By Holden Mann and Rich Heidorn Jr.

FERC on Wednesday accepted NERC Notices of Penalty against the Bonneville Power Administration, Idaho Power and the Niles Light Department. There were no monetary penalties.

The commission said it would not review NP20-5 regarding BPA or NP20-6, a spreadsheet NOP. The spreadsheet included 16 critical infrastructure protection (CIP) violations against unnamed entities reported by the Western Electricity Coordinating Council and ReliabilityFirst, which were redacted to protect sensitive information about how the entities implemented controls to address security risks. Five of the violations included financial penalties totaling $525,000.

Bonneville Power Administration

BPA was cited for two incidents, the first in September 2015, when it discovered that the rating on one of its current transformers (CT) was lower than the facility ratings of two associated transmission lines. The CT should have been rated as the most limiting element when BPA established the facility ratings. However, the utility’s rating methodology assumed CT equipment “to be sized such that it would never be the most limiting element in a facility.”

According to a NOP filed Dec. 30, after BPA reported the discovery to WECC, the regional entity performed an analysis that revealed similar issues in at least 52 facilities, at least six of which were part of one or more of WECC’s major transfer paths (NP20-5). The widespread failure to effectively determine facility ratings violated the FAC-009-1 standard. Although WECC found that the violation “posed a serious risk to the reliability of the bulk power system,” BPA is not subject to monetary penalties, in accordance with a D.C. Circuit Court of Appeals ruling that FERC and NERC cannot impose such penalties against federal governmental entities.

The RE noted that the incident constituted BPA’s first violation of the standard in question; BPA self-reported the violation and cooperated during the enforcement action; there was no evidence of any attempt to conceal the violation or intent to do so; and the violation did not cause or extend a loss of load. BPA typically operates its system conservatively, and the affected facilities were never in danger of exceeding a system operating limit.

In addition, BPA has since implemented a mitigation plan approved by WECC to prevent future incidents. In a separate incident, BPA submitted a self-report in May 2017 saying it may have failed to comply with six transmission operator (TOP) and interconnection reliability operations and coordination (IRO) requirements resulting from an outage on Nov. 30, 2016. BPA implemented the outage as part of its boundary remedial action scheme (RAS), which includes line-loss logic for three transmission lines.

BPA did not correctly implement the study limit information memo (SLIM) required by its operating plan, which specified that a 650-MW system operating limit (SOL) should be set at the one boundary’s flowgate.

Although a dispatcher limited output of the main generating station on the lines to 650 MW, BPA did not lower the boundary SOL from 1,300 MW to 650 MW.

Because the lower SOL was not entered in the control system, the alarm monitoring did not alert to three SOL exceedances between 2:15 and 2:45 p.m.

WECC said the incident, which posed a “moderate” risk, resulted because the dispatcher mistakenly relied on a dispatch standing order rather than the SLIM.

“BPA was already operating its system with the RAS in a degraded state. If BPA were to have lost another line, the RAS could have caused a loss of load and potentially opened the remaining lines entirely,” WECC said.

It credited BPA for discovering the mistake during a routine monitoring activity nine days after the incident and said the 650-MW limit on the generating station reduced the risk.

Idaho Power

Idaho Power submitted a self-report on July 24, 2018, saying it may have failed to comply with PRC-005-2(i) R3 by failing to maintain a battery used to power communications equipment during an emergency outage at a 230-kV substation for two 18-month intervals.

The vented lead acid battery was maintained in June 2014, but the company missed its 18-month maintenance interval on Jan. 1, 2016, and did not correct the error until July 2017.

WECC said the problem resulted when a transmission and distribution engineer disabled the battery maintenance trigger because he thought the utility’s communications group was responsible for tracking the maintenance and testing. The communications group had not been notified of the change in responsibility, the RE said.

The violation posed a minimal risk because the battery voltage was continuously monitored by the energy management system, which would have produced an alarm had a battery failure occurred.

WECC said the company’s PRC-005 compliance history was an aggravating factor in the incident but imposed no monetary penalty.

Niles Light Department

During a compliance audit in spring 2018, ReliabilityFirst determined that the Niles Light Department, the distribution provider for the Ohio city, had violated COM-002-4 R3 by failing to conduct initial training for each of its operating personnel who can receive oral two‐party operating instructions.

The city did not train three individuals until March 1, 2018, although they had been receiving operating instructions from FirstEnergy before then. The training requirement was effective July 1, 2016.

The risk of harm to the grid was partially reduced because Niles’ personnel only receive operating instructions in the presence of FirstEnergy operators with written switching orders. “Although entity personnel had not been formally trained on how to receive an oral two‐party, person‐to‐person operating instruction, the entity indicated that personnel performed three-part communication in practice when receiving operating instructions,” ReliabilityFirst said.

Niles misinterpreted the standard, believing that its established communication process with FirstEnergy meant it did not need to train its own personnel.

The audit also found Niles in violation of PRC-005-2(i) R3 for failing to conduct all required testing for a battery and charger. Niles failed to perform an unintentional ground test (required every four months); a battery terminal connection resistance test (required every 18 months); a battery intercell or unit-to-unit connections resistance test (18 months); and load tests (every 18 months and every six years).

RF said Niles failed to update its protection system maintenance program with the new tests as required.

“The risk is partially reduced because the entity was performing quarterly tests and monthly tests on the protection system equipment and that testing would likely indicate to the entity any battery degradation before failure occurred,” RF said, noting the city’s peak load is only 68 MW.