NERC Case Notes: Reliability Standard PRC-006-1 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard PRC-006-1

NERC Case Notes: Reliability Standard PRC-006-1

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East Texas Electric Cooperative, Inc. (ETEC), FERC Docket No. NP17-29 (September 28, 2017)

Reliability Standard: PRC-006-1

Requirement: R9

Violation Risk Factor: High

Violation Severity Level: Lower

Region: Southwest Power Pool Regional Entity (SPP RE)

Issue: ETEC, a TO and DP, was determined by SPP RE to be in violation of PRC-006-1 R9 during a Compliance Audit conducted from September 9, 2015 to September 10, 2015. SPP RE determined that ETEC failed to provide for the automatic tripping of load pursuant to the UFLS Plan established by the SPP Planning Coordinator. The SPP audit team observed that, as submitted by ETEC on January 8, 2015, the total UFLS inventory identified comprised only twenty-eight percent of its total load which did not meet the thirty percent minimum accumulated load relief standard. The root cause of the violation was the failure of ETEC to apprise its member cooperatives of the UFLS requirements and attendant lack of controls and oversight to ensure the requirements were met.

Finding: SPP RE determined that the violation posed a minimal risk to BPS reliability. Although failure to comply with the regional UFLS program increases the risk that the response to an underfrequency event will be insufficient to prevent a cascading event, the UFLS requirement of the ETEC system is only approximately 33 MW, or less than once percent of the regional UFLS requirement, and thus not likely to have a significant effect on the operation of the system. The duration of the violation was October 1, 2013 (when the Standard became mandatory) through August 12, 2016 (completion of testing of UFLS relays). SPP RE considered ETEC's internal compliance program to be a neutral factor. ETEC mitigated the violation by updating its member cooperative UFLS data, completed and verified all testing of UFLS relays, and initiated new internal programs to its UFLS program so that member cooperatives are sufficiently aware of the requirement.

Penalty: $47,600

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

Northwest Texas Electric Cooperative, Inc. (NTEC), FERC Docket No. NP17-29 (September 28, 2017)

Reliability Standard: PRC-006-1

Requirement: R9

Violation Risk Factor: High

Violation Severity Level: Severe

Region: Southwest Power Pool Regional Entity (SPP RE)

Issue: NTEC, a DP, was determined by SPP RE to be in violation of PRC-006-1 R9 during a Compliance Audit conducted from September 9, 2015 to September 10, 2015. SPP RE determined that NTEC did not provide for automatic load tripping in accordance with the minimum accumulated load relief required by all three Steps of the SPP Planning Coordinator (SPP PC) Underfrequency Load Shed (UFLS) Plan. NTEC failed to inform its member cooperatives of the applicable UFLS program requirements and to subsequently monitor and ensure compliance.

Finding: SPP RE determined that the violation posed a minimal risk to the reliability of the BPS. Although NTEC was not complying with the specific load shed requirements of the SPP PC's UFLS Plan, it had established an UFLS inventory that substantially met the SPP PC's UFLS Plan requirements. The duration of the violation was February 16, 2017 through April 13, 2017. SPP RE considered NTEC's internal compliance program to be a neutral factor and determined there were no previous violations of this standard. NTEC redesigned its UFLS program following the violation and to prevent reoccurrence. In addition, NTEC implemented new oversight items for the review of its UFLS program during its annual member meeting.

Penalty: $53,900

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