NERC Case Notes: Reliability Standard PRC-023-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-023-1

NERC Case Notes: Reliability Standard PRC-023-1

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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.

Alabama Power Company, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1/1.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: In July 2011, Alabama Power Company (APC), as a TO, self-reported that the phase protective relay settings for one of its 230 kV transmission line did not satisfy the loadability requirements. As a result of mistake by the Power System Coordinator, the re-rate for the Pike County to Pinckard 230 kCline had not evaluated for Zone 3 loadability by the Protection and Control Applications workgroup as required by the APC’s policy for planning and executing a re-rate.

Finding: SERC found that the violation constituted a minimal risk to BPS reliability since the physical configuration of the line did not change. In addition, the system was operated under the more conservative seasonal Summer B ratings, and not the lower Winter A ratings. Therefore, the system would not have allowed the load on the re-rated line to approach 149% of the Winter A rating and the original relay setting are able to accommodate 176% of the Summer B rating of the line. The duration of the violation was from May 23, 2011 through August 29, 2011. SERC evaluated APC’s compliance program as a mitigating factor.

Penalty: $0

FERC Order: Order issued June 29, 2012 (no further review)

American Electric Power Service Corporation, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: In July 2011, American Electric Power (AEP), as a DP and a TO, self-reported that when it increased the Facility Rating for a conductor that was the most limiting element on one of its circuit, the relay trip setting decreased to 127% of the highest seasonal Facility Rating (whereas the relay setting was required to be equal to 150% or more than the most limiting element).

Finding: RFC found that this violation constituted a moderate risk to BPS reliability. But, the relay would not have tripped when operating under normal loading conditions. In addition, the relay did not limit transmission loadability. The duration of the violation was from July 1, 2010 through October 4, 2011. RFC considered as mitigating factors certain aspects of AEP’s compliance program, the violations being self-reported and the cooperation provided by AEP.

Penalty: $34,000 (aggregate for 4 violations)

FERC Order: Order issued June 29, 2012 (no further review)

Duquesne Light Company (Duquesne), Docket No. NP12-26-000 (April 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1/1.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: During preparation for an upcoming audit, Duquesne found, and self-reported, that one out of 23 circuits failed to meet the loadability criteria as set forth in PRC-023-1 R1.1. As the result of human error, a relay was incorrectly set, leaving a circuit with less than the 150% loadability value, which Duquesne chose as its criterion for circuit loadability (the circuit was 108.2% of its 32° F four-hour rating). Duquesne, in its role as a TO, was found to be in violation of PRC-023-1 R1.1 by not having set transmission line relays correctly to ensure their operation at or below 150% of the highest seasonal Facility Rating of a circuit.

Finding: The violation posed a moderate risk to BPS reliability because the relevant relays were set so that at peak times the line loadability was 137.5% of its 95° F four-hour rating, leaving greater margins during increased stress periods, which was closer to the established loadability value. Also, during the violation period, the relevant circuit’s maximum actual peak load was 1,522 amperes. The circuit trip setting of 2,683 amperes compared to the actual peak load left an effective margin of 176%, using historical loading data. In determining the appropriate penalty, RFC considered Duquesne’s compliance program to be a mitigating factor. Additional mitigating credit was given because Duquesne self-reported the issues and proactively worked to mitigate the violations.

Penalty: $18,000 (aggregate for 2 penalties)

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

Georgia Power Company, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1/1.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: In May 2011, Georgia Power Company (GPC), as a TO, self-reported that several of its phase protective relay settings on three 230 kV breakers and one 500 kV breaker did not meet the setpoints in the Reliability Standard. The relays on the three 230 kV breakers had been found to be deficient before the Reliability Standard came into effect, but the relays had not been properly updated. The relay on the 500 kV breaker was also deficient since the Reliability Standard came into effect, but was not identified as such as a result of a data input error. GPC also identified three additional relays that did not satisfy the loadability requirements (two Zone 3 relays and one pilot trip relay).

Finding: SERC found that the violation constituted a minimal risk to BPS reliability. For the relays that protect generation radials, they are not exposed to networked current and had setpoints of at least 119% of the facility rating (which provides some loadability greater than the facility rating). In addition, the 500 kV breaker would not have operated in the case of a remote fault. For the relays on the transmission lines, the terminal pilot relay was only out of compliance for five weeks and the Zone 3 relays had setpoints at 138% of the facility rating. The duration of the violation was from July 1, 2010 through August 29, 2011. SERC evaluated GPC’s compliance program as a mitigating factor.

Penalty: $5,000

FERC Order: Order issued June 29, 2012 (no further review)

Holy Cross Energy, Docket No. NP11-270 (September 30, 2011)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: WECC

Issue: Holy Cross Energy (HCE) self-certified non-compliance with R1 following a report by Xcel Energy Inc., the company HCE contracted to be responsible for Protection System operation and maintenance of its facilities, that two distance relays at a substation were not within the range of the loadability standards prescribed under R1.1. The violation lasted from July 1, 2010 to December 20, 2010.

Finding: WECC determined that the violation posed a minimal risk to the reliability of the BPS because the violation only involved two relays on a single transmission line and were part of an extended zone of protection seldom called upon to operate. In addition, the violation lasted less than six months and HCE is a single transmission facility operated by a third party.

Penalty: $5,000

FERC Order: Issued October 28, 2011 (no further review)

LCRA Transmission Services Corporation (LCRA TSC), Docket No. NP12-44-000 (August 31, 2012)

Reliability Standard: PRC-023-1

Requirement: 1/1.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: TRE

Issue: LCRA TSC, in its role as a TO, submitted a self-report in August 2011 detailing a violation of PRC-023-1 as it found that two 345 kV line terminals did not meet the loadability requirements set forth in the Reliability Standard. Specifically, the two transmission lines were set to operate at 130% of the highest seasonal Facility Rating of a circuit; however, the Standard requires the setting to be 150%. Because of that, the relays would not trip under certain load conditions. It was determined that the relay lines were set in March 2010, prior to the enforcement date of July 2010. Both lines were energized in February 2011 with the March 2010 settings. The issue was corrected upon LCRA TSC discovering the error.

Finding: The violation was deemed by TRE to pose minimal risk to BPS reliability which was mitigated by three reasons. First, the wrong setting was above the normal capacity rating by approximately 30%. Second, the capacity of the two lines is much higher than that of nearby transmission lines in the same voltage class. And, third, the percentage loading was under the line capacity. It was noted that the two transmission lines were put into service to handle expected overloads related to other facilities effectively serving as spare capacity on the BPS. In determining the appropriate penalty, TRE considered LCRA TSC's strong compliance program. LCRA TSC was also given credit for "above and beyond" mitigation measures as set forth in the Notice of Penalty. TRE found no evidence that the issue was a result of broader corporate compliance issues. LCRA TSC neither admitted to nor denied TRE's findings.

Penalty: $0

FERC Order: Issued September 28, 2012 (no further review)

Louisville Gas and Electric Company and Kentucky Utilities Company, Docket No. NP13-33 (April 30, 2013)

Reliability Standard: PRC-023-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: In May 2012, Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E/KU), as a TO, self-reported that in six instances it had the wrong settings for relay loadability affecting three 345 kV lines. Two of the errors were caused by incorrect calculations and the other four errors were caused by incorrect field settings.

Finding: SERC found that this violation constituted a moderate risk to BPS reliability since not having enough margin between relay set points and the associated Facility Ratings could cause the facilities to be automatically removed from service and for operators to not have sufficient time to mitigate overload conditions. But, the set points at issue would likely not have limited loadability since the average relay set points were 298.5% of the maximum historical loads (and never less than 143.1%). The duration of the violation was from July 1, 2010 through December 28, 2012. LG&E/KU neither admitted nor denied the violation. LG&E/KU’s internal compliance program was viewed as a neutral factor.

Total Penalty: $40,000 (aggregate for 6 violations)

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

Mississippi Power Company, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1/1.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: In May 2011, Mississippi Power Company (MPC), as a TO, self-reported that several of its phase protective relay settings on seven 230 kV lines did not satisfy loadability requirements. An error in spreadsheet calculations and in a value on one System Conductor Map caused the phase protective relay settings for the seven 230 kV lines to range from 115.2% to 148.8% of the facility ratings (as opposed to 150% as required). The relevant relays were all Zone 3 relays at networked terminals that provided back-up protection.

Finding: SERC found that the violation constituted a minimal risk to BPS reliability since the relevant relays would not have operated prematurely. In addition, the system was evaluated with the erroneous relay loadability setting and, even under the most severe hot weather scenarios, the lines would not have exceeded their Zone 3 loadability thresholds prior to the system having a voltage collapse. The duration of the violation was from July 1, 2010 through June 30, 2011. SERC evaluated MPC’s compliance program as a mitigating factor.

Penalty: $0

FERC Order: Order issued June 29, 2012 (no further review)

Northern Indiana Public Service Company (NIPSCO), Docket No. NP14-11 (Dec. 30, 2013)

Reliability Standard: PRC-023-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: In October 2011, NIPSCO self-reported to RFC that the trip point for relays on two of its 345 kV transmission lines was set below 150% of the highest seasonal Facility Rating of the circuit in violation of the standards found in PRC-023-1 R1. Specifically, one circuit was set to trip at 107% of the line rating and the other was set to trip at 105% of the line rating. NIPSCO reported that the load for the circuits at issue did not approach the maximum rating of the circuits during the period at issue.

Finding: The violation was deemed to pose a moderate risk to reliable BPS operations, but not a serious or substantial risk. Although premature tripping has the potential to affect reliable BPS operations, in this case, risk was mitigated as NIPSCO’s annual Transmission Planning assessment showed that loss on either or both circuits would have no thermal violation, voltage violation or cascading outage on the BPS. In determining the appropriate penalty, RFC considered that the PRC-023-1 violation was a first occurrence and was self-reported; the prior violation of FAC-009-1 was not an aggravating factor; and the prior resolved issue concerning PRC-005-1 was not an aggravating factor. RFC gave partial mitigating credit for NIPSCO finding and reporting the issues concerning the FAC-009-1 violation.

Total Penalty: $0 (for four violations)

FERC Order: Issued January 29, 2014 (no further review)

PacifiCorp, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: WECC

Issue: In October 2011, PacifiCorp, as a TO, GO and DP, self-reported that it had not properly maintained the settings for 26 of its relays (approximately 7% of its relays subject to the Reliability Standard) because it did not update the relays settings after changes made to the system.

Finding: WECC found that the violation constituted a moderate risk to BPS reliability. Four of the relays at issue are associated with major transmission paths in WECC. There were backup protection systems in place to protect the BPS. In addition, PacifiCorp had initially established the relay settings in accordance with the Reliability Standard. The duration of the violation was from July 1, 2010 through November 30, 2011. PacifiCorp had a previous violation of PRC-023-1 (related to a relay located at a non-PacifiCorp owned interface substation), but WECC did not view this as an aggravating factor based on the different circumstances.

Penalty: $15,000

FERC Order: Order issued June 29, 2012 (no further review)

PacifiCorp, FERC Docket No. NP14-3 (October 30, 2013)

Reliability Standard: PRC-023-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: WECC found that PacifiCorp, as a DP, GO and TO, had not set 11 out-of-step tripping and blocking relays according to the requirements of the Reliability Standard.

Finding: WECC found that the PRC-023-1 violation constituted a moderate risk to BPS reliability as the failure to properly set the relays could limit transmission system loadability and interfere with operators’ ability to take remedial action. The improper setting of the relays could have made the transmission system susceptible to large separation generator rotor angles, large swings of power flows, and large fluctuations of voltages and currents. The relevant relays in this case were only associated with eight transmission lines (4.6% out of PacifiCorp’s 173 200+ kV transmission lines), but three of those lines were associated with Path 28 (a WECC-identified major transmission path). But, the risk was mitigated since the relays settings at issue did not impact the rating of any transmission line or PacifiCorp’s transmission studies or SOL calculations. In addition, the relevant relays were set within a range would have provided a degree of protection to PacifiCorp’s BES equipment. The duration of the PRC-023-1 violation was from July 1, 2010 through December 31, 2012. PacifiCorp agreed and stipulated to the violations. In approving the settlement agreement, NERC BOTCC considered the fact that PacifiCorp had a repeat violation of PRC-023-1 (which was evaluated as an aggravating factor). PacifiCorp also self-reported the violations, was cooperative during the enforcement process, complied with all applicable compliance directives, did not conceal the violations and had a compliance program in place when the violations occurred. In addition, PacifiCorp undertook additional voluntary corrective actions designed to remediate the violations and submitted a narrative to WECC which described its PRC-023 Project Management Improvement Plan.

Total Penalty: $92,000 (aggregate for 2 violations)

FERC Order: Issued November 29, 2013 (no further review)

Public Service Company of Colorado (PSCO), Docket No. NP12-26-000 (April 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: WECC

Issue: PSCO, as a TO, GO and DP, submitted a self-report detailing a violation of PRC-023-1. While conducting an internal compliance review on its relay loadability settings, PSCO found that 17 devices were not meeting the requirements of the Reliability Standard. Eight instances involved incorrect relay settings at a new substation, determined to be caused by human error. The 17 relays protect 7 transmission lines and 1 transformer subject to the Standard.

Finding: The violation was found to pose minimal risk to BPS reliability because the devices found to be non-compliant still performed their protection functions. Also, the amount of relays involved represents a small proportion of PSCO’s total relays. In addition, the lines were 230 kV or lower and not part of any major paths in WECC, lowering any possible impact to the BPS. In determining the appropriate penalty, PSCO’s internal compliance program was considered a mitigating factor and credit was given for the self-report.

Penalty: $50,000 (aggregate for 5 violations)

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

Public Service Company of New Mexico (PNM), Docket No. NP12-47-000 (September 28, 2012)

Reliability Standard: PRC-023-1

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: After receiving a Notice of On-site Compliance Audit, PNM, as a GOP, submitted a self-report of non-compliance with PRC-023-1. Subsequently, the Audit Team confirmed the following violation: (1) although PNM obtained requisite agreements as to the calculated circuit capability with the TOP and PC, it did not obtain agreement with the RC, in violation of PRC-023-1 R2.

Finding: The violation was deemed to pose minimal risk to BPS reliability which was mitigated because PNM was able to obtain agreement with both the TOP and PC. Further, PNM's violation is limited to relays on two transmission lines that do not operate unless a significant reversal of prevailing power flow occurs. As such, the risk of relays interfering with the system operator's ability to take remedial action or limit transmission loadability was unlikely. In determining the appropriate penalty, WECC considered PNM's internal compliance program as a mitigating factor and the repeat violation of BAL-004-WECC-01 as an aggravating factor. PNM agreed/stipulated to WECC's findings.

Penalty: $79,000 (aggregate for nine penalties)

FERC Order: Issued October 26, 2012 (no further review)

Public Utility District No. 1 of Chelan County (CHPD), Docket No. NP12-26-000 (April 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Moderate

Region: WECC

Issue: CHPD, as a TO, GO and DP, submitted a self-report detailing a violation of PRC-023-1 based upon its failure to set eight relays at three locations as set forth by PRC-023-1 by the date of mandatory enforcement. CHPD reported the failure was due to misunderstanding the requirements in the Standard. CHPD did not use the right criteria to calculate loadability for the eight relays.

Finding: The violation was found to pose minimal risk to BPS reliability because the devices found to be non-compliant still performed their protection functions. Also, the amount of relays involved represents a small proportion of PSCO’s total relays. In addition, the lines were 230 kV or lower and not part of any major paths in WECC, lowering any possible impact to the BPS. In determining the appropriate penalty, PSCO’s internal compliance program was considered a mitigating factor and credit was given for the self-report.

Finding: The violation was found to pose minimal risk to BPS reliability the violation is limited to 8 out of 31 relays (25.8%) subject to the Standard. Also, the breaker was out of service during the time of the violation and relays were set in a manner that left relay tripping unlikely. In determining the appropriate penalty, CHPD’s internal compliance program was considered a mitigating factor.

Penalty: $4,000

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

Public Utility District No. 2 of Grant County, Washington, FERC Docket No. NP11-151-000 (March 30, 2011)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: Public Utility District No. 2 of Grant County, Washington (PUD) self-reported that it had identified twenty-one 200 kV or above transmission line segments that were not compliant with the loadability requirements of R1 of the Standard. Duration of violation was July 1, 2010, when the Standard became enforceable, through October 14, 2011 (estimated mitigation plan completion date).

Finding: WECC Enforcement determined that the violation did not pose a serious or substantial risk to the bulk power system because only minor adjustments to the settings were required for PUD to meet the required 150% of the highest seasonal Facility Rating level, and PUD’s transmission line segments were short and thus less affected by its failure to apply the criteria in the Standard. Further, the NERC BOTCC concluded the penalty appropriate because this was PUD’s first violation of the Standard involved, PUD self-reported the violation, PUD had a compliance program in place at the time of the violation, and PUD was cooperative during the investigation.

Penalty: $25,100

FERC Order: Issued April 29, 2011 (no further review)

Silicon Valley Power (SVP), Docket No. NP13-21-000 (January 31, 2013)

Reliability Standard: PRC-023-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: SVP, as a TOP, self-certified that it did not comply with the requirements in the Reliability Standard that are designed to prevent its phase protective relay settings from limiting transmission system loadability while maintaining reliable protection of the bulk electric system for all fault conditions for its specific circuit terminal.

Finding: WECC found that the PRC-023-1 R1 violation constituted a moderate risk to BPS reliability since SVP may not have been sufficiently prepared to maintain the reliable protection of the bulk electric system in all fault conditions. But, it was later determined that this was a documentation issue as SVP’s relay settings were appropriate and satisfied the criteria of the Reliability Standard. The duration of the PRC-023-1 violation was from May 27, 2011 through June 29, 2012. SVP agreed and stipulated to the violations. In approving the settlement agreement, the NERC BOTCC considered the fact that these were the SVP’s first violations of the relevant Reliability Standards and four of the violations were self-reported. URE was also cooperative during the enforcement process, did not conceal the violations and engaged in voluntary corrective action to remediate the violations. Twelve of the violations posed a minimal risk to BPS reliability, and five of the violations posed a moderate risk, while none of the violations posed a serious or substantial risk to BPS reliability.

Total Penalty: $150,000 (aggregate for 17 violations)

FERC Order: Issued March 1, 2013 (no further review)

Southern Power Company, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1/1.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: In May 2011, Southern Power Company (SPC), as a TO, self-reported that one of its phase protective relay settings (on the West Georgia terminal on the Thomaston-to-West Georgia 230 kV line) did not satisfy loadability requirements. Entity A owns the 230 kV line and SPC owns the phase protective relay on the West Georgia terminal. Entity A performs maintenance activities for SPC, but failed to perform a work order to change the setting for the relay at issue. The relay is a Zone 3 relay that provides back-up protection for the generator radial.

Finding: SERC found that the violation constituted a minimal risk to BPS reliability since the relevant transmission line would never experience a network flow loadability event since it connects generation to Georgia Power Company’s transmission system. In addition, the Zone 3 relay at issue would have been able to accommodate 125% of the highest seasonal rating of the line and the relay settings provided for greater than 150% of the peak line-loading capability of the West Georgia Generating Station. The duration of the violation was from July 1, 2010 through June 30, 2011. SERC evaluated SPC’s compliance program as a mitigating factor.

Penalty: $0

FERC Order: Order issued June 29, 2012 (no further review)

Tennessee Valley Authority (TVA), Docket No. NP13-5-000 (October 31, 2012)

Reliability Standard: PRC-023-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: SERC

Issue: TVA, in its role as TOP, self-reported ten relay set-points that violated R1 by failing to follow criteria for specific circuit terminals to prevent the phase protective relay settings from limiting the loadability of eight transmission circuits.

Finding: SERC determined that the R1 violation posed a minimal risk to the reliability of the BPS since historical data of the minimum and average margin between the relay set-points and the actual line loading showed that the set-points would not likely have limited loadability. In addition, the combination of two radial generation lines and relay set-points above the maximum output rating of the generator meant that the set-points should not have limited loadability on those lines. Furthermore, the loadability was limited on three of the lines only when spare breakers were in service, which occurred only for short durations. SERC and TVA entered into a settlement agreement to resolve multiple violations, whereby TVA agreed to pay a penalty and to undertake other mitigation measures to come into compliance with R1. SERC considered TVA's documented internal compliance program a mitigating factor in making its penalty determination and also found that TVA's compliance history was not an aggravating factor. The duration of the violation was from July 1, 2010 through June 11, 2012. TVA neither admits nor denies the R1 violation.

Penalty: $25,000 (aggregate for 4 violations)

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

Unidentified Registered Entity, FERC Docket No. NP12-16 (February 29, 2012)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High Violation Severity Level: Moderate

Region: WECC

Issue: URE self-reported that the relays on one of its transmission lines were not able to operate at or below 150% of the highest 4-hour Facility Rating as required. URE originally believed that the ownership and maintenance of the relays was the responsibility of the line’s substation owner, but it was later clarified that URE was responsible for the relay maintenance and ownership.

Finding: WECC found that the PRC-023-1 violation constituted only a minimal risk to the BPS. The relevant relays were only a back-up device on the transmission line and the primary protection relays were found to be compliant with the Reliability Standard. The back-up relays settings did not cause line trips or system damage. In addition, URE had over 200 sets of transmission line relay settings and only one transmission line relay setting was found to be non-compliant. In approving the settlement agreement, URE evaluated URE’s violation history; the violations were self-reported; URE was cooperative during the enforcement process and did not conceal the violations; URE had a compliance program in place; and the violations did not constitute a serious or substantial risk to BPS reliability.

Penalty: $80,000 (aggregate for 6 violations)

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

Unidentified Registered Entity, FERC Docket No. NP12-20 (March 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: During an audit, WECC found that URE did not possess sufficient documentation showing that it had evaluated relay loadability at 0.85 per unit voltage and at a power factor angle of 30 degrees as required.

Finding: WECC found that the PRC-023-1 violation constituted only a minimal risk to BPS reliability. Even though URE has three interconnections with neighboring transmission owners, any load loss from a relay trip caused by abnormal circumstances affecting the three interconnections would probably be limited to URE’s system (and would have minimal impact on the rest of the BPS). URE also has a peak demand under 150 MW and has less than 200 miles of 230 kV transmission lines. In approving the settlement agreement, NERC BOTCC considered the fact that these were URE’s first violations of the relevant Reliability Standards; URE was cooperative during the enforcement process and did not conceal the violations; and the violations did not constitute a serious or substantial risk to BPS reliability.

Penalty: $60,000 (aggregate for 13 violations)

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

Unidentified Registered Entity, Docket No. NP12-22-000 (March 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: URE submitted a self-report stating that it did not obtain agreements from its PC, TOP and RC in which the parties agree to use the calculated circuit capability as the Facility Rating of the circuit, which affected four of URE’s facilities. Although URE did use the circuit capabilities as set forth in PRC-023-1 R2, it never followed through with an agreement among the parties

Finding: It was determined that the violation posed a minimal risk to BPS reliability because even though URE had not ensured that protective relay settings did not limit transmission loadability or interfere with URE’s system operators’ ability to protect the BPS, not did it security the required agreements with its PC, TOPs and RC, all parties used the correct Facility Ratings. In determining the appropriate penalty, WECC considered that the violation was self-reported and URE had no previous violations of this Reliability Standard or negative compliance history.

Penalty: $8,000 (aggregate for 2 penalties)

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

West Penn Power Company, Monongahela Power Company, and The Potomac Edison Company, dba Allegheny Power, (WP/MP/PE), Docket No. NP12-22-000 (March 30, 2012)

Reliability Standard: PRC-023-1

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: WP/MP/PE self-reported on July 21, 2011 that in its role as a TO it was not in compliance with the Standard because it had not followed one specific criteria set forth in PRC-023-1 R1. Specifically, the settings on its phase protective relays were not set to ensure the relays could not limit transmission system loadability during fault conditions while maintaining the integrity of the BPS. While reviewing transmission loadability, WP/MP/PE found that one transmission line relay at MP and one transmission line relay at PE on lines greater than 200 kV were not set to ensure they would not operate at or below 150% of the highest seasonal Facility Rating of a circuit. The relays had been set to follow a June 2004 NERC recommendation, but they were not changed to comply with the requirements of PRC-023-1 once it became effective.

Finding: The violation posed a moderate risk to BPS reliability because the protective relays had the ability to limit the amount of power the lines could carry which could have impacted BPS operation. WP/MP/PE adjusted the relevant relays to comply with the PRC-023-1 R1 requirements, and RFC noted that the loadability margins previously set were in compliance with a 2004 NERC Recommendation. In determining the appropriate penalty, RFC considered the entities’ parent company’s (Allegheny Energy, at the time of the violation) internal Compliance Program as a mitigating factor, as well as the fact the violation was self-reported.

Penalty: $7,500

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