NERC Case Notes: Reliability Standard PRC-004-2.1a | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-004-2.1a

NERC Case Notes: Reliability Standard PRC-004-2.1a

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US Bureau of Reclamation, FERC Docket No. NP17-9 (November 30, 2016)

Reliability Standard: PRC-004-2.1a

Requirement: R1

Violation Risk Factor: High

Violation Severity Level: Lower

Region: WECC

Issue: The United States Bureau of Reclamation (USBR), a GO, was found by WECC to be in violation of PRC-004-2a R2 during a compliance audit that was conducted from February 23, 2015 to February 25, 2015.  USBR failed to submit investigation results for one generator Protection System misoperation.  Additionally, USBR failed to submit quarterly updates for an additional generator Protection System misoperation. 

Finding: WECC found the violation posed moderate risk to BPS reliability. USBR failed to submit requisite documentation to WECC regarding generator Protection System misoperations which could have limited WECC’s situational awareness of the status of the misoperations and could have limited USBR’s ability to implement Corrective Action Plans to avoid future misoperations of a similar nature.  The duration of the violation was December 1, 2012 (the deadline for submitting investigation results for the first misoperation) to April 16, 2015 (the date the mitigation plan was completed).  To mitigate this violation, USBR: 1) revised and implemented revisions addressing this requirement in its maintenance manual for unexpected event reporting; and 2) implemented a quarterly preventive maintenance task to ensure that status updates for existing misoperations are reported.  WECC did not review USBR’s internal compliance program when determining disposition method.  WECC considered USBR’s compliance history and determined there were no relevant instances of noncompliance.

Penalty: No Penalty

FERC Order: Issued November 30, 2016 (no further review)