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NERC Case Notes: Reliability Standard PRC-005-1.1b

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AEP Generation Resources Inc. (AEPGR), FERC Docket No. NP18-5 (December 28, 2017)

Reliability Standard: PRC-005-1.1b

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Lower

Region: ReliabilityFirst

Issue: On January 12, 2016, AEPGR, a GO, Self-Reported a violation of PRC-005-1.1b R2. AEPGR identified the violation on March 31, 2015, finding 192 devices—including relays, batteries, chargers and DC control circuits—for which maintenance and testing was not performed within the mandated intervals. The instances of missed maintenance and testing  occurred in the generation and transmission business units of AEPGR, although in sum only involved 0.19 percent of the total batteries, chargers, and relays in the regions in which AEPGR is active. Many of the instances were of a short duration (including one day), however, some of the instances dated back to the initial date of compliance on June 18, 2007. The detection was aided by controls previously implemented by AEPGR in response to similar issues in the past, enabling AEPGR to identify multiple instances through those programs.

Finding: ReliabilityFirst found the violation constituted a moderate risk to BPS reliability and did not pose a serious or substantial risk to the BPS. The overall risk was diminished due to the small proportion of devices affected (192 out of a total of 99,358) and did not represent a systemic issue across the AEPGR footprint. ReliabilityFirst found that any potential harm from the devices failing or not operating efficiently would not be significant or widespread. The duration of the violation was from February 28, 2014 (when AEPGR failed to complete testing and maintenance) through October 13, 2015 (when AEPGR completed the outstanding testing and maintenance activities). ReliabilityFirst considered the cooperation of AEPGR during the Settlement Agreement process as a mitigating factor. ReliabilityFirst also considered prior noncompliance with PRC-005-1 R2, similar to the current violation. In light of those multiple incidents and potentially extent factors that have not fully addressed the problem, such as a delay in inputting new equipment into the AEPGR asset database, ReliabilityFirst determined that the compliance history was an aggravating factor.

NP19-3-000: Bonneville Power Administration

Reliability Standard: PRC-005-1.1b

Requirement: R2

Violation ID: WECC2016016710

Method of Discovery: Self-Report

Violation Risk Factor: High

Violation Severity Level: Lower

Region: WECC

Issue: On December 23, 2016, BPA submitted a Self-Report stating that, as a Transmission Owner, it was in violation of PRC-005-1.1b R2. Specifically, BPA reported that on November 22, 2016, it discovered that a transfer trip analog device was installed at its Control Center, without indicating in the Asset Management System, critical information necessary to trigger priority and maintenance intervals for the device. Within the Asset Management System, the window for asset intake contained a system indicator designed to identify when a device is subject to the requirements of PRC-005-1.1b R2. In this case, the system indicator was not applied to the device, therefore the maintenance interval trigger did not operate as intended. The transfer trip analog device was installed in January 2008, and Protection System maintenance and testing should have been completed in March 2014 as defined by BPA's Protection System Maintenance and Testing Program.   After reviewing all the relevant information, WECC determined that BPA failed to implement its Protection System maintenance and testing program for one transfer trip analog device within its maximum maintenance interval as required by PRC-005-1.1b R2.

Finding: This violation posed a minimal risk and did not pose a serious or substantial risk to the reliability of the Bulk Power System (BPS).  In this instance, BPA failed to implement its Protection System maintenance and testing program for one transfer trip analog device within its maximum maintenance interval as required by PRC-005-1.1b R2. Such failure could result in a device misoperation leading to a loss of generation or damage to the associated 230 kV transmission elements if the device failed to send the signal to trip. Therefore, WECC assessed the potential harm to the security and reliability of the BPS as intermediate.  However, BPA had good compensating controls. If the transfer trip had failed to operate, BPA would have dropped generation. BPA has many generation drop contingencies in place to address a failed transfer trip. Based on this, WECC determined that there was a low likelihood of causing intermediate harm to the BPS. No harm is known to have occurred.

Penalty: No penalty

Duration of Violation: 1 March 2014 through 28 March 2016

FERC Order: Issued December 27, 2018 (no further review)

Penalty: $50,000

FERC Order: Issued December 28, 2017 (no further review)

CCI Signal Hill LLC (CCI SH), FERC Docket No. NP15-29-000 (May 28, 2015)

Reliability Standard: PRC-005-1.1b

Requirement: R2, R2.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: Texas RE

Issue: Texas RE, during a compliance audit, found that CCI SH had delayed the maintenance and testing for 31.7% of its DC circuits and 100% of its batteries by about 2.5 months, according to the intervals set out in its Protection System maintenance and testing program.

Finding: Texas RE found that this issue posed a moderate, but not a serious or substantial, risk to BPS reliability. Two of the plant's four units were Blackstart resources, and missed maintenance of Protection System equipment could have led to the failure of the Blackstart units and to relay misoperations. This could have delayed restoration of firm load. However, the plant's two other units had the ability to support the Blackstart and CCI SH was contracted to supply only 3.4% of ERCOT's primary Blackstart capability. To mitigate the violation, CCI SH (1) tested and completed maintenance on the circuits and batteries and (2) hired a consultant to review CCI SH's internal compliance program.

Penalty: $50,000 (aggregate for 6 violations)

FERC Order: FERC approved the settlement on June 26th, 2015.

CMS Generation Michigan Power, L.L.C. (CMSMP), Docket No. NP13-39-000 (May 30, 2013)

Reliability Standard: PRC-005-1.1b

Requirement: 2; 2.1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: RFC

Issue: Following CMSMP’s self-certification, RFC found that CMSMP as a Generator Owner violated PRC-005-1 R2 in failing to keep evidence of maintenance and testing within defined intervals certain Protection System devices. At its Livingston generating station, CMSMP did not conduct maintenance and testing on the station’s 32 voltage sensing devices within the required seven-year interval.

Finding: RFC found that this violation posed a moderate risk, but not a serious or substantial risk, to BPS reliability. The relays had both audible and visual alarms located in the Livingston generating station control room, which is manned at all times when the plant is in operation. During the period of violation, CMSMP experienced no misoperations. In determining an appropriate penalty, RFC considered CMSMP’s internal compliance program (ICP), which is widely distributed throughout CMSPC and actively overseen by senior management and a compliance review committee. The violation was quickly corrected because of swift and proper use of the ICP, which identified the problems before any harm could occur. CMSMP had not previously violated PRC-005-1 R2. Certain of CMSMP’s affiliated entities have previous violations of PRC-005-1 R2, but RFC found the mitigating credit afforded CMSMP in its effective use of the ICP cancelled out potential penalty aggravation.

Total Penalty: $0

FERC Order: Issued June 28, 2013 (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)

NP20-14-000: Exelon Generation Company, LLC – Exelon Nuclear

Reliability Standard: PRC-005-1.1b

Requirement: R2, R2.1

Violation ID: NPCC2017017379

Method of Discovery: Self-Report

Violation Risk Factor: High

Violation Severity Level: Lower

Region: NPCC

Issue: On April 7, 2017, Exelon Nuclear submitted a Self-Report stating, as a Generator Owner (GO), it was in violation of PRC-005-1.1b R2. (R2.1.). Following extent of condition reviews, Exelon Nuclear updated its Self-Report on August 11, 2017, January 24, 2018, and October 1, 2018. Exelon Nuclear did not perform testing in accordance with its Protection System Maintenance Program ("PSMP") for:

(a) Thirteen (13) out of 111 Current Transformers (CTs) and nine (9) out of 150 sections of DC control circuitry at the R.E Ginna Nuclear Power Plant (Ginna).

(b) Fifty-two (52) out of 372 sections of DC control circuitry and one (1) out of 180 relays at Nine Mile Point Nuclear Station, Units 1 (NMP1). 

(c) Nineteen (19) out of 372 sections of DC control circuitry at its Nine Mile Point Nuclear Station, Units 2 (NMP2).

(d) Forty-three (43) out of 150 sensing devices, thirteen relays, eight sudden pressure relays, and four associated pressure sensors at its Jame A. FitzPatrick Nuclear Power Plant (FitzPatrick).

NPCC determined that the overall root cause of the violation at Ginna, NMP1, and NMP2 was the lack of proper management oversight and attention to detail in the implementation of the Exelon PSMP as the ERO was transitioning from PRC-005-1b to PRC-005-2/6. A contributing factor was that Exelon became the GO and Generator Operator ("GOP") in December 2014 for the three units and there was the need to reconcile the maintenance that was completed by the previous GO with the incoming Exelon PSMP. As such, much of the testing that was not completed was inherited by Exelon. However, there were some aspects of the missed testing that could have been performed after the acquisition had the Exelon Nuclear PSMP not lacked clarity for the performance of those specific maintenance/test activities.

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 uncompleted maintenance affected four generating units with an aggregate nameplate rating of approximately 3,375 MW. The failure to maintain and test the affected components could have caused the Protection System to either misoperate or fail to operate. Under certain conditions, this could cause the generating units to either trip offline unnecessarily, operate in an unstable manner potentially leading to cascading outages under stressed system conditions, and/or cause the nuclear site to exceed its Technical Specification for off-site power where a controlled plant shutdown would be initiated.

The Points of Interconnection (POIs) to the BES of the four generating units are in close electrical proximity to one another and in the same generation corridor. In particular, NMP1 and 2 are part of the Oswego Generation Complex, which is listed by the New York Independent System Operator (NYISO) as a stability-constrained Interconnection Reliability Operating Limit (IROL) interface in the New York Control Area. If the violation had caused the loss of all of Exelon Nuclear's generating capacity during a system event, the aggregate capacity of the four non-compliant generators significantly exceeds the current NYISO daily Operating Reserve of 1,965 MW. However, this would be a highly improbable situation as the overall redundancy associated with the overwhelming majority of the unmaintained aspects of the relay protection systems (e.g. DC wiring associated with the breaker backup relays and redundant transmission line protective relaying) and the other tests performed by Exelon Nuclear that indirectly provided some indication of the functionality of the unmaintained equipment reduced the probability of a misoperation and reduced the risk to the BPS.

No harm is known to have occurred as a result of this violation.

Penalty: $110,000

Duration of Violation: 5 December 2014 through 30 September 2020 (approved completion date only)

FERC Order: Issued December 27, 2018 (no further review)

NP19-8-000: Idaho Power Company (IPCO)

Reliability Standard: PRC-005-1.1(b)

Requirement: R2

Violation ID: WECC2017017203

Method of Discovery: Self-Report

Violation Risk Factor: High

Violation Severity Level: High

Region: WECC

Issue: On March 7, 2017, WECC created the Self-Report stating that, as a Generator Owner, IPCO was in violation with PRC-005-1.1b R2. Specifically, IPCO reported that during an internal compliance review in December 2016, it identified missing maintenance and testing records for ten Protection System relays. The testing should have been completed on January 1, 2015, but was not completed until February 24, 2017. After reviewing all relevant information, WECC determined that there was a change in scope from what IPCO originally reported. WECC found that IPCO failed to provide documentation of its Protection System maintenance and testing program and the implementation of that program for the metering devices that send signals to one relay (Current Transformers and Potential Transformers), as required by PRC-005-1.1b R2. The root cause of the violation was not having formally documented controls to verify that relay testing and maintenance were performed within the required timeframe.

Finding: WECC determined this violation posed a minimal risk and did not pose a serious or substantial risk to the reliability of the Bulk Power System (BPS). In this instance, IPCO failed to provide documentation of its Protection System maintenance and testing program and the implementation of that program for only one Protection System relay, as required by PRC-005-1.1b R2. However, the Protection System relay is associated with IPCO's 12 kV – 4.16 kV generator bus and could only have tripped the 1.75 MVA generator. This generator runs less than 15% of the time during a typical year, and the IPCO grid is operated to remain stable should that amount of generation trip off.

Penalty: $0

Duration of Violation: 1 January 2015 through 24 February 2017

FERC Order: Issued April 8, 2019 (no further review)

NP20-8-000: Public Service Company of New Mexico (PNM)

Reliability Standard: PRC-005-1.1b

Requirement: R2

Violation ID: WECC2016016414

Method of Discovery: Self-Report

Violation Risk Factor: High

Violation Severity Level: Lower

Region: WECC

Issue: On October 26, 2016, PNM submitted a Self-Report stating, as a Generator Owner and Transmission Owner, it had a potential noncompliance with PRC-005-1.1b R2. Specifically, PNM did not provide documentation for maintenance of its three valve-regulated lead-acid (VRLA) batteries, one vented-regulated lead-acid (VLA) battery, two transmission relays, eight battery chargers, and 155 instrument transformers within their maximum maintenance intervals defined in PNM's Protection System Maintenance Program (PSMP), as required by PRC-005-1.1b R2. The root cause of the violation was attributed to ambiguous instructions related to documenting and retaining evidence of PSMP maintenance tasks. In addition, there was a lack of quality control or inspection of the protection system devices that required preventative maintenance. PNM's PSMP during this time required visual inspections for the Protection System devices every four months, which are not required under the new version of the Standard. The missed maintenance activities for the 155 Instrument Transformers were missed visual inspections that would not have been required under PRC-005-6. In addition, the missed maintenance activities for the two transmission relays were four calendar-year requirements that, under PRC-005-6, would have only needed to be completed every six calendar years.

Finding: WECC determined this violation posed a minimal risk and did not pose a serious and substantial risk to the reliability of the BPS. In this instance, PNM failed to provide documentation of maintenance activities for three VRLA batteries, one VLA battery, two transmission relays, eight battery chargers, and 155 instrument transformers as a part of its PSMP, as required by PRC-005-1.1b R2. PNM had weak preventative and detective controls. However, PNM was following a stricter timeline for its maintenance and testing for its Protection System devices than is required by the current version of the Standard, reducing the risk by increasing the maintenance and testing activities. Specifically, the missed maintenance activities for the 155 Instrument Transformers were missed visual inspections that would not have been required under PRC-005-6. In addition, the missed maintenance activities for the two transmission relays mentioned above were four calendar-year requirements that, under the current version of the Standard, would have only needed to be completed every six calendar years.

Penalty: $70,000

Duration of Violation: 1 January 2015 through 27 February 2017

FERC Order: Issued February 27, 2020 (no further review)