NERC Case Notes: Reliability Standard PRC-008-0

 

American Electric Power Service Corporation (AEP), Docket No. NP12-30-000 (May 30, 2012)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Severe (SPP)/High (RFC)/Lower (SPP/TRE)

Region: RFC (1)/SPP (2)/TRE (1)

Issue: AEP, in its roles as a TO and DP, submitted self-reports to each of the three Regions reporting violations of PRC-008-0 R2 based on its finding that it failed to test certain UFLS equipment located in each of the Regions within defined intervals and in accordance with its UFLS equipment maintenance and testing program.

In RFC, AEP reported it had not tested 81 (11.5%) of 706 UFLS station batteries, accounting for 4.0% of AEP’s total UFLS Protection System relays and batteries. The period of violation was April 26, 2008 through January 21, 2010, when testing was completed.

In SPP, AEP submitted two self-reports. The first (dated October 2009) stated that AEP had not tested 3 (1.5%) of 197 UFLS station batteries, accounting for 12.2% of AEP’s total UFLS Protection System relays and batteries. The second (dated December 2010) stated AEP had not tested one (0.5%) of its 197 UFLS relays, accounting for 0.3% of total UFLS Protection System relays and batteries. The period of violation was June 18, 2007 through October 22, 2010, when testing was completed.

In TRE, AEP reported that it had not tested 6 (3.3%) of 184 UFLS relays, accounting for 1.8% of its total UFLS Protection System relays and batteries. The period of violation was January 1, 2008 through November 21, 2008, when testing was completed.

Finding: The violations were deemed to constitute moderate risk to BPS reliability because even though AEP had not tested its UFLS equipment according to schedule, risk was mitigated as AEP could shed load in excess of its load requirements in each of the Regions. Had an event occurred related to the subject devices, AEP would have been able to meet its UFLS program requirements. Further, the testing uncovered no misoperations, and AEP tracks its station batteries through the SCADA system, which confirmed there were no reported issues. In determining the appropriate penalty, AEP’s Internal Compliance Program was considered a mitigating factor, as well as the fact that AEP self-reported the violations. AEP was cooperative during the enforcement process and timely completed mitigation plans to remediate the violations. The Regions found no attempt to conceal a violation or evidence of any intent to conceal a violation. The violations in RFC and SPP were considered repeat violations of PRC-005-1 and were considered an aggravating factor in reaching the penalty figure. There were no other mitigating or aggravating factors affecting the penalty determination.

Penalty: $42,999 (aggregate for 8 violations)

FERC Order: Issued June 29, 2012 (no further review)

Blachy-Lane Electric Coop/PNGC, FERC Docket No. NP11-209-000 (June 29, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium (for R1, R2)

Violation Severity Level: Severe (for R1, R2)

Region: WECC

Issue: Blachy-Lane Electric Coop/PNGC (BLEC), as a Distribution Provider, self-reported that it did not possess an Under Frequency Load Shedding (UFLS) maintenance and testing program which incorporated UFLS equipment identification and a scheduled for maintenance and testing as required (R1). In addition, BLEC did not have proper documentation of its maintenance and testing results for its UFLS equipment (R2).

Finding: WECC and BLEC entered into a settlement agreement to resolve the violations, whereby BHCE agreed to undertake mitigation measures. WECC found that the violations only constituted a minimal risk to bulk power system reliability since the UFLS equipment was properly functioning and being adequately maintained (even without a formal program). Furthermore, even if there was an UFLS event, BLEC would shed a maximum of 12.6 MW of load (a very small amount in the Northwest). The duration of both violations was from June 18, 2007 through September 30, 2010. In approving the settlement agreement, NERC found that these were BLEC’s first violations of the relevant Reliability Standards; the violations were originally self-reported in May 2007 (and then retracted with WECC’s consent) and therefore WECC exercised its discretion not to impose a penalty; BLEC was cooperative during the enforcement proceeding and did not conceal the violations; and there were no additional aggravating or mitigating factors.

Penalty: $0

FERC Order: Issued July 29, 2011 (no further review)

Brazos Electric Power Cooperative, Inc., FERC Docket No. NP09-45-000 (September 25, 2009)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: TRE

Issue: Brazos Electric Power Cooperative, Inc. (Brazos) did not test and maintain certain UFLS relays within defined intervals.

Finding: The violation duration was June 28, 2007 through November 14, 2007. TRE and Brazos entered into a Settlement Agreement in which TRE assessed no monetary penalty because the violation occurred during a period in which Brazos was transitioning its 2006 maintenance program and procedures to comply with mandatory Reliability Standards and Brazos’ maintenance programs for 2007 and beyond allow no deferred maintenance. By the end of 2007 all subject relays were tested and operating properly and the four 138 kV panel subject relays amounted to 2 percent of 207 relay panels and though not formally tested in accordance with Brazos’s maintenance procedure, worked properly during the audit period. Brazos showed evidence of internal programs to confirm all relay operations during system events as correct, or its ability to initiate expedited maintenance if not correct and based on the configuration of the relays, failure of any of those relays were found to pose no substantial or serious risk to the reliability of the bulk power system. Further, Brazos had no prior violation of this Reliability Standard and there was no evident misrepresentation or concealment of facts, and Brazos' compliance program promoted a culture of compliance in the company.

Penalty: $0

FERC Order: Issued October 23, 2009 (no further review)

Cedar Falls Utilities, FERC Docket No. NP11-109-000 (February 23, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe (R1), Lower (R2)

Region: MRO

Issue: As the result of a compliance audit, MRO determined that Cedar Falls Utilities (CFU), as a Transmission Owner and Distribution Provider, had not identified UFLS equipment and components associated with UFLS relays as well as the schedule of testing and maintenance for its UFLS equipment in its Protection System maintenance and testing program as effective June 18, 2007 through January 22, 2009, in violation of PRC-008-0 R1. Further, CFU violated PRC-008-0 R2 as it did not have specific gravity test records at one substation for November 2008 and had no monthly battery maintenance and testing records at another substation from February 2009 through May 2009, as set forth in its UFLS maintenance and testing program.

Finding: MRO and CFU entered into a Settlement Agreement in which CFU admitted to multiple violations and agreed to the assessed penalty. MRO determined that the violation of PRC-008-0 R1 posed a minimal risk to the reliability of the bulk power system because the UFLS equipment had not been identified in the Protection System maintenance and testing program, but the PRC-008-0 R2 violation was found not to pose a serious risk to the bulk power system due to the small number of UFLS devices not maintained or tested during the defined interval. The NERC Board of Trustees Compliance Committee considered the following in determining the penalty: the violations were the first of the subject Reliability Standard, CFU was cooperative during the compliance enforcement process; there was no evidence of any attempt or intent to conceal a violation; and there were no additional mitigating or aggravating factors that would affect the penalty amount.

Penalty: $3,000 (aggregate for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

Central Iowa Power Cooperative, FERC Docket No. NP11-133-000 (February 28, 2011)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: Central Iowa Power Cooperative (CIPCO) self-reported that an early version of its UFLS program did not include a UFLS equipment testing schedule or a schedule for UFLS equipment maintenance for relays, DC control circuitry, PTs and batteries.

Finding: MRO assessed no penalty for the violation but determined that it posed a minimal risk to the bulk power system because CIPCO had performed the UFLS equipment maintenance and testing for 90% of the equipment and is responsible for approximately 80 MW of UFLS load. MRO noted that CIPCO was conducting maintenance and testing of the devices that were not included in its program document and that the violation related to a prior UFLS program document.

Penalty: $0

FERC Order: Issued March 25, 2011 (no further review)

City of Austin dba Austin Energy, Docket No. NP12-18 (February 29, 2012)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: Texas RE

Issue: While conducting a compliance audit, Texas RE found that Austin Energy, as a TO and a DP, did not test seven Under Frequency Load Shedding (UFLS) relays, representing 7.8% of the total number (90) of UFLS relays. The relay testing was delayed from less than one month (on 1 relay) to as much as four months (on 2 relays). The duration of the violation was from November 17, 2007 through January 28, 2009 and testing was overdue for ten of the fifteen months of this violation.

Finding: Texas RE determined the violation constituted a minimal risk to BPS reliability for five reasons. First, only a small percentage of relays were involved. Second, the seven relays were tested on average only 2.7 months late. Third, all UFLS testing is current. Fourth, no misoperations occurred as a result of the seven relays being tested out of time. Fifth, no relays were outside of acceptable tolerances. In considering the appropriate penalty, Texas RE noted that Austin Energy has a strong compliance program, and some credit was given for the self-report. Texas RE noted that Austin Energy had a previous violation of another Reliability Standard although it was not considered as an aggravating factor since it did not involve the same Standard.

Penalty: $40,000 (aggregate for three violations)

FERC Order: Issued March 30, 2012 (no further review)

City of Camden, FERC Docket No. NP11-266-000 (August 31, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SERC

Issue: SERC determined through an on-site audit that City of Camden (Camden) violated R1 because it did not have a Under Frequency Load Shedding (UFLS) equipment maintenance and testing program, although Camden's Transmission Owner/Transmission Operator was performing monthly visual inspections of Camden's substations during the relevant period. SERC further determined that Camden violated R2 because, since it did not have a UFLS equipment maintenance and testing program, it could not provide evidence that such a program was being properly implemented.

Finding: SERC found that the violations did not constitute a serious or substantial risk to the bulk power system (BPS) because Camden is a small utility of 52 MW serving a small number of residential and commercial customers with about 650 miles of 12 kV distribution lines, and thus should have a small impact on the BPS if an underfrequency event occurred; the interconnecting Transmission Owner/Transmission Operator has its own Protection System such that events on the Camden system should not affect the BPS; and the Transmission Owner/Transmission Operator inspected Camden's substations including the UFLS devices monthly since June 2007, and a contractor has performed maintenance on substation equipment, which should include UFLS devices, since 2007. Duration of violation was June 18, 2007 through April 21, 2010 (R1) and June 18, 2007 through April 21, 2011 (R2).

Penalty: $0

FERC Order: Issued September 30, 2011 (no further review)

City of Clarksdale, Mississippi, Clarksdale Public Utilities Commission, FERC Docket No. NP11-62-000 (December 22, 2010)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SPP

Issue: The City of Clarksdale, Mississippi, Clarksdale Public Utilities Commission (Clarksdale), as a Distribution Provider, failed to maintain a documented Under Frequency Load Shedding (UFLS) equipment maintenance and testing program.

Finding: The NERC Board of Trustees Compliance Committee (NERC BOTCC) approved a $5,000 penalty for this and other Reliability Standards violations. In assessing the penalty, the NERC BOTCC considered the following facts: this was Clarksdale’s first violation of the subject NERC Reliability Standard; the violation was self-reported; Clarksdale cooperated during the compliance enforcement process; Clarksdale did not attempt to conceal the violation or intend to do so; the violation did not create a serious or substantial risk to the bulk power system; and there were no other mitigating or aggravating factors or extenuating circumstances.

Penalty: $5,000 (aggregate for multiple violations)

FERC Order: Issued January 21, 2011 (no further review)

City of Forest Grove Light and Power, FERC Docket No. NP10-160-000 (September 13, 2010)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium (for R1 and R2)

Violation Severity Level: Not provided

Region: WECC

Issue: In May 2008, the City of Forest Grove Light and Power (CYFG) self-certified that it did not have an Underfrequency Load Shedding (UFLS) equipment maintenance and testing program in place that contained the UFLS equipment identification, the schedule for UFLS equipment testing, and the schedule for UFLS equipment maintenance. As a result, CFYG was unable to respond, within 30 days as required, to WECC’s request for the results of the UFLS maintenance and testing.

Finding: WECC found that these violations did not constitute a serious or substantial risk to the bulk power system since CFYG’s UFLS program was designed to trip a single breaker. CFYG also has a small load in a much larger system. The duration of the violations was from August 23, 2007 through November 30, 2009. The violations were CYFG’s first violation of this Reliability Standard.

Penalty: $0

FERC Order: Issued October 13, 2010 (no further review)

City of Healdsburg, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: The City of Healdsburg self-reported in August 2007 that it did not possess sufficient documentation of the maintenance and testing for its underfrequency load shedding (UFLS) program as required. Although the City of Healdsburg had hired a third party to perform the maintenance and testing of the equipment, neither the contractor nor the City of Healdsburg had properly documented the procedures used.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the City of Healdsburg did have an UFLS program in place and had made arrangements for the equipment to be tested (even though the testing and maintenance procedures were not documented as required). Also, the City of Healdsburg interconnection was only a 60 kV radial feed system. The City of Healdsburg self-reported the violation; this was the City of Healdsburg's first violation of this Reliability Standard; and a mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

City of Healdsburg, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: The City of Healdsburg self-reported in August 2007 that it had not implemented its underfrequency load shedding (UFLS) program as required. Although the City of Healdsburg had hired a third party to perform the maintenance and testing of the equipment, neither the contractor nor the City of Healdsburg had properly documented the procedures used.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the City of Healdsburg did have an UFLS program in place and had made arrangements for the equipment to be tested (even though the testing and maintenance procedures were not documented as required). Also, the City of Healdsburg interconnection was only a 60 kV radial feed system. The City of Healdsburg self-reported the violation; this was the City of Healdsburg's first violation of this Reliability Standard; and a mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

City of Loveland, Colorado, FERC Docket No. NP11-203-000 (June 29, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Moderate

Region: WECC

Issue: In December 2009, the City of Loveland, Colorado (CYLV), as a Distribution Provider, self-reported that it had not properly implemented an Under Frequency Load Shedding (UFLS) equipment maintenance and testing program as six of its nine UFLS relays were improperly wired (which invalidated any program results for those relays).

Finding: WECC and CYLV entered into a settlement agreement to resolve the violation, whereby CYLV agreed to pay a penalty of $3,000 and to undertake other mitigation measures. WECC found that the violation constituted a moderate risk to bulk power system reliability since the incorrect configuration of the UFLS equipment could have resulted in CYLV being unable to shed 31 MW of load during a system peak event. But, CYLV was at least implementing a UFLS program. The duration of the violations was from June 18, 2007 through December 10, 2009. In approving the settlement agreement, NERC found that this was CYLV’s first violation of this Reliability Standard; the violation was self-reported; CYLV was cooperative during the enforcement proceeding and did not conceal the violation; and there were no additional aggravating or mitigating factors.

Penalty: $3,000

FERC Order: Issued July 29, 2011 (no further action)

City of McMinnville, FERC Docket No. NP11-144-000 (March 30, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: In February 2010, the City of McMinnville (CYMM) self-report that, as a Distribution Provider, it did not possess a maintenance and testing program for its Under Frequency Load Shedding (UFLS) equipment (R1). Therefore, CYMM was also unable to produce documentation showing the maintenance and testing program results for its UFLS equipment (R2).

Finding: WECC and CYMM entered into a settlement agreement to resolve the violations, whereby CYMM agreed to pay a penalty of $6,000 and to undertake other mitigation measures. WECC found that the violations only constituted a minimal risk to bulk power system reliability since CYMM has UFLS devices in three stations and, according to Bonneville Power Administration procedures, the devices would drop 70 MW in three steps. Even if the devices failed, it would only cause a minimal impact on the bulk power system. Plus, CYMM could produce documentation showing that devices in two of the stations had actually been tested within the previous three years. The duration of the violations was from June 18, 2007 through June 4, 2010. In determining the penalty amount, NERC considered the fact that these were CYMM’s first violations of the relevant Reliability Standards; the violations were self-reported; CYMM was cooperative during the enforcement process and did not attempt to conceal the violations; and there were no additional mitigating or aggravating factors.

Penalty: $6,000 (aggregate for 2 violations)

FERC Order: Issued April 29, 2011 (no further review)

City of Roseville, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007 the City of Roseville self-reported that it had not properly documented, as required, the equipment maintenance and testing program of its underfrequency load shedding (UFLS) program.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since the City of Roseville was actually performing the relevant testing (even though it did not possess sufficient documentation for the equipment). This violation was primarily a documentation issue. Also, the City of Roseville self-reported the violation; this was the City of Roseville's first violation of this Reliability Standard; and a mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

City of Santa Clara d/b/a Silicon Valley Power, FERC Docket No. NP11-130-000 (February 28, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: During an off-site compliance audit, Silicon Valley Power (SVP) failed to provide documentation of its underfrequency load shedding equipment maintenance and testing program as required by R1. SVP also did not provide results of its underfrequency load shedding maintenance and testing program as required by R2. Duration of violation was June 18, 2007, when the Standard became enforceable, through June 24, 2008, when the violations were mitigated.

Finding: WECC Enforcement determined that the violations did not pose a serious or substantial risk to the bulk power system because SVP had an underfrequency load shedding program, though it was not compliant with requirements, and in the event of an underfrequency event, the California ISO would provide greater flexibility as it coordinates large utilities with sufficient generation to mitigate such an event. Further, the NERC BOTCC concluded the penalty appropriate because this was SVP’s first violation of the Standard, about half of the aggregate violations found were documentation issues, and SVP was cooperative during the investigation.

Penalty: $94,000 (aggregate for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

Dairyland Power Cooperative, FERC Docket No. NP09-29-000 (July 10, 2009)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: MRO

Issue: Dairyland Power Cooperative (DPC) was not able to produce a summary of the UFLS protection system maintenance and testing procedures, including testing intervals and their basis as required by the standard.

Finding: MRO assessed a $10,000 penalty (aggregate for multiple violations) based upon the determination that DPC was cooperative and forthcoming during the audit and demonstrated commitment to compliance. As well, it was DPC’s first violation of the standard and the violation would not put bulk power system reliability at serious or substantial risk because protection system maintenance and testing was being performed, but the overall maintenance and testing program and the UFLS equipment maintenance program were not sufficiently documented.

Penalty: $10,000 (aggregate for multiple violations)

FERC Order: Issued August 7, 2009 (no further review)

Denton Municipal Electric, FERC Docket No. NP08-4-000 (June 4, 2008)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: TRE

Issue: Denton Municipal Electric was unable to provide to TRE scheduled maintenance and testing documentation for under frequency relays or documentation showing that maintenance had been performed on the relays.

Finding: TRE did not assess a penalty for the violation because it occurred during the transition period to mandatory standards and the alleged violation would not put bulk power system reliability at serious or substantial risk.

Penalty: $0

FERC Order: July 3, 2008 (no further review)

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

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

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-008-0 R2 during a Compliance Audit from September 9, 2015 to September 10, 2015. SPP RE determined that ETEC failed to test its underfrequency relays in accordance with its UFLS Program. ETEC failed to demonstrate relays were tested for operation at designated frequency at the Slocum substation and failed to maintain additional relays in accordance with its underfrequency load shed (UFLS) program. Over the course of the audit period, ETEC revised its UFLS program procedures multiple times but did not remedy the lack of comprehensive testing of its relay units. In multiple cases, ETEC noted that tests had been performed on its test data sheet, but could not substantiate that the underfrequency function of the relay had specifically been tested.

Finding: SPP RE found the violation posed a minimal risk to BPS reliability. Although failure to maintain and properly arm underfrequency relays increases the risk that these relays will not respond during an underfrequency 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 May 1, 2009 (when the audit program began) through August 12, 2016 (completion of maintenance and testing of UFLS relays). SPP RE considered ETEC's internal compliance program to be a neutral factor and determined that prior violations did not typify recurring conduct and consequently did not serve as an aggravating factor. ETEC mitigated the violation by testing its UFLS relays, performing a review of UFLS test records to verify that all maintenance activities had been completed, and initiated annual training for its member cooperatives and contractors.

Penalty: $47,600

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

East Texas Electric Cooperative, Inc., FERC Docket No. NP10-162-000 (September 30, 2010)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SPP

Issue: East Texas Electric Cooperative, Inc. (ETEC), as a Distribution Provider and Transmission Owner was in violation of PRC-008-0 R1 because ETEC’s Implementation and Documentation of UFLS Equipment Maintenance Program procedure did not have a schedule for the UFLS relay maintenance and testing.

Finding: The alleged violation occurred from June 18, 2007, when the Standard became mandatory and enforceable, until November 6, 2009. SPP imposed a $15,000 penalty for this and other violations. In assessing the penalty, SPP determined that the alleged violation did not create a serious or substantial risk to the bulk power system because ETEC was testing its UFLS relays within the interval specified in the Protection Systems maintenance and testing program, but failed to include the schedule of testing in its UFLS procedure. Therefore, the violation was a documentation rather than a performance issue.

Penalty: $15,000 (aggregate for multiple violations)

FERC Order: Issued October 29, 2010 (no further review)

Empire Electric Association, Inc., FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Empire Electric Association, Inc. (EEA) could not produce documentation or other evidence showing that it had a Underfrequency Load Shedding (UFLS) equipment maintenance and testing program in place.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since EEA was actually testing the UFLS relays (as EEA conducted tests on all of the relays in August 2007 and submitted the results to WECC). This violation was primarily a documentation issue. EEA self-reported the violation and this was EEA's first violation of this Reliability Standard. Although the violation occurred before the Reliability Standards became mandatory on June 18, 2007, EEA did not complete a mitigation plan on time and therefore this violation also became a post-June 18 violation. Even though the mitigation plan was completed late, WECC determined that no penalty was warranted.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Empire Electric Association, Inc., FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Empire Electric Association, Inc. (EEA) could not produce documentation or other evidence showing that it had an Underfrequency Load Shedding (UFLS) equipment maintenance and testing program in place and therefore it was unable to implement the maintenance and testing program as required.

Finding: WECC found that this violation did not involve a serious or substantial risk to bulk power system reliability since EEA was actually testing the UFLS relays (as EEA conducted tests on all of the relays in August 2007 and submitted the results to WECC). This violation was primarily a documentation issue. EEA self-reported the violation and this was EEA’s first violation of this Reliability Standard. Although the violation occurred before the Reliability Standards became mandatory on June 18, 2007, EEA did not complete a mitigation plan on time and therefore this violation also became a post-June 18 violation; however, WECC determined that no penalty was warranted.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Eugene Water & Electric Board, FERC Docket No. NP10-23-000 (December 30, 2009)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Eugene Water & Electric Board (EWEB) failed to test some of its Protection System relays in accordance with defined intervals.

Finding: WECC and EWEB entered into a settlement agreement in which WECC assessed a $6,000 penalty (aggregate for multiple violations). WECC considered that the alleged violation was EWEB’s first violation of NERC Reliability Standards and there was no evidence of an attempt to conceal a violation by EWEB, and EWEB cooperated during the enforcement process. The violation did not pose a serious or substantial risk to the bulk power system because even though two of the subject relays were not tested per the scheduled maintenance and testing program, EWEB tested the two relays immediately after discovering the possible violation and the two UFLS relays on a system of EWEB’s size represented a minimal reliability impact to the bulk power system. The duration of the alleged violation was from June 18, 2007, the date the standard became enforceable, through December 14, 2007, when EWEB completed a mitigation plan.

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

FERC Order: Issued January 29, 2010 (no further review)

Farmington Electric Utility System, FERC Docket No. NP10-40-000 (February 1, 2010)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Farmington Electric Utility System ("FEUS") did not have evidence of the last test date for 16 relays.

Finding: Duration of the violation was from June 18, 2007 when the standard became enforceable through May 21, 2008. Penalty was deemed appropriate because this was FEUS' first violation of the applicable standard, FEUS self-reported eleven of the violations, and FEUS is a small generation and transmission system that had made a substantial commitment of financial and personnel resources to NERC compliance relative to its size.

Penalty: $40,250 (aggregate for multiple violations)

FERC Order: Issued March 3, 2010 (no further review)

FERC Docket No. NP11-111-000 (February 23, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: MRO

Issue: MRO conducted an audit of a Registered Entity in which it determined that the Registered Entity was unable to produce documentation of its maintenance and testing for 83.9 percent of its UFLS equipment within the defined intervals of its UFLS maintenance and testing program.

Finding: MRO and the Registered Entity entered into a settlement agreement to resolve multiple violations, whereby the Registered Entity agreed to pay a penalty of $120,000 and to undertake other mitigation measures to resolve the multiple violations. In terms of the PRC-008-0 violation, MRO found that the violation constituted a moderate risk to bulk power system reliability. But, the Registered Entity's three-year UFLS maintenance intervals (which do not include a grace period for its UFLS relays) are greater than NERC's recommended frequency. In addition, the battery banks associated with the UFLS equipment are installed at 69 kV, and the Registered Entity possesses high and low voltage alarms that are connected to the power system control center to monitor the battery voltage. The duration of the PRC-008-0 violation was from June 18, 2007 through March 19, 2010. In approving the settlement agreement, NERC found that these were the Registered Entity's first violations of the relevant Reliability Standards; the Registered Entity was cooperative during the enforcement process and did not conceal the violations; the remedies that the Registered Entity adopted in response to the violations were considered a mitigating factor; and there were no additional mitigating or aggravating factors.

Penalty: $120,000 (aggregate for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

Flathead Electric Coop., Inc., FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Before the Reliability Standards became mandatory, Flathead Electric Coop., Inc. (Flathead) self-reported that while the Bonneville Power Administration (BPA) had an Underfrequency Load Shedding (UFLS) equipment maintenance and testing program and was conducting tests for Flathead, Flathead had not documented this BPA program as its own.

Finding: WECC found that the violation did not pose a serious or substantial risk to the bulk power system since BPA had actually timely completed the maintenance and testing for a majority of Flathead’s underfrequency relays. This violation was self-reported; it was primarily a documentation issue; and this was Flathead’s first violation of this Reliability Standard. Even though the violation occurred before the Reliability Standards became mandatory, Flathead did not timely complete a mitigation plan, turning the violation into a post-June 18, 2007 violation, however, WECC determined no penalty was appropriate.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Gainesville Regional Utilities, FERC Docket No. NP11-105-000 (February 23, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: N/A

Region: FRCC

Issue: Gainesville Regional Utilities (GRU) self-reported to FRCC that, as a Transmission Owner and Distribution Provider, one underfrequency relay had not been tested within the established six-year interval.

Finding: FRCC and GRU entered into a Settlement Agreement in which GRU neither admitted nor denied the violations, but agreed to the assessed penalty. FRCC found that the violation did not pose a serious or substantial risk to the reliability of the bulk power system because the relay was tested just 2.5 months beyond the six-year interval, and GRU stated it had been functioning properly. The NERC Board of Trustees Compliance Committee considered the following in determining the penalty: GRU self-reported the violation; GRU was cooperative during the enforcement process; and there was no evidence that GRU intended to conceal or intentionally violate the Reliability Standard.

Penalty: $45,000 (aggregate for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

Great River Energy, FERC Docket No. NP10-111-000 (June 2, 2010)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium (for R1 and R2)

Violation Severity Level: Not provided

Region: MRO

Issue: During a compliance audit in January 2009, MRO discovered that Great River Energy's (GRE) Under Frequency Load Shedding (UFLS) Equipment Maintenance and Testing Program only identified the UFLS relays and did not include the identification for the DC control circuitry, voltage sensing devices, and batteries. In addition, GRE could not produce the maintenance and testing records for 24% of its UFLS devices.

Finding: MRO and GRE entered into a Settlement Agreement to resolve multiple violations, whereby GRE agreed to pay a penalty of $125,000 and to undertake other mitigation measures. MRO found that the violations of PRC-008-0 did not create a serious or substantial risk to bulk power system reliability since GRE was able to show that it had actually performed maintenance and testing on all the required elements (including the DC control circuitry, current transformers/potential transformers, batteries, and relays) – even though its program had insufficient documentation. As for the unavailable maintenance and testing records, those records mainly concerned battery maintenance and DC control circuitry tests for substations which operated at 69 kV or lower and GRE could produce 92% of its maintenance and testing records for the relays in its UFLS program. In determining the penalty amount, MRO considered the fact the violations were GRE's first violations of the relevant Reliability Standards and GRE was cooperative during the enforcement process and did not attempt to conceal the violations. GRE has completed mitigation plans for the violations of PRC-008-0 and has also undertaken other efforts to strengthen its compliance program.

Penalty: $125,000 (aggregate for multiple violations)

FERC Order: Issued July 2, 2010 (no further review)

Holy Cross Energy, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium (for both R1 and R2)

Violation Severity Level: Not provided

Region: WECC

Issue: In April 2008, Holy Cross Energy (HCE) self-certified that it did not have complete documentation for its Underfrequency Load Shedding (UFLS) equipment testing and maintenance procedures as required by R1. In addition, HCE self-certified that it had acquired equipment and lines in November 2007, but had not yet tested the equipment under its UFLS equipment testing and maintenance procedures as required by R2.

Finding: In terms of R1, WECC found that the violation did not pose a serious or substantial risk to the bulk power system since the violation was primarily a documentation issue and HCE had already started the process of updating its documentation. For R2, WECC also found that the violation did not pose a serious or substantial risk based on the nature and location of HCE’s assets. These violations were HCE’s first violations of this Reliability Standard. A mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Idaho Power Company, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In April 2008, Idaho Power Company (IPC) self-reported that the maintenance and testing of its Underfrequency Load Shedding (UFLS) relays had been overlooked, and therefore did not occur according to IPC’s UFLS maintenance and testing program.

Finding: WECC found that the violation did not pose a serious or substantial risk to the bulk power system since all of the relays were microprocessor types and they all remained in service. In addition, if one of these relays had failed, an alarm would have been sent to the Regional Operations desk, which would have caused a technician to be dispatched to undertake corrective action. This violation was self-reported and it was IPC’s first violation of this Reliability Standard. A mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Independence Power & Light (Independence), Docket No. NP13-5-000 (October 31, 2012)

Reliability Standard: PRC-008-0

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: Moderate

Region: SPP

Issue: During a Compliance Audit, SPP discovered that Independence, a DP and TO, violated R2 by failing to properly implement its Under Frequency Load Shedding (UFLS) equipment maintenance and testing program. Specifically, Independence could not provide evidence that 8 of the 24 UFLS relays in its program were tested within the intervals established by the Independence Power and Light Relay Testing and Maintenances Practices, Revision 3 procedure.

Finding: SPP determined that the R2 violation posed a minimal risk to the reliability of the BPS because Independence had records to show that seven of the eight relays had been tested within 11 years, the relays were monitored such that the system operator would be notified immediately if a relay failed and a critical alarm was triggered. Independence also kept back-up relays on hand, allowing for replacement if needed. In addition, even without the eight relays that are the subject of the violation, Independence would only have been 7% short of the SPP Criteria that requires members to maintain a UFLS program that will shed at least 30% of load. SPP and Independence entered into a settlement agreement to resolve multiple violations, whereby Independence agreed to pay a penalty and to undertake other mitigation measures to come into compliance with R2. SPP considered Independence's compliance program to be a neutral factor in making its penalty determination. The duration of the violation was from June 18, 2007 through March 31, 2010. Independence neither admits nor denies the R2 violation.

Penalty: $1,500

FERC Order: Issued November 29, 2012 (no further review)

Lafayette Utilities System (LAFA), Docket No. NP13-39-000 (May 30, 2013)

Reliability Standard: PRC-008-0

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: High

Region: SPP RE

Issue: Following a compliance audit, SPP RE found LAFA in violation of PRC-008-0 R2 as a Transmission Owner and Distribution Provider, for failing to execute and document its underfrequency load shedding (UFLS) equipment maintenance and testing program. LAFA could not show that it completed required testing within the five-year interval provided in its UFLS testing program as it could not produce results for 3 of its 26 UFLS relays.

Finding: SPP RE found that this violation posed a minimum, but not a serious or substantial, risk to the reliability of the bulk power system. 23 out of the 26 UFLS relays were tested within defined intervals. All 26 UFLS relays are monitored by the LAFA energy control system (ECS), and none-the-less will self-alarm if the relays fails a self-test or operates due to an underfrequency event. Finally, no underfrequency events occurred while LAFA was in violation of this standard. LAFA’s size, with only a peak load of 478 MW, also mitigated risk. In assessing the appropriate penalty, SPP RE credited LAFA’s internal compliance program (ICP) which was developed and improved with consulting input. LAFA utilizes an internal compliance committee, comprised of both employees and consultants, to update its ICP. LAFA also has a separate Electric Reliability Department dedicated to compliance and reliability matters. LAFA uses SharePoint sites to enhance document and record management and yearly self-assessments and mock audit to detect compliance issues.

Total Penalty: $34,000 (aggregate for 24 violations)

FERC Order: Issued June 28, 2013 (no further review)

Lane Electric Cooperative, Inc./PNGC, FERC Docket No. NP11-201-000 (June 29, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium (for R1, R2)

Violation Severity Level: Severe (for R1, R2)

Region: WECC

Issue: In April 2010, Lane Electric Cooperative, Inc./PNGC (LEC), as a Distribution Provider, self-reported that it did not have an Under Frequency Load Shedding (UFLS) maintenance and testing program which incorporated UFLS equipment identification and a schedule for maintenance and testing (R1). In addition, LEC did not possess documentation of the maintenance and testing results for its UFLS equipment as required (R2).

Finding: WECC and LEC entered into a settlement agreement to resolve the violations, whereby LEC agreed to undertake mitigation measures. WECC found that the violations only posed a minimal risk to bulk power system reliability since the UFLS equipment was actually being maintained and was properly functioning. Plus, if a UFLS event were to occur, LEC would only shed 15.2 MW of load (a very small amount). The duration of the violations was from June 18, 2007 through September 3, 2010. In approving the settlement agreement, NERC found that these were LEC’s first violations of this Reliability Standard; the violations were self-reported (originally back in 2007 and then retracted with WECC’s consent); LEC was cooperative during the enforcement proceeding and did not conceal the violations; based on the original self-report in 2007, WECC found it appropriate to use its discretion and not impose a penalty; and there were no additional aggravating or mitigating factors.

Penalty: $0

FERC Order: Issued July 29, 2011 (no further review)

LCRA Transmission Services Corporation, FERC Docket No. NP11-104-000 (February 1, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: Texas RE

Issue: The UFLS relay on Gonzales Panel 14 had been inadvertently tested when instead the UFLS relay on Gonzales Panel 4 should have been tested. Panel 4 was tested on June 24, 2004 and was scheduled to be tested again on October 7, 2008, although the due date for testing was June 24, 2009. Despite those scheduled test dates, testing was not performed until June 14, 2010, which was outside of the 60-month interval.

Finding: The violation posed a minimal risk to the reliability of the bulk power system because the peak demand on the affected relay is only approximately 3 MW. Further, LCRA TSC's percent load under UFLS would have been 11.1% had the relay failed, leaving them well above the ERCOT minimum requirement of 10%. In addition, when the subject relay was tested, it was found to be within tolerance.

Penalty: $0

FERC Order: Issued March 3, 2011 (no further review)

Los Angeles Department of Water and Power (LADWP), Docket No. NP12-40 (July 31, 2012)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: After reviewing LADWP’s Self-Report submitted on December 30, 2010, WECC determined that LADWP violated PRC-008-0 R2 because it could not demonstrate that it maintained or tested ten batteries related to the Underfrequency Load Shedding (UFLS) relay equipment pursuant to LADWP’s quarterly testing interval. WECC determined the scope of the violation is limited to LADWP’s UFLS Protection System batteries, highlighting that LADWP could not demonstrate that 10 out of 41 batteries supporting the system were tested every three months. The duration of this violation was from November 8, 2009 through December 30, 2010.

Finding: This violation posed only a minimal risk to BPS reliability for three reasons. First, LADWP timely conducted over 95% of its scheduled battery inspections of UFLS Protection System batteries, missing, or not having documentation for, only 6 of 178 inspections. Second, LADWP has alarms on all of its UFLS Protection System batteries, including the 10 batteries at issue in this violation. LADWP’s Energy Control Center strictly monitors the status of the batteries and immediately responds if an alarm is triggered. Third, LADWP replaces its station batteries when a battery is run down to 60% conductivity. LADWP agreed/stipulated to WECC’s findings. In determining the proper penalty, WECC considered LADWP’s internal compliance program as a mitigating factor.

Penalty: $60,000 (aggregate for five violations)

FERC Order: Issued August 30, 2012 (no further review)

Los Angeles Department of Water and Power (LADWP), Docket No. NP12-47-000 (September 28, 2012)

Reliability Standard: PRC-008-0

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: WECC

Issue: In July 2011, LADWP self-reported a violation of PRC-008-0 R2 in that, as a TO and DP with an Under Frequency Load Shedding (UFLS) program, it had no documentation to show that maintenance and testing had occurred within the six-year defined interval for two UFLS relays at its Velasco Receiving Station. WECC review confirmed that the violation only involved LADWP's UFLS Protection System relays. LADWP was found to be in violation of PRC-008-0 R2 for failure to maintain and test two of its 126 (1.59%) relays, within the six-year testing interval for UFLS Protection System relays as required by its UFLS equipment maintenance and testing program. WECC reported that the violation is LADWP's second violation of PRC-008-0 R2. The first violation occurred because LADWP had not fully implemented its UFLS equipment maintenance and testing program on 10 of its 41 UFLS station batteries. Therefore, the start date of the violation was June 18, 2007, when the Standard became mandatory and enforceable, to July 15, 2011, when the mitigation plan was completed.

Finding: The violation was deemed to pose minimal risk to BPS reliability because LADWP missed the maintenance interval for only two of 126 UFLS Protection System relays. The violation involved missed or undocumented inspections on relays that are found on a normally open circuit with an adjacent entity. The normally open circuit may be used as backup during abnormal system operating conditions. Since June 18, 2007, LADWP has operated the line for 7 hours, or 0.02% of total hours in the period. Also, LADWP had maintained and tested over 98% of the UFLS relays. LADWP's Energy Control Center continuously monitors its UFLS system, and immediate corrective action would be taken if abnormal system conditions were present. In determining the appropriate penalty, WECC considered LADWP's Internal Compliance Program as a mitigating factor. However, the instant violation is LADWP's second violation of the PRC-008-0 R2 Reliability Standard, which was considered an aggravating factor. WECC found no other aggravating factors warranting a higher proposed penalty. LADWP neither admitted to nor denied WECC's findings.

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

FERC Order: Issued October 26, 2012 (no further review)

Merced Irrigation District, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In July 2007, Merced Irrigation District (Merced) self-reported that it did not have an Underfrequency Load Shedding (UFLS) equipment maintenance and testing program and, therefore, had not implement the UFLS program as required.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system due to the nature and location of Merced’s facilities. The violations were self-reported and they were Merced’s first violations of this Reliability Standard. A mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Midstate Electric Cooperative, Inc., FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: Before the Reliability Standards became mandatory, Midstate Electric Cooperative, Inc. (Midstate) self-reported that while its Balancing Authority had an Underfrequency Load Shedding (UFLS) equipment maintenance and testing program in place and was conducting testing for Midstate, Midstate had not documented this UFLS program as its own and, therefore, it had not implemented the UFLS program as required.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since the Bonneville Power Administration, Midstate’s Balancing Authority, was actually performing the testing. The violation of R1 was primarily a documentation issue. The violations were self-reported and they were Midstate’s first violations of this Reliability Standard. Even though the violations occurred before the Reliability Standards became mandatory, Midstate did not timely complete a mitigation plan, turning the violations into post-June 18, 2007 violations; however, WECC determined no penalty was appropriate.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Minnesota Power (Allete, Inc.), FERC Docket No. NP11-08-000 (November 5, 2010)

Reliability Standard: PRC-008-1

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: MRO determined that Minnesota Power (Allete, Inc.) (MP), as a Transmission Owner and Distribution Provider, did not provide proof of UFLS maintenance and testing records for four devices representing approximately 8% of the total UFLS equipment devices.

Finding: MRO imposed a $62,500 penalty for this and other violations. In assessing the penalty, MRO considered the following facts: the violations constituted MP's first violations of the subject NERC Reliability Standards; MP cooperated during the compliance enforcement process; MP's compliance program; MP did not attempt to conceal a violation or intend to do so; the violations did not create a serious or substantial risk to the bulk power system and there were no other mitigating or aggravating factors or extenuating circumstances.

Penalty: $62,500 (aggregate for multiple violations)

FERC Order: Issued December 3, 2010 (no further review)

Muscatine Power and Water, FERC Docket No. NP11-104-000 (February 1, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: During an April 2010 on-site audit of Muscatine Power and Water's (MPW) maintenance and testing records for the UFLS equipment, the relays, DC circuitry, PTs, and batteries, auditors found that certain hydrometer tests were not conducted since the hydrometer used by MPW was out of service for repairs. The auditors further found that the Pine Substation batteries had not been tested since June 1, 2009 and but were due for testing on January 1, 2010 and the Isett Substation batteries had not been tested since May 12, 2009 and were due for testing on December 12, 2009.

Finding: MRO determined that the violation posed a minimal risk to the reliability of the bulk power system. MPW is interconnected with Alliant Energy and Mid-American Energy via 33 miles of 161 kV transmission lines and owns and operates a total underfrequency load shed program of 45 MW. Given that MPW may fail to shed less than 45 MW of UFLS load and it is local to Alliant Energy and Mid-American Energy, a failure of any part of MPW's UFLS program would have a low impact to the bulk power system.

Penalty: $0

FERC Order: Issued March 3, 2011 (no further review)

National Nuclear Security Administration – Los Alamos National Laboratory, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In July 2007, National Nuclear Security Administration – Los Alamos National Laboratory (NNSAL) self-reported that even though it was performing maintenance and testing on its Underfrequency Load Shedding (UFLS) equipment, it did not possess a written UFLS equipment maintenance and testing program and could not verify that it had all of the necessary documentation for its UFLS system elements. As NNSAL did not document its UFLS equipment maintenance and testing program, it was unable to implement its UFLS program as required.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since NNSAL was actually performing maintenance and testing on its UFLS equipment (even though not by the methods required by the Reliability Standard). The violations were self-reported and they were NNSAL’s first violations of this Reliability Standard. A mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Navopache Electric Cooperative, Inc., FERC Docket No. NP10-160-000 (September 13, 2010)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium (for R1 and R2)

Violation Severity Level: Not provided

Region: WECC

Issue: In March 2008, Navopache Electric Cooperative, Inc. (NPEC) self-reported that it did not have the required Underfrequency Load Shedding (UFLS) equipment maintenance and testing program in place. As a result, NPEC did not implement a UFLS equipment maintenance and testing program and was unable to respond, within 30 days as required, to WECC’s request for the results of the UFLS maintenance and testing. Maintenance and testing on NPEC’s UFLS equipment at the Navopache Coronado Substation delivery point in St. Johns, Arizona was not being performed at regular intervals.

Finding: WECC found that these violations did not constitute a serious or substantial risk to the bulk power system since the violations were limited to one facility that is only connected to the bulk power system at one radial connection. The duration of the violations was from June 18, 2007 through October 14, 2008. The violations were self-reported and they were NPEC’s first violation of this Reliability Standard. Even though the mitigation plan was completed late, WECC decided not to impose a penalty.

Penalty: $0

FERC Order: Issued October 13, 2010 (no further review)

Nebraska Public Power District, FERC Docket No. NP11-199-000 (May 26, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: During an audit in September 2010, MRO determined that one of Nebraska Public Power District (NPPD)’s batteries for its UFLS equipment (out of 95 devices) missed its six-month maintenance and testing interval.

Finding: MRO found that the violation only posed a minimal risk to bulk power system reliability since NPPD only missed the maintenance and testing interval for the relevant battery by two days and the other approximately 99% of its UFLS devices had been properly maintained and tested. The duration of the violation was from December 31, 2008 through January 2, 2009.

Penalty: $0

FERC Order: Issued June 24, 2011 (no further review)

Northern Lights/PNGC, FERC Docket No. NP11-266-000 (August 31, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: Northern Lights/PNGC (Northern Lights) self-reported that it did not have an Under Frequency Load Shedding (UFLS) maintenance and testing program in violation of R1 and, therefore, did not provide evidence demonstrating implementation of a UFLS maintenance and testing program in violation of R2.

Finding: WECC found that the violations did not constitute a serious or substantial risk to the bulk power system because during a possible UFLS event, Northern Lights would shed no more than 11.95 MW of load in the summer and 17.22 MW of load in the winter. Moreover, the UFLS equipment was functioning properly when tested. Duration of both violations was June 18, 2007 through May 27, 2011.

Penalty: $0

FERC Order: Issued September 30, 2011 (no further review)

NorthWestern Energy, FERC Docket No. NP11-133-000 (February 28, 2011)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: NorthWestern Energy (NWE) self-reported a violation of PRC-008-0, R1 after it found that it had not identified all of its UFLS equipment, including voltage sensing devices, batteries, and DC circuitry. MRO determined that NWE did not have a UFLS equipment maintenance and testing program in place which included UFLS equipment identification for all UFLS devices, a schedule for UFLS equipment testing, and a schedule for UFLS equipment maintenance as required by PRC-008-0 R1.

Finding: MRO assessed no penalty for this violation and determined that it posed a minimal risk to bulk power system reliability because even though NWE failed to identify voltage sensing devices, batteries and DC circuitry within its UFLS maintenance and testing program, NWE was following an informal, undocumented program. NWE was able to show that 79% of maintenance and testing was conducted in accordance with the informal program.

Penalty: $0

FERC Order: Issued March 25, 2011 (no further review)

NorthWestern Energy, FERC Docket No. NP11-266-000 (August 31, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: NorthWestern Energy (NWE) self-reported that during an annual internal compliance review, and a follow-up comprehensive review of all Under Frequency Load Shedding (UFLS) devices ordered by MRO, it discovered that of 68 UFLS, NWE performed required maintenance of 99% of the devices and performed testing of 41 devices in accordance with its UFLS program.

Finding: MRO found that the violation did not constitute a serious or substantial risk to the bulk power system because NWE performed maintenance and testing on a large portion of its UFLS devices and because of the small size of the load potentially impacted. Duration of violation was from June 18, 2007 through January 14, 2011.

Penalty: $0

FERC Order: Issued September 30, 2011 (no further review)

NorthWestern Energy, Docket No. NP12-27 (May 30, 2012)

Reliability Standard: PRC-008-0

Requirement: R2 (2 violations)

Violation Risk Factor: Medium (for both)

Violation Severity Level: Lower (for both)

Region: MRO

Issue: In May 2011, NorthWestern Energy (NWE), as a DP and a TO, self-reported that it did not have the maintenance and testing records, as required by its UFLS program, on one of its 34.5 kV bus power transformers for a 34.5 kV underfrequency relay (first violation). In November 2011, NWE also self-reported that it did not complete, as required by its UFLS program, the quarterly specific gravity testing for one of its UFLS station batteries (second violation).

Finding: MRO found that the violations constituted a minimal risk to BPS reliability since NWE is only responsible for shedding 96 MW of UFLS load but is capable of shedding up to 118 MW of load. Since the voltage and current sensing device at issue in the first violation was associated with only 0.97 MW, and the battery at issue in the second violation was associated with only 1.33 MW, NWE would have been able to meet its obligations without the devices. In addition, NWE did not discover any problems when it re-tested the devices. The first violation was from June 18, 2007 through April 14, 2011, and the second violation was from June 30, 2011 through September 27, 2011. NWE had a prior violation of PRC-008-0 R2, which MRO evaluated as an aggravating factor.

Penalty: $6,000

FERC Order: Order issued June 29, 2012 (no further review)

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

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

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-008-0 R2 during a Compliance Audit conducted from September 9, 2015 to September 10, 2015. NTEC failed to provide test data for eight underfrequency relays in accordance with its underfrequency load shed (UFLS) testing and maintenance program. SPP RE determined that NTEC did not substantiate the maintenance and testing of nine of the 19 UFLS relays, principally due to the lack of training afforded to NTEC member cooperatives.

Finding: SPP RE found the violation posed a moderate risk to the reliability of the BPS. Although failure to test relays increases the risk that they will not operate properly when called upon, NTEC uses microprocessor based relays exclusively, which are inherently reliable. Moreover, NTEC's UFLS requirement is only 162 MW, less than two percent of the regional UFLS requirement. The duration of the violation was May 1, 2009 (when the audit program began) through September 15, 2016 (the completion of UFLS relays maintenance and testing). SPP RE considered NTEC's internal compliance program to be a neutral factor and determined there were multiple prior violations of this standard that were an aggravating factor. NTEC performed a review of all UFLS test records and completed testing of all UFLS relays, in addition to implementing annual training for its member cooperatives and contractors on the UFLS Program.

Penalty: $53,900

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

Oncor Electric Delivery Company LLC (Oncor), Docket No. NP12-26-000 (April 30, 2012)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: TRE

Issue: Oncor, a DP and TO, submitted self-reports reporting a violation of PRC-008-0 due to its failure to identify or test certain Underfrequency Load Shedding (UFLS) Protection Systems within established intervals. Specifically, 14 (out of 522) relays and 51 (out of 403) UF battery systems were misclassified causing the equipment to be left off the monthly maintenance progress report, which alerts Oncor employees to maintenance activity.

Finding: The violation was found to pose a moderate risk to BPS reliability because the non-tested equipment consists of important components for BPS reliability, in particular during stressed or critical conditions, although the relays represent only 2.7% of Oncor’s total Underfrequency Protection Systems and the battery systems account for 12.7% of UF battery systems. No misoperations occurred as a result of the missed testing. RFC noted that Oncor has in place controls to prevent or mitigate any problems that may have occurred during the violation time period and no issues were found once the equipment was tested. In determining the appropriate penalty, RFC considered Oncor’s compliance program as a mitigating factor. No credit was given for the self-report because the violation was found during preparation for an upcoming audit by TRE.

Penalty: $15,000 (aggregate for 3 penalties)

FERC Order: Order issued May 30, 2012 (no further review)

Otter Tail Power Company, FERC Docket No. NP11-133-000 (February 28, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: Otter Tail Power Company (OTP) self-reported it was missing evidence of maintenance and testing of UFLS equipment at several substations for calendar years 2007, 2008, and 2009. OTP was required to perform a full inventory of its UFLS equipment maintenance and testing records for its 24 UFLS relays, 30 voltage and current sensing devices, 24 station batteries and 54 DC control circuits. OTP could not produce evidence for maintenance and testing of 2 voltage and current sensing devices, 1 station battery, and 8 DC control circuits comprising 8% of its devices subject to PRC-008-0, R2.

Finding: MRO assessed no penalty for the violation and determined that it posed a minimal risk to bulk power system reliability because the total MW affected by the missing maintenance and testing records was 40 MW. OTP’s UFLS available shed is 233 MW so the majority of the UFLS system would have been available and operating to reduce the load if the system had an underfrequency event. Additionally, OTP had maintenance and testing records for 92% of its UFLS equipment.

Penalty: $0

FERC Order: Issued March 25, 2011 (no further review)

PacifiCorp, FERC Docket No. IN11-6 (December 1, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Issue: On February 14, 2008, a short circuit occurred on a transformer at PacifiCorp’s Huntington generation plant in Utah, which triggered an immediate loss of approximately 2800 MW of generation across PacifiCorp’s East Balancing Authority Area (“PacifiCorp East” – which consists of Utah, southeast Idaho and western Wyoming) and the shedding of approximately 183 MW of firm load in Utah. Prior to the February 14, 2008 disturbance, PacifiCorp self-reported to WECC a violation of PRC-008-0 R2, which mandates a maintenance and testing program for UFLS equipment.

Finding: On December 1, 2011, FERC approved a Stipulation and Consent Agreement between FERC Office of Enforcement (“Enforcement”), NERC and PacifiCorp regarding PacifiCorp’s actions as a BA and TOP surrounding the February 14, 2008 disturbance. After the disturbance, Enforcement and NERC investigated PacifiCorp’s compliance with the PRC standards, even though PacifiCorp had completed relevant mitigation plans. Enforcement and NERC identified three overall deficiencies with PacifiCorp’s maintenance management system: (a) lack of verification of the data when it changes maintenance plan databases, (b) failure to oversee data entry and other changes made to the database, and (c) lack of proper managerial controls and oversight of the maintenance system. These problems cause PacifiCorp to have missing data and inaccurate maintenance cycles.

Penalty: $3,925,000 (aggregate for 23 violations)

FERC Order: http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=12829507

Port of Oakland, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In December 2007, the Port of Oakland self-reported that its Underfrequency Load Shedding (UFLS) equipment maintenance and testing program did not meet the requirements of Reliability Standard PRC-008-0 R1 and R2.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system due to the nature and location of the Port of Oakland’s facilities. The violations were self-reported and they were the Port of Oakland’s first violations of this Reliability Standard. A mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Provo City Corporation, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In March 2008, Provo City Corporation (PCYC) self-certified that it did not have its own Underfrequency Load Shedding (UFLS) equipment testing and maintenance program in place, since it incorrectly assumed that an UFLS program was being managed by another entity. Therefore, PCYC was unable to implement its UFLS program and was not testing its UFLS relays as required.

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system due to the nature and location of PCYC’s facilities. The violations were PCYC’s first violations of this Reliability Standard. A mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Public Service Commission of Yazoo City, FERC Docket No. NP11-54-000 (November 30, 2010)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SPP

Issue: The Public Service Commission of Yazoo City ("Yazoo") submitted two self-reports because it did not have a documented Under-Frequency Load Shedding (UFLS) equipment maintenance and testing program as required by R1 and had not tested its UFLS equipment as required by R2.

Finding: It was determined by SPP that the violation did not pose a serious or substantial risk to the reliability of the bulk power system because the three UFLS relays identified by Yazoo in its self-reports are continuously monitored, testing performed in August 2009 showed that the UFLS relays were operating properly, failure of the relays would have triggered an alarm on the Yazoo City Supervisory Control and Data Acquisition system, and Yazoo is a small entity with minimal impact on the bulk power system. The duration of violation was June 18, 2007, when the Reliability Standard became enforceable, through February 8, 2010. In determining the penalty, consideration was given to the fact that Yazoo self-reported the violations, and this was Yazoo’s first occurrence of violations of the Reliability Standards.

Penalty: $2,000

FERC Order: Issued December 30, 2010 (no further review)

Public Utility District No. 1 of Benton County, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: In June 2007, Public Utility District No. 1 of Benton County (Benton PUD) self-reported that its Underfrequency Load Shedding (UFLS) equipment maintenance and testing program did not include the auxiliary relays (and, therefore, Benton PUD had not tested its UFLS auxiliary relays as required).

Finding: WECC found that the violations did not pose a serious or substantial risk to the bulk power system since Benton PUD did have a UFLS equipment maintenance and testing program in place (even though the program did not cover the auxiliary relays). In addition, Benton PUD had timely completed the maintenance and testing on its two underfrequency relays. Once the auxiliary relays were tested, they were found to be fully operational. The violations were self-reported and they were Benton PUD’s first violations of this Reliability Standard. A mitigation plan was completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Public Utility District No. 1 of Snohomish County, FERC Docket No. NP11-239-000 (July 28, 2011)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: Following a Self-Report, WECC determined the Public Utility District No. 1 of Snohomish County (SNDP) did not have an Under Frequency Load Shedding (UFLS) maintenance and testing program in place that included the potential transformers and DC control circuitry associated with its UFLS relays in violation of R1. WECC also determined SNDP failed to maintain and test 13 of its 47 UFLS relays pursuant to the schedule in its maintenance and testing program, and missed one or more monthly, quarterly or annual tests for each for its station batteries from June 18, 2007 to the present, and failed to provide maintenance and testing records for its PTs and DC control circuitry.

Finding: WECC assessed a $20,000 penalty for these violations. WECC determined that the violations posed a minimal risk to the reliability of the bulk power system (BPS) but did not pose a serious or substantial risk to the reliability of the BPS because SNDP had a UFLS equipment maintenance and testing program that included relays and station batteries, but did not address PTs and DC control circuitry. Moreover, SNDP’s system was designed in such a manner that a misoperation of a relay during an underfrequency event would result in only a small amount of load failing to clear the system. In approving the settlement between SNDP and WECC, the NERC BOTCC considered the following factors: the violations did not constitute repeat violations; SNDP self-reported the violations; SNDP was cooperative; SNDP had a compliance program in place, which WECC deemed a mitigating factor; there was no evidence of an attempt or intent to conceal the violations; WECC determined the violations posed a minimal risk and did not pose a serious or substantial risk to the BPS; there were no other aggravating or mitigating factors.

Penalty: $20,000 (aggregate for 8 violations)

FERC Order: Issued August 29, 2011 (no further review)

Rayburn Country Electric Cooperative, Inc., FERC Docket No. NP11-228-000 (June 30, 2011)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SPP

Issue: During a compliance audit in August 2010, SPP found that the documentation for Rayburn Country Electric Cooperative, Inc.’s (Rayburn) Underfrequency Load Shedding (UFLS) program did not incorporate UFLS equipment identification or a schedule for UFLS equipment maintenance and testing as required.

Finding: SPP found that the PRC-008-0 violation constituted only a minimal risk to bulk power system reliability since the violation was primarily a documentation issue. Rayburn was actually performing maintenance and testing on its UFLS equipment and was following industry guidelines in establishing the bases for its maintenance and testing procedures and intervals. The duration of the violation was from June 18, 2007 through December 20, 2010.

Penalty: $14,000 (aggregate for 6 violations)

FERC Order: Issued July 29, 2011 (no further review)

Rochester Public Utilities, FERC Docket No. NP11-133-000 (February 28, 2011)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: During a compliance audit, MRO determined that an earlier version of Rochester Public Utilities’ (RPU) UFLS equipment maintenance and testing program document failed to satisfy the requirements of PRC-008-0 R1 as it did not include a schedule for UFLS equipment testing, a schedule for UFLS equipment maintenance, or UFLS equipment identification.

Finding: MRO assessed no penalty for this violation and determined that it posed a minimal risk to bulk power system reliability because even though the previous UFLS equipment maintenance and testing program document was not it compliance, RPU had performed most (45 of 68) of the maintenance and testing on its UFLS devices. RPU was regularly performing maintenance and testing and showed that it met the maintenance and testing interval for 66% of its UFLS devices. Additionally, MRO determined that, based on the size and location of RPU’s facilities, the violation posted a minimal risk to the bulk power system. RPU’s facilities are located approximately 75 miles south of Minneapolis and have two interconnection points to the bulk power system at 161 kV. Should the protection system fail to operate at the interconnection point, RPU has a parallel path remaining. Tests of the subject components showed the devices were within tolerance and no issues were identified.

Penalty: $0

FERC Order: Issued March 25, 2011 (no further review)

Rochester Public Utilities, FERC Docket No. NP11-254-000 (August 11, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Moderate

Region: MRO

Issue: During a compliance audit, MRO conducted a random sampling of 22 Under Frequency Load Shedding (UFLS) relay maintenance and testing records and identified 8 UFLS relays that were not maintained and tested within the required intervals. MRO required a review of all UFLS relays and discovered that about 35% of the UFLS equipment lacked evidence of maintenance and testing records. Duration of violation was June 18, 2007 through September 16, 2010.

Finding: MRO determined that the violation posed a minimal risk to the bulk power system because Rochester Public Utilities’ (RPU) system operators had the ability to open all UFLS feeders via the SCADA system in the event any of the UFLS relays failed to work and RPU is relatively small. The NERC BOTCC also considered the following: MRO originally assessed a penalty for the violations but reduced it to $0 because RPU’s proposed mitigating actions went above and beyond those required to bring RPU into compliance (RPU’s above and beyond activities include the planned purchase of $68,340 in new testing equipment and training); RPU was cooperative throughout the investigation; RPU created a compliance committee in response to the findings; and there was no evidence RPU attempted to conceal the violations

Penalty: $0

FERC Order: Issued September 9, 2011 (no further review)

Salt River Project Agricultural Improvement and Power District, Docket No. NP10-74-000 (March 31, 2010)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: WECC

Issue: During an audit in January 2008, WECC discovered a possible violation of Reliability Standard PRC-008-0 R2 based on Salt River Project Agricultural Improvement and Power District's (SRP) failure to timely test and maintain one of its Under Frequency Load Shedding (UFLS) relays according to its UFLS equipment maintenance and testing program. Maintenance and testing for this one UFLS relay was conducted two and a half months behind schedule.

Finding: WECC and SRP entered into a settlement agreement to resolve all outstanding issues related to multiple alleged violations, whereby SRP neither admitted nor denied the alleged violations but agreed to pay a penalty of $10,000 and to undertake other mitigation measures. WECC found that the alleged violation of Reliability Standard PRC-008-0 R2 did not cause a serious or substantial risk to the bulk power system since only one of SRP's relays was non-compliant and this relay was tested and maintained only a few months outside of the defined intervals. Also, SRP still had ample UFLS capability (330 other relays), so a misoperation of one relay would not pose a threat to the bulk power system. In assessing the penalty, WECC considered the fact that the alleged violation was the first violation of the relevant Reliability Standard and that SRP was cooperative during the compliance process and did not attempt to conceal the alleged violation. SRP has successfully completed a mitigation plan for the alleged violation of the Reliability Standard PRC-008-0 R2.

Penalty: $10,000 (aggregate for multiple violations)

FERC Order: Issued April 30, 2010 (no further review)

Sharyland Utilities, LP, as successor in interest to Cap Rock Energy Corporation, FERC Docket No. NP11-84-000 (January 31, 2011)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: TRE

Issue: Cap Rock Energy Corporation (Cap Rock) self-certified that, as of the date it was included on the NERC Registry, June 19, 2009, it did not have a written Underfrequency Load Shedding (UFLS) equipment identification, maintenance and testing schedule in place as required by PRC-008-0 until August 28, 2009.

Finding: TRE determined the violation did not pose a serious or substantial risk to the reliability of the bulk power system. TRE and Sharyland Utilities, LP (Sharyland), as successor in interest to Cap Rock, entered into a settlement agreement whereby Sharyland neither admitted nor denied the violation, but agreed to a penalty of $2,500. In determining the penalty, the NERC Board of Trustees Compliance Committee (BOTCC) considered the following facts: the violation was Sharyland and Cap Rock's first occurrence of a violation of NERC Reliability Standards; Cap Rock cooperated during the compliance enforcement process; Cap Rock had an internal compliance program; and there was no evidence CPS attempted to conceal the violations.

Penalty: $2,500

FERC Order: Issued March 2, 2011 (no further review)

Sierra Pacific Power Company (SPPC), d/b/a, NV Energy, FERC Docket No. NP12-12 (January 31, 2012)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium

Violation Severity Level: Moderate

Region: WECC

Issue: As the result of an on-site audit, it was found that SPPC, as a TO and DP, did not include 5 of 16 battery stations supporting its Under Frequency Load Shedding (UFLS) Protection System in its UFLS maintenance and testing program (Program). All other components of the UFLS program were identified and addressed. (R1). Regarding R2, SPPC was found to have violated the Standard because it did not maintain or test one UFLS relay (out of 22) with specified intervals set forth in the Program.

Finding: The violations were found to constitute a minimal risk to BPS reliability because even though the station batteries were not identified in the UFLS program, they were maintained and tested as part of regular station battery maintenance and testing. SPPC had previously been audited and no violations of the UFLS maintenance and testing program were found during that audit. SPPC made no changes to its program in the intervening time period and SPPC relied on the previous audit’s results assuming it was in compliance with the Standard. (R1). Regarding R2, the violation involved only one of the SPPC UFLS protective devices and the device was tested six months after the required date. SPPC’s internal compliance program was considered a mitigating factor in determining the appropriate penalty amount.

Penalty: $16,400 (aggregate for four violations)

FERC Order: Order issued March 1, 2012 (no further review)

Southwestern Public Service Company, FERC Docket No. NP10-2-000 (October 14, 2009)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Not provided

Region: SPP

Issue: Southwestern Public Service Company self-reported that, due to a customer's request to delay a plant outage, one relay (out of the 15 specific UFLS relays identified for maintenance and testing in 2007) would not be able to be tested by the end of 2007 as required. As it would be able to schedule a plant outage without harming its customer during the first quarter of 2008, Southwestern Public Service Company agreed to test that one relay during that time.

Finding: Based on two UFLS surveys, SPP determined that this violation did not involve a serious or substantial risk to bulk power system reliability since Southwestern Public Service Company had more UFLS relay installations than was required (which were sufficient to meet load shed requirements) and therefore Southwestern Public Service Company would have been able to adequately respond to a system unfrequency event. This was also the first violation of this Reliability Standard by Southwestern Public Service Company and a mitigation plan has been completed.

Penalty: $0

FERC Order: Issued November 13, 2009 (no further review)

Sunflower Electric Power Corporation, Docket No. NP12-21, March 30, 2012

Reliability Standard: PRC-008-0

Requirement: 1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SPP

Issue: Following a self-report, SPP determined Sunflower Electric Power Corporation (“Sunflower”) violated R1 because its UFLS maintenance and testing program did not contain a list of all of its UFLS relays and did not include maintenance and testing schedules for 34 of its 74 unidentified UFLS relays.

Finding: SPP determined that the violation posed a minimal risk, but did not pose a serious or substantial risk, to the reliability of the BPS. Sunflower provided evidence that its UFLS relays would have responded appropriately in an under-frequency event and that it regularly maintained and tested 89% of its total UFLS load shedding capability. The duration of the violation was from June 18, 2007 to March 24, 2011.

Penalty: $135,000 (aggregate for 16 violations)

FERC Order: Order Issued April 30, 2012 (no further action)

Sunflower Electric Power Corporation (Sunflower) and Mid-Kansas Electric Company, LLC (Mid-Kansas), FERC Docket No. NP13-13 (December 31, 2012)

Reliability Standard: PRC-008-0

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: High

Region: SPP

Issue: Sunflower self-reported that it had not maintained and tested 51% of its UFLS equipment (156 out of 303 devices) according to the intervals in its UFLS maintenance and testing program.

Finding: SPP found that this violation constituted only a minimal risk to BPS reliability since Sunflower had tested all of its UFLS relays on May 12, 2007 or later. In addition 83% of Sunflower’s UFLS relays are microprocessor-based and are monitored through the SCADA system, which would sound an alarm if there were any issues with the relays. Even if there was load shed, a relay failure would only have an incremental impact on Sunflower’s total load shed at a particular frequency. The duration of the PRC-008-0 R2 violation was from June 18, 2007 through August 13, 2012. Sunflower and Mid-Kansas neither admitted nor denied the violations. In approving the settlement agreement, the NERC BOTCC considered the fact that some of the violations were self-reported and Sunflower’s compliance program (which was evaluated as a mitigating factor). Sunflower and Mid-Kansas were also cooperative during the compliance process and did not conceal the violations. Sunflower’s prior violations of TOP-002-2 R11 and TOP-004-1 R6 were viewed as an aggravating factor.

Total Penalty: $60,000 (aggregate for 6 violations)

FERC Order: Issued January 30, 2013 (no further review)

Tampa Electric Company, FERC Docket No. NP11-132-000 (February 28, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: FRCC

Issue: Tampa Electric Company (TEC) self-reported that it failed to test four of its 325 UnderFrequency Load Shedding relays within the time specified in its maintenance program. Duration of violation was January 10, 2009 (the day after the first test date was missed), through July 9, 2009 (the day testing was completed).

Finding: FRCC Enforcement determined that the violation did not pose a serious or substantial risk to the reliability of the bulk power system because TEC demonstrated that there had been no misoperations of the applicable relays and had tripped their respective circuits appropriately in 2008 and 2009 on 31 occasions. The NERC BOTCC concluded the penalty appropriate because this was TEC’s first violation of the Standard, TEC self-reported the violation, and TEC was cooperative during the investigation.

Penalty: $46,000 (aggregate for multiple violations)

FERC Order: Issued March 25, 2011 (no further review)

Tampa Electric Company (TEC), FERC Docket No. NP15-29-000 (May 28, 2015)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: FRCC

Issue: FRCC, through a compliance audit, found that approximately 30% of the relay tests documented in TEC's Underfrequency Load Shedding (UFLS) equipment and maintenance and testing program had not measured the underfrequency pickup set point or the time delay function.

Finding: FRCC found that this issue posed a moderate, but not a serious or substantial, risk to BPS reliability. The tests' failure to measure time delay and frequency set points may have led to uncoordinated relays, which, in turn, may have resulted in the inability to stop a declining frequency. However, all the relays that were not properly tested were digital relays which, over time, experience a drift in settings that is very small. Additionally, all relay tests were adequate for the three years prior to the compliance audit. To further mitigate this violation penalty, TEC (1) reviewed all UFLS test documents, (2) re-tested relays that had not been properly tested, and (3) trained relay technicians on NERC test requirements in PRC-008-0.

Penalty: $3,000 (aggregate for 2 violations)

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

Tex-La Electric Cooperative of Texas, Inc., FERC Docket No. NP11-27-000 (November 30, 2010)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: SPP

Issue: During a compliance audit of Tex-La Electric Cooperative of Texas, Inc. (Tex-La) in April 2009, SPP determined that Tex-La, as a Distribution Provider and Transmission Owner, did not possess a list of its Under-Frequency Load Shedding (UFLS) devices and a schedule for their relay maintenance and testing.

Finding: SPP and Tex-La entered into a settlement agreement to resolve all outstanding issues, whereby Tex-La agreed to pay a penalty of $5,000 and to undertake other mitigation measures to resolve multiple violations. SPP found that the violation of PRC-008-0 posed a minimal risk to bulk power system reliability since Tex-La was actually testing its UFLS relays within the defined intervals in its Protection Systems maintenance and testing program. The duration of the PRC-008-0 violation was from June 18, 2007 through November 6, 2009. In approving the settlement agreement, SPP considered the fact that this was Tex-La's first violation of PRC-008-0; other violations were self-reported; Tex-La was cooperative during the enforcement process and did not attempt to conceal the violations; and there were no additional mitigating or aggravating factors.

Penalty: $5,000 (aggregate for multiple violations)

FERC Order: Issued December 30, 2010 (no further review)

Tex-La Electric Cooperative of Texas, Inc., FERC Docket No. NP11-104-000 (February 1, 2011)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: Texas RE

Issue: Tex-La Electric Cooperative of Texas, Inc. (Tex-La) did not have a complete program identifying UFLS equipment nor did it have a schedule for the testing or maintenance of the relays. A blank schedule form was found in Tex-La's procedure but did not include any equipment identification or schedule dates. Texas RE conducted its audit of Tex-La together with the Southwest Power Pool (SPP) because Tex-La's equipment spans both regions. SPP found a concurrent violation of PRC-008-0 during the audit.

Finding: The violation posed a minimal risk to the reliability of the bulk power system because test reports existed which showed that the relays had been tested in 2008 even though the UFLS equipment identification and schedules were not documented. Tex-La had been the subject of a spot-check in November 2007 by Texas RE, during which it provided a maintenance and testing schedule. According to Tex-La, the maintenance and testing schedule had been mistakenly removed from its procedure in between the spot-check and the audit.

Penalty: $3,000

FERC Order: Issued March 3, 2011 (no further review)

The Detroit Edison Company, FERC Docket No. NP13-5 (October 31, 2012)

Reliability Standard: PRC-008-0

Requirement: 2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: RFC

Issue: In January 2011, the Detroit Edison Company (Detroit Edison), as a GO and DP, self-reported that it did not possess sufficient documentation showing that that it had conducted the required inspections, testing and maintenance in 2007 on 24% of the batteries in its automatic UFLS program according to the defined intervals. In addition, Detroit Edison also did not possess sufficient documentation showing that that it had conducted the required inspections, testing and maintenance in 2008 on 14% of the batteries in its automatic UFLS program according to the defined intervals.

Finding: Detroit Edison admitted the PRC-008-0 R2 violation. RFC found that the PRC-008-0 R2 violation constituted a moderate risk to BPS reliability since the UFLS maintenance and testing program is supposed to provide last resort system preservation measures. But, for six of the 16 batteries in 2007 and five of the nine batteries in 2008, it was determined that they were not actually part of the automatic UFLS program. And once tested, the remaining batteries were found to be in proper condition. Furthermore, Detroit Edison was able to manually shed, through its control center, an additional 5,733 MW of load at any frequency level. The PRC-008-0 R2 violation was from January 1, 2008 through December 30, 2009. RFC evaluated parts of Detroit Edison's compliance program as a mitigating factor. RFC also considered the fact that the violation was self-reported as a mitigating factor.

Penalty: $24,000 (aggregate for 6 violations)

FERC Order: Issued November 29, 2012 (no further review)

Town of Stantonsburg, FERC Docket No. NP11-266-000 (August 31, 2011)

Reliability Standard: PRC-008-0

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: SERC

Issue: Town of Stantonsburg (Stantonsburg) self-reported that it did not have an Under Frequency Load Shedding (UFLS) equipment maintenance and testing program in place, as required of a Distribution Provider with UFLS equipment.

Finding: SERC found that the violation did not constitute a serious or substantial risk to the bulk power system because Stantonsburg is a small utility of 6.1 MW with a small number of residential and commercial customers and no bulk power system (BPS) facilities; therefore, even if its equipment failed to respond as expected, it would have little impact on the BPS. In addition, Stantonsburg provided evidence that it was actually testing its UFLS equipment. Duration of violation was June 18, 2007 through January 19, 2011.

Penalty: $0

FERC Order: Issued September 30, 2011 (no further review)

Unidentified Registered Entity, FERC Docket No. NP12-11 (January 31, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: WECC

Issue: URE self-reported (as well as self-certified) that it had not been properly maintaining its UFLS equipment according to the defined intervals in its UFLS maintenance and testing program. One of URE’s UFLS relays was one day overdue for testing and another two relays were four days overdue for testing. In addition, URE reported that it did not document, as required, the UFLS maintenance and testing results for its potential transformers and DC control circuitry and that it had numerous problems with the maintenance and testing for its UFLS equipment batteries.

Finding: WECC found that the PRC-008-0 R2 violation constituted only a minimal risk to the BPS since URE has a variety of options to shed load automatically, as well as the ability to shed load manually if necessary. There is a low probability that multiple pieces of UFLS equipment would fail at the same time, and the failure of any one piece is unlikely to cause a significant impact on the BPS. In addition, URE employs NERC-certified operators, and URE’s SCADA system provides control and visibility over URE’s power system. In determining the penalty amount, the NERC BOTCC evaluated URE’s violation history; some of the violations were self-reported; URE was cooperative during the enforcement process and did not conceal the violations; URE has a compliance program in place (which was evaluated as a mitigating factor); the violations did not constitute a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.

Penalty: $135,000 (aggregate for 20 violations)

FERC Order: Issued March 1, 2012 (no further review)

Vermont Marble Power Division of Omya Inc (VMPD), FERC Docket No. NP10-173-000 (September 30, 2010)

Reliability Standard: PRC-008-0

Requirement: R1, R2

Violation Risk Factor: Medium (for R1, R2)

Violation Severity Level: Lower (for R1, R2)

Region: NPCC

Issue: In June 2009, Vermont Marble Power Division of Omya Inc (VMPD) self-certified that it did not have (and therefore did not implement) a maintenance and testing program in place for its Under Frequency Load Shedding (UFLS) system. VMPD mistakenly believed that its parent company had enacted a UFLS maintenance and testing program.

Finding: NPCC found that the violations of PRC-008-0 did not constitute a serious or substantial risk to the bulk power system since the UFLS equipment was actually tested on December 23, 2009 and the test results came back within the accepted specifications. VPMD also has a small load of only approximately 8 MW. The duration of the violations was from June 21, 2007 through December 23, 2009. NPCC reported that VMPD was not fully cooperative during the enforcement process for multiple violations (i.e., VMPD was late in responding to NPCC requests and produced some incorrect information). But, VMPD did have a compliance program in place and did not attempt to conceal any violations. Furthermore, the violations were VMPD’s first violations of the relevant Reliability Standard; some of the violations (including the violations of PRC-008-0) were self-certified; and there were no additional mitigating or aggravating factors present.

Penalty: $5,000 (aggregate for multiple violations)

FERC Order: Issued October 29, 2010 (no further review)

Western Area Power Administration – Upper Great Plains Region and Western Area Power Administration – Upper Great Plains East (WAPA-UGPR), FERC Docket No. NP14-33 (February 27, 2014)

Reliability Standard: PRC-008-0

Requirement: 1

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: MRO

Issue: During a WECC-MRO compliance audit, audit staff found that WAPA-UGPR did not include a schedule for maintenance and testing of microprocessor-based relays in its UFLS maintenance and testing program, as required.

Finding: MRO found that the PRC-008-0 R1 violation constituted only a minimal risk to BPS reliability since WAPA-UGPR had properly maintained and tested its microprocessor-based UFLS relays within the mandated 12-year interval (or the microprocessor-based UFLS relays were common to the microprocessor-relays addressed in another violation). The duration of the PRC-008-0 R1 violation was from June 18, 2007 through August 18, 2011. WAPA-UGPR admits the violations. In approving the settlement agreement, NERC BOTCC considered the fact that WAPA-UGPR engaged in above and beyond mitigation activities (such as training system operators, hiring additional compliance staff and replacing relays at a substation) and other actions to facilitate future compliance with the Reliability Standards. In addition, these were WAPA-UGPR’s first violations of the relevant Reliability Standards and WAPA-UGPR conducted a compliance assessment after the June 17, 2010 Eastern Montana-Western North Dakota Disturbance. WAPA-UGPR has a compliance program in place, which was evaluated as a mitigating factor. WAPA-UGPR was also cooperative during the enforcement process and did not conceal the violations. Certain of the violations constituted a serious or substantial risk to BPS reliability. In addition, although it lost multiple Bulk Electric System elements during the Eastern Montana-Western North Dakota Disturbance, it did not lose any generation or customer load as a result of the PRC-001-1 R2 violation.

Total Penalty: $0

FERC Order: Issued March 28, 2014 (no further review)

West Penn Power Company, Monongahela Power, and The Potomac Edison Company, FERC Docket No. NP12-7 (December 30, 2011)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: RFC

Issue: In November 2010, West Penn Power Company, Monongahela Power, and the Potomac Edison Company (WP/MP/PE), as a DP and TO, self-reported that it had not properly maintained and tested two of its UFLS relays (out of 236 total) according to its UFLS equipment maintenance and program. Though an oversight, WP/MP/PE did not enter these relays into its maintenance tracking system.

Finding: RFC found that the PRC-008-0 violation constituted a moderate risk to BPS reliability. But, the relevant relays trip 11.6 MW of load if the frequency drops below 59.0 Hz, while WP/MP/PE is able to shed 49 MW of load in excess of the UFLS program requirements. So, even if both relays failed, WP/MP/PE would still have been able to meet the load shedding requirements. Once the relays were tested, they were found to be in working condition (even though in need of a calibration adjustment). The duration of the PRC-008-0 violation was from January 1, 2010 through September 28, 2010. In determining the aggregate penalty amount, NERC BOTCC considered the fact that the violations were self-reported; WP/MP/PE was cooperative during the enforcement process and did not conceal the violations; WP/MP/PE had a compliance program in place (which was evaluated as a mitigating factor); the violations did not pose a serious or substantial risk to BPS reliability; and there were no additional aggravating or mitigating factors.

Penalty: $40,000 (aggregate for 2 violations)

FERC Order: Issued January 27, 2012 (no further review)

Wisconsin Public Service Corporation, FERC Docket No. NP11-17-000 (November 5, 2010)

Reliability Standard: PRC-008-0

Requirement: R2

Violation Risk Factor: Medium

Violation Severity Level: N/A

Region: MRO

Issue: During an on-site compliance audit, Wisconsin Public Service Corporation (WPS) notified MRO that it had not conducted specific gravity tests on 4 of its 147 station batteries.

Finding: The violation did not pose a serious or substantial risk to the reliability of the bulk power system because once WPS realized the specific gravity tests had not been conducted, it conducted the missing tests and all of the devices were fully operational at all times. In addition, WPS was cooperative, had an effective compliance program, and there was no evidence of an intention or attempt to conceal the violation, all of which were considered mitigating factors.

Penalty: $6,000 (aggregated for multiple violations)

FERC Order: Issued December 3, 2010 (no further review)