NERC Case Notes: Reliability Standard PRC-011-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-011-0

NERC Case Notes: Reliability Standard PRC-011-0

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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 Transmission Systems, Incorporated (ATSI), Docket No. NP13-41-000 (June 27, 2013)

Reliability Standard: PRC-011-0

Requirement(s): 2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: ReliabilityFirst Corporation (RFC)

Issue: ATSI, a registered TO, reported to RFC through self-certification that it was unable to show that it had a formally established Undervoltage Load Shedding (UVLS) equipment maintenance and testing program in place and working. ATSI reported that it could not locate the test record for one of its 65 (1.5%) UVLS relays. ATSI also self-certified noncompliance based on its inability to locate testing records for four relay schemes from 2003 to 2005. However, ATSI reported it had evidence supporting performance of maintenance and testing on these four relays as of June 18, 2007, the date of mandatory compliance. RFC determined ATSI’s failure to locate testing records for four relay schemes from 2003 to 2005 was not a violation of PRC-011-0 R2 as the standard and requirement was not subject to mandatory enforcement during that time period.

Finding: The violation was deemed to pose minimal risk to BPS reliability, but not serious or substantial risk, which was mitigated because the violation was ultimately determined to be documentation related. In determining the appropriate penalty, RFC considered aspects of ASTI’s internal compliance program (ICP), including that the ICP is overseen by its parent company, FirstEnergy, and ASTI follows FirstEnergy’s Reliability and Compliance Policy, which RFC found to be a mitigating factor. ASTI and certain of its affiliates previously violated various Reliability Standards, and although all previous violations were properly mitigated, the repeat infractions and the FirstEnergy entities’ compliance history were viewed as an aggravating factor, but RFC determined the FirstEnergy entities’ compliance history did not warrant a financial penalty. Jersey Central’s prior violation was an isolated incident involving less than 1% of its Protection System relays which RFC took into consideration. Also, RFC considered that Monongahela’s and AE Supply’s prior violations of PRC-005-1 R2 occurred prior to FirstEnergy’s February 25, 2011 acquisition of Monongahela and AE Supply.

Total Penalty: $0

FERC Order: Issued August 26, 2013 (no further review)

City of Roseville, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-011-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007 the City of Roseville self-reported that it had not properly documented, as required, the Maintenance and Testing Program for its Under-Voltage Load Shedding (UVLS) program.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the City of Roseville was actually conducting the appropriate maintenance and testing on the system components (even though this maintenance and testing was not sufficiently documented). This violation was primarily a documentation issue. Also, the City of Roseville self-reported the violation; this was the City of Roseville's first violation of this Reliability Standard; and a mitigation plan was completed.

Penalty: $0

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

Merced Irrigation District, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-011-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In July 2007, Merced Irrigation District (Merced) self-reported that it did not have a Under Voltage Load Shedding (UVLS) Maintenance and Testing Program as required.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since a UVLS was not needed to maintain system reliability in light of the size, nature, and location of Merced's facilities. The violation was self-reported and this was Merced's first violation of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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

PacifiCorp, FERC Docket No. IN11-6 (December 1, 2011)

Reliability Standard: PRC-011-0

Requirement: R2

Issue: On February 14, 2008, a short circuit occurred on a transformer at PacifiCorp’s Huntington generation plant in Utah, which triggered an immediate loss of approximately 2800 MW of generation across PacifiCorp’s East Balancing Authority Area (“PacifiCorp East” – which consists of Utah, southeast Idaho and western Wyoming) and the shedding of approximately 183 MW of firm load in Utah. Prior to the February 14, 2008 disturbance, PacifiCorp self-reported to WECC a violation of PRC-011-0 R2, which mandates a maintenance and testing programs for UVLS equipment.

Finding: On December 1, 2011, FERC approved a Stipulation and Consent Agreement between FERC Office of Enforcement (“Enforcement”), NERC and PacifiCorp regarding PacifiCorp’s actions as a BA and TOP surrounding the February 14, 2008 disturbance. After the disturbance, Enforcement and NERC investigated PacifiCorp’s compliance with the PRC standards, even though PacifiCorp had completed relevant mitigation plans. Enforcement and NERC identified three overall deficiencies with PacifiCorp’s maintenance management system: (a) lack of verification of the data when it changed maintenance plan databases, (b) failure to oversee data entry and other changes made to the database, and (c) lack of proper managerial controls and oversight of the maintenance system. These problems cause PacifiCorp to have missing data and inaccurate maintenance cycles.

Penalty: $3,925,000 (aggregate for 23 violations)

FERC Order: http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=12829507

Plumas-Sierra Rural Electric Cooperative, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-011-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Plumas-Sierra Rural Electric Cooperative (Plumas-Sierra) self-reported that it did not have a documented Under Voltage Load Shedding (UVLS) Maintenance and Testing Program.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since this was primarily a documentation issue. Plumas-Sierra had actually performed tests on its newly installed transmission protection system. The violation was self-reported and this was Plumas-Sierra's first violation of this Reliability Standard. Even though the violation occurred before the Reliability Standards became mandatory, Plumas-Sierra did not timely complete its mitigation plan, turning the violation into a post-June 18, 2007 violation. Even with the late completion of the mitigation plan, no penalty was imposed.

Penalty: $0

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

Tillamook People's Utility District, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-011-0

Requirement: R1, R2

Violation Risk Factor: Medium (R1); Lower (R2)

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007, Tillamook People's Utility District (Tillamook) self-reported that that it did not have a Under Voltage Load Shedding (UVLS) Maintenance and Testing Program. Therefore, Tillamook did not possess a documented UVLS Maintenance and Testing Program to provide, upon request, to its Reliability Coordinator.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system due to the nature and location of Tillamook's facilities. In addition, Tillamook's Balancing Authority gives voltage support for Tillamook. The violation of R2 was also primarily a documentation issue. The violations were self-reported and they were Tillamook's first violations of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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

Unidentified Registered Entity, FERC Docket No. NP12-11 (January 31, 2011)

Reliability Standard: PRC-011-0

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: WECC

Issue: URE self-reported that it did not have proper UVLS maintenance and testing records for its potential transformers and that it had not performed all of the required maintenance and testing on its UVLS equipment batteries.

Finding: WECC found that the PRC-011-0 violation constituted only a minimal risk to the BPS since URE was actually monitoring its batteries and DC circuitry in order to evaluate their status and integrity. In addition, the failure of any one piece of UVLS equipment is unlikely to cause a significant impact on the BPS. In determining the penalty amount, the NERC BOTCC evaluated URE’s violation history; some of the violations were self-reported; URE was cooperative during the enforcement process and did not conceal the violations; URE has a compliance program in place (which was evaluated as a mitigating factor); the violations did not constitute a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.

Penalty: $135,000 (aggregate for 20 violations)

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