NERC Case Notes: Reliability Standard PRC-005-1.1b | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-005-1.1b

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.

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)