NERC Case Notes: Reliability Standard PRC-017-0 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-017-0

NERC Case Notes: Reliability Standard PRC-017-0

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

Reliability Standard: PRC-017-0

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: In the course of a Compliance Violation Investigation, RFC determined American Electric Power Service Corporation (AEP) erroneously concluded its Rockport area protection scheme at its Rockport Plant was not a Special Protection System and consequently AEP did not have a documented maintenance and testing program in place for the entire scheme. RFC concluded AEP should have properly identified the scheme as a SPS.

Finding: RFC determined that the violation did not pose a serious or substantial risk to the reliability of the BPS because AEP had successfully tested the fast valving portion of the Rockport area protection scheme during a scheduled repair outage and general boiler inspection. 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)

Farmington Electric Utility System, FERC Docket No. NP10-40-000 (February 1, 2010)

Reliability Standard: PRC-017-0

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: WECC

Issue: Farmington Electric Utility System (FEUS) self-reported that it did not have a summary procedure for battery testing as required by the standard, though it performed and documented testing and maintenance on its special protection system.

Finding: Duration of the violation was from June 18, 2007, when the standard became enforceable, through January 8, 2008. Penalty was deemed appropriate because these were FEUS's first violations of the applicable standards, FEUS self-reported eleven of the violations, and FEUS is a small generation and transmission system that had made a substantial commitment of financial and personnel resources to NERC compliance relative to its size.

Penalty: $40,250 (aggregate for multiple violations)

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

Farmington Electric Utility System, FERC Docket No. NP10-42-000 (February 1, 2010)

Reliability Standard: PRC-017-0

Requirement: R1.6

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Farmington Electric Utility System (FEUS) failed to annually test and maintain up to 25% of its Special Protection Systems equipment in 2008.

Finding: WECC determined that a $15,000 penalty was appropriate for the referenced violation. Duration of the violation was from January 1, 2008 until September 21, 2009. In reaching the determination, WECC considered the following factors: (1) the violation was self-reported; (2) the violation was FEUS's second violation of the standard; (3) there was no evidence of any attempt by FEUS to conceal the violation; (4) FEUS was cooperative during the enforcement process; and (5) the violation did not put the reliability of the bulk power system at serious or substantial risk.

Penalty: $15,000

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

Great River Energy, FERC Docket No. NP10-111-000 (June 2, 2010)

Reliability Standard: PRC-017-0

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: MRO

Issue: During a compliance audit in January 2009, MRO discovered that Great River Energy's (GRE) Protection System Maintenance and Testing Program did not identify all of the required elements (such as the instrument transformers and the communication system associated with its Special Protection Systems (SPS) and their intervals for maintenance and testing), provide the basis for the intervals for the identified SPS devices, nor provide a summary of the maintenance and testing procedures for the SPS devices. But, GRE did produce documentation showing that maintenance and testing were being performed on all of its SPS.

Finding: MRO and GRE entered into a Settlement Agreement to resolve multiple violations, whereby GRE agreed to pay a penalty of $125,000 and to undertake other mitigation measures. MRO found that the violations of PRC-017-0 did not create a serious or substantial risk to bulk power system reliability since GRE could show that maintenance and testing was being performed on all of its SPS (even though GRE did not possess sufficient documentation). In determining the penalty amount, MRO considered the fact the violations were GRE's first violations of the relevant Reliability Standards and GRE was cooperative during the enforcement process and did not attempt to conceal the violations. GRE has completed a mitigation plan for the violation of PRC-017-0 and has also undertaken other efforts to strengthen its compliance program.

Penalty: $125,000 (aggregate for multiple violations)

FERC Order: Issued July 2, 2010 (no further review)

NERC Registered Entity, FERC Docket No. NP10-137-000 (July 6, 2010)

Reliability Standard: PRC-017-0

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Not discussed

Region: WECC

Issue: The NERC Registered Entity failed to maintain policies, procedures, and records developed for maintenance and testing of its Special Protection System.

Finding: The NERC Registered Entity mitigated the violation by creating procedures and implementing a policy and procedure for maintenance and testing of its special protection systems. In addition, The NERC Registered Entity was required to complete and document end-to-end testing and maintenance of its special protection systems. No further publicly available information was provided.

Penalty: $39,000 (aggregate for multiple violations)

FERC Order: Issued August 5, 2010 (no further review)

Oncor Electric Delivery Company LLC (Oncor), Docket No. NP12-26-000 (April 30, 2012)

Reliability Standard: PRC-017-0

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: TRE

Issue: Oncor, a DP and TO, submitted self-reports reporting a violation of PRC-017-0 due to its failure to test nine (out of 19) Special Protection System (SPS) relays within defined intervals. Oncor stated that within the nine SPS relays, two were not completely tested, and seven were misidentified in Oncor’s SPS maintenance and testing program.

Finding: The violation was found to pose a moderate risk to BPS reliability because the non-tested equipment consists of important components for BPS reliability, in particular during stressed or critical conditions. The relevant equipment accounts for 47.4% of Oncor’s total SPSs. No misoperations occurred as a result of the missed testing. RFC noted that Oncor has in place controls to prevent or mitigate any problems that may have occurred during the violation time period and no issues were found once the equipment was tested. In determining the appropriate penalty, RFC considered Oncor’s compliance program as a mitigating factor. No credit was given for the self-report because the violation was found during preparation for an upcoming audit by TRE.

Penalty: $15,000 (aggregate for 3 penalties)

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

Pacific Gas and Electric Company, FERC Docket No. NP10-96-000 (April 28, 2010)

Reliability Standard: PRC-017-0

Requirement: R1, R1.6

Violation Risk Factor: Medium

Violation Severity Level: Not discussed

Region: WECC

Issue: Pacific Gas and Electric Company (PG&E) self-reported that it did not have documentation that it had conducted maintenance for certain Special Protection Systems communications equipment.

Finding: The alleged violation occurred from June 18, 2007, the date the Standard became enforceable, and will continue until August 1, 2010, the date PG&E has committed to complete a mitigation plan. WECC imposed an aggregate penalty of $85,000 for multiple violations of NERC Reliability Standards. In assessing the penalty, WECC considered that the violations were self-reported; this was PG&E first incident involving this Reliability Standard; PG&E cooperated during the compliance enforcement process and did not attempt to conceal the violations; the violations were not intentional; and the violations did not create a serious or substantial risk to the bulk power system.

Penalty: $85,000 (aggregate for multiple violations)

FERC Order: Issued May 28, 2010 (no further review)

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

Reliability Standard: PRC-017-0

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-017-0 R2, which mandates a maintenance and testing programs for Special Protection System 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

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

Reliability Standard: PRC-017-0

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: PGE self-reported that it did not have a maintenance and testing program for its Special Protection Schemes that fulfilled PRC-017-0 requirements 1.3, 1.4, 1.5, and 1.6. It placed two Local Area Protection Schemes (LAPS) into service without recognizing that they met NERC’s definition for an 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. PGE may not have conducted the particular maintenance and testing required by PRC-017-0. 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.

Sacramento Municipal Utility District, FERC Docket No. NP10-29-000 (December 30, 2009)

Reliability Standard: PRC-017-0

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Not provided

Region: WECC

Issue: Because SMUD did not think certain equipment met the definition of a Special Protection System, it did not have the required system maintenance and testing procedures in place with respect to that equipment. Violation duration was from June 18, 2007, when the standard became enforceable, through June 30, 2008.

Finding: WECC determined the penalty justified because (1) the violation involved documentation failure only; (2) it was SMUD’s first violation of this standard; and (3) there was no evidence SMUD attempted to conceal the violation.

Penalty: $65,000 (aggregate for multiple violations)

FERC Order: Issued January 29, 2010 (no further review)

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

Reliability Standard: PRC-017-0

Requirement: R1.1, R1.2, R1.3

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: FRCC

Issue: During an audit, FRCC discovered that the system maintenance and testing program used by SEC, a TO and GO, did not include the following: relays (R1.1.1), instrument transformers (R1.1.2) and communication systems (R1.1.3). Also, SEC had no documentation of the maintenance testing interval basis (R1.2) or a summary of the testing procedure (R1.3) for all of the elements identified for the time period June 18, 2007 until August 26, 2009. SEC’s currently effective SPS maintenance and testing program included the missing equipment.

Finding: FRCC determined the violation posed a minimal risk to BPS reliability because SEC did the maintenance on the SPS relays and its associated components as required even though there was no defined documented maintenance program. 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)

Sierra Pacific Power Company (SPPC), d/b/a, NV Energy, FERC Docket No. NP12-12 (January 31, 2012)

Reliability Standard: PRC-017-0

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: WECC

Issue: As the result of an on-site audit, it was found that SPPC, as a TO, DP and GO, did not maintain and test associated station batteries within the intervals defined in the Special Protection System Maintenance and Testing plan (SPS Plan). SPPC could not demonstrate that it maintained and tested the station batteries at the Rusty Spike station, associated with the Airport 173 Line Thermal Overload SPS, and the Eight Mile station, associated with the Eight Mile Creek Overload SPS, within the intervals defined in the SPS Plan. The two batteries were self-reported as not in compliance with PRC-005, but were not self-reported again in PRC-017. SPPC’s failure to maintain and test station batteries at the Rusty Spike and Eight Mile facilities within defined intervals resulted in SPPC not implementing its program.

Finding: The violation was found to constitute a minimal risk to BPS reliability. SPPC conducts quarterly station battery inspections. This violation relates to SPPC's failure to conduct its annual (not to exceed 16 month) scheduled SPS battery tests. Although SPCC did not perform annual inspection, SPPC did not miss its quarterly battery inspections. SPPC personnel are aware of the condition of the batteries based on the quarterly inspections and would note and take action if SPPC detected a potential battery failure. The violation only relates to two of SPPC’s six Special Protection Systems. Further, the violation is associated with station batteries whose battery maintenance records receive regular review from protection engineers. SPPC’s internal compliance program was considered a mitigating factor in determining the appropriate penalty amount.

Penalty: $16,400 (aggregate for four violations)

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

Unidentified Registered Entity, FERC Docket No. NP11-63-000 (December 22, 2010)

Reliability Standard: PRC-017-0

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Not discussed

Region: WECC

Issue: Unidentified Registered Entity (URE) failed to have a Special Protection System maintenance and testing program in place for the Remedial Action Scheme.

Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a penalty in the amount of $80,000 for this and other Reliability Standards violations. In reaching this determination, the NERC BOTCC considered the following facts: the violation constituted URE’s first violation of the subject Reliability Standard; the URE self-reported the violation; URE cooperated during the compliance enforcement process; URE’s compliance program; URE did not attempt to conceal a violation or intend to do so; and the violation did not create a serious or substantial risk to the bulk power system.

Penalty: $80,000 (aggregate for multiple violations)

FERC Order: Issued January 21, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP11-111-000 (February 23, 2011)

Reliability Standard: PRC-017-0

Requirement: R2

Violation Risk Factor: Lower

Violation Severity Level: Moderate

Region: MRO

Issue: MRO conducted an audit of a Registered Entity in which it determined that the Registered Entity was unable to provide record evidence showing its maintenance and testing for one of the Special Protection Systems (SPSs) at one its facilities (constituting 25 percent of the Registered Entity's total SPSs).

Finding: MRO and the Registered Entity entered into a settlement agreement to resolve multiple violations, whereby the Registered Entity agreed to pay a penalty of $120,000 and to undertake other mitigation measures to resolve the multiple violations. In terms of the PRC-017-0 violation, MRO found that the violation constituted a moderate risk to bulk power system reliability since the Registered Entity relied heavily on the relevant facility’s SPS in situations where there are local high voltage transmission circuits offline for maintenance. Furthermore, the Registered Entity could not show documentation of testing for the relevant SPS for a nine-year period (even though when it was maintained and tested, the relevant SPS performed properly). But, the relevant SPS shares elements with other protection systems that are installed at the facilities and that were receiving testing as required. In addition, the transmission operator would be able to manually manage any overloading that might result from the relevant SPS failing to signal a generator to back down its output. The duration of the PRC-017-0 violation was from June 18, 2007 through June 29, 2009. In approving the settlement agreement, NERC found that these were the Registered Entity’s first violations of the relevant Reliability Standards; the Registered Entity was cooperative during the enforcement process and did not conceal the violations; the remedies that the Registered Entity adopted in response to the violations were considered a mitigating factor; and there were no additional mitigating or aggravating factors.

Penalty: $120,000 (aggregate for multiple violations)

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

Unidentified Registered Entity, Docket No. NP13-1 (October 31, 2012)

Reliability Standard: PRC-017-0

Requirement: 2

Violation Risk Factor: Lower

Violation Severity Level: Lower

Region: WECC

Issue: Following a self-report, WECC determined URE violated R2 because it could not provide evidence that it had implemented its Special Protection Systems (SPS) maintenance and testing program on 1.9% of its SPS devices.

Finding: WECC determined that the violation posed a minimal risk, but did not pose a serious or substantial risk, to the reliability of the BPS. The risk was mitigated because the devices at issue were maintained and tested shortly after the defined period, and the affected transmission systems were protected by redundant systems. Furthermore, there were no actual consequences as a result of the delay for the duration of the violation. In approving the Settlement Agreement between WECC and URE, NERC BOTCC considered the following: URE's violation history, 11 of the 12 violations were self-reported, URE was cooperative, URE had a compliance program in place at the time of the violation, which was considered a mitigating factor, and there was no evidence of any attempt or intent to conceal a violation, nor that the violation was intentional.

Penalty: $200,000 (aggregate for 12 violations)

FERC Order: Issued November 29, 2012 (no further review)

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

Reliability Standard: PRC-017-0

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: MRO

Issue: During a WECC-MRO compliance audit, audit staff found that WAPA-UGPR Special Protection Systems (SPS) maintenance and testing program did not include the required documentation regarding the maintenance and testing intervals and their basis, a summary of the DC control circuitry testing procedures or a schedule or summary for microprocessor-based relays maintenance and testing. There were also discrepancies between WAPA-UGPR’s Protection Systems maintenance and testing program and its reliability-centered maintenance (RCM) studies regarding the maintenance and testing requirements for station batteries, current and voltage sensing devices and DC control circuitry.

Finding: MRO found that the PRC-017-0 R1 violation constituted a moderate risk to BPS reliability since it increased the risk that the SPS devices would be unable to detect abnormal system conditions and take the needed corrective actions in order to provide acceptable system performance. But, WAPA-UGPR was actually conducting maintenance and testing on the SPS devices and retained the supporting documentation. The duration of the PRC-017-0 R1 violation was from June 18, 2007 through March 30, 2012. 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 Bulk Electric System 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)