NERC Case Notes: Reliability Standard PRC-015-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-015-0

NERC Case Notes: Reliability Standard PRC-015-0

White & Case NERC Database

American Electric Power Service Corporation, FERC Docket No. NP11-164-000 (April 29, 2011)

Reliability Standard: PRC-015-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: RFC

Issue: Following a Compliance Violation Investigation, RFC determined American Electric Power Service Corporation (AEP) failed to maintain a list and associated data, including data related to modifications made pursuant to the NERC Event Analysis Report, for the Rockport Special Protection System at its Rockport Plant in violation of R1. AEP had concluded the system was not a Special Protection System and therefore did not fall under requirements applicable to SPS facilities, but RFC found AEP should have recognized it as an SPS. In addition, AEP did not provide evidence that it reviewed the Rockport area protection scheme prior to putting it into service per RFC's procedures in violation of R2.

Finding: RFC determined that the violation did not pose a serious or substantial risk to the reliability of the BPS because AEP had an operating guide for the Rockport area protection scheme addressing the design, operations and modeling, and maintained this documentation at all relevant times. In approving the settlement between AEP and RFC, the NERC BOTCC considered the following factors: AEP self reported the violations; AEP was cooperative; AEP had a compliance program in effect at the time of the violation, which RFC considered a mitigating factor, there was no evidence of an attempt or intent to conceal the violation; RFC determined the violation did not pose a serious or substantial risk to the BPS; there were no other aggravating or mitigating factors.

Penalty: $35,000 (aggregated for multiple violations)

FERC Order: Issued May 27, 2011 (no further review)

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

Reliability Standard: PRC-015-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: PGE self-reported that it failed to "maintain a list of and provide dates for its existing and proposed [Special Protection Schemes (SPS)] as specified in PRC-013-0 R1" when it placed two Local Area Protection Schemes (LAPS) into service. 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. If operators of PGE and nearby utilities did not know of the SPSs, there was an increased possibility that they would respond to situations improperly. 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. 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: FERC approved the settlement on May 29, 2015.

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

Reliability Standard: PRC-015-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: PGE self-reported that it failed to "have evidence that it reviewed" two new or functionally modified Local Area Protection Schemes (LAPS) as Special Protection Systems (SPS) "in accordance with the Regional Reliability Organization's procedures as defined in PRC-012-0 R1 prior to being placed in service." 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. The operation of one SPS could have resulted in 40 MW of load shedding, and operation of the other SPS could have resulted in 337 MW of curtailed generation. 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. 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: FERC approved the settlement on May 29, 2015.