SERC Reliability has levied penalties totaling $320,000 against Dominion Energy (NYSE:D) subsidiary Virginia Electric and Power Co. for violations of NERC reliability standards, according to a pair of settlements between the utility and the regional entity approved last week by FERC (NP23-9).
NERC filed the settlements Dec. 29 in its monthly Spreadsheet Notice of Penalty. On Friday the commission said that it would not further review the filing, leaving the penalties intact.
SERC assessed separate penalties against the utility’s generation and transmission divisions (respectively dubbed VEP-PG and VEP-Trans in the filing). Both involved infringements of FAC-008-3 (Facility ratings) and its predecessor, FAC-009-1 (Establish and communicate facility ratings), and were self-reported.
According to requirement R1 of FAC-009-1, generator owners (GO) and transmission owners (TO) must “each establish facility ratings for [their] solely and jointly owned facilities that are consistent with the associated facility ratings methodology” (FRM). Requirement R6 of the successor standard — which became effective in 2013 and has since been superseded by FAC-008-5 — contains nearly identical language.
Virginia Electric initially reported to SERC that, as both a TO and GO, it was in violation of FAC-008-3. The RE later determined that the infringement began under the earlier standard.
During an extent-of-condition assessment on April 2, 2020, caused by a suspected FAC-008-3 violation at a solar facility, VEP-PG found that the low-side and high-side cables in the facility’s generation step-up transformer had not been included in its facility ratings calculation, as required by the FRM. The utility subsequently performed a walk-down of all 102 facilities to which FAC-008-R6 applied, discovering 41 incorrect ratings that resulted in 28 uprates of up to 200%, and 13 derates of up to 33.14%.
VEP-Trans discovered its violation on Nov. 13, 2019, during an internal data validation process. According to its self-report, the utility found that the facility rating for a 500-kV networked line was inconsistent with the FRM because the rating had been changed during an upgrade without confirming the change was made in the field.
After SERC requested that VEP-Trans walk-down four transmission stations to check their ratings, the utility found 40 incorrect ratings. It then began a full system walk-down of all its bulk electric system transmission facilities on June 1, 2021. The full walk-down is expected to be completed by June 2025, but according to SERC’s filing, VEP-Trans had reviewed 244 facilities by Sept. 29, 2022, discovering misratings at six of them.
SERC concluded that the violations by both VEP-PG and VEP-Trans posed a moderate risk to the reliability of the bulk power system on the grounds that “incorrect ratings could cause system instability because planning models and system operating limits would not accurately reflect the true limits of the facility.” In the case of VEP-PG, the RE did note that the length of time of the violation and the number of affected facilities were aggravating factors.
Mitigating actions by VEP-PG include revising its FAC-008 compliance procedure document, along with other internal documents, implementing an “over-arching power generation document … to ensure consistency fleet-wide,” and conducting training on change management documents and requirements. VEP-Trans’ mitigation steps include conducting a third-party review of its facility rating process and streamlining its notification process, along with the full walk-down of its facilities.
SERC noted several credits to both VEP-PG and VEP-Trans for self-reporting the violations and demonstrating a high level of cooperation. However, it still assessed penalties of $130,000 against VEP-PG and $190,000 against VEP-Trans.
