NERC Case Notes: Reliability Standard PRC-004-WECC-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-004-WECC-1

NERC Case Notes: Reliability Standard PRC-004-WECC-1

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

Reliability Standard: PRC-004-WECC-1

Requirement: R1; R1.2

Violation Risk Factor: Lower

Violation Severity Level: Severe

Region: WECC

Issue: The United States Bureau of Reclamation (USBR), a TO, was found by WECC to be in violation of PRC-004-WECC-1 R1 and R1.2 during a compliance audit that was conducted from February 23, 2015 to February 25, 2015. USBR failed to analyze two relay operations within the 20 business day timeframe required by R1.2. USBR system protection personnel did not analyze a relay operation on a Major WECC Path that occurred on March 14, 2012 after a tree fell into a line. Similarly, USBR system protection personnel did not analyze a relay operation on a Major WECC Path that occurred on January 22, 2014 during an ice storm. It was later determined that the relays operated properly in each event.

Finding: WECC found the violation posed minimal risk to BPS reliability. Although USBR failed to analyze operations according to the time specified in R1.2, it did review the operations within the 24 hour timeframe required by R1.1. The duration of the violation was April 12, 2012 (21 days after the first relay operation) to March 13, 2014 (the date USBR analyzed the second relay operation). To mitigate this violation, USBR: 1) revised and implemented revisions addressing this requirement in its maintenance manual for unexpected event reporting; and 2) assigned a dedicated employee to oversee all of USBR's Unexpected Event Reporting to decrease likelihood of recurrence. 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)