NERC Case Notes: Reliability Standard PRC-005-1b | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-005-1b

NERC Case Notes: Reliability Standard PRC-005-1b

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Potomac Electric Power Company (Pepco), FERC Docket No. NP17-29 (September 28, 2017)

Reliability Standard: PRC-005-1b

Requirement: R2; R2.1; R2.2

Violation Risk Factor: High

Violation Severity Level: Lower

Region: ReliabilityFirst

Issue: On October 16, 2015, Pepco, a TO, Self-Reported a violation of PRC-005-1b R2.  Following a low voltage disturbance event in the Washington, DC area on April 7, 2015, ReliabilityFirst initiated its compliance assessment process to determine if the violation was a factor in the event.  Pepco provided its breaker trip test records associated with the 2012 testing cycle, the most recent prior to the event due to the 4-year interval of the test cycle.  Pepco could not produce evidence that the breaker involved in the disturbance event had been tested in 2012.  The breaker had been tripped upon commissioning in 2010 and again in 2014 due to a system fault, but not as part of the line relay tests conducted in 2012, as would have been required by its PRC-005 procedures.

Finding: ReliabilityFirst found the violation did not cause the disturbance and that it constituted a moderate risk to BPS reliability.  Although Pepco failed to demonstrate that the breaker involved in the disturbance was tested in 2012 as required by its procedures, operation of the breaker in 2014 under fault conditions suggest that it may have tripped if tested.  Moreover, even if the breaker had been tested, it is unlikely that Pepco would have uncovered the loose connection that contributed to the protracted clearing of the fault that led to the disturbance.  Like most PRC-005 testing programs, Pepco’s program does not test for loose connections.  The duration of the violation was from March 14, 2012 (when the Standard became mandatory and enforceable on Pepco) through March 23, 2016 (upon completion of the Mitigation Plan).  ReliabilityFirst considered the cooperation of Pepco during the Settlement Agreement process as a significant mitigating factor and also awarded mitigating credit for extenuating circumstances surrounding the violation, due to the high degree of cooperation and transparency of Pepco.  Due to the moderate risk and difficulties in identifying the violation when it occurred, ReliabilityFirst imposed additional nonmonetary sanctions on Pepco, including a suspension of its ability to self-log noncompliances with PRC-005-1b R2, PRC-005-2 R2, and PRC-005-6 R2 until ReliabilityFirst is satisfied that Pepco can do so appropriately.

Penalty: $45,000

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