Certrec’s NERC Penalties

NERC Focus on Violation Risk Evident in Quarter 1 of 2022

February 2, 2023

Summary of NERC Penalties

When?	Notices	Violations	Compliance Area	Penalty Amount
Quarter 1, 2022	Five full NOPs	Six violations	O&P Reliability Standards	$841,000
Quarter 1, 2022	Six full NOPs	91 violations	CIP Reliability Standards	-
Quarter 1, 2022	Two SNOPs	Four violations	O&P Reliability Standards	$132,000
Quarter 1, 2022	Three SNOPs	16 violations	CIP Reliability Standards	-

Summary:

In Quarter 1 of 2022, NERC filed five Full NOPs (Notice of Penalty) with FERC that included six violations of the operations and planning (O&P) Reliability Standards, carrying a total penalty of $841,000. NERC filed six Full NOPs in Quarter 1 of 2022 that included 91 violations of the CIP Reliability Standards. Additionally, in Quarter 1 of 2022, NERC filed two SNOPs (Spreadsheet Notice of Penalty) with FERC that included four violations of the O&P Reliability Standards, carrying a total penalty of $132,000. NERC filed three SNOPs in Quarter 1 of 2022 that included 16 violations of the CIP Reliability Standards.

Additional Discussion:

Full NOPs
The O&P Full NOPs filed in Quarter 1 of 2022 addressed a mix of serious and moderate risk violations, including failures to

maintain sufficient alarm management for the Real-time Contingency Assessment system.
implement and maintain accurate Facility Ratings.
implement and maintain accurate methodology for determining Facility Ratings, including failure to adhere to the most limiting applicable equipment rating, identify points of interconnection, and specify conditions for use.
provide timely and accurate information to the Balancing Authority regarding unit availability.

SNOPs
The O&P SNOPs filed in Quarter 1 of 2022 addressed moderate risk issues, including failures to

maintain visibility into remote terminal unit and Inter-Control Center Communications Protocol (ICCP) data during a planned outage, and resulting failure to perform a Real-time Assessment.
timely recognize and respond to SCADA alarms to maintain reliability of transmission operations.

NOTE: CIP Violation Data (additional information beyond what is presented here) is not publicly available.

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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