Certrec’s NERC Penalties

Gila Bend Operations Company (GBOC) Assessed a $126,000 Penalty for Violations of FAC-008-3

March 3, 2023

Summary of NERC Penalties

REGION	WHEN?	ENTITY	REASON	VIOLATIONS	COMPLIANCE AREA	PENALTY AMOUNT
NERC	Quarter 1 09/30/19- 10/04/19	Gila Bend Operations Company (GBOC)	Lack of internal knowledge or expertise to draft and implement the FRM.	Facilities Design, Connections, and Maintenance (FAC) Standard	FAC-008-3 R2 and FAC-008-3 R6.	$126k

Summary:

During a compliance audit conducted September 30, 2019, through October 4, 2019, WECC determined GBOC, as a Generator Owner, had a potential noncompliance with FAC-008-3 R2 and FAC-008-3 R6. GBOC did not include the statement that a Facility Rating shall respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility, as required by FAC-008-3 R.2.3. the Facility Rating for each Generator Step-Up (GSU) transformer was not listed in the Facility Ratings appendix, and only six out of 12 GSU transformer Facility Ratings were shown on the one-line diagram. The highest Facility Rating for the six GSU transformers was used as the continuous rating in the element in Facility Ratings appendix, thus did not represent the most limiting element for those Facilities. The FRM also did not specify under what conditions each rating was meant to be used nor the time duration of such ratings, which was not consistent with one-line diagrams, as required by FAC-008-3 R2.2.3. The FRM did not identify clearly the Points of Interconnection (POI) with its Transmission Operator (TOP). The one-line diagrams showed that there were three disconnect switches with the TOP; however, the FRM does not specify how these ratings for jointly owned Facilities should be determined, as required by FAC-008-3 R2. 7. In addition, six metering current transformers (CTs) were not addressed in the FRM nor in the Facility Ratings appendix. Specifically, the Facility Ratings were not listed in the FRM for all metering CTs as elements of the 18 kV (low side) or the 525 kV (high side) circuits of the GSUs as required by FAC-008-3 R.2.4 and R.2.4.1. Lastly, jumpers and overhead conductors were not included. GBOC did not correctly determine the correct most limiting element for five Facilities. Also, GBOC had incorrectly converted from amps to MVA in its Facility Ratings appendix for several elements. According to the Settlement Agreement WECC assessed a penalty of one hundred and twenty-six thousand dollars ($126,000) for the referenced violations.

Additional Discussion:

WECC found several issues with GBOC’s Facility Ratings Methodology (FRM). WECC determined that GBOC’s FRM did not

include the statement that a Facility Rating shall respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility;

specify under what conditions each rating was meant to be used, and was not consistent GBOC’s one-line diagrams;

identify clearly the Points of Interconnection with the TOP or specify how ratings for jointly owned Facilities should be determined; and

have Facility Ratings listed for six current transformers as elements of the 18 kV (low side) or the 525 kV (high side) circuits.

Background

In June 2017, Salt River Project (SRP) acquired the Gila River Power Station (GRPS) Block 4 from Gila River Power, LLC, registered with NERC as Gila Bend Operating Company (GBOC), and in May 2018 SRP acquired the GRPS Blocks 1 and 2 from Sundevil Power. Previously, GBOC subcontracted its operational responsibilities to EthosEnergy, and in June 2018 operational responsibilities transferred to SRP.

Causal Information

The cause of this violation was lack of internal knowledge or expertise to draft and implement the FRM. WECC determined that the violations resolved in this Settlement Agreement collectively posed a serious and substantial risk to the reliability of the bulk power system (BPS).

Penalty Determination

WECC considered the following factors:

The violations of WECC2019022528 and WECC2019022529 collectively posed a serious and substantial risk to the reliability of the BPS;
GBOC accepted responsibility and admitted to the violation;
GBOC was cooperative throughout the compliance enforcement process; and
there were no other mitigating or aggravating factors or extenuating circumstances that would affect the assessed penalty/disposition method.

After consideration of the above factors, WECC determined that, in this instance, the penalty amount of one hundred and twenty-six thousand dollars ($126,000) is appropriate and bears a reasonable relation to the seriousness and duration of the violations.

Associated Files:

Public_FinalFiled_NOP_NOC-2766

About Certrec:
Certrec is a leading provider of regulatory compliance solutions for the energy industry with the mission of helping ensure a stable, reliable, bulk electric supply. Since 1988, Certrec’s SaaS applications and consulting expertise have helped hundreds of power-generating facilities manage their regulatory compliance and reduce their risks.

Certrec’s engineers and business teams bring a cumulative 1,500 years of working experience in regulatory areas of compliance, engineering, and operations, including nuclear, fossil, solar, wind facilities, and other Registered Entities generation and transmission.

Certrec has helped more than 200 generating facilities establish and maintain NERC Compliance Programs. We manage the entire NERC compliance program for 80+ registered entities in the US, Canada, and Mexico that trust us to decrease their regulatory and reputational risk. Certrec is ISO/IEC 27001:2013 certified and has successfully completed annual SOC 2 Type 2 examinations.

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