NERC FFT Reports: Reliability Standard PRC-005-1

 

Ameren Energy Generating Company (AEGC), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1.1; 1.2; 2.2

Region: RFC

Issue: RFC, in performing a Compliance Audit of AEGC for the period of July 11, 2011 to July 22, 2011, found that AEGC, as a GO, failed to comply with PRC-0050-1 R1 in that it failed to include maintenance and testing intervals for voltage and current sensing devices in its Protection System maintenance and testing program as mandated by PRC-005-1 R1.1. Despite AEGC's claim of continuous monitoring in its Protection System maintenance and testing program, RFC found that its monitoring did not qualify as an alternative to defined intervals of maintenance and testing because it did not check for all types of instrument transformer failures. AEGC also did not include a summary of maintenance and testing procedures for voltage and current sensing devices, as mandated by PRC-005-1 R1.2. Furthermore, AEGC did not document the dates for when the voltage and current sensing devices were last tested or maintained, violating PRC-005-1 R2.2.

Finding: RFC found that this issue posed a minimal risk to the reliability of the bulk power system since AEGC possesses a generally comprehensive maintenance and testing program, of which includes a partial continuous monitoring of instrument transformers with alarming, thermography, and commissioning testing, as well as a conducting of informal visual inspections of relays and instrument transformers. RFC also found the issue to be a minimal risk because AEGC did not cause any generating unit outage, equipment failure, or confirmation of any current and voltage sensing misoperation from July 11, 2011 to July 22, 2011.

Ameren Services Company (Ameren), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: PRC-005-1

Requirement: R2/2.1

Region: SERC

Issue: Ameren, in its role as a TO, submitted self-reports in February and May 2010 and in January 2011. In February 2010, Ameren submitted the first self-report stating that nine Protective Relays had not been tested pursuant to the intervals established in its Protection System maintenance and testing program. In May 2010, two more self-reports were submitted each reporting that maintenance on a station battery (two total) had not been undertaken. And, in January 2011, Ameren submitted a final self-report explaining that 31 Protective Relays had not been tested pursuant to intervals set forth in Ameren’s Protection System maintenance and testing program. SERC review found the later self-reports to be an extension of the February 2010 self-report as those reports involved the same issue of missed testing required under PRC-005-1. The total number of Protection System devices having missed the defined testing intervals or having no maintenance and testing records equalled 42 out of 11,582 (or about 0.36%).

Finding: The issued was deemed by SERC to pose minimal risk to BPS reliability as the 40 relays were tested and found to be functional and Ameren had backup protection provisions in the event of a relay failure. The two Station Batteries were also tested with no problems reported. The batteries were also alarmed to notify personnel to any failure and were less than 10 years old.

ANP Bellingham Energy Company (ANP Bellingham), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 2

Region: NPCC

Issue: ANP Bellingham, as a GO, self-report an issue with PRC-005-1 R2 to NPCC after determining that 2 of its 17 instrument transformers were missing test certificates from 2007, the previous defined testing four-year interval. ANP Bellingham also found that in the 2007 testing interval, no test certificates for relay functional checks had been provided by the contractor who performed the testing.

Finding: NPCC determined that the issue posed a minimal risk to the reliability of the BPS because the documentation issue did not change the fact that the affected relays had actually been tested and maintained within the defined interval.

Associated Electric Cooperative, Inc. (AECI), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R2

Region: SERC

Issue: AECI, a GO and TO, submitted a self-report detailing a violation of PRC-005-1 R2. AECI’s maintenance and testing program calls for six-year testing intervals on its voltage and current sensing devices; however, AECI was unable to provide testing data for those devices on two generating station units. AECI tested all 109 transmission substations at or above 100kV in order to have complete testing records for all elements of its Protection System. Subsequently, AECI also self-reported that it found one 161 kV substation relays had been trip tested outside of defined testing intervals and 44 days beyond the six-month grace period. SERC staff found ultimately that AECI tested 33 out of 9,807 (0.34%) Protection System devices outside of established intervals.

Finding: The issue was found to pose a minimal risk to BPS reliability because no required maintenance had been skipped such as replacing old parts and calibrating tasks and once the Protection System devices were later tested, no issues were found requiring attention. Also, one plant is small, with a total rating of 614 MW equalling 11.7% of total AECI capacity of 5,255 MW, and any failures as a result of missed testing would not likely have much impact on AECI or the BPS.

Big Rivers Electric Corporation, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R1

Region: SERC

Issue: During a spot check, SERC determined that Big Rivers Electric Corporation’s (BREC) Protection System maintenance and testing program did not include the bases for the maintenance and testing intervals for BREC’s associated communication systems, voltage and current sensing devices, and DC control circuitry.

Finding: SERC found that this issue constituted only a minimal risk to the BPS since all of the required maintenance and testing was being performed. There was only a gap in documentation from June 18, 2007 through June 30, 2008.

Borger Energy Associates, LP (Borger), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R2

Region: SPP RE

Issue: Borger, as a GO, self-reported an issue with PRC-005-1 R2 to SPP RE when it found that it had failed to test or maintain all of its Protection System devices within the defined intervals established in its Protection System maintenance and testing program (PSMTP). In particular, 2 of 70 instrument transformers had not been tested during a 2010 testing of the GO’s substation Protection System devices.

Finding: SPP RE determined that the issue posed a minimal risk to the reliability of the BPS because the relays associated with the two instrument transformers at issue are equipped with alarms and are monitored continuously by Borger operators. No alarms were recorded for these instrument transformers during the issue, and the devices passed the maintenance and testing performed on them without any problems. In addition, Border has a total plant capacity of 230 MW, which further reduces risk to the BPS.

Calumet Energy Team, LLC (Calumet), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: RFC

Issue: During RFC's Compliance Audit of Calumet for the period from July 11, 2011 to July 22, 20111, RFC found that Calumet, as a GO, failed to show RFC documentation indicating that voltage and current sensing devices, direct current (DC) control circuitry, and protective relay devices were tested and maintained within defined intervals, as dictated by PRC-005-1 R2.1. In particular, Calumet did not show documentation suggesting testing of voltage and current sensing devices. Furthermore, it did not give any previous records of test for DC control circuitry or a record of test for a single protective relay.

Finding: RFC found this issue to be a minimal risk to the reliability of the bulk power system because despite the fact that Calumet did not maintain documentation for some devices, it still conducted scheduled testing and maintenance for protective relays and voltage and current sensing devices. Furthermore, though Calumet did not have testing on DC control circuitry before 2010, it affirmed that trip circuits during normal unit shutdowns were continuous and functional.

Cambria CoGen Company (CCC), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: ReliabilityFirst

Issue: As a result of a compliance audit conducted between January 23 and February 3, 2012, ReliabilityFirst determined that CCC, as a GO, violated PRC-005-1 for three reasons. First, CCC’s Protection System maintenance and testing Program (Program) did not include maintenance and testing intervals for its current and voltage sensing devices, DC control circuitry or station batteries. Second, CCC failed to establish a basis for the maintenance and testing intervals of its relays. Third, CCC did not have a summary of maintenance and testing procedures in its Program for any Protection System devices.

Finding: ReliabilityFirst determined this issue posed only a minimal risk to the reliability of the BPS for two reasons. First, during the duration of the issue, although CCC did not properly document its testing and maintenance practices, it did correctly maintain and test its voltage sensing devices, DC control circuitry and station batteries. CCC, through an outside firm, relied on the 2001 International Electrical Testing Association Maintenance Testing Specifications manual to test and maintain its Protection System devices, but did not set forth the related tests, intervals and bases for those intervals in its own Program. Second, during the compliance audit, CCC provided ReliabilityFirst with maintenance and testing records demonstrating that all of its Protection System devices were properly maintained while the issue was ongoing.

CenterPoint Energy Houston Electric, LLC (CenterPoint), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: TRE

Issue: CenterPoint found that, as a TO and a DP, it had not entirely maintained Protection System Devices – particularly, 100 station batteries, equalling 0.5% of CenterPoint’s total Protection System devices – pursuant to its Protection System and Under Frequency Load Shedding maintenance and testing programs. In October 2011, CenterPoint submitted a self-report describing that it had not completed two of six required maintenance procedures on the 100 station batteries. A CenterPoint crew leader reviewing the results of a September 21, 2011 report found that the crews responsible for battery system testing at a 345 kV switching station and a 345/138 kV station were using historical maintenance procedures that did not included all of the testing required by updated, CIP-compliant maintenance and testing programs. First, battery inter-cell connection resistance and internal cell impedance testing was not undertaken. And, second, specific gravity testing had also been missed. CenterPoint performed a comprehensive review of all station battery testing and found only the subject batteries had missed these two tests. The duration of the violation was determined to be June 18, 2009 through October 7, 2011 when the issue was mitigated.

Finding: The issue was deemed by TRE to pose minimal risk to BPS reliability because of the small number of overall station batteries involved and because the station batteries were found to be performing correctly and also had been consistently checked on during the relevant time period. All other required maintenance tasks had been performed pursuant to defined intervals.

CER - Colorado Bend Energy Partners LP (CBEC), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R1; R1.1; R1.2; R2; R2.1; R2.2

Region: TRE

Issue: Further to a Spot Check, TRE found that CBEC, as a GO, had an issue with PRC-005-1 R1.1 and R1.2, as well as R2.1 and R2.2. Regarding R1.1 and R1.2, the GO’s initial version of its documented generation Protection System maintenance and testing program failed to include maintenance and testing intervals and their basis or a summary of maintenance and testing procedures, and the subsequent versions included maintenance and testing intervals that either did not have a documented basis or were not consistent with the documented basis. Regarding R2.1 and R2.2, for 22 out of 54 devices (involving relays and current transformers), the GO was either missing certain maintenance and test records or reflected exceeded required intervals.

Finding: TRE determined that the issue posed a minimal risk to the reliability of the BPS. Regarding R1, the deficiency with the initial maintenance and testing program lasted only three months, and the issue that followed was of a limited nature. Regarding R2, four factors mitigated the risk to the reliability of the BPS: (1) it was very likely that the subject equipment was maintained and tested during the commissioning of the plant in 2007; (2) the final intervals were much more conservative than the intervals recommended by NERC; (3) the relays and current transformers were continuously monitored, allowing the GO to be alerted to any equipment issue if it had occurred; and (4) the GO had backup relaying in place in the event of primary systems failure.

CER - Quail Run Energy Partners LP (QREC), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R1; R1.1; R1.2; R2; R2.1; R2.2

Region: TRE

Issue: Further to a Spot Check, TRE found that QREC, as a GO, had an issue with PRC-005-1 R1.1 and R1.2, as well as R2.1 and R2.2. Regarding R1.1 and R1.2, the GO’s initial version of its documented generation Protection System maintenance and testing program failed to include maintenance and testing intervals and their basis or a summary of maintenance and testing procedures, and the subsequent versions included maintenance and testing intervals that either did not have a documented basis or were not consistent with the documented basis. Regarding R2.1 and R2.2, for 9 out of 58 devices (involving relays and current transformers), the GO was either missing certain maintenance and test records or reflected exceeded required intervals.

Finding: TRE determined that the issue posed a minimal risk to the reliability of the BPS. Regarding R1, the deficiency with the initial maintenance and testing program lasted only three months, and the issue that followed was of a limited nature. Regarding R2, four factors mitigated the risk to the reliability of the BPS: (1) it was very likely that the subject equipment was maintained and tested during the commissioning of the plant in 2007; (2) the final intervals were much more conservative than the intervals recommended by NERC; (3) the relays and current transformers were continuously monitored, allowing the GO to be alerted to any equipment issue if it had occurred; and (4) the GO had backup relaying in place in the event of primary systems failure.

Chambers Cogeneration, LP (CCLP), Docket No. RC13-6-000 (February 28, 2013)

Reliability Standard: PRC-005-1

Requirement: 1/1.1

Region: RFC

Issue: CCLP, a GO, submitted a self-report in November 2012 stating that while conducting a compliance review it found its Protection System maintenance and testing (M&T) program called for periodic M&T of instrument transformers at plant commissioning or upon suspected problems; however, CCLP determined that its method for M&T of instrument transformers would not correctly address risk and possibly would not be compliant with PRC-005-1.

Finding: The issue was deemed to pose minimal risk to BPS reliability which was mitigated because CCLP had performed testing on the instrument transformers when the plant was commissioned in 1993. The manufacturer's recommendations did not call for periodic testing of the devices. In addition, CCLP's Protection System employs many instrument transformers which would protect the system from any single failure. CCLP conducted M&T of the devices, and they were found to be operational and performing as required.

City of Austin dba Austin Energy (AE), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R1; R1.1; R1.2; R2; R2.1; R2.2

Region: TRE

Issue: AE, as a GO, self-reported to TRE that it had issues with PRC-005-1 R1.1 and R1.2, as well as R2.1 and R2.2. Regarding R1.1 and R1.2, the GO had not clearly defined maintenance and testing intervals and their basis for its voltage or current sensing devices, DC control circuitry, and battery testing in its maintenance and testing program, involving 94 out of 333 devices. Regarding R2.1 and R2.2, the GO could not provide evidence that all of its Protection System devices were maintained and tested within the defined intervals, and AE failed to include the date these systems were last tested and maintained.

Finding: TRE determined that the issue posed a minimal risk to the reliability of the BPS because AE asserted that it completed its testing, but merely failed to document the evidence, and further attested that the facilities at issue are continuously staffed such that any operational issues would have been immediately detected an addressed. Furthermore, there had been no generating unit outage, equipment failure, or confirmation of any current and voltage sensing misoperation during the issue period.

City of Gardner (Gardner), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: PRC-005-1

Requirement: R1, R2

Region: SPP

Issue: While conducting a Compliance Audit in June 2011, SPP found that Gardner, in its role as a DP and TO, was not in compliance with PRC-005-1 R1 requirements in that Gardner had no Protection System maintenance and testing program for Protection Systems that could affect BPS reliability. The violation period was determined to be December 20, 2007 until January 1, 2010. Regarding the violation of R2, Gardner was unable to show that Potential Transformers (PT) or Current Transformers (CT) had been properly maintained and tested according to established intervals during 2008 or 2009 nor that Station Batteries were maintained and tested before June 2011. The violation involved 54 out of 86 devices, or 63% of total Protection System devices. This violation period was December 20, 2007 until June 2011 when battery testing was undertaken.

Finding: The violations were deemed by SPP to pose minimal risk to BPS reliability which was mitigated for several reasons. (1) The facility is a 161kV substation having two interconnections to the TOP and several relays housed in a nearby substation that is owned and maintained by the TOP. (2) Gardner was able to show that Protection System devices were being maintained despite lacking a documented maintenance and testing program. (3) Gardner’s system is set up such that any PT or CT failures occurring during the relevant time period would be found during other relay testing activities. (4) Gardner was able to provide results of impedance testing on its batteries that took place within set intervals.

City of Springfield, IL – CWLP (CWLP), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1; 1.1; 1.2; 2; 2.1; 2.2

Region: SERC

Issue: CWLP, as a GO, self-reported a violation of R1 of PRC-005-1 to SERC on February 9, 2012, after having found that its Protection System maintenance and testing program failed to contain maintenance and testing intervals and a maintenance and testing procedure summary for its Dallman Unit 4 generator battery, which started commercial operation in November 2009. CWLP also self-reported a violation of R2 of PRC-005-1, in that it didn't possess documentation showing that it maintained and tested one generator battery system at defined intervals and that it didn't record the date in which the battery was last tested and maintained. SERC confirmed CWLP's self-report that CWLP's Protection System maintenance and testing program failed to contain maintenance and testing intervals and a maintenance and testing procedure summary for Dallman Unit 4 generator battery. SERC, after analyzing CWLP's spreadsheets showing its Protection System devices and the maintenance and testing intervals, determined that CWLP failed to provide records for maintenance or testing for 0.1% of its Protection System devices.

Finding: SERC found that the issue posed a minimal risk to the reliability of the bulk power system because despite the exclusion of Dallman Unit 4 battery system in the Protection System maintenance and testing procedure, CWLP did maintain and test the Unit 4 battery system in the same ways it did its Unit 3 battery system, which involved monthly and semi-annual testing, and because after February 9, 2012, CWLP included the Unit 4 battery system in the Protection System maintenance and testing procedure, and tested it with appropriate procedures, with no issues found. SERC further found that CWLP possessed local and control room alarms on its battery systems for alarming CWLP staff in case of an issue.

Cottonwood Energy Company LP (Cottonwood), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 2

Region: SERC

Issue: Cottonwood, as a GO, self-reported an issue with PRC-005-1 R2 to SERC after discovering that it could not provide certain test documentation for 5 current transformers, 1 relay test date, and 5 missed communication system tests for 2 devices. After an evaluation, SERC determined that Cottonwood tested the following devices outside of the defined intervals: 1 out of 62 protective relays (1.61%), 2 out of 2 associated communication system (ACS) devices (100%), 5 out of 404 voltage and current sensing devices (1.23%), and 1 out of 62 DC control devices (1.61%).

Finding: SERC determined that the issue posed a minimal risk to the reliability of the BPS because Cottonwood continuously monitors the communication channels of the ACS devices and if communications are lost (e.g., if there is a relay failure or trip), an alarm in the control room will sound, triggering an investigation. In addition, subsequent testing of the Protection System devices at issue revealed that all such devices were fully functional with no issues.

Covanta Pasco Inc. (COVPA), Docket No. RC13-7-000 (March 27, 2013)

Reliability Standard: PRC-005-1

Requirement: 1/1.2; 2

Region: FRCC

Issue: While conducting a compliance audit in April 2012, FRCC found, first, that the generation Protection System maintenance and testing (M&T) program in use by COVPA, a registered GO, did not have a summary of M&T procedures for associated communication systems. COVPA owns one pilot wire relay which requires it to comply with PRC-005-1 R1. Second, FRCC compliance auditors found that COVPA could not show that the pilot wire relay had been tested before November 8, 2011, meaning COVPA did not have all documentation required by R2.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk. Regarding R1, if an alarm from the relay in the relay panel had tripped, operators would have seen it during their daily rounds. And, in 2008 and 2010, the pilot wire relay was used and was working as expected. Also, COVPA is a small generator accounting for less than 1% of generation in its region. Regarding R2, only the pilot wire relay had not been tested. All other relays were tested as required and no issues were discovered.

Craven County Wood Energy Limited Partnership (Craven), Docket No. RC13-8, April 30, 2013

Reliability Standard: PRC-005-1

Requirement: 2

Region: SERC

Issue: Craven filed a self-report in December 2012 stating that it had not conducted relay functional testing for its DC control circuitry devices in accordance with established intervals, as required of GOs, during 2009 and 2011. Craven reported that a miscommunication regarding what defines “DC control circuitry” left staff assuming only communications circuitry was included, and therefore no relay functional testing had been performed.

Finding: The violation was deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because even though Craven had not tested the DC control circuitry during the defined time frame, the associated relays had been maintained within the established interval. Subsequent testing discovered no misoperations. Although Craven had a previous violation of this Reliability Standard, SERC found the different circumstances warranted this violation FFT treatment.

Duquesne Light Company, Docket No. RC12-10 (March 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R2

Region: RFC

Issue: During a compliance audit conducted during October 2011, RFC found that Duquesne, as a DP and TO, had no evidence that current transformers (CTs), potential transformers (PTs), DC control circuitry and associated communication systems had been maintained or tested, although Duquesne was able to show its relays had been tested. Previously used procedures did cover testing and maintenance for the relevant equipment; however, the steps to complete that testing were not documented in the maintenance and testing program in use during the time period. Subsequently, Duquesne revised its work order forms to include a checklist of steps required for complete testing satisfying the documentation requirements of the Standard.

Finding: RFC found the violation constituted a minimal risk to BPS reliability which was mitigated by the following facts. First, Duquesne was performing the required maintenance and testing, but its documentation was lacking; and second, equipment problems are detected through voltage alarms and SCADA system tools. During the violation period, four alarms went off each time creating an automatic work order to investigate the problem conditions. And, SCADA system tools also detected one CT problem. Duquesne properly resolved all five issues.

Eagle Point Power Generation, LLC (Eagle Point), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R1

Region: RFC

Issue: Eagle Point, as a GO, self-reported an issue with PRC-005-1 R1 to RFC when it found that its Protection System maintenance and testing program failed to include maintenance and testing intervals and their basis for voltage and current sensing devices and direct current control circuitry.

Finding: RFC determined that the issue posed a minimal risk to the reliability of the BPS because the GO is interconnected by two separate and completely redundant 230 kV feeds from the same interconnection location, and also has a backup battery system in the event of a failure. The GO also has an alarm system that would alert to any failures. Finally, prior to a transfer of ownership in May 2012, to the best of Eagle Point’s knowledge, maintenance and testing on all relays was performed within their defined maintenance and testing intervals.

Electric Energy, Inc. (EEI), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: SERC

Issue: EEI, in its role as a GO, submitted a self-report stating that it did not have evidence that all relays were maintained and tested within the defined intervals of its Protection System maintenance and testing program. Specifically, EEI tested 16 out of 176 protective relays (9.1%) and five out of six batteries (83.3%) outside of their defined intervals. In total, EEI tested 21 out of 556 Protection System devices (3.8%) outside of their defined intervals.

Finding: SERC determined that the issue posed a minimal risk to BPS reliability because EEI's batteries are alarmed with direct current (DC) ground, loss of power, and voltage alarms, which would alert EEI personnel to possible problems and prompt them to investigate; even though EEI conducted the five-year battery load test three to six years outside of the defined interval, it still tested and maintained the batteries according to the monthly, quarterly and annual requirements; and although the relays were tested two to five years late, EEI's subsequent testing of the relays was successful and found no problems, suggesting that the relays likely would have performed as intended if called upon to do so.

Equistar Chemical, LP (Equistar), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R1; R2

Region: TRE

Issue: Further to a Compliance Audit, TRE determined that Equistar, as a GO, had an issue with PRC-005-1 R1 and R2. Regarding R1, the GO did not have maintenance and testing intervals and their basis for DC circuits and communications, and also could not provide a basis for adjusting the intervals for its relay maintenance and testing. Regarding R2, TRE found that the GO had missed at least one maintenance and/or test for all of its Protection System devices except for Potential Transformers (PT) and Current Transformers (CTs).

Finding: TRE determined that the issue posed a minimal risk to the reliability of the BPS because: (1) the plant has a nameplate rating of 45 MW, the chemical plant uses half of that capacity, and the cogen plant typically exports less than 10 MW to the Electric Reliability Council of Texas’s market; (2) the GO only exported more than 20 MW during the unusually cold weather period in February 2011; (3) the GO has policy of performing maintenance on all the cogen devices during the chemical plant outages every two years, which is a short time frame as compared to industry standards; (4) the GO has one communications circuit to a TO substation it ties to 0.9 miles from the plant; and (5) this TO substation tied to the GO would have isolated any issue that might have arisen due to missed Protection System device maintenance and testing.

Exelon Wind 4, LLC (Exelon), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: SPP

Issue: SPP found that Exelon violated R2 of PRC-005-1 during a June 25, 2012 audit. Exelon, as a GO, failed to give documentation that it performed annual testing on one battery bank in 2010 and failed to give documentation of monthly battery inspections from October 31, 2007 to June 25, 2012.

Finding: SPP found that the issue posed a minimal risk to the reliability of the bulk power system, for Exelon, a 79.8 MW wind facility, is a non-firm power vendor. Exelon showed that with the exception of its battery bank, all its PRC-005 devices were tested and maintained as stipulated by its Protection System maintenance and testing program. The failure to perform annual testing on one battery bank was an isolated incident. Also, the battery bank is monitored and has alarms to signal inspection personnel in case of voltage issues. Despite the lack of documentation showing monthly battery inspections, Exelon was able to show that its staff did perform monthly inspections of the facilities in which the battery bank was found.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1

Region: SPP

Issue: During a compliance audit, SPP found that FFT Entity’s relay maintenance and testing procedures did not include testing intervals, and their bases, for the current transformers and potential transformers, and the associated communication system. The relay maintenance and testing procedures also did not address the basis for the battery testing intervals.

Finding: SPP found that this issue constituted a minimal risk to BPS reliability since FFT Entity was actually testing these protection system devices through its SCADA system. In addition, FFT Entity was routinely inspecting its substations, which included checks of the Protection System devices.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1, R2

Region: FRCC

Issue: FFT Entity self-reported that it did not possess sufficient documentation showing that its generation Protection System maintenance and testing program included the maintenance and testing intervals and the bases and a summary of the maintenance and testing procedures for the protective relays, associated communication systems, DC control circuitry, voltage and current sensing devices and station batteries (R1). FFT Entity also self-certified that it did not possess adequate documentation showing that it had conducted preventative maintenance, as specified in its preventative maintenance program, on one of its current transformers and one of its potential transformers. This affected 51 (out of 159) of FFT Entity’s Protection System devices (R2).

Finding: FRCC found that these issues constituted only a minimal risk to BPS reliability. The violation of PRC-005-1 R1 was first self-reported before June 18, 2007, but FRCC required additional mitigation measures after the Reliability Standard came into force. In terms of PRC-005-1 R2, the output from the current transformers and the potential transformers would have alerted the control room if there were any problems. In addition, FFT Entity is a small generating facility.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1, R2 (2 violations)

Region: FRCC

Issue: During a spot check, FRCC found that FFT Entity did not possess sufficient documentation, as part of its Protection System maintenance and testing program, on the bases for its intervals for its associated communication systems, voltage and current sensing devices, and DC control circuitry and for the intervals for its voltage and current sensing devices (R1). FRCC also determined that FFT Entity was 12 days late, as a result of broken test equipment, in its quarterly battery testing for one of its transmission substations (R2). FFT Entity was also late in its annual load testing for one of its power plant’s battery banks (which represented one out of 251 Protection System devices) (R2).

Finding: FRCC found that these issues constituted only a minimal risk to BPS reliability. In regards to the R1 violation, FFT Entity was operating and testing its equipment according to the manufacturer’s recommendations. In regards to the R2 violations, FFT Entity satisfied its other testing intervals and the missed intervals were for relatively short periods.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1.1, R1.2, R2.1

Region: MRO

Issue: As the result of a self-report, MRO determined FFT Entity was in violation of R1 because previous versions of its generation protection system maintenance and testing programs failed to include a documented summary of M&T procedures and M&T documents failed to include M&T intervals and their basis on voltage and current sensing device equipment at two of its seven generating plants. MRO determined FFT Entity was in violation of R2 because it did not have evidence that all required Protection System devices had been maintained and tested per its Protection System maintenance and testing procedure.

Finding: MRO found that this issue constituted only a minimal risk to bulk power system reliability because the FFT Entity maintained and tested most of its protection system devices within defined intervals, and of the 2.2% of devices that were not tested within FFT Entity’s defined intervals, over half were tested within intervals set forth in the NERC Protection System Maintenance Technical Reference Guide recommended intervals.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1.1/1.2, R2.1

Region: MRO

Issue: FFT Entity self-reported that a previous version of its transmission Protection System maintenance and testing program did not properly incorporate the intervals, bases, and a summary of the maintenance and testing procedures for its station batteries, current and voltage sensing devices, DC control circuitry, and associated communication devices (R1.1/1.2). FFT Entity also self-reported that it did not have the required maintenance and testing records for 74 DC control circuits, 5 potential transformers, 14 current transformers, and 2 capacitance coupled voltage transformers (representing 63% of FFT Entity’s Protection System devices) (R2.1).

Finding: MRO found that these issues constituted only a minimal risk to BPS reliability. FFT Entity actually had a Protection System maintenance and testing program in place when it filed its self-report. FFT Entity had been properly testing its protective relays, continuously monitoring the DC control circuitry to the circuit breakers through the SCADA system, and conducting visual inspections on its exposed current transformers. Any problem with the associated communication devices or the DC control circuitry would have been found in near real time. In addition, FFT Entity does not have any internal generation and imported all of its power.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1.1/1.2, R2.1/2.2

Region: MRO

Issue: During a compliance audit, MRO found that FFT Entity’s Protection System maintenance and testing program did not incorporate the maintenance and testing intervals, and their bases, or other test schedules for its current and voltage sensing devices (R1.1/1.2). In addition, FFT Entity self-reported that it had not followed the testing intervals in its Protection System maintenance and testing program for its station battery voltage measurements (R2.1/2.2).

Finding: MRO found that the issues constituted only a minimal risk to BPS reliability. In terms of the R1.1/1.2 issue, FFT Entity was monitoring its current and voltage sensing devices through its SCADA. In terms of the R2.1/2.2 issue, MRO found that it did not constitute a serious or substantial risk to BPS reliability as FFT Entity had conducted the required maintenance and testing, according to its defined intervals, for 98.5% of its Protection System devices. In addition, FFT Entity satisfied the IEEE Standards for measuring individual cell voltage for 68% of its station batteries. FFT Entity also was continuously monitoring its station battery voltage via a plant control room and there were no relevant batter system trouble alarms.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R2.1

Region: MRO

Issue: As the result of a self-report, MRO determined FFT Entity failed to maintain evidence of testing records for 8 current transformers and 1 potential transformer.

Finding: MRO found the violation did not pose a serious or substation risk to the reliability of the BPS because the devices are associated with transformers that step the voltage down from the BPS to the sub-transmission level and had back-up protection. In addition, all the relays were tested and performed satisfactorily.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R2.1

Region: RFC

Issue: As the result of a self-report, RFC determined FFT Entity failed to perform required maintenance and testing in one quarterly interval for seven battery banks. The maintenance and testing occurred 10 to 17 days after the defined quarterly interval.

Finding: RFC found the violation posed a minimal risk to the reliability of the BPS because: the violation was short in duration; the FFT Entity’s M&T program is more stringent than IEEE Standard 450 recommendations; the battery banks were in good condition; all monthly battery testing was conducted in time; and the battery banks have alarms that would have been triggered by any abnormal conditions.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R2.1/2.2

Region: MRO

Issue: During a compliance audit, MRO found that FFT Entity did not possess adequate documentation showing that it had been conducting maintenance and testing according to the defined intervals in its transmission Protection System maintenance and testing program for its station batteries (representing 14% of FFT Entity’s Protection System devices).

Finding: MRO found that this issue constituted only a minimal risk to BPS reliability since FFT Entity was actually conducting more rigorous testing (on a weekly basis) than was required by the NERC Guide (which calls for monthly tests).

Find, Fix and Track Entity, FERC Docket No. RC12-1 (October 31, 2011)

Reliability Standard: PRC-005-1

Requirement: R2

Region: FRCC

Issue: FFT Entity self-reported that it had misclassified one of its relays (as a microprocessor type relay instead of as a solid state based relay) and therefore did not properly test that relay in the proper interval according to its Protection System maintenance and testing program.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since the relevant relay (one out of 698 Protection System devices) only protected a single transmission capacitor bank at one substation. In addition, the relay functioned properly during a fault which caused the capacitor bank to be taken out of service. No other relays were misclassified.

Find, Fix, Track and Report, Docket No. RC12-2 (November 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1

Region: RFC

Issue: During a compliance audit, RFC determined that FFT Entity did not provide the basis for maintenance and testing intervals for protective relays, voltage and current sensing devices, DC control circuitry, and associated communication systems for 15 of 16 Protection System devices in its Protection System maintenance and testing program (Program). FFT Entity did include maintenance and testing intervals for these devices in its Program, but did not define the basis for those maintenance and testing intervals, as required by PRC-005-1 R1.1.

Finding: RFC determined that the issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS which was mitigated by the fact that although FFT Entity failed to document a basis for the maintenance and testing intervals in its Program, it did include maintenance and testing intervals in its Program. Moreover, FFT Entity completed all maintenance and testing within the maintenance and testing intervals of its Program except for certain transmission relays, as noted in a separate enforcement action.

Find, Fix, Track and Report, Docket No. RC12-2 (November 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1, R.1.1, R1.2

Region: MRO

Issue: FFT Entity self-reported that its transmission Protection System maintenance and testing program did not include a basis for maintenance and testing intervals for voltage and current sensing devices, station batteries and DC control circuitry, and also failed to include a summary of its maintenance and testing procedures as required by PRC-005-1 R1.1 and R1.2.

Finding: The issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because FFT Entity had performed the maintenance and testing for 93.5% of its Protection System devices within its defined maintenance and testing intervals.

Find, Fix, Track and Report, Docket No. RC12-2 (November 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R2

Region: SERC

Issue: FFT Entity self-reported that nine batteries at its generation facilities were not being tested in accordance with the defined intervals of its Protection System maintenance and testing program.

Finding: SERC staff determined that the issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because the station batteries and the relays are constantly monitored as part of FFT Entity’s system which would have indicated potential problems with these devices.

Find, Fix, Track and Report, Docket No. RC12-2 (November 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R2, R.2.1, R2.2

Region: MRO

Issue: FFT Entity self-reported that it had not tested 7 protective relays, 7 station batteries and 42 DC control circuits in accordance with its transmission Protection System maintenance and testing program and in compliance with PRC-005-1 R2.

Finding: The issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because the relevant relays were being continuously monitored via FFT Entity’s SCADA system.

Find, Fix and Track Entity, Docket No. RC12-6 (December 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R1/1.1

Region: ReliabilityFirst

Issue: During a compliance audit, FFT Entity was found to be in violation of the Standard because it did not state the basis applying to every Protection System device it its Protection System maintenance and testing program.

Finding: ReliabilityFirst found the issue constituted a minimal risk to BPS reliability because FFT Entity did follow its Protection System maintenance and testing program for all of its 105 Protection System devices however, it did not include a specific designation as to which basis applies to which Protection System device. Also, the SCADA system has visual alarms which alert operators if a substation circuit breaker is activated. FFT Entity also has backup and redundant protection for its relays.

Find, Fix and Track Entity, FERC Docket No. RC12-6 (December 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R2/2.1/2.2

Region: FRCC

Issue: FFT Entity self-reported that upon completion of a 230 kV primary line relay replacement, one it its employee misinterpreted test results documentation which created incorrect due dates (four years from the replacement date) for testing and maintenance of all relays (with the exception of the newly replaced relay) of both primary and back up relay groups. To fix the problem, the back up relay group was maintained three months past the required maintenance due date and the primary groups were maintained approximately one year and three months later.

Finding: FRCC found the issue posed a minimal and not serious or substantial risk to the BPS since FFT Entity’s primary and backup relay group was tested correctly (within the entity's PRC-005 program requirements) and was operational. Also, no misoperations were found for this line during the time of the missed testing and testing was only 98 days out of time.

Find, Fix and Track Entity, Docket No. RC12-6 (December 30, 2011)

Reliability Standard: PRC-005-1

Requirement: R2/2.1/2.2

Region: MRO

Issue: FFT Entity did not have maintenance and testing records for 8.6% of 300 Protection System devices to show that they were tested or maintained as required by the Standard.

Finding: MRO found the issue constituted a minimal risk to BPS reliability because some of the relevant devices are watched periodically or continuously through FFT Entity’s SCADA system and those devices not having the proper records were tested and had no issues regarding performance. Also, FFT Entity did have evidence of maintenance and testing records for 91% of its Protection System devices.

Find, Fix and Track Entity, FERC Docket No. RC12-8 (February 29, 2012)

Reliability Standard: PRC-005-1

Requirement: R1.1

Region: TRE

Issue: FFT Entity self-reported that it did not have sufficient bases for its test intervals in its Protection System maintenance and testing program for its relays, batteries, instrument transformers and DC control circuitry.

Finding: TRE found that the issue constituted only a minimal risk to the BPS since this was primarily a documentation issue. FFT Entity conducted its Protection System maintenance and testing according to intervals that were the same or shorter than specified by NERC.

First Wind O&M LLC (First Wind), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R1, R2

Region: NPCC

Issue: First Wind self-reported that it had no Protection System maintenance and testing program established for two generating assets in violation of R1. As such, First Wind also self-reported that testing at the two substations had not been undertaken pursuant to established intervals, as required by R2. First Wind missed two six-month testing intervals prior to the date testing was eventually performed.

Finding: The issue was found to pose a minimal risk to BPS reliability because First Wind had an established maintenance and testing program that was in place 18 days after First Wind registered as a GO; however, it did not include those two assets. Also, one of the substations was not in commercial operation at the time the program was established and both substations’ Protection Systems were tested during commissioning. When First Wind became aware of the issue, it conducted the testing as required. NPCC noted that First Wind has a maintenance and testing program in which testing intervals exceed NERC requirements.

Fowler Ridge Wind Farm LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R1

Region: RFC

Issue: During a compliance audit, RFC found that Fowler Ridge Wind Farm LLC (“Fowler Ridge”), as a GO, did not include in its Protection System maintenance and testing program its power line carrier communication device (which represented 1.85% of its Protection System devices).

Finding: RFC found that this issue constituted only a minimal risk to the BPS. The communication device is continuously monitored and an alarm would be triggered if the system detected a communications error or other improper operation. The alarm is connected to a Remote Operations Center that deals with real-time emergency situations. In addition, the communication device was tested in October 2008 when the plant was commissioned.

Fowler Ridge Wind II Farm LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R1

Region: RFC

Issue: During a compliance audit, RFC found that Fowler Ridge II Wind Farm LLC (“Fowler Ridge II”), as a GO, did not include in its Protection System maintenance and testing program its power line carrier communication device (which represented 1.85% of its Protection System devices).

Finding: RFC found that this issue constituted only a minimal risk to the BPS. The communication device is continuously monitored and an alarm would be triggered if the system detected a communications error or other improper operation. The alarm is connected to a Remote Operations Center that deals with real-time emergency situations. In addition, the communication device was tested in October 2008 when the plant was commissioned.

Fowler Ridge Wind III Farm LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R1

Region: RFC

Issue: During a compliance audit, RFC found that Fowler Ridge III Wind Farm LLC (“Fowler Ridge III”), as a GO, did not include in its Protection System maintenance and testing program its power line carrier communication device (which represented 1.85% of its Protection System devices).

Finding: RFC found that this issue constituted only a minimal risk to the BPS. The communication device is continuously monitored and an alarm would be triggered if the system detected a communications error or other improper operation. The alarm is connected to a Remote Operations Center that deals with real-time emergency situations. In addition, the communication device was tested in October 2008 when the plant was commissioned.

Gainesville Regional Utilities (GRU), Docket No. RC12-16-000 (September 28, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: FRCC

Issue: On December 8, 2011, GRU, as a GO, self-reported a violation of PRC-005-1 R2 for two reasons. First, GRU had insufficient evidence verifying that its generating unit batteries for its Deerhaven Units (specifically, CT1, CT2, CT3 and DH1) were maintained pursuant to its generation Protection System maintenance and testing procedure. Second, GRU was three days late in performing its monthly inspection of the generating unit batteries on Deerhaven Unit DH1.

Finding: This issue posed only a minimal risk to the reliability of the BPS for four reasons. First, the batteries were constantly monitored and equipped with an alarm that would have alerted the control room if any issues arose. Second, the batteries were checked each day by operators during their rounds. Third, GRU, in accordance with its procedures, performed both quarterly and annual battery testing. Fourth, documentation is missing for only three months during the 2010 maintenance schedule, and late by only three days in the case of the monthly inspection of Deerhaven Unit DH1.

 

FERC noted that GRU twice violated this Standard previously and had one remediated event, but determined the instant issue is appropriate for FFT treatment because it was unrelated to the previous occurrences. FERC distinguished the instant violation because the previous violations and GRU's subsequent remediating efforts did not involve or address the instant issue, the maintenance of battery banks during plant outages. Instead, two of the prior instances involved relays and the third involved relays and battery maintenance on transmission batteries. GRU properly responded to all these occurrences by August 2010, instituting preventative maintenance software to ensure that batteries were tested according to the intervals defined in its Protection System maintenance and testing program, and improving its procedures for developing and maintaining maintenance and testing documentation.

GenOn East 2, FERC Docket No. RC13-3-000 (December 31, 2011)

Reliability Standard: PRC-005-1

Requirement: 2; 2.1

Region: RFC

Issue: GenOn East 2, as a GO, self-reported a violation of R2 of PRC-005-1 to RFC, on September 30, 2011, specifically the failure of maintenance and testing on one relay, which was a backup relay, within the defined interval of four years (and a 10% grace period). GenOn East 2 tested the backup relay, one out of 85 relays it has, at a different time than the primary relay, which it did test and maintain within the defined interval.

Finding: RFC found the issue to pose a minimal risk to the reliability of the bulk power system, for the relay in violation was a backup relay and the primary relay was tested and maintained as stipulated. In addition, the primary relay has a shorter response timeframe than the backup relay and in the event of a misoperation, GenOn East 2 has alarms to signal to the control room. Finally, GenOn East 2 self-reported in a timely manner, through a self-report.

GIM Channelview Cogeneration LLC (GIM Channelview), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R2

Region: TRE

Issue: Further to a Compliance Audit, TRE determined that GIM Channelview, as a GO, had an issue with PRC-005-1 R2 when it found that two relays had not been tested within the program intervals. The GO’s testing interval (5 years and 10 months) for these two relays exceeded the program interval of 4 years (with the provision that if maintenance interval exceeds 4 years, then maintenance must be performed during the next unit outage). The two untested relays represented 1.16% of the GO’s 172 devices.

Finding: TRE determined that the issue posed a minimal risk to the reliability of the BPS because the two relays at issue were tested 20 months beyond the program interval, and the GO was able to provide records to show that previous testing had occurred in 2004. In addition, when the relays were tested, the results were satisfactory.

Golden Spread Panhandle Wind Ranch, LLC (Golden Spread), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 1; 1.1; 1.2

Region: SPP RE

Issue: Golden Spread, as a GO, self-reported an issue with PRC-005-1 R1 to SPP RE when it found that it had not included maintenance and testing intervals or a summary of maintenance and testing procedures for its DC control circuitry within its documented Protection System maintenance and testing program.

Finding: SPP RE determined that the issue posed a minimal risk to the reliability of the BPS because Golden Spread had tested all Protection System devices during the plant commissioning in 2001, including DC control circuitry, and based on this testing, Golden Spread is only two years into the five-year test interval recommended in NERC’s Protection System Maintenance Technical Reference for DC control circuitry.

Gulf Power Company (Gulf), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: SERC

Issue: Gulf, in its role as a GO, submitted a self-report in February 2012 explaining that it could not establish that eight relay sets associated with a standby spare station service transformer at its Scholz generating plant were tested within the intervals defined in its Protection System maintenance and testing program as a result of being misclassified. Gulf tested five out of 1,160 protective relays (0.4%) approximately two years outside of the defined interval and did not have previous test or maintenance records for one out of 1,160 protective relays (0.1%). Gulf had six out of 2,319 Protection System devices (0.3%) that were tested outside of the defined interval or had missing previous test or maintenance records. SERC staff confirmed that no other issues were present relating to Gulf's Protection System devices under its Transmission Owner (TO) function.

Finding: SERC deemed the issue posed minimal risk to BPS reliability Gulf staff perform daily rounds through the plant and would have seen relay targets had the six relays operated unexpectedly. Gulf personnel did not observe any such unexpected operation of these relays; Gulf calibrated the six relays and no issues were reported. This is a repeat violation by Gulf; however, the previous violation was in 2007 and so NERC determined FFT treatment was appropriate.

Hennepin County, MN (HCMN), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: MRO

Issue: While conducting a Compliance Audit in July 2011, MRO found that HCMN, in its role as a GO, had failed to establish intervals for the maintenance and testing (M&T) of current transformers (CTs), potential transformers (PTs) and DC control circuitry, which make up 20% of all Protection System devices, pursuant to the requirements of PRC-005-1 R1. In addition, the Protection System M&T program in use by HCMN did not contain a summary of M&T procedures for Protection System devices.

Finding: The issue was deemed by MRO to pose minimal risk to BPS reliability because upon HCMN’s review of M&T documentation and intervals for such testing, HCMN found evidence that the relevant devices had been tested and maintained as required, it was documentation that was lacking. MRO also found that HCMN was performing M&T on the Protection System devices more frequently than required. In addition, the HCMN facility is connected to the BPS by 115 kV with a generating output of only 34 MW.

High Prairie Wind Farm II, LLC (HPWF), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R2; R2.1

Region: MRO

Issue: Further to a Compliance Audit, MRO determined that HPWF, as a GOP and GO, had an issue with PRC-005-1 R2.1 when it found that HPWF had not performed annual battery testing in 2008 and was therefore unable to provide maintenance and testing evidence for one of its Protection System station batteries in accordance with the intervals listed in its Protection System maintenance and testing program. A comprehensive review of HPWF’s Protection System maintenance and testing records showed that HPWF had failed to provide maintenance and testing records for only the one station battery, representing 4% of its devices.

Finding: MRO determined that the issue posed a minimal risk to the reliability of the BPS because of the localized nature of the issue, involving only one station battery at one substation for one testing interval. In addition, as the plant began commercial operation in November 2007, and HPWF missed the maintenance and testing interval in November 2008, the battery was one year old when its annual testing was not conducted. In sum, the issue posed a minimal risk to the reliability of the BPS because of the duration of the issue, the other battery testing HPWF performed on a monthly and quarterly basis, the age of the station battery, and the size of HPWF (with total installed capacity of 100.65 MW, provided by 61 1.65 MW turbines).

Hopewell Cogeneration Limited Partnership (Hopewell), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2, 1

Region: SERC

Issue: Hopewell, as a GOP, submitted a self-report stating that the interval for battery load testing had been exceeded and it had no evidence of testing the DC control circuitry prior to October 2009. SERC confirmed that Hopewell tested the following Protection System devices outside of its defined intervals: four out of four station batteries (100%) and four out of four DC control circuitry devices (100%). In total, Hopewell tested eight out of 265 Protection System devices (3.0%) outside of the defined interval. (R2). Regarding R1, in July 2012, Hopewell submitted a self-report stating that its Protection System maintenance and testing program did not include associated communication system (ACS) devices as required by the Standard. Hopewell does not own ACS devices, but it did not include a statement saying such in its procedure.

Finding: SERC found the issues posed minimal risk to BPS reliability. Regarding R2, Hopewell's battery charger and DC system has basic alarming in the control system and the alarms are part of a supervisory control and data acquisition (SCADA) system that allows the operators to monitor the alarms continuously which would allow Hopewell personnel to respond to a battery or charger failure. Hopewell missed one monthly maintenance interval in July 2010 for all four batteries and the two-year interval for three out of the four batteries by approximately three years, but otherwise met all maintenance and testing intervals. Hopewell also visually inspected the batteries monthly and annually. Hopewell subsequently conducted load tests on the batteries and replaced faulty cells, but found no other issues. Power flow analysis simulating the loss of Hopewell under peak conditions was performed on August 15, 2012 and demonstrated that the loss of Hopewell would not cause a reliability impact on the transmission system; and Hopewell subsequently tested its DC control circuitry devices and found no issues. Regarding R1, SERC determined that the issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the bulk power system because the only omission from Hopewell's Protection System maintenance and testing procedures was a statement that Hopewell does not own any ACS devices.

Hot Spring Power Company, LLC ("Hot Spring"), FERC Docket No. FERC Docket No. FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 1; 2

Region: SERC

Issue: Hot Spring, as a GO, self-reported an issue with R2, stating that during an internal assessment of the Protection System, it could not locate documentation for capacity load testing of the two Valve Regulated Lead Acid (VRLA) batteries for the period of 2008. Hot Spring noted a work order from March 2008 indicated that capacity load testing had been performed, however the vendor test records did not include capacity load tests. Subsequently, Hot Spring tested both batteries twice within the defined intervals. In addition, Hot Spring self-reported an issue with R1, stating that the Protection System maintenance and testing procedure did not contain associated communication systems (ACS) devices. Hot Spring does not own ACS devices; however the Protection System maintenance and testing procedure did not include a statement to that effect until it was amended on April 1, 2011 to include a statement that it did not own ACS devices.

Finding: SERC found the issue posed a minimal risk to the reliability of the BPS since Hot Spring's battery charger and DC system has basic alarming in the control system that allows the operators to monitor the alarms continuously and alerts personnel to a battery or charger failure. In addition, Hot Spring conducted monthly and annual maintenance and inspections on the batteries and found no issues. Furthermore, Hot Spring's plant is a merchant power plant and does not have a long term contract in place. Also, Hot Spring's Protection System maintenance and testing procedure only omitted a statement that Hot Spring does not own any ACS devices

Kiowa Power Partners, LLC (KPP), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: TRE

Issue: KPP, in its role as a GO, submitted two self-reports in October 2011 explaining that it was not in compliance with PRC-005-1 R2 because ten batteries missed weekly battery tests from February 2009 through September 2011.

Finding: TRE and SPP found the issue posed minimal risk to BPS reliability because it was documentation related.

Lea Power Partners, LLC (LEAPP), Docket No. RC13-7-000 (March 27, 2013)

Reliability Standard: PRC-005-1

Requirement: 1

Region: SPP RE

Issue: LEAPP submitted a self-report in July 2012 alerting SPP RE to a compliance issue with PRC-005-1 as it had not described procedures for maintenance and testing (M&T) on each kind of Protection System device on its system. LEAPP stated that, as a GO, it had an M&T program that included M&T intervals and their bases, but no further instruction was included.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk because LEAPP had performed the required M&T on its Protection System devices as instructed by manufacturer and/or industry recommendations and within the prescribed intervals, it only failed to have a summary of its M&T procedures.

Lea Power Partners, LLC (Lea Power), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 2

Region: SPP RE

Issue: Lea Power, as a GO, self-reported an issue with PRC-005-1 R2 to SPP RE when it found that it was unable to provide evidence that it had tested or maintained certain Protection System devices within the intervals provided for by its Protection System maintenance and testing program, including: three battery banks in 2009 and 2011, direct current (DC) control circuits since 2008, 92 of 198 voltage and current transformers within the one and three years intervals, and 28 of 42 DC control circuits and 28 of 42 protective relays within the three-year interval.

Finding: SPP RE determined that the issue posed a minimal risk to the reliability of the BPS because the Protection Systems at issue are associated with one 500 MW generating facility, which was commissioned in 2008 at which time all of its Protection System devices were functionally tested. In addition, Lea Power’s testing intervals as established in its Protection System maintenance and testing program are conservative, and all of the protection system devices at issue were tested within the maximum intervals established in the NERC technical reference. Many of the devices also have trouble alarms which link to a control room that is continuously manned and any issue with such devices would have triggered operator intervention.

Lincoln Electric System (LES), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 2/2.1

Region: MRO

Issue: LES, in its roles as a DP, GO and TO, submitted a self-report in September 2011 stating that it could not produce maintenance and testing (M&T) records as required by its generation and transmission Protection System M&T program which led to MRO asking that LES undertake a complete review of all M&T records. That review confirmed that LES could not show that it had maintained and tested 4% of its total Protection System devices, including 114 voltage and current sensing devices, 14 station batteries, and 1 DC control circuit out of approximately 3,043 Protection System devices subject to the Reliability Standard.

Finding: The issue was deemed by MRO to pose minimal risk to BPS reliability because of the short duration involved and because LES was able to show that quarterly infrared scans had been performed on the current and voltage sensing devices. As well, LES’s SCADA system monitored a subset of those devices. MRO noted that the batteries had received other maintenance and testing as required by LES’s M&T program, although voltage checks had been missed for a two-month period.

Llano Estacado Wind, LP (Llano), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: PRC-005-1

Requirement: R2.1

Region: SPP

Issue: Llano, a GO as of March 2008, submitted a self-report disclosing that it was unable to show that its Protection System devices had been maintained and testing pursuant to defined intervals set forth in its Protection System maintenance and testing program. In particular, for the year 2008, Llano could not show that annual battery tests had been undertaken. All other Protection System devices had documented test results confirming testing had taken place. The violation period was from March 3, 2008 until May 2009.

Finding: The issue was deemed by SPP to pose minimal risk to BPS reliability which was mitigated by the fact that Llano could show regular, monthly battery inspections had occurred during the relevant time period, and minutes of a company meeting showed that the testing had in fact taken place in 2008. In addition, the Protection System maintenance and testing program in use by Llano did acknowledge all Protection System devices, including batteries.

Lower Colorado River Authority (LCRA), FERC Docket No. RC13-5-000 (January 31, 2013)

Reliability Standard: PRC-005-1

Requirement: 2

Region: TRE

Issue: LCRA, as a GO, self-reported two violations of R2 of PRC-005-1 to TRE on January 17, 2012 and August 20, 2012. First, LCRA did not have records demonstrating maintenance and testing for its Protection System devices at the Fayette Power Project and Sims Gideon generation plans, as mandated by its Protection System maintenance and testing program. LCRA failed to show testing documentation for the three generating units, 46 current and voltage sensing devices, and six DC control circuitry components at the Fayette Power Project plant; it failed to do so for three generating units, three current and voltage sensing devices, and nine DC control circuitry components at the Sims Gideon plant, making a total of test failure for 64 devices. The duration of the violation was determined to be from June 18, 2007, when LCRA was mandated to comply with the Reliability Standards, to October 30, 2012, when LCRA last tested its devices.

Finding: TRE found that the issue posed a minimal risk to the reliability of the bulk power system because the number of devices LCRA failed to show testing and maintenance for was small compared to LCRA's total Protection System devices. Furthermore, of the 64 devices at issue, 27 (55.1%) voltage and current sensing devices signal to LCRA's TO Protection Systems, not to its GO Protection Systems, though owned by the GO, and make up 2.4% of the total GO Protection System devices. The other 37 (57.8%), constituents of the GO's Protection Systems, make up 3.3% of the total GO Protection System devices. Additionally, the 64 devices in question did not show any issues during the Mitigation Plan testing.

LSP Energy Limited Partnership (LSP Energy), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: SERC

Issue: LSP Energy, as a GO and TO, self-reported a violation of PRC-005-1 after being unable to locate monthly battery maintenance records for five batteries in October 2010. Subsequently, SERC staff reviewed spreadsheets detailing the maintenance and testing intervals for each of LSP Energy’s Protection System devices confirming LSP Energy missed the monthly battery maintenance in October 2010, and making the additional finding that LSP Energy missed the required monthly battery maintenance for four batteries in January 2009 and one battery in October 2009. Consequently, SERC held that LSP Energy failed to document that five batteries were maintained and tested within the defined intervals, but noted that noncompliance was limited to three non-consecutive monthly maintenance intervals for five of its 133 Protection System devices (approximately 3.8%).

Finding: SERC determined this issue posed only a minimal risk to the reliability of the BPS because of four reasons. First, LSP Energy personnel visually inspect the batteries during operator rounds twice per twenty-four hour period. Second, the battery chargers are equipped with alarms designed to alert personnel of a malfunction. No alarms were triggered during the violation period. Third, no problems were discovered when LSP completed its testing during the maintenance periods before and after the missed intervals. Fourth, LSP missed battery maintenance inspections in non-consecutive months. More specifically, LSP missed one battery in three monthly inspections, three batteries in two monthly inspections, and one battery in one monthly inspection.

LSP University Park, LLC (LSP University Park), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R1

Region: RFC

Issue: LSP University Park, as a GO, self-reported an issue with PRC-005-1 R1 to RFC when it found that it had not implemented a fully-developed Protection System maintenance and testing program (Program) at facility registration.

Finding: RFC determined that the issue posed a minimal risk to the reliability of the BPS because LSP University Park had been performing some maintenance and testing even without a formal Program, and during a Compliance Audit, LSP University Park was able to provide records of testing and maintenance on station batteries in 2009 and 2012, testing and maintenance on relays in 2005 and 2009, and commissioning test records for instrument transformers in 2002.

Michigan South Central Power Agency (MSCPA), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 1

Region: RFC

Issue: Further to a Compliance Audit, RFC determined that MSCPA, as a GO, had an issue with PRC-005-1, R1 because it did not have a summary of maintenance and testing procedures in its Protection System maintenance and testing program.

Finding: RFC determined that the issue posed a minimal risk to the reliability of the BPS because it was merely a documentation issue, and because MSCPA had indeed performed maintenance and testing in accordance with its program. MSCPA also has a relatively small contribution to the BPS.

Midwest Energy, Inc. (Midwest), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2; 2.1

Region: SPP

Issue: Midwest, as a Distribution Provider and a TO, self-reported a violation of R 2.1 of the PRC-005-1 to SPP on March 30, 2012. While Midwest Protection System Maintenance and Testing Procedure (PSMP) mandated that station battery banks be tested within five-year intervals, eight of 23 battery banks (34.8%) had not been tested within that interval, with five battery banks late for testing by three months or less. The other three battery banks were late for testing by two to 3.5 years. All batteries had been tested as of April 3, 2012. Midwest then supplied a letter to SPP on April 19, 2012, noting that it had not tested three of 715 Protection System relays (0.4%) within the three-year interval as mandated by the PSMP. Midwest noted that the testing of the microprocessor-based relays was late by one year and two months.

Finding: SPP found that the issues posed a minimal risk to the reliability of the bulk power system for the following reasons: (1) the relays were inspected visually and monitored by the Midwest Supervisory Control and Data Acquisition System (SCADA) despite the failure of the testing; (2) the testing of the relays were late by one year and two months, which is shorter than the seven to 10 year testing interval recommended by the NERC Protection System Maintenance Technical Reference (NERC Reference) for monitored microprocessor based relays; (3) the battery banks were also inspected monthly and checked for corrosion, jumper contact, and their charger DC voltage recorded; (4) the battery banks were monitored via SCADA; (5) the testing of the battery banks happened at 5.25 years, 7 years, and 8.5 years marks, which are within the maximum ten-year testing interval mandated by NERC Reference for monitored battery banks; (6) there were no equipment failures due to the testing failures.

Milford Wind Corridor Phase I, LLC (MILW), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: WECC

Issue: MILW, self-certified in January 2012 that, in its role as a TO, it failed to maintain compliance with PRC-005-1 R2 because it had missed a required six-month status check of digital input and outputs and voltage and current inputs to its Protection System equipment.

Finding: The issue was deemed by WECC to pose minimal risk to BPS reliability because all other protection equipment had been maintained and tested as required, and MILW did conduct the subsequent status check on time.

NedPower Mount Storm, LLC (Ned Power), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 2; 2.1

Region: RFC

Issue: Ned Power, as a GO, self-reported a violation of R2.1 of PRC-005-1 to RFC on April 3, 2012, found while it was reviewing its Reliability Standards compliance documentation. Ned Power found that it did not maintain documentation that it performed two monthly battery inspections. During a Compliance Audit (from April 30, 2012 to May 16, 2012) of Ned Power, RFC found an additional violation of R1 in that Ned Power had not maintained documentation that it carried out visual inspections or heat scans for current and voltage sensing devises as mandated by its Protection System maintenance and testing program and that it also did not maintain documentation of control circuitry testing as mandated by the program.

Finding: RFC found that this issue posed a minimal risk to the reliability of the bulk power system because despite the two missed battery inspections, it had conducted inspections before and after the missed inspections showing that the batteries were functioning properly. The 2009 load test also corroborated to the functionality of the batteries. Ned Power had also installed climate control in the control house, which was installed in 2007, along with the batteries. Ned Power furthermore monitored via automatic alarms and regulator operator checks. With regard to the missed visual and heat scan inspections, RFC found that the issue posed a minimal risk to the reliability of the bulk power system because Ned Power carried out electrical testing of current and potential sensing devises during the relay testing. RFC determined that Ned Power would have found any issue with the devices during the relay testing.

Nelson Industrial Steam Company (NISCO), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R1, R2

Region: SERC

Issue: NISCO submitted a one self-report disclosing that, as a GO, it was not sufficiently documenting the interval basis or summary of battery maintenance and testing procedures. SERC staff review confirmed that NISCO had no documented maintenance and testing program for batteries including intervals, interval basis, and a summary of maintenance and testing procedures before June 2, 2009. All over equipment was covered in the maintenance and testing program, which also stated that NISCO does not own any associated communication devices. NISCO submitted a second self-report explaining that it had no evidence available to prove that the battery had been tested during three months in 2008 and two months in 2009. The battery is one of 125 Protection System devices (equalling 0.8% of all devices) on which testing at the required interval could not be confirmed.

Finding: The issues were found to pose minimal risk to BPS reliability because the batteries were being tested and maintained according to the GOP’s automated maintenance management system, and NISCO was using its GOP’s maintenance program since June 2007. Further, for the five monthly tests that were missed, each battery was tested during the month after the missed interval and no issues were found. Also, operators perform visual checks daily. NISCO did have proof that 99% of its Protection System devices had been properly maintained and tested.

New Athens Generating Company, LLC (New Athens), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R2

Region: NPCC

Issue: New Athens, a GO, self-reported that it found an issue with PRC-005-1 R2 when it was discovered during a review of its Protection System maintenance and testing program that relay testing related to unit 2 had not been undertaken pursuant to defined intervals. The number of non-tested relays on Athens’ system equaled 30% of total relays. Specifically, Athens’ unit 1 main transformer had experienced a major failure in January 2011 and was out of service until August 2011. During the outage, unit 2 was placed into service to maintain grid support during the summer months. Testing on unit 2 was to take place prior to summer 2011, but Athens’ elected not to take the unit out of service for testing during the unit 1 outage.

Finding: The issue was found to pose a minimal risk to BPS reliability because even though testing had not been completed pursuant to defined intervals, testing was completed when the unit 1 transformer was placed back into service, and was only four months overdue. NPCC noted that Athens uses a testing schedule shorter than that required by NERC, and Athens delayed testing in order to maintain grid support and reliability during the peak load period (i.e., summer) for the New York region.

Northampton Generating Company ("Northampton"), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 1; 2

Region: RFC

Issue: During an audit, RFC discovered that, as a GO, Northampton's documented Protection System maintenance and testing program indicated that Northampton did not perform periodic maintenance and testing for current transformers (CTs) and potential transformers (PTs) at defined intervals (per R1). Northampton, instead, waited until a device exhibited problems to perform maintenance and testing. In addition, RFC found that Northampton was missing documentation from fourth quarter of 2008 and the first, third and fourth quarters of 2010 indicating that it tested its two battery systems, per the requirements of the maintenance and testing program ( and in compliance with R2)

Finding: RFC found that the issues posed a minimal risk to the reliability of the BPS because the risk was mitigated by the fact that Northampton provided evidence verifying that it tested its CTs and PTs upon commissioning the generating station in 1995 and had not required continued periodic maintenance for them based on recommendations from the devices' manufacturers. The CTs in question were designed by the manufacturer to require very little maintenance. In addition, Northampton had documented maintenance and testing procedures to be implemented in the event a CT or PT experienced a problem. Furthermore, work orders indicating that Northampton requested testing to be performed during the calendar quarters in question by a contractor were provided, and RFC considered the work orders as strong evidence that the quarterly tests did in fact occur.

Northern Indiana Public Service Company (NIPSCO), FERC Docket No. RC13-5-000 (January 31, 2013)

Reliability Standard: PRC-005-1

Requirement: 2

Region: RFC

Issue: RFC, while conducting a compliance audit, discovered that NIPSCO, as a DP and TO, violated R2 of PRC-005-1 in that it failed to provide complete maintenance and testing records for its station batteries. Particularly, NIPSCO did not find two specific gravity readings for testing done on August 4, 2010 and September 13, 2010.

Finding: RFC found that the issue posed a minimal risk to the reliability of the bulk power system because NIPSCO did show specific gravity readings for all but two out of 60 inspections. Furthermore, NIPSCO showed cell voltage readings, internal resistance readings, and inter-cell resistance readings for all 60 inspections. There seemed to be no indication of battery malfunctions, including the two that NIPSCO could not find the gravity readings.

Northern Indiana Public Service Company GO GOP (NIPSCO), FERC Docket No. RC13-5-000 (January 31, 2013)

Reliability Standard: PRC-005-1

Requirement: 2

Region: RFC

Issue: NIPSCO, as a GO, self-reported a violation of R2 of PRC-005-1 to RFC on September 30, 2011, before 90 days of a scheduled compliance audit. One violation involved NIPSCO's failure to test 5 out 8,877 relays 85 days after the date mandated by its Protection System maintenance and testing program. Another also involved the failure to follow its Protection System maintenance and testing program, specifically the failure to test or maintain 10 sets of batteries within 60 days for 41 out of 2,790 maintenance and testing. Both violations were a result of a defect in NIPSCO's job tracking software, which failed to track preventative maintenance (PM) when it was performed but not closed out in the software. This led to the software not notifying a subsequent PM task within the time interval as mandated by NIPSCO's program. Furthermore, NIPSCO could not provide documentation showing that it had carried out monthly and quarterly maintenance and testing on its Sugar Creek generating plant's batteries within the 60 days as mandated by its Program, though NIPSCO did carry out said maintenance and testing.

Finding: RFC found that the issue posed a minimal risk to the reliability of the bulk power system for the following reasons: (1) the five relays are only secondary to the primary overcurrent and differential protection scheme and only part of a small 78 MW generating unit; (2) NIPSCO contracts with an URE and have documentation showing it annually carried out maintenance and testing for its Sugar Creek generating plant's batteries; (3) NIPSCO possesses notification voltage and charger alarms in case of battery bank malfunction; (4) NIPSCO found that all the protection system devices met the requirements of the program and would have functioned as specified if needed.

Northern Indiana Public Service Company GO GOP (NIPSCO), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R1

Region: RFC

Issue: Further to a Compliance Audit, RFC determined that NIPSCO, as a GO, had an issue with PRC-005-1 R1 because NIPSCO failed to address DC Control circuitry in its Protection System maintenance and testing program (Program). As a result, there was no maintenance and testing interval and a basis for DC control circuitry or a summary of maintenance and testing procedures for DC control circuitry in NIPSCO’s Program.

Finding: RFC determined that the issue posed a minimal risk to the reliability of the BPS because the issue was a documentation error. NIPSCO had been conducting functional tests of its DC control circuitry for the duration of the issue and was able to provide logs for the circuits for each shutdown event to demonstrate its performed functional tests of its DC control circuitry.

NRG Rockford LLC and NRG Rockford II LLC, Docket No. RC12-10 (March 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R2/2.1

Region: RFC

Issue: During a compliance audit conducted during July 2011, RFC found that NRG Rockford LLC and NGR Rockford II LLC (collectively, NRG Rockford), as Generator Owners, could not show that associated communication systems (four SEL-321 relays at the point of interconnection) had been tested prior to May 2, 2011. The Protection System maintenance and testing program (M&T Program) in use did call for two-year testing intervals; however, NRG Rockford was unable to verify to RFC that it was maintaining and testing the communication systems as set forth in the M&T Program.

Finding: RFC found the violation constituted a minimal risk to BPS reliability which was mitigated by the following facts. First, the violation is primarily documentation related as associated communications systems were being continuously monitored, and manual maintenance and testing of the relevant equipment was conducted on May 2, 2011. That testing confirmed the automatic testing results. Second, the relevant equipment has self-testing features installed, and as of the date the Standards became mandatory, the four relays have been continuously monitored. Should any irregular actions occur, alarms are triggered. Third, NRG Rockford tests the associated communication systems approximately 60 times per second by the use of “Mirrored Bits,” which sends alarms in the event a relay is disabled or the Mirrored Bits protocol is not activated or data is received in error or no message is received within the time that three messages are sent. Lastly, during the violation period, no alarms were sounded.

Oklahoma Gas & Electric Company Co. (OGE), Docket No. RC13-10, June 27, 2013

Reliability Standard: PRC-005-1

Requirement: R2; R2.1; R2.2

Region: SPP RE

Issue: OGE, as a GO, self-reported an issue with PRC-005-1 R2 to SPP RE when it found that it was unable to locate documentary evidence that it had implemented its maintenance and testing program for all of its batteries, DC circuitry, and relays. Specifically, OGE was missing documentation for three years of annual station battery bank tests for 14 generating units, at 4 generating stations, and OGE only had documentation for 89% of the required monthly station battery bank inspections and 88% of the required quarterly station battery bank inspections at 3 of the 4 generating stations during the time period. In addition, rather than providing documentation of monthly station battery bank inspections for the fourth generating station, OGE provided closed work orders showing that 22% of the monthly battery bank inspections occurred in the same time period. OGE had also not tested DC circuitry or relays at its Horseshoe Lake Generating Station A-1 Unit during the same time frame. SPP RE further found that a number of relay tests results were marked as “failed”, but OGE could not provide documentation of corrective action.

Finding: SPP RE determined that the issue posed a minimal risk to the reliability of the BPS for three reasons: (1) despite its lack of documented records of annual testing for 14 generating units, OGE had other documentation as evidence of some testing and maintenance on its station batteries, and continuously monitored the batteries during the issue through its Energy Management System, (2) the Horseshoe Lake Generating Station A-1 unit had a nameplate generating capacity of 2.5 MW and was not directly connected to the BPS, and (3) only 12 of 146 relay test results reviewed y SPP RE were left in a “failed” state and OGE provided an adequate explanation for these “failures” to show that it was more of a documentation issue than an actual failure.

Oncor Electric Delivery Company LLC (Oncor), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 2; 2.1

Region: TRE

Issue: Oncor, as a TO and DP, self-reported an issue with PRC-005-1 R2 to TRE when Oncor missed testing on four panels such that 4 of 5 Protection System devices on each panel were not being tested. Battery testing on the fifth device was also missed on one of these 4 panels. This occurred when a work order pertaining to the testing was incorrectly closed prior to the work being performed and a battery was erroneously classified as a non-Oncor asset and was therefore was not tested by Oncor.

Finding: TRE determined that the issue posed a minimal risk to the reliability of the BPS because the 4 reported panels that were not tested account for only 0.23% of Oncor’s total of 1,762 relay Protection Systems, and the batteries that went untested were tested on the other three panels.

Pattern Gulf Wind LLC ("Pattern Gulf"), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: TRE

Issue: Pattern Gulf Wind, as a GO, self-reported that weekly maintenance and tests were not documented from the time the generation facility in question was purchased from Texas Gulf Wind (March 17, 2010) until December 17, 2010 (per R2). Upon the ownership change, testing and maintenance was contracted to BluArc Management Group until December 17, 2010.

Finding: TRE found the issue posed a minimal risk to the reliability of the BPS because BluArc Management Group had provided an attestation that testing was being done during the remediated issue period despite the lack of documentation. Pattern Gulf had shown that it was performing comprehensive system maintenance and testing from December 17, 2010 onwards.

Peabody Municipal Light Plant (PMLP), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: NPCC

Issue: While conducting a one-day off-site Compliance Audit in August 2011, NPCC found that PMLP, in its role as a GO, was unable to show that it had a compliant program in place for testing of current and potential transformer (CT/PT) devices and direct current (DC) controls for its GT2 generator Protection System. Testing of the devices had taken place upon start-up in 1990. NPCC found that the interval for testing in PMLP’s program had been met – that is, testing was required upon installation or replacement, however, no other testing intervals had been established as required by the Standard.

Finding: The issue was deemed to pose minimal risk to BPS reliability because even though no formal testing had taken place since commissioning, the devices were protected by other means, such as an alarm system to alert operators of issues, as well as regular, visual inspections. NPCC also considered that the 52 MW generating unit had a five-year run time of only 208.2 hours per year.

Pinellas County Resource Recovery (PCRR), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: PRC-005-1

Requirement: R2

Region: FRCC

Issue: PRCC, a GO, submitted a self-report explaining that it was unable to locate documentation or evidence that it had conducted required monthly battery testing during January and March 2011 as required by its maintenance and testing program.

Finding: The issue was found to pose a minimal risk to BPS reliability because the batteries are subject to daily visual checks and are monitored at all times. Alarms are in place to signal operators to any issues with the batteries. Also, only two months’ testing data was missing.

PowerSmith Cogeneration Project LP (PowerSmith), Docket No. RC13-8, April 30, 2013

Reliability Standard: PRC-005-1

Requirement: 1

Region: Southwest Power Pool Regional Entity (SPP RE)

Issue: PowerSmith filed a self-report with SPP RE in July 2011 disclosing that, as a GO, it did not have a compliant maintenance and testing program for its Protection Systems to include intervals and their basis for testing or a summary of maintenance and testing procedures for all of its Protection System devices, mainly batteries.

Finding: The violation was deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because even though PowerSmith did not have the formal program documented as of its date on the Compliance Registry, PowerSmith was testing and maintaining the batteries and it did have available a “Instrument Calibration Program” during the relevant time period.

PSEG Fossil LLC (PSEG Fossil), Docket No. RC13-6-000 (February 28, 2013)

Reliability Standard: PRC-005-1

Requirement: 2

Region: RFC

Issue: PSEG Fossil, in its role as a GO, submitted a self-report in March 2012 stating that it found a certain relay scheme had not been tested according to established intervals. Towards the end of 2011, PSEG Fossil and Public Service Electric & Gas Company (PSE&G), the TO that performs maintenance and testing (M&T) for some of PSEG Fossil's Protection System devices, were discussing the assignment of responsibility for Protection System M&T. During the discussion, it was determined that a certain relay scheme at one generating station had not been tested according to the five-year testing schedule due to a misunderstanding as to which entity was responsible for M&T. The relay scheme had last been tested in 2002. PSEG Fossil performed the M&T on December 27, 2011.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk. The risk to BPS operations was mitigated because PSEG Fossil has other relays that are part of its generator protection that would have provided backup protection if needed. Also, only one relay was involved.

Richmond Power & Light (RP&L), Docket No. RC13-8, April 30, 2013

Reliability Standard: PRC-005-1

Requirement: 1

Region: ReliabilityFirst Corporation (RFC)

Issue: RP&L submitted a self-certification stating that it did not have a Protection System maintenance and testing (M&T) program. RP&L stated that since it has no transmission Protection Systems, it believed it was exempt from the requirement to have a Protection System M&T program; however and outside consultant determined RP&L was facing a compliance issue.

Finding: The violation was deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because RP&L connects on non-critical transmission lines and is not essential to BPS operations. RP&L does test its batteries and relays and no misoperations were reported.

Richmond Power & Light (RP&L), Docket No. RC13-8, April 30, 2013

Reliability Standard: PRC-005-1

Requirement: 1, 2

Region: ReliabilityFirst Corporation (RFC)

Issue: RP&L submitted a self-certification stating that it did not have a Protection System maintenance and testing (M&T) program. Regarding R1, RP&L stated that since it has no transmission Protection Systems, it believed it was exempt from the requirement to have a formal Protection System M&T program; however, an outside consultant determined RP&L was facing a compliance issue, and therefore M&T certified the non-compliance issue to RFC. Regarding R2, as RP&L had no M&T program, it could not be documented and implemented.

Finding: The violations were deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because RP&L connects on non-critical transmission lines and is not essential to BPS operations. RP&L does test its batteries and relays and no misoperations were reported.

South Carolina Electric & Gas Company (SCE&G), Docket No. RC13-7-000 (March 27, 2013)

Reliability Standard: PRC-005-1

Requirement: 2

Region: SERC

Issue: SCE&G submitted a Self-Certification in mid-2012 alerting SERC to a compliance issue with PRC-005-1. SCE&G self-certified that as a TO, GO and DP, it had not met the testing protocols established in its maintenance and testing (M&T) procedures for certain Protection System equipment. SERC review found that SCE&G was unable to provide the M&T records for 8 of 3,086 relays, or 0.26%; 2 of 167 associated communication systems, or 1.20%; 8 of 3,078 PT/CTs, or 0.26% and 17 of 3,086 DC control circuits.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk. SCE&G was found to have records for 99% of its Protection System devices. The relevant devices have adequate protection and backup so that an individual failure would cause minimal adverse effects on overall system operations.

Sweetwater Wind 2 LLC (Sweetwater 2), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: Texas RE

Issue: During an audit, Texas RE found that Sweetwater 2, as a GO and wind generator in the ERCOT service region, did not have in place generation Protection System maintenance and testing program standards (per R1). Sweetwater 2 failed to comply with the Standard until October 3, 2007, when it created a Protection System maintenance and testing program.

Finding: Texas RE found the issue posed a minimal risk to the reliability of the BPS because Sweetwater 2's nameplate capacity is 91 MW, and it is not normally supposed to contribute operating reserves to the ERCOT system when operating below nameplate capacity due to the inconsistencies inherent to a wind resource. Additionally, Sweetwater 2's control center monitored the generation Protection System 24 hours a day, and Sweetwater 2 had an Operations and Maintenance contract with General Electric that stipulated yearly testing, relay maintenance and a facility testing schedule more frequent than the standards implemented by Sweetwater 2 after October 3. Also, there were no relay misoperations and there were at least two levels of overlapping protection during the three-month period in question. Lastly, Sweetwater 2 performed weekly visual inspections and each feeder and wind turbine had protective relays.

Sweetwater Wind 3 LLC (Sweetwater 3), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: Texas RE

Issue: During an audit, Texas RE found that Sweetwater 3, as a GO and wind generator in the ERCOT service region, did not have in place generation Protection System maintenance and testing program standards (per R1). Sweetwater 3 failed to comply with the Standard until October 3, 2007, when it created a Protection System maintenance and testing program.

Finding: Texas RE found the issue posed a minimal risk to the reliability of the BPS because Sweetwater 3's nameplate capacity is 135 MW, and it is not normally supposed to contribute operating reserves to the ERCOT system when operating below nameplate capacity due to the inconsistencies inherent to a wind resource. Additionally, Sweetwater 3's control center monitored the generation Protection System 24 hours a day, and Sweetwater 3 had an Operations and Maintenance contract with General Electric that stipulated yearly testing, relay maintenance and a facility testing schedule more frequent than the standards implemented by Sweetwater 3 after October 3. Also, there were no relay misoperations and there were at least two levels of overlapping protection during the three-month period in question. Lastly, Sweetwater 3 performed weekly visual inspections and each feeder and wind turbine had protective relays.

Sweetwater Wind 4 LLC (Sweetwater 4), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: Texas RE

Issue: During an audit, Texas RE found that Sweetwater 4, as a GO and wind generator in the ERCOT service region, did not have in place generation Protection System maintenance and testing program standards (per R1). Sweetwater 4 failed to comply with the Standard until October 3, 2007, when it created a Protection System maintenance and testing program.

Finding: Texas RE found the issue posed a minimal risk to the reliability of the BPS because Sweetwater 4 is not normally supposed to contribute operating reserves to the ERCOT system when operating below nameplate capacity due to the inconsistencies inherent to a wind resource. Additionally, Sweetwater 4's control center monitored the generation Protection System 24 hours a day, and Sweetwater 4 had an Operations and Maintenance contract with General Electric that stipulated yearly testing, relay maintenance and a facility testing schedule more frequent than the standards implemented by Sweetwater 4 after October 3. Also, there were no relay misoperations and there were at least two levels of overlapping protection during the three-month period in question. Lastly, Sweetwater 4 performed weekly visual inspections and each feeder and wind turbine had protective relays.

Tenaska Gateway Partners Ltd ("Tenaska"), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 2

Region: TRE

Issue: Tenaska, as a GO, self-reported (to TRE and SPP) that it did not have the sufficient documentation to verify testing and maintenance of all DC control circuitry (per R2). Testing and maintenance did occur at the properly defined intervals on most of the Protection System components at the Tenaska plant; however, testing of the DC control circuitry was not been performed and documented in a manner necessary to establish compliance. Tenaska implements NETA maintenance testing specifications for testing its Protection System components. The remediated issue occurred from June 28, 2007, when Tenaska's registered as a GO, to May 1, 2012, when the DC Circuit tests were properly documented.

Finding: TRE found the issue posed a minimal risk to the reliability of the BPS since Tenaska the remaining Protection System equipment had tests and maintenance administered. In addition, Tenaska took relay events and successful equipment starts as indications of functional testing of the DC control circuitry in question. Also, the remediated issue only applied to 9.37% of the Protection System Devices, further mitigating the risk to the BPS. Furthermore, when tests on the DC control circuitry were administered, all units were judged to be operating properly. Lastly, upon review of all plant Protection System operations, Tenaska did not detect any misoperations during the duration of the remediated issue.

The Empire District Electric Company (EDE), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: PRC-005-1

Requirement: 2.1

Region: SPP RE

Issue: EDE self-reported that it failed to inspect five station batteries, located at two of its substations, within the ninety-day period outlined in its Protection Systems testing and maintenance plan (a violation of R2.1 ). The two substations in question were previously inspected on March 10, 2010, and EDE did not inspect the batteries again until July 1, 2010 and July 12, 2010, respectively.

Finding: SPP RE found the issue posed a minimal risk to the reliability of the BPS because of the limited scope and duration of the issue. EDE discovered the oversight and performed the necessary tests to remediate the issue.

USACE - Charleston District (USACE-Charleston), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: SERC

Issue: On June 30, 2008, USACE-Charleston, in its role as a GO, self-certified a violation of PRC-005-1 R1 because its Protection System maintenance and testing program did not include (a) intervals for testing batteries and DC control circuits; (b) the basis for intervals for batteries, DC control circuits, relays, communication systems and sensing devices; and (c) a description summarizing its maintenance and testing procedures.

Finding: SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE–Charleston supplied various records, including maintenance and testing records and procedures, corporate policies, and manufacturer’s recommendations, proving that all components of USACE-Charleston’s Protection System were being maintained and tested on a regular basis despite a lack of documentation in its Protection System maintenance and testing program.

USACE - Mobile District (USACE-Mobile), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: SERC

Issue: On June 19, 2008, USACE-Mobile, in its role as a GO, self-certified a violation of PRC-005-1 R1 because its Protection System maintenance and testing program did not include (a) intervals for testing batteries and DC control circuits; (b) the basis for intervals for batteries, DC control circuits, relays, communication systems and sensing devices; and (c) a description summarizing its maintenance and testing procedures.

Finding: SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE –Mobile supplied various records, including maintenance and testing records and procedures, corporate policies, and manufacturer’s recommendations, proving that all components of USACE-Mobile’s Protection System were being maintained and tested on a regular basis despite the lack of required documentation.

USACE - Savannah District (USACE - Savannah), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: SERC

Issue: On July 7, 2008, USACE-Savannah, a GO, self-certified a violation of PRC-005-1 R1 because its Protection System maintenance and testing program did not include (a) intervals for testing batteries and DC control circuits; (b) the basis for intervals for batteries, DC control circuits, relays, communication systems and sensing devices; and (c) a description summarizing its maintenance and testing procedures.

Finding: SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE-Savannah supplied various records, including maintenance and testing records and procedures, corporate policies, and manufacturer’s recommendations, proving that all components of USACE-Savannah’s Protection System were being maintained and tested on a regular basis despite the lack of required documentation.

USACE - Wilmington District (USACE-Wilmington), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: SERC

Issue: On July 14, 2008, USACE-Wilmington, a GO, self-certified a violation of PRC-005-1 R1 because its Protection System maintenance and testing program did not include (a) intervals for testing batteries and DC control circuits; (b) the basis for intervals for batteries, DC control circuits, relays, communication systems and sensing devices; and (c) a description summarizing its maintenance and testing procedures.

Finding:SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE-Wilmington supplied various records, including maintenance and testing records and procedures, corporate policies, and manufacturer’s recommendations proving that all components of USACE-Wilmington’s Protection System were being maintained and tested on a regular basis despite the lack of required documentation.

Wabash Valley Power Association, Inc. ("Wabash"), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: PRC-005-1

Requirement: 1

Region: RFC

Issue: Wabash, as a Distribution Provider that owns a transmission Protection System, self-reported an issue with R1, stating that it did not have a maintenance and testing program for Protection System devices in two of its substations that interconnect above 100 kV. In the RFC region, there are approximately 297 points at which Wabash has interconnections with transmission facilities owned by other utilities, and only 1% of those interconnection points are operated at 100 kV or above and contain a transmission Protection System stipulating a maintenance and testing program. Thus the configuration of the substations in question is extremely rare for Wabash.

Finding: RFC found the issue posed a minimal risk to the reliability of the BPS because the risk was mitigated by the fact the extent of Wabash's issue includes two Protection System Relays and two Protection System battery systems and that during the duration of the period in question, Wabash contracted a third-party to conduct maintenance and testing of its Protection System battery systems. The contractor performed maintenance and testing on the battery systems annually, with the exception of one location in 2010. After 2010, testing was ceased due to safety concerns Wabash had with the contractor. Subsequently, Wabash hired a new contractor, Energy Systems Maintenance LLC, to provide testing and services. In addition, the two Protection System relays in question are microprocessor relays that were monitored by Wabash and NIPSCO during the duration of the period in question. Consequently, NIPSCO would have been aware of any operations issues related to these relays, and there were no operational issues or mis-operations of the Protection System during the period in question.

Westar Energy, Inc. (Westar), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: PRC-005-1

Requirement: 1.2

Region: SPP

Issue: Westar, as a GO, TO and DP, submitted a self-report explaining that three of its power plants did not include a summary of maintenance and testing procedures in their Protection System testing and maintenance programs for station batteries.

Finding: The issue was deemed by SPP to pose minimal risk to BPS reliability. Even though Westar had no summary of station battery maintenance and testing procedures in its Protection System maintenance and testing program for three of its 13 plant locations, Westar's Protection System maintenance and testing program documentation was complete through the implementation of its Electrical Maintenance Manual. Also, Westar had performed visual inspections of the station batteries at the three 3 plants during the period of non-compliance, thereby further reducing the risk to the BPS.

Western Area Power Administration - Sierra Nevada Region (WASN), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 2

Region: WECC

Issue: WASN, as a TO, self-reported an issue with PRC-005-1 R2 to WECC when it found that it had not completed maintenance and testing of its DC control circuitry at one of its 15 substations within the defined intervals of its Protection System maintenance and testing program. This testing was not completed on time due to several equipment failures.

Finding: WECC determined that the issue posed a minimal risk to the reliability of the BPS because WASN performed maintenance and testing on its other Protection System devices at the substation at issue. Furthermore, WASN began maintenance and testing before the end of the defined interval, and was only unable to complete the process due to equipment failure. WASN took immediate steps to resolve the issues preventing testing when they were discovered, and testing was ultimately completed within two weeks of the required date. Finally, WASN also maintained and tested its Protection System devices in accordance with WASN’s defined intervals for the remainder of WASN’s 15 substations.

Western Farmers Electric Cooperative (WFEC), Docket No. RC13-9, May 30, 2013

Reliability Standard: PRC-005-1

Requirement: 1; 1.1; 1.2

Region: SPP RE

Issue: Further to a Compliance Audit, SPP RE determined that WFEC, as a GO, had an issue with PRC-005-1 R1.1 and R1.2 because WFEC failed to include in its generation protection system maintenance and testing program (Program) the maintenance and testing interval, and the basis or a summary of maintenance and testing procedures for one of its associated communication systems, a relay pilot wire system. WFEC had relied on the erroneous conclusion of its engineering consultant that the relay pilot wire system was not an associated communication system under the purview of the PRC-005 Protection System maintenance and testing Standard.

Finding: SPP RE determined that the issue posed a minimal risk to the reliability of the BPS because WFEC continuously monitored the relay pilot wire system via a line current differential relay which triggers alarms in the event of any loss of communications to a continuously manned plant control room. Furthermore, the relays at each terminal of the relay pilot wire system were being tested in accordance with WFEC’s Program. Lastly, the relay pilot wire system at issue constituted < 1% of WFEC’s Protection System devices.