University Park Energy’s $32,000 Penalty For Violation of PRC-005-2(i) R3

The specific problems are described below: 

(a) For potential transformers (PTs) and current transformers (CTs), maintenance documentation for Units 1-6 could not be found; 

(b) For DC control circuitry, maintenance documentation for Units 1-6 could not be found; 

(c) For DC supply systems, maintenance documentation for both the 4-month and 18-month battery maintenance activities was not found; and (d) For sudden pressure relays, maintenance documentation for Units 1-6 could not be found.

Cause
The root cause of this noncompliance involved inadequate management review and oversight to ensure that required maintenance activities were completed and appropriate records were generated and retained. This root cause involves the management practices of grid maintenance, which includes monitoring maintenance performance, and external interdependencies in that the entity utilizes a contractor to manage and perform the requisite maintenance.

The violation began on October 1, 2015, the date University Park was required to comply with PRC-005-2(i) R3. The violation ended on May 21, 2021, the date University Park completed its Mitigating Activities.

Disposition

Effective oversight of the reliability of the Bulk Electric System depends on robust and timely self-reporting by Registered Entities. The entity identified and reported the violation as a result of an internal review of their compliance program. Because ReliabilityFirst seeks to encourage this type of self-reporting, it awarded the entity mitigating credit for its self-disclosure.

ReliabilityFirst considered the entity’s relevant compliance history and determined that prior issues with PRC-005-1 (i.e., RFC2012010353 and RFC2012010354) should serve as an aggravating factor in the penalty determination because the entity’s affiliated company failed to sustain the mitigating actions it implemented in response to those prior issues. A penalty of $32,000 was levied.