Cooperative Energy Noncompliant with FAC-008-5 R6; Received $20,000 Penalty

Summary:

Cooperative Energy (CoEn) notified SERC that it was noncompliant with FAC-008-5 R6. CoEn failed to have Facility Ratings for its solely and jointly owned Facilities that are consistent with the associated Facility Ratings Methodology (FRM) or documentation for determining its Facility Ratings. This noncompliance began under FAC-009-1 R1 and spanned to FAC-008-5 R6. On October 13, 2023, during the substation facility walkdown, CoEn observed 161 kV gas circuit breaker (GCB) 1592 did not have a Current Transformer Rating Factor (CT RF) on the CT nameplate. In addition, the group noted the GCB did not have the same manufacture date as the other four 161 kV circuit breakers at the facility. The four newer 161 kV GCBs had a CT RF of 1.5 stamped on the CT nameplates. Transmission Planning reviewed the walkdown notes and sent CT nameplate pictures of GCB 1592 for review and confirmation. On October 18, 2023, CoEn reviewed the nameplate and electronic documentation. The group located electronic documentation for GCB 1592. This documentation did not provide a CT RF. Because of lack of information for CT RF on GCB 1592, a conservative CT RF of 1.0 must be utilized instead of the CT RF of 1.5 that was in the system information database (SID) for GCB 1592. CoEn made a request to the manufacturer to provide the CT RF of the circuit breaker CTs. The manufacturer could not verify the CT RF based on the information available. On October 31, 2023, the Transmission Planning group notified CoEn Compliance of the potential noncompliance. CoEn failed to properly calculate the rating of Line 173 due to the CT RF used in the CT Rating calculation for GCB 1592 CTs in its SID. Line 173 required a derate from 273 MVA to 223 MVA. Reducing GCB 1592 CT RF from 1.5 to 1.0 while using the CT ratio 800:5 made GCB 1592 CTs the most limiting equipment rating on Line 173. This reduced the true rating on Line 173 from 273 MVA to 223 MVA. On November 8, 2023, CoEn changed the CT tap settings from 800:5 to 1200:5 to return to compliance. Using the 1200:5 CT ratio with an assumed CT RF 1.0, the most limiting equipment rating is the designed temperature of the line. Currently, Line 173 has a rating of 273 MVA. There were no exceedances. On February 6, 2024, Transmission Planning completed 100 percent of the substation walkdowns. It did not discover any additional CT RF issues that affected the MLE. CoEn also determined that reverification should be completed of elements that were previously walked down but since then had field work performed necessitating an in-person verification of the equipment. CoEn determined elements at five Facilities needed to be reverified. On May 13, 2024, CoEn completed its extent of condition (EOC) assessment and confirmed that it did not discover any additional CT RF issues that affected the MLE. The assessment consisted of physically walking down Facilities and confirming that it used the correct CT RF Ratio values in the calculation of the Facility Ratings. This violation started on June 18, 2007, when CoEn failed to have Facility Ratings for its solely and jointly owned Facilities that are consistent with the associated Facility Ratings methodology or documentation for determining its Facility Ratings, and ended on November 8, 2023, when CoEn changed the CT tap settings from 800:5 to 1200:5. The duration was 5,987 days (16 years, four months, and three weeks).

Additional Discussion:

Cause

The cause for this violation was an ineffective training program. Specifically, CoEn did not provide staff with appropriate training to recognize that the breaker in question, while manufactured by the same company, was an older model breaker based on electronic documentation. Thus, the SME attributed the wrong RF value/CT Ratio to GCB 1592.

Disposition

SERC considered CoEn’s repeated compliance failures involving FAC-008-5 R6 and FAC-009-1 R1 to be an aggravating factor in the penalty determination. Although one prior noncompliance is distinguishable from the current issue because the cause of this issue was different than that of the earlier prior noncompliance (procedural deficiency), SERC is aggravating for CoEn’s other relevant prior violation. Following the 2021 SERC audit finding, CoEn updated its SID to include CT Ratio data for incorporation into Facility Rating calculations, completed field work to eliminate CT Ratio limitations, and de-rated all remaining affected lines that it identified in the EOC. During the 2021 EOC assessment, CoEn determined the CT on GCB 1592 was the most limiting equipment for Line 173 at the 400:5 tap setting. During relay upgrades, the System Protection group moved from the 400:5 to the 800:5 on GCB 1592. This mitigating action was flawed because of the CT RF used to calculate the CT Rating on GCB 1592. The CT RF cannot be verified for GCB 1592 by the manufacturer or any nameplate or documentation. The CT RF value used in the calculation was obtained from electronic documentation for newer 161 kV GCBs located at the substation. CoEn moved to a more conservative CT RF for GCB 1592 due to the CT RF being unverifiable. Since the initial EOC, CoEn revised its policy for making changes to the SID. The changes, including a new data validation process, could have potentially caught the issue. Therefore, SERC is aggravating the penalty because the results of the prior mitigation plan failed to detect or further prevent the instant violation.

SERC reviewed CoEn’s Internal Compliance Program and considered it to be a neutral factor in the penalty determination.

CoEn has been highly cooperative throughout the entire enforcement process relating to this violation. Throughout the enforcement process, CoEn voluntarily provided SERC with information that was timely, detailed, thoughtful, organized, and thorough. CoEn fully cooperated in SERC’s investigation of the violation and all associated mitigating activities and openly shared information regarding its processes, procedures, internal controls, assets, systems, and organization. Thus, SERC applied cooperation credit.

CoEn self-reported the violation. Effective oversight of the reliability and resilience of the BES depends upon self-reporting by Registered Entities. SERC seeks to encourage self-reporting of offenses and, therefore, is applying mitigating credit for the violation.

SERC awarded penalty credit because CoEn agreed to settle the violation resolved by this Agreement thereby avoiding a hearing on this matter. A willingness to resolve cases without the need for a trial-type hearing reduces the amount of time and resources that SERC, NERC, and the Commission time would otherwise expend to resolve these violations. Additionally, it is important to promote prompt resolution of enforcement actions so that CoEn can focus on mitigation and reducing risks to reliability.

CoEn recognized and affirmatively accepted responsibility for its conduct by admitting to the Alleged Violations resolved by this Agreement. SERC is applying mitigating credit since there is independent value in organizations accepting responsibility for their violations. A penalty in the amount of $20,000 was assessed.