NERC Case Notes: Reliability Standard PRC-STD-005-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-STD-005-1

NERC Case Notes: Reliability Standard PRC-STD-005-1

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Avista Corporation, FERC Docket No. NP11-108-000 (February 23, 2011)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: WECC

Issue: Avista Corporation (Avista) self reported a violation of PRC-STD-005-1 WR1 because, as a Transmission Operator and Transmission Owner, it was unable to provide records of maintenance and inspection for four periods at three switching stations between June 2007 and September 2007.

Finding: WECC and Avista entered into a Settlement Agreement in which Avista stipulated to the facts of the violations and agreed to the assessed penalty. WECC determined that the violation posed a minimal risk, but not a serious or substantial risk, to the reliability of the bulk power system. The NERC Board of Trustees Compliance Committee considered the following in determining the penalty: the violation of PRC-005-1 R2 was the second of that Reliability Standard and was deemed an aggravating factor; the violation was self-reported; Avista was cooperative during the compliance enforcement process; Avista has a compliance program which WECC considered a mitigating factor; there was no evidence of any attempt or intent to conceal a violation; and there were no additional mitigating or aggravating factors that would affect the penalty amount.

Penalty: $18,000 (for two violations of Reliability Standards)

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

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

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: None

Violation Severity Level: Not provided

Region: WECC

Issue: Farmington Electric Utility System's ("FEUS") documentation of its TMIP and related practices were incomplete with respect to Path 31 (Glade terminal of the Hesperus Glade 115 kV line), from the Glade end to the Colorado state line. Duration of the violation was from June 18, 2007 when the standard became enforceable through June 10, 2008.

Finding: Penalty was deemed appropriate because these were FEUS' 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)

Idaho Power Company, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: Not provided

Region: WECC

Issue: In February 2008, Idaho Power Company (IPC) self-reported that it had not fully implemented its 2008 Transmission Maintenance and Inspection Program (TMIP) as it had not documented details of its substation apparatus maintenance program. IPC did have an Apparatus Management Program in place as part of a computer based maintenance management program, but IPC had not summarized and compiled this information into its TMIP, as required.

Finding: WECC found that this violation did not pose a serious or substantial risk to the bulk power system since IPC did actually have an Apparatus Maintenance Program in place. The violation was self-reported and this was IPC’s first violation of this Reliability Standard. A mitigation plan has been completed.

Penalty: $0

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

Imperial Irrigation District, FERC Docket No. NP11-148-000 (March 30, 2011)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: WECC

Issue: In January 2010, Imperial Irrigation District (IID) self-reported that, as a Transmission Owner and Transmission Operator, it had not developed and enacted a Transmission Maintenance and Inspection Plan (TMIP) for its facilities that contained all of the mandated components as required and that the TMIP did not include the substation facilities associated with Path 46.

Finding: IID agreed to pay a penalty of $23,223 and to undertake other mitigation measures to resolve multiple violations. WECC found that the violation of PRC-STD-005-1 only posed a minimal risk to bulk power system reliability. IID was actually testing and maintaining its protection systems according to the protection system maintenance and testing plan. In addition, the substation facilities associated with Path 46 were being inspected and maintained but not properly documented. The duration of the PRC-STD-005-1 violation was from June 18, 2007 through March 11, 2010. In determining the penalty amount, NERC considered the fact that the violations were self-reported; IID was cooperative during the enforcement process and did not attempt to conceal the violations; and there were no additional mitigating or aggravating factors.

Penalty: $23,223 (aggregate for 2 violations)

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

Los Angeles Department of Water and Power, FERC Docket No. NP10-141-000 (July 6, 2010)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: Not provided

Region: WECC

Issue: LADWP self-reported that its Transmission Maintenance and Inspection Plan (“TMIP”) did not fully address all the requirements for the maintenance and testing of transmission and station facilities as required. LADWP submitted its completed mitigation plan on December 31, 2007 but WECC later determined that not all required elements of the standard had been addressed adequately in the revised TMIP. On January 23, 2009, LADWP self-reported a second violation because it found an instance where it had not performed “time and doctor” (timing) testing on two of its Intermountain Switching Station 345 kV Circuit Breakers as required by its Protection System Maintenance and Testing Program.

Finding: Duration of the violation was from June 18, 2007, when the standard became enforceable, through May 30, 2008. The violation did not pose a serious or substantial risk to the reliability of the bulk power system because it was a documentation issue only. The violation did not pose a serious or substantial risk to the reliability of the bulk power system because the breakers at issue were not extensively used and were part of a system that provided sufficient redundancy for the affected line. LADWP was given credit for self-reporting the violation.

Penalty: $225,000 (aggregate for multiple violations)

FERC Order: Issued Oct. 8, 2010 (no further review)

NERC Registered Entity, FERC Docket No. NP10-159-000 (July 30, 2010)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: Not provided

Region: WECC

Issue: The Registered Entity failed to provide evidence that it had inspected a particular transmission line in accordance with the Reliability Standard because it had not believed that it was subject to this Reliability Standard.

Finding: Duration of the violation was from June 18, 2007, when the Reliability Standard became enforceable, through September 25, 2008. The violation posed a moderate risk to the reliability of the bulk power system because loss of the line due to lack of maintenance and inspections could reduce capacity in a critical path during unusual "Arctic storm" conditions that had occurred in the past. This was the Registered Entity's first violation of the Reliability Standard.

Penalty: $109,000 (aggregate for multiple violations)

FERC Order: Issued August 27, 2010 (no further review)

Pacific Gas and Electric Company, FERC Docket No. NP10-145-000 (July 30, 2010)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: None

Violation Severity Level: N/A

Region: WECC

Issue: In September 2009, Pacific Gas and Electric Company (PG&E), as a Transmission Owner, self-reported that a detailed inspection on its Malin-Round Mountain #2 500 kV line (for which it is responsible for maintenance) had not been performed within the three-year interval as required by its Transmission Maintenance and Inspection Plan. This missed inspection was the result of a work management scheduling module programming error and that the detailed inspection for the line was completed by July 22, 2009 (almost a year late).

Finding: WECC found that the violation did not cause a serious or substantial risk to bulk power system reliability since PG&E had actually completed the other two required inspections (the working patrols and climbing inspections) within the defined intervals. The duration of the violation was from July 29, 2008 (when the detailed inspection was supposed to have been done) until July 22, 2009 (when the detailed inspection was actually performed). Under WECC's Penalty Table for the violation, WECC was required to issue a letter to PG&E's CEO concerning the non-compliance with the Regional Reliability Standard (with copies of the letter sent to NERC, WECC member representative, and the WECC Operating Committee representative). Furthermore, NERC considered the fact that this violation was PG&E's first violation of this Regional Reliability Standard; the violation was self-reported; PG&E was cooperative during the enforcement process and did not attempt to conceal the violation; and there were no additional mitigating or aggravating factors.

Penalty: $0

FERC Order: Issued August 27, 2010 (no further review)

Pacific Gas and Electric Company, No. NP11-270 (September 30, 2011)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: WECC

Issue: Following a self-report, WECC determined that Pacific Gas and Electric Company (PG&E) violated WR1 because it did not sample the oil on its Midway 500 kV shunt reactors within the intervals defined in its Transmission Maintenance and Inspection Plan. The samples were completed four days past the compliance due date. The violation was from February 1, 2011 to February 4, 2011.

Finding: WECC determined that the violation posed minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because PG&E was only four days late in completing the samples and there were no events or equipment reliability impacts as a result of the delay.

Penalty: $20,300 (aggregate for 2 violations)

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

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

Reliability Standard: PRC-STD-005-1

Requirement: WR1

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-STD-005-1 WR1, which requires maintenance inspections for PacifiCorp’s facilities on certain transmission paths in WECC (Path C, TOT-2B, and Bridger West).

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

Puget Sound Energy, Inc., FERC Docket No. NP11-33-000 (November 30, 2010)

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: WECC

Issue: WECC determined that Puget Sound Energy (“PSE”), as a Transmission Operator and Transmission Owner, failed to perform monthly inspections at its Cascade Substation as necessary pursuant to its Transmission Maintenance and Inspection Plan.

Finding: The NERC Board of Trustees Compliance Committee (“BOTCC”) did not assess a penalty for this violation. In reaching this determination, the BOTCC considered the following facts: the violation constituted PSE’s first violation of this Reliability Standard; PSE cooperated during the compliance enforcement process; PSE self-reported the violation; PSE did not attempt to conceal a violation or intend to do so; the violation did not create a serious or substantial risk to the bulk power system; the monthly data inspections were missed because of extenuating circumstances; and there were no other mitigating or aggravating factors or extenuating circumstances.

Penalty: $0

FERC Order: Issued December 30, 2010 (no further review)

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

Reliability Standard: PRC-STD-005-1

Requirement: WR1

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: WECC

Issue: The Transmission Maintenance and Inspection Plan of Unidentified Registered Entity (URE) failed to address each requirement of the Reliability Standard. In addition, URE failed to (1) adequately maintain station maintenance records and (2) outline station maintenance details as required by PRC-STD-005-1.

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 violations of these NERC Reliability Standards; the URE self-reported most of the violations; URE cooperated during the compliance enforcement process; URE’s compliance program; URE did not attempt to conceal a violation or intend to do so. However, WECC determined that the violation of PRC-STD-005-1 WR1 posed a severe risk to the reliability of the bulk power system because a failure of a URE substation could disrupt URE’s facilities, as well as neighboring entities.

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

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

Unidentified Registered Entity, FERC Docket No. NP11-218-000 (June 29, 2011)

Reliability Standard: PRC-STD-005-1

Requirement: WR1 (two violations)

Violation Risk Factor: N/A

Violation Severity Level: N/A

Region: WECC

Issue: The Registered Entity self-reported that it had not inspected two of the Paths transmission circuits according to the specification in its Transmission Maintenance and Inspection Plan on a WECC Qualified Path it operates (one violation). In addition, WECC found that the Registered Entity did not perform a required 10-year comprehensive inspection, as detailed in its Transmission Maintenance and Inspection Plan, on one of the WECC Qualified Paths it operates (one violation).

Finding: WECC and the Registered Entity entered into a settlement agreement to resolve multiple violations, whereby the Registered Entity agreed to pay a penalty of $130,000 and to undertake other mitigation measures. WECC found that the first PRC-STD-005-1 violation constituted a moderate risk to bulk power system reliability. But, the Registered Entity had followed its Transmission Maintenance and Inspection Plan for three of its WECC Qualified Paths, and inspected two other WECC Qualified Paths from the air. In regards to the second violation of PRC-STD-005-1, WECC found that the violation constituted only a minimal risk to bulk power system reliability since the Registered Entity followed its Transmission Maintenance and Inspection Plan for all of the other WECC Qualified Paths that it operates and pole decay only posed a minimal risk in terms of potential pole failure. The duration of the PRC-STD-005-1 violations was from June 18, 2007 through March 30, 2009 and from December 13, 2009 through January 24, 2010. In approving the settlement agreement, NERC found that there were three instances of noncompliance with Regional Reliability Standard PRC-STD-005-1 WR1 (which was evaluated as an aggravating factor); some of the violations were self-reported; the Registered Entity was cooperative during the enforcement process and did not conceal the violations; the Registered Entity had a compliance program in place (which was evaluated as a mitigating factor); the penalties for the violations of Reliability Standards EOP-001-0 R6 and EOP-005-1 R2 were aggregated since both penalties were based on a single act of noncompliance; the penalties for the violations of Reliability Standards PRC-STD-005-1 WR1 and VAR-STD-002b-1 WR1 were based on the respective Sanction Tables; and there were no additional aggravating or mitigating factors.

Penalty: $130,000 (aggregate for 27 violations)

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