Valley Electric Association, Inc. (VEA) Awarded a $50,000 Penalty for FAC-008-3 R6 Violation

Summary:

During a Compliance Audit, WECC determined Valley Electric Association, Inc. (VEA), as a Transmission Owner, had a potential noncompliance with FAC-008-3 R6. Specifically, seven of VEA’s 13 138 transmission Facilities were sampled for a detailed review. VEA provided the requested Facility Ratings database spreadsheet. During their review, WECC Auditors found discrepancies across the sampled transmission line Facilities. One of the 138kV transmission lines had three different Facility Ratings, which included the Facility Rating from VEA’s original database spreadsheet (196 MVA), one Facility Rating from a data request (143 MVA), and one Facility Rating from the WECC base case (191 MVA). VEA verified that the element causing the discrepancy at one switching station was owned by Department of Energy (DOE) and DOE had released a new rating for the switch, but the ratings from DOE engineering drawings were not communicated internally at VEA or used to update the Facility Rating. In addition, several circuit breakers and disconnect switches were missing from the database that were on the one-line diagrams, and elements that were in the database were not on the one-line diagrams. As well, conductor jumper ratings were not included in the database for one substation. Bus work was not included for two substations but were added to the database during the audit. VEA provided a revised database during the audit with the noted corrections herein, however the revised database was compared to the one-line diagrams dated November 20, 2018 and CTs were missing from the revised database. VEA later provided the CTs for each circuit breaker in subsequent data requests. This violation began on January 1, 2013, when the Standard became mandatory and enforceable, and will end when mitigation is complete.

Additional Discussion:

Cause

The root cause of the violation was attributed to an incomplete understanding of the Standard as well of a lack of formal written and verbal internal procedures, communication, training and coordination between internal departments.

Disposition

WECC reviewed VEA’s Internal Compliance Program (ICP) and considered it to be a neutral factor in the penalty determination. Although VEA does have a documented ICP, WECC determined that it was not effective in preventing or detecting this violation.

WECC provided credit for VEA’s cooperation and for agreeing to settle and admit to the violation.

WECC determined that VEA’s compliance history should not serve as a basis for aggravating the penalty because the previous violation was a result of the NERC Standards becoming mandatory and enforceable and did not indicate a systemic issue or programmatic failure. A $50,000 penalty was awarded.