FERC last week approved penalties totaling $344,000 against three utilities as part of settlements between them and WECC for violations of NERC reliability standards, along with a $192,000 penalty assessed by the Texas Reliability Entity against Oncor Electric Delivery.

The commission also approved settlements between ReliabilityFirst and the Twin Ridges Wind Farm in Pennsylvania , and between an unnamed utility and registered entity for a violation of NERC’s Critical Infrastructure Protection (CIP) standards (NP21-3). The CIP violation is being kept confidential in accordance with FERC and NERC’s new policy on the treatment of such information announced last September. (See FERC, NERC to End CIP Violation Disclosures.)

NERC submitted the settlements to the commission Nov. 30, filing separate Notices of Penalty for the settlement between WECC and Southern California Edison (NP21-4) and the unnamed entity, and a spreadsheet NOP that included Twin Ridges, Oncor and the other WECC utilities (NP21-2). FERC indicated last Wednesday that it would not review the NOPs, leaving the settlements intact.

Tree Inspection Leads to SCE Penalty

SCE’s $296,000 settlement with WECC involves two violations of FAC-003-3 (Transmission vegetation management), both involving the same transmission right of way in the Sierra National Forest. The first incident, involving requirement R2 of the standard (requiring transmission and generator owners to prevent interference with their lines by vegetation) was self-reported. WECC discovered another violation of requirement R6 (requiring 100% of transmission lines to be inspected for vegetation encroachment at least once a year) in a compliance audit.

In the first case, a third-party contractor for SCE performing a routine pre-inspection for vegetation management in August 2017 observed that a tree might be encroaching on the minimum vegetation clearance distance (MVCD) of a 220-kV transmission line originating in the utility’s Rector Substation. However, because of heavy brush growth on the line’s right of way the inspector could not get close enough for an accurate measurement.

SCE technicians later went out to inspect the line in a helicopter but were again unable to get a good view. It was only after ground crews managed to clear a path to the line that SCE could confirm that the tree was indeed within the MCVD. The utility sent a crew to remove the tree the day after the issue was first identified.

WECC attributed the root cause of the violation to SCE’s “misinterpretation of the expectation for a vegetation inspection” and failure to perform a systematic examination of vegetation conditions for the area, resulting in fast-growing plants obscuring the view of the tree in the MCVD. The regional entity determined that the violation posed a moderate risk to reliability of the bulk power system.

In addition to removing the tree, SCE took a number of other steps to mitigate the issue. These included performing emergency field inspections on transmission circuits in the same area to detect potential MVCD encroachments — of which none were found — developing a process for reporting inaccessible areas, improving training for pre-inspection and line-clearing work, and updating its right-of-way maintenance and vegetation plan.

WECC found the violation of requirement R6 during an October 2018 audit, in which the RE examined SCE’s records of vegetation inspections of the line in the prior MVCD incident. While SCE had completed aerial vegetation inspections of the relevant areas in 2015 and 2016, WECC could not find evidence that inspectors had taken sag and sway of the transmission line into account and, thus, could not verify that the inspection was complete. The same was true of SCE’s ground inspections, the RE found.

SCE’s mitigation measures for this violation included contracting for a light detection and ranging survey of most of the 220-kV lines in the area to ensure it detected all vegetation issues and updating its transmission vegetation management plan to account for sag and sway.

SMUD, SPS Face WECC Criticism

WECC’s other settlements were with the Sacramento Municipal Utility District (SMUD), for $26,000, and sPower Services (SPS), an independent power producer headquartered in Utah, for $22,000.

The SMUD settlement arose from violations of FAC-008-3 (Facility ratings), discovered by WECC during a September 2019 compliance audit. The RE determined that SMUD had incorrectly applied the standard’s requirements both as a generator owner and a transmission owner.

On the generation side, the facility ratings methodology that SMUD used for eight of its generation facilities did not state that “the demarcation for generation facilities must extend from the high-side terminals of the main step-up transformers to the point of interconnection with the TO,” in this case SMUD itself. This oversight could have resulted in the utility’s facility ratings being incorrectly calculated, though auditors reported that the generator facilities in question were rated appropriately.

As a TO, SMUD did not “explicitly describe which of its transmission facilities were jointly owned.” As a result, according to WECC, the utility could not clearly describe how it rated these 12 facilities with their joint owners, though the RE noted that SMUD “provided evidence that all components that make up its jointly owned transmission facilities were rated appropriately” and that the utility did coordinate with neighboring entities in some form.

Both violations posed a moderate risk to the BPS, WECC determined, noting that because it found no issues with the affected equipment, SMUD’s infringement appeared to be limited to failing to document its procedures. In response the utility revised its ratings methodology for both generators and jointly owned transmission facilities, in addition to updating its definition of jointly owned facilities. It also added a requirement to annually request updates from neighboring entities on any facilities that they might share with SMUD and ensure their ratings are verified.

The SPS settlement applied to four separate violations of VAR-002-4.1 and its predecessor VAR-002-4, both of which govern generator operation for maintaining network voltage schedules; the violation of VAR-002-4 occurred before the current standard was adopted in September 2017.

SPS self-reported all of the violations, starting with an incident on March 10, 2017, and continuing with reports in March 2018, September 2018 and November 2019. All reports were for the same issue: failing to notify the transmission operator of a status change on the automatic voltage regulation (AVR) in one of its wind or solar facilities within 30 minutes of the change, as required by the standard.

The violations had various causes, WECC concluded. In one case the RE attributed the infringement to “an unreliable communications path from the generating unit to the control room,” while another was from the generating unit’s supervisory control and data acquisition controller “not being properly commissioned by [its] vendor.” All violations concluded within one hour except for one, which lasted for about 18 hours.

WECC determined that all of the violations posed a minimal risk to the BPS. Mitigation measures by SPS included updating its systems to ensure that AVR status changes are properly communicated, implementing software to ensure involuntary changes are detected, and replacing faulty equipment.

Oncor also Cited for Ratings Issues

The Texas RE-Oncor settlement also stems from violations of FAC-008-3, discovered in an audit in November 2017. The RE reported that 22 Oncor transmission facilities had ratings that were inconsistent with its reported ratings methodology. Oncor was also cited with a separate violation for vailing to “provide accurate and timely facility ratings data to its associated reliability coordinator, ERCOT.”

Texas RE attributed both violations to failure of internal controls at Oncor. In the first case, the utility’s ratings methodology was said to “[lack] sufficient processes to track and timely reflect equipment ratings changes.” For the second infringement, the RE noted that while Oncor had a procedure to preform weekly comparisons between its facility ratings and the corresponding ratings in ERCOT’s network operations model, the utility did not adequately ensure that its rating changes were submitted in a timely fashion to address identified discrepancies.

Both violations were found to pose a moderate risk by Texas RE, though it noted that Oncor has a history of compliance issues with reliability standard IRO-010-1a (Reliability coordinator data specification and collection), which has since been replaced by IRO-010-2. In that case the utility was determined to have failed to provide ERCOT with accurate rating data for 10 of its facilities over a period of more than four years. Texas RE considered this an aggravating factor in determining the penalty amount.

To mitigate the infringement, Oncor corrected the incorrect facility ratings and implemented a new project tracking and communication application to consolidate the previously separate systems that it used for initiating and executing transmission projects. It also revised its rating discrepancy review and commissioning process to ensure that discrepancies are tracked, reviewed and resolved quickly, and that “assets are energized in the field only after a proper ERCOT model topology and rating review.”

RF Scolds Twin Ridges for Missing Documents

RF’s settlement with Twin Ridges originated from a spot-check conducted July 8-19, 2019, during which it found the facility to be in violation of PRC-019-2 (Coordination of generating unit or plant capabilities, voltage regulating controls, and protection).

During the spot-check, RF could not verify that Twin Ridges had properly coordinated its generating facilities because of the absence of “dated documents that would demonstrate that the facility coordinated the voltage-regulating system controls … with the applicable equipment capabilities and settings of the applicable protection system devices and functions.” The RE determined that neither the current owner of Twin Ridges nor its previous owner — neither of which was named in the filing — were aware that the entity was not compliant with the standard.

Once RF discovered the noncompliance, Twin Ridges contracted with an outside engineering firm to perform a coordination study and determine whether it needed to change any of its procedures, with the firm reporting that none were required. It also engaged in a separate review of its compliance program to verify this assessment, which also confirmed that no further mitigating activities would be necessary.

Although the violation had a long duration — beginning in July 2016 when the standard took effect and ending in February 2020 when mitigating activities concluded — RF determined that the risk posed was moderate. This is particularly evident in the fact that no changes were required when the coordination was finally performed. As a result, no monetary penalty was assessed.