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NERC FFT Reports: Reliability Standard PRC-005-1a
White & Case NERC Database
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Black Hills/Colorado Electric Utility Company, LP (BHCE), Docket No. RC12-16 (September 28, 2012)
Reliability Standard: PRC-005-1a
Requirement: 2
Region: WECC
Issue: BHCE, as a TO and DP, self-reported that it had failed to test and maintain one relay within its defined interval for a period of roughly 60 days (per R2). BHCE's unit in question should have been maintained and tested by February 13, 2012, however it was not tested until April 6, 2012.
Finding: WECC found the issue posed a minimal risk to the reliability of the BPS since the entity tested shortly following its scheduled five-year interval. In addition, the relay had a functioning backup in place that had been maintained and tested within its defined interval.
City of Cleveland, Dept. of Public Utilities, Division of Cleveland Public Power (CPP), Docket No. RC13-6-000 (February 28, 2013)
Region: RFC
Issue: CPP, a TO and DP, submitted a self-report in January 2012 stating that it did not timely complete monthly substation maintenance checks for 10 substations during October and November 2011 in accordance with its Protection System maintenance and testing program.
Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk. Any risk to BPS operations was mitigated because CPP completed the maintenance checks to all stations within 10 days of the intervals established in its Protection System maintenance and testing program. All equipment was found to be in working condition upon maintenance and testing and would have performed as required during the relevant time frame.
Commonwealth Edison Company (ComEd), Docket No. RC13-10, June 27, 2013
Requirement: R2; R2.1
Issue: ComEd, as a Distribution Provider, self-reported an issue with PRC-005-1a R2.1 to RFC when it found during the review of a daily preventative maintenance look-ahead report that Protection System maintenance tasks were identified as having a due date beyond their interval plus grace period as defined in the Protection System maintenance and testing program. The issue was due to an employee's keystroke error during data entry which changed the due dates for certain preventive maintenance tasks for four batteries from 2011 to 2012. As a result of the error, certain work orders were not generated on a timely basis.
Finding: RFC determined that the issue posed a minimal risk to the reliability of the BPS because the issue involve only four of 1,737 total batteries and 7,839 total Protection System devices, and ComEd performed all other battery maintenance and testing during the issue period. In addition, ComEd found no battery health concerns existed on the batteries at issue.
Florida Power & Light Co. (FPL), Docket No. RC12-15 (August 31, 2012)
Region: FRCC
Issue: On April 11, 2012, FPL, a TO, after an internal review of its Protection System maintenance and testing program, self-reported a violation of PRC-005-1a R2 for completing maintenance on one of its transmission substation battery banks four days after the interval-based due date. The due date for maintenance completion was September 30, 2011, but maintenance was completed on October 4, 2011.
Finding: This issue posed only a minimal risk to the reliability of the BPS for three reasons. First, the batteries were constantly monitored and were equipped with an alarm that would have alerted FPL personnel in the event of a voltage issue or an open battery bank. Second, testing and maintenance was overdue by only four days. Third, the batteries were fully functional when they were tested.
While FPL violated this Standard previously, the instant issue deserved FFT treatment because the oversight did not indicate a failure to mitigate its prior violation. The prior incident occurred in 2007, where a computer tracking error and misunderstanding of program flexibility regarding generator schedules and equipment outages caused FPL to fail to maintain and test a number of devices by its required interval due date. In response to the prior violation, FPL improved its processes and computer software. In contrast, the instant remediated issue resulted from insufficient training for contractors and personnel.
National Grid USA, Docket No. RC13-1 (October 31, 2012)
Requirement: 2/2.1
Region: NPCC
Issue: National Grid USA, in its role as a DP and TO, submitted a self-report in January 2012 disclosing a violation of PRC-005-1a based upon its failure to complete annual communication testing of a three-terminal transmission line pursuant to established intervals set forth in its Protection System maintenance and testing program due to scheduling issues. The date the annual communication testing should have been completed by was December 31, 2011, but National Grid USA did not complete the testing until January 27, 2012.
Finding: The issue was deemed by NPCC to pose minimal risk to BPS reliability because National Grid USA had conducted a limited inspection of its equipment associated with the transmission line. Risk to the BPS was mitigated by National Grid USA's inspection and testing on as much of its communications facilities as was possible without participation of the other entities. National Grid USA's system has built in redundancies, system monitoring, and system alarming to ensure reliable operations. The subject transmission line's has two fully independent high-speed relaying systems for line protection. No alarm conditions occurred during the period of violation, and system tests were completed with no issues reported 27 days past the expected date. In determining whether to impose FFT treatment, NPCC considered the compliance history of affiliates and the fact that they do not share compliance documents or responsibilities.
North Carolina Electric Membership Corporation (NCEMC), FERC Docket No. FERC Docket No. RC13-5-000 (January 31, 2013)
Region: SERC
Issue: NCEMC, as a GO, self-reported a violation of R2 of PRC-005-1a to SERC on January 25, 2012, in that it did not have documentation showing fourth quarter 2011 battery testing of two units as mandated by its Protection System maintenance and testing procedure for combustion turbine plants, which mandated testing unit batteries quarterly. However, NCEMC found that one set of quarterly test documentation could not be found. The violation happened at the same time that NCEMC started using a handheld test device in lieu of a fluke meter, pencil, and paper. SERC verified the violation by reviewing NCEMC's records of its Protection System devices for its GO and TO functions and the mandated maintenance and testing intervals, the date of the most recent test, and dates of previous tests for those devices.
Finding: SERC found that the issue posed a minimal risk to the reliability of the bulk power system because NCEMC had visible alarms on their batteries in case of ground trip, AC power low, and low DC voltage that would notify the plant operators in the plant control rooms, was able to demonstrate that sample cells used for November and December 2011 monthly testing reports met the Protection System maintenance and testing procedure requirements, was able to show that there were no subsequent issues in the next quarterly test.
Southern Power Company (SC), Docket No. RC12-14 (July 30, 2012)
Issue: SC, in its role as a GO, submitted a self-report in February 2012, explaining that for two months – September and October 2011 – it had no evidence that battery testing had been performed on a temporary battery bank as required by the Reliability Standard and SC's own maintenance and testing program.
Finding: The issue was deemed by FRCC to pose minimal risk to BPS reliability because the relevant batteries are monitored and alarmed to alert system operators of any issues. Operators make daily rounds to visually inspect the batteries. SC could not produce documentation for only two months of testing, and the issue involved only one battery bank out of 64 total battery banks. SC has three previous violations of this Standard, but FRCC determined FFT treatment was called for because the instant violation was not the result of SC failure to resolve the previous violations. SC undertook appropriate measures to mitigate the previous violations, including changing its preventative maintenance software so that batteries were tested pursuant to its Protection System maintenance and testing program, and SC implemented a system for proper recordkeeping of maintenance and testing. FRCC reported the instant violation was different because the batteries at issue here were part of a temporary battery bank, and SC operators were not aware they were subject to the same requirements as permanent battery stations. The violation period was three years, however, FRCC found it was not caused by a failure in SC's maintenance and testing program.
Triton Power Michigan, LLC (Triton), Docket No. RC13-6-000 (February 28, 2013)
Issue: Triton, in its role as a GO, submitted a self-report in February 2012 stating that it found two current differential relays had not been tested according to established intervals in its Protection System maintenance and testing program. Triton mistakenly believe the TO was performing the maintenance and testing on the relays.
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 the TO had performed maintenance and testing on an identical set of relays that can separate the Triton facility from the BPS. Also, Triton has other relays that protect its system, and those relays were tested as required. Finally, the relays were subsequently tested and no issues were reported.
Daniel Hagan
Partner|Washington, DC
Project Development and Finance, Energy, Regulatory & Compliance, Power, Financial Restructuring and Insolvency, Financial Institutions