FERC last week approved a $20,000 penalty against ITC Transmission, the result of a settlement between the entity and ReliabilityFirst over violations of NERC reliability standards (NP22-10).
RF filed the settlement with FERC Dec. 30 in a spreadsheet notice of penalty; the commission indicated on Friday that it would not review the agreement, leaving the penalty intact. FERC also approved two other nonpublic NOPs regarding unnamed registered entities (NP22-8 et. al), in accordance with the commission and NERC’s policy on violations of the Critical Infrastructure Protection standards.
ITC’s penalty stemmed from infringements of PRC-005-6 (protection system, automatic reclosing, and sudden pressure relaying maintenance) and PRC-023-4 (transmission relay loadability). Both violations involved protection system assets in six substations at the Dearborn Industrial Generation (DIG) site, which ITC acquired in 2018 from DIG, Ford Motor and the Cleveland-Cliffs mining company.
The utility reported the violations to RF in October 2019, admitting that it was not fully compliant with either standard. However, it laid blame for the shortcomings at the door of the previous owners. In the case of PRC-005-6, ITC informed RF that it had found maintenance had not been performed for 44 protection systems as mandated by requirement R3 of the standard. As a result, 29 protection systems were not compliant with the standard and required mitigation.
Bringing the affected systems into compliance took more than a year; ITC did not report completion of the work until Dec. 3, 2021. The utility reported that that remediation “took an extended amount of time because it [was] difficult to get outages for the industrial customers approved to perform the overdue maintenance.”
Similarly, ITC reported to RF that the previous owners had no internal controls for protection systems subject to PRC-023-4 and that it had discovered six protection schemes that were not compliant with requirement R1 of the standard, which requires that utilities prevent “phase protective relay settings from limiting transmission system loadability while maintaining reliable protection of the [bulk electric system] for all fault conditions.”
In this case, the violation had already ended when ITC performed a settings reset in July 2019, which brought all six relay settings into compliance.
RF said that neither violation posed a serious risk to the bulk power system, because the substations in question mainly serve industrial load, meaning that even if a failure had occurred, the impact on the BPS would be minimal. However, the regional entity also stated that the duration of the violations — both of which lasted more than a year — meant it could not classify their risk as minimal.
The RE also awarded ITC “a significant amount of internal compliance program credit” for its quick action to identify and report the violations, along with the “considerable resources” it spent to address the issues. RF said it hoped that this credit would “encourage this sort of behavior by ITC and other registered entities in the future.”
