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NERC Case Notes: Reliability Standard PER-005-1

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NP19-1-000: Bonneville Power Authority

Reliability Standard: PER-005-1, PRC-001-1

Requirement: R1, R2 (PER-005-1); R2, R3.2 (PRC-001-1)

Violation ID: WECC2013013078, WECC2013013079, WECC201301390

Method of Discovery: Compliance Audit

Violation Risk Factor: Medium (PER-005-1); High (PRC-001-1)

Violation Severity Level: Severe

Region: WECC

Issue: During a Compliance Audit conducted from October 7, 2013 to October 11, 2013, WECC determined that BPA, a Balancing Authority (BA) and Transmission Operator (TOP), was in violation of PER-005-1 R1 and R2 and PRC-001-1 R2 and R3.2.

Based on the definition of "reliability-related task" provided during the off-site audit paired with the BPA-provided Task List, as well as System Operator interviews, WECC determined that not all BPA reliability-related tasks performed by the System Operators had been identified on its Task List, and thus the Task List was severely deficient. In addition, because the BPA Task List excluded key and critical system operator tasks, it did not meet the requirement of being an acceptable, comprehensive list of tasks performed by its System Operators. While WECC was able to verify BPA's historical practice of delivering training that goes beyond the tasks identified, there was not a Task List equivalent review and evaluation performed to ensure the Task List was up to date and comprehensive. Because BPA did not produce a sufficient Task List, it was impossible to verify that each System Operator was capable of performing each assigned task which was yet to be identified on the Task List, new tasks assigned to each operator type, or modified tasks on the Task List.

Therefore, after reviewing all relevant information, WECC determined that BPA failed to create a sufficient list of BES company-specific reliability-related tasks performed by its System Operators as required by PER-005-1 R1.1, which led to the failure to verify each of its System Operator's capabilities to perform each assigned task identified in R1.1 at least one time as required by PER-005-1 R2.
WECC also determined that BPA made 633 protective system changes during the audit period. However, BPA was not able to produce evidence that showed that it coordinated all 633 changes with neighboring BAs and TOPs. Therefore, after reviewing all relevant information, WECC determined that BPA failed to coordinate all new protective systems and all protective system changes with neighboring Transmission Operators and Balancing Authorities as required by PRC-001-1 R3.

Finding: The violation of PER-005-1 posed a moderate risk and did not pose a serious and substantial risk to the reliability of the Bulk Power System (BPS).  The failure of BPS to create a sufficient list of BES company-specific reliability-related tasks, performed by its System Operators. could result in the inability of BPA to ensure that its System Operators were competent to perform real-time BES reliability-related tasks potentially resulting in BES equipment damage, sustained outages, loss of load, loss of visibility, and increase system restoration time, or cause a burden on neighboring and interconnected entities.

As a BA and TOP, BPA's transmission system covers 300,000 square miles in the Pacific Northwest and adjoining areas. The system includes approximately 15,000 transmission circuit miles and more than 200 substations. BPA has over 32,000 MW of nameplate generation within its footprint and is responsible for balancing approximately 11,000 MW of peak load. BPA also operates 10 WECC Major Transfer Paths and multiple interconnections with 12 other entities. WECC assessed the potential harm to the security and reliability of the BPS as substantial.

WECC determined that BPA had weak or no controls in place to prevent or detect these issues. However, as compensation, WECC verified BPA's historical practice of providing competent training that goes beyond the tasks identified in the Task List. Based on this, WECC determined that there was a moderate likelihood of causing substantial harm to the BPS. No harm is known to have occurred.
This violation of PRC-001-1 posed a moderate risk and did not pose a serious or substantial risk to the reliability of the BPS. In this instance, the coordination of all new protective systems and all protective system changes with neighboring TOPs and BAs allows GOPs, TOPs, and neighboring TOPs and BAs to be familiar with protective schemes applied in their areas that can have significant impacts on the reliability of the BES. If this coordination is not performed, it can contribute to uncontrolled outages, separations, and delay restorations following valid protective system actuations. 
The 633 changes could have affected approximately 15,000 transmission circuit miles and more than 200 substations. WECC assessed the potential harm to the security and reliability of the BPS as substantial.

However, BPA coordinated new protective systems and changed protective systems with neighboring TOPs and BAs when the changes affected those entities.  If one of the uncoordinated changed internal protective systems had operated, the fault would have been isolated to BPA's system and would not have cascaded into a neighboring entity. Based on this, WECC determined that there was a low likelihood of causing substantial harm to the BPS. No harm is known to have occurred.

Penalty: No penalty

Duration of Violation: 1 April 2013 through 7 June 2017

FERC Order: Issued October 31, 2018 (no further review)

NP18-8-000: Rochester Public Utilities

Reliability Standard: PER-005-1

Requirement: R1, R1.3, R2

Violation ID: MRO2017017922, MRO2017017927

Method of Discovery: Compliance Audit

Violation Risk Factor: Medium (R1); High (R2)

Violation Severity Level: Severe

Region: MRO

Issue: During a Compliance Audit, MRO determined that RPU, as a Transmission Operator, was in violation of PER-005-1 R1.3 and R2. RPU was unable to provide evidence that it delivered training on eight of its 12 Bulk Electric System (BES) company-specific reliability-related tasks that were identified per R1.1. The four remaining reliability-related tasks that had training records were related to RPU's system restoration, and the training was conducted during its Reliability Coordinator's annual drill. While RPU was not able to provide any training documentation on eight of its 12 BES company-specific reliability-related tasks, RPU was able to provide "practical application" reports for these eight reliability-related tasks. The "practical application" reports were daily operator logs that confirmed that the System Operator performed the reliability-related task. The daily operator logs did not constitute evidence that RPU provided training to the System Operator on that reliability-related task or that RPU verified the System Operator's capability to correctly perform a BES company-specific reliability-related task.

Finding: This violation posed a moderate risk and did not pose a serious or substantial risk to the reliability of the bulk power system (BPS).  The duration of the noncompliance was over three years, although the practical application reports indicate that the System Operators had a level of competency with those tasks, and that System Operators routinely performed RPU's reliability-related tasks without a reportable event.  RPU's 161 kV transmission system primarily distributes power to the city of Rochester, meaning that its impact to the BPS outside of its footprint is limited, and RPU does not have any Interconnection Reliability Operating Limits, Blackstart Resources, or Cranking Paths. No harm is known to have occurred.

Penalty: $10,000

Duration of Violation: 1 April 2013 through 30 November 2017

FERC Order: Issued February 28, 2018 (no further review)

NP20-17-000: DTE Electric Company

Reliability Standard: PER-005-1; PRC-005-1.1b

Requirement: R2 (each)

Violation ID: RFC2017017450, RFC2018018988

Method of Discovery: Self-Report

Violation Risk Factor: High

Violation Severity Level: Lower

Region: RF

Issue: On April 17, 2017, DTE submitted a Self-Report stating that, as a Generator Owner (GO), it was in violation of PRC-005-1 R2. Specifically, DTE had not maintained or tested relays for four Combustion Turbine Generators (CTGs) at the Enrico Fermi Nuclear Power Plant (Fermi) since the late 1990s/ The CTGs were attached to a 120 kV switchyard. Three of the CTGs were dispatchable peakers (i.e., used for emergency peaks in demand for power), and one CTG was designated as an alternate alternating current (AC) power source at Fermi. The contributing factors to this violation were the initial misclassification of relay maintenance requirements for the CTGs in Fermi's maintenance system, a lack of effective detective controls and procedures, and the presence of vertical silos between Fermi personnel and a separate DTE engineering team.

During a subsequent compliance audit, ReliabilityFirst determined that DTE, as a DP and GO, was in violation of PRC-005-1.1b R2. The audit team reviewed submittals from DTE and determined that nine out of thirty-three samples did not satisfy the requirements of PRC-005. DTE conducted an extensive review of all protection system components and discovered that it had insufficient testing and maintenance records for 325 (6.67 percent) of its total applicable components.

Finding: ReliabilityFirst determined that the violation of PER-005-1 posed a moderate risk to the reliability of the bulk power system (BPS). Neglecting to maintain and test Protection System devices could lead to device malfunction, premature or undetected device failure, and Protection System misoperation. The risk was partially mitigated based on the minimal amount of generation at issue and because they were emergency generators that are rarely used. However, the length of this violation, coupled with the fact that one of the CTGs was an alternate AC source for Fermi, made this a moderate risk.

ReliabilityFirst determined that the violation or PRC-005-1.1b posed a serious risk to the reliability of the BPS. Protection System issues could have significant consequences related to equipment damage and power system performance. The scope of this violation and variety of causes and issues exacerbated the risk, as they evidenced a programmatic failure.

Penalty: $375,000,000

Duration of Violation: 18 June 2007 through 15 September 2017 (PRC-005-1); 25 November 2013 through 15 December 2019 (PRC-005-1.1b)

FERC Order: Issued June 26, 2020 (no further review)

NP20-22-000: Associated Electric Cooperative, Inc. (AECI)

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