interval defined in its maintenance and testing program. GCPD’s Protection System maintenance and testing program states that battery systems must be tested and maintained every six months, with an allowance of an approximate 45-day grace period. GCPD controls 52 substations, 46 of which are distribution substations, and six are transmission substations. Each substation contains at least one battery bank with 58 total battery banks across all substations. Of all the battery banks, only the battery bank at GCPD’s Wanapum Station was not tested or maintained within the prescribed interval. The Wanapum Station’s battery bank was last tested on May 12, 2011, making the next test due no later than December 27, 2011. GCPD, however, did not complete the test until January 10, 2012, fourteen days after the deadline. The duration of the violation was from December 27, 2011 to January 10, 2012.

Finding: This violation posed only a minimal risk to BPS reliability for four reasons. First, GCPD failed to test or maintain only one out of 58 battery banks during the defined interval. Second, GCPD’s compliance staff regularly conducts visual inspections of the batteries at issue, thereby further reducing the risk to the BPS. Third, the GCPD compliance staff routinely reviews the maintenance schedule to ensure tests are conducted within the defined interval. The Wanapum Station’s battery bank was tested earlier than anticipated, requiring the next test date to be earlier in the subsequent testing schedule. While the compliance staff properly accounted for the early testing in May 2011, they failed to ensure the subsequent test was timely completed in December 2011. This error was partially due to GCPD’s task software system which did not properly account for the earlier testing. Fourth, the test was only delayed fourteen days. GCPD did not contest WECC findings. In determining the proper penalty, WECC considered GCPD’s internal compliance program as a mitigating factor. As an aggravating factor, WECC noted that this is GCPD’s second violation of PRC-005 R2, citing that the instant violation of failing to conduct and document maintenance and testing within prescribed intervals is the same conduct as the previous offense. GCPD did not receive self-reporting credit because they only did so after being notified that WECC was requiring a Self-Certification period.

Penalty: $4,500

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