Duke Energy Renewable Services’ (DERS) NOTWIN001 Noncompliant with MOD-025-2 R1; R1.2 Resulting in $20,000 Penalty
Summary of NERC Penalties
REGION | WHEN? | ENTITY | COMPLIANCE AREA | VIOLATION | REASON | PENALTY AMOUNT |
|---|---|---|---|---|---|---|
SERC | Quarter 4 - December 2023 | Duke Energy Renewable Services (DERS) | SERC's Regulations | MOD-025-2 R1; R1.2 | Duke Energy Renewable Services (DERS), a leading renewable energy services provider, faced a compliance issue stemming from a deficient fleet-wide management approach to MOD-025. They failed to submit a completed Attachment 2, or a form containing the same information, to its Transmission Planner within 90 calendar days of the date the data was recorded for a staged test thus violating the requirements of MOD-025-2 R1; R1.2 which are mandatory parts of SERC's regulations. | $20,000 |
Cause
For the extent-of-condition (EOC) assessment, DERS reviewed MOD-025-2 documentation across the DERS fleet from 2016 through March 2023. DERS confirmed initial Real Power verification test dates and secondary test dates, where applicable, for all MRRE Group #15b Generator Owners, and verified whether submission of the verification data occurred within 90 days of the Real Power verification test. The EOC identified six additional registered entities that did not meet the compliance requirements, all of which were individually self-reported to SERC. As part of its mitigation, DERS will also conduct an Enterprise-wide EOC on evidence submitted to TPs/Planning Coordinators (PCs) including registration date and implementation date information and report any additional findings to SERC.
The cause of this noncompliance was an inadequate fleet-wide compliance management approach to MOD-025. Personnel responsible for the oversight of the compliance activities lacked training and awareness on MOD-025, which resulted in the deficient procedures, unmaintained controls, and inadequate compliance training across multiple Generator Owners. The MOD-025 procedure did not have clearly defined roles and responsibilities for all groups involved in producing and submitting MOD‑025 model data. Additionally, there was a deficient compliance tracking tool that included a narrative reminding personnel of upcoming submission deadlines and the requirement to notify the TP, but did not include a follow-up method to make sure all compliance activities were completed. This resulted in the tool being effective for performing the MOD-025 testing, but deficient in ensuring personnel communicated those test results to the TP within 90 days.
This noncompliance started on January 18, 2022, when NOTWIN001 exceeded the 90-calendar day submission requirement, and ended on December 19, 2022, when NOTWIN001 submitted the results to the TP.
Disposition
SERC reviewed NOTWIN00’s internal compliance program and considered it to be a neutral factor in the penalty determination due to a lack of annual reviews of the program and lack of training for mandatory compliance requirements. NOTWIN001 was assessed a $20,000 penalty.
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