NERC Case Notes: Reliability Standard PRC-016-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-016-0

NERC Case Notes: Reliability Standard PRC-016-0

White & Case NERC Database

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

Reliability Standard: PRC-016-0

Requirement: R1, R3

Violation Risk Factor: Medium (R1), Lower (R3)

Violation Severity Level: Severe

Region: RFC

Issue: Following a Compliance Violation Investigation, RFC determined American Electric Power Service Corporation (AEP) failed to analyze operations of its Rockport area protection scheme at its Rockport Plant, and failed to maintain a record of all misoperations and produce a corrective action plan for a fast valving scheme misoperation that had occurred. AEP previously 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.

Finding: RFC determined that the violation did not pose a serious or substantial risk to the reliability of the BPS because although AEP did not report the misoperations to RFC, it did immediately report them to the TOP, PJM. In addition, once RFC concluded the Rockport area protection scheme was an SPS, AEP cooperated with NERC in conducting an event analysis and providing associated information. 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)