NERC filed the settlement with the commission as part of its monthly spreadsheet notice of penalty at the end of December (NP24-4). FERC said in its filing Jan. 26 that it will not review the MRO settlement, along with an additional nonpublic spreadsheet NOP concerning infringements of NERC’s Critical Infrastructure Protection standards, leaving the penalty intact.
ATC owns and operates high-voltage transmission lines in Wisconsin, Minnesota, Michigan and Illinois. The settlement involves violations of FAC-009-1 (Establish and communicate facility ratings) and its successor FAC-008-3. According to MRO, the violations began in December 2009 and ended in August 2022, and involved facilities in both its footprint and that of ReliabilityFirst. However, NERC’s spreadsheet NOP did not indicate whether the regional entities would share the penalty.
The settlement says ATC submitted a self-report in October 2017 indicating that it was not compliant with FAC-008-3, followed by a second self-report involving two additional violations of the same standard in the first quarter of the following year. Because MRO determined that both violations began before FAC-008-3 became effective in 2013, the RE processed them under the earlier standard.
In the first self-report, ATC indicated that the rating for a winter season line segment was incorrect because the utility had not correctly recorded the segment’s temperature. The utility’s second submission reported a “bus section rating that did not reflect an equipment rating and a line conductor rating discrepancy that affected the transmission line facility rating.”
After discovering these issues, ATC ordered an independent evaluation of its data sets and found rating errors in 47 facilities — one substation and 46 transmission lines. MRO observed that this amounted to less than 5% of ATC’s total facilities.
Nineteen of the misratings were “lower than the actual rating of the most limiting element,” MRO said, which “and may have prevented system operators from utilizing the full capability of these facilities.” More serious were the 28 facility ratings that exceeded the most limiting element, which the RE said could have resulted in equipment overloads and damage to critical equipment.
Most of the equipment involved was never actually operated above the corrected rating; however, one 138-kV cranking path facility did exceed the corrected rating for five minutes at one point. MRO said this event posed a moderate risk to grid reliability because the involved line was part of the utility’s black-start restoration plan, although the RE also noted that the risk of damage to equipment was “highly unlikely” and that load on this segment would likely not reach its actual rating during a system restoration event.
ATC’s mitigation actions include updating its substation equipment and line database, correcting any incorrectly assigned relays, and updating procedure and process documents used in updating facility ratings. The utility also performed internal training, defined and documented its approach to quality checks, and completed evaluations and extent-of-condition reviews for its data sets and mitigation plans.
MRO gave ATC mitigating credit for self-reporting the issues and for cooperating in the enforcement process. The RE also considered the utility’s internal compliance program “as a mitigating factor in the penalty determination” because of its important role in the enforcement process. According to MRO the ICP empowers ATC’s employees to “go directly to the most senior leader and/or” the company’s Board of Directors, and “directs operational staff to be involved in the investigation of noncompliance and the creation of mitigation.”