November 8, 2024
FERC Approves $490K in Penalties for NERC Violations
PPL's headquarters building in Allentown, Pa.
PPL's headquarters building in Allentown, Pa. | PPL
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FERC last week approved settlements by NPCC and ReliabilityFirst leveraging $490,000 in penalties for violations of NERC reliability standards.

PPL Electric Utilities will pay $400,000 to ReliabilityFirst for violations of NERC’s reliability standards, according to a settlement approved by FERC last week (NP24-12).  

The commission also approved a settlement between the Northeast Power Coordinating Council and Constellation Energy carrying a $90,000 penalty (NP24-11). 

NERC filed the PPL-ReliabilityFirst settlement in a notice of penalty on Aug. 29. FERC indicated in a Sept. 27 filing that it would not further review the settlement, leaving the penalty intact. 

The settlement stemmed from a violation of FAC-003-4 (Transmission vegetation management), which aims to establish “a defense-in-depth strategy to manage vegetation located on transmission rights of way … and minimize encroachments from vegetation located adjacent to the ROW.” Requirement R2 of the standard mandates that applicable transmission owners (TO) and generator owners (GO) “prevent encroachments into the MVCD [minimum vegetation clearance distance] of [their] applicable lines.” 

According to the agreement, PPL submitted a self-report in September 2023, indicating the utility had experienced a sustained outage the previous month. The outage, which lasted about 10 hours, was the result of a cherry tree that grew into the MVCD of a conductor loop on PPL’s Susquehanna-Wescosville 500-kV line. PPL said the line “tripped to lockout because of this vegetation encroachment.” 

ReliabilityFirst said the utility had not been “sufficiently modeling conductor loops located at transmission poles” in its transmission vegetation management program (TVMP). The TVMP used light detection and ranging data, along with foot patrols, to determine potential future vegetation issues, but PPL’s 3D model did not capture the conductor loops, leaving “blind spots” where vegetation growth was not monitored.

In the agreement, ReliabilityFirst observed that PPL’s violation “occurred nearly 20 years following the 2003 Northeast Blackout,” a major cause of which was trees growing into transmission rights of way. The regional entity noted that FAC-003 was one element of the ERO’s response to the 2003 blackout, and that compliance with the standard “is a fundamental expectation of industry.” ReliabilityFirst said the violation “posed a serious risk to the reliability of the” electric grid. 

To mitigate the issue, PPL removed the tree that caused the outage and restored the affected line. It then performed a gap analysis on its TVMP to find potential areas for improvement, updated its models so LiDAR data will better reflect the reality of the system, updated its TVMP, and completed an extent of condition plan to identify and address any additional issues. The utility certified its completion of mitigation activities to ReliabilityFirst on Jan. 22, 2024. 

NPCC Settles Nuclear Plant’s Issues

NPCC’s settlement was filed in NERC’s monthly spreadsheet notice of penalty Aug. 29. FERC’s Sept. 27 filing said it also would not review this agreement. 

In the settlement, the RE asserted the utility violated three requirements of PRC-023-4 (Transmission relay loadability), which were filed as three separate infringements in the spreadsheet NOP. The infringements involved the utility’s nuclear energy division and its facilities at the Nine Mile Point Nuclear Generating Station: Nine Mile Point Unit 1 (NMP1), Nine Mile Point Unit 2 (NMP2) and the James A. FitzPatrick Nuclear Power Plant (JAF).  

Constellation submitted a self-report for the three violations July 14, 2020, the settlement said. The report indicated that two protective relays at JAF “were misclassified by the previous owner.” According to Constellation, the relays were load responsive and therefore should have been categorized under PRC-023-4, Requirement R1. In a subsequent extent of condition review, the utility found a 115-kV line overcurrent relay at NMP1 also was noncompliant. 

Along with this infringement, Constellation said it was in violation of Requirement R3 for failing to agree with its planning coordinator on the use of two 115-kV lines at NMP2. Constellation owns 82% of NMP2, with the rest held by the Long Island Power Authority; however, Constellation is the sole operator of Units 1 and 2. 

Finally, Constellation told NPCC that it had “failed to provide its [PC], transmission operator and reliability coordinator with an updated list of circuits associated with the applicable JAF transmission line relays,” a violation of PRC-023-4 Requirement R4. The utility indicated it had found two separate instances of noncompliance: the first from January 2018 to November 2019, caused by a failure of the previous owner’s preventive controls, the second from January to April 2022, caused by a failure of the utility’s notification controls. 

To mitigate the issues, Constellation outlined its strategies for modifying preventive relay settings and completed an extent of condition review for the JAF and NMP1 units, enhanced its guidance for implementation of NERC standards on the NMP2 case and generated a recurring activity to track compliance with R4. 

NPCC noted that Constellation’s self-reporting and cooperation during the investigation process, lack of previous noncompliance with the standard and willingness to settle the matter as factors in penalty assessment. It also noted that no events or harm occurred during any of the noncompliances. 

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