AICPA SOC Service Organizations - Certrec

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

Summary of NERC Penalties









Quarter 1



University Park Energy

PRC-005-2(i) R3

Protection and Control (PRC) Standard

Not all components were being maintained/tested as required


University Park Energy, LLC, submitted a Self-Report to ReliabilityFirst stating that, as a Generator Owner, it was in violation of PRC-005-2(i) R3. In July 2019, the entity engaged a third-party contractor to assess its NERC compliance program. As part of that review, the entity discovered that not all components were being maintained/tested, or maintenance and testing activities were not being documented, as required. In total, 23 percent of the entity’s components were affected by this issue.

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.

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.


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.

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 120 generating facilities establish and maintain NERC Compliance Programs. We manage the entire NERC compliance program for 60+ registered entities in the US and Canada 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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