Louisiana Energy & Power Authority Noncompliant with PRC-005-6 R3 Results in Spreadsheet Notice of Penalty (SNOP)

Summary:

On January 17, 2023, SERC sent Louisiana Energy & Power Authority (LEPA) an audit notification letter notifying it of a compliance audit scheduled for May 15, 2023, through May 19, 2023. On January 30, 2023, LEPA notified SERC that it was noncompliant with PRC-005-6 R3. LEPA failed to maintain its Protection System Relaying, Sudden Pressure Relaying, and associated Control Circuitry Components that are included within the time-based maintenance program in accordance with the minimum maintenance activities and maximum maintenance intervals prescribed within Tables 1-1, 1-5, and 5 for a total of 15 devices. This noncompliance affects LEPA Unit 1, which is a 83 MW generator and is the only generator owned by LEPA.

Additional Discussion:
Mitigation

To mitigate this violation, LEPA has or will

• created an accurate PRC-005 spreadsheet to manage and track PRC-005-6 obligations.
• utilize a monthly compliance questionnaire sent to the Energy Control Center Operations Manager and CIP Senior Manager to answer compliance related questions including if any unresolved maintenance activities have occurred. This will require the Energy Control Center Operations Manager and CIP Senior Manager to be familiar with the new spreadsheet and be aware of any upcoming or unresolved maintenance. The Energy Control Center Operations Manager & CIP Senior Manager will also consult and direct the LEPA Unit 1 Plant personnel on maintenance activities. Plant personnel will be made aware of the PRC-005-6 spreadsheet and any upcoming maintenance activities;
• The LEPA Energy Control Center Manager will schedule a reoccurring meeting with plant personnel when four-month battery testing is due and the DC Power Supply report is received.
• The Energy Control Center Operations Manager will review records with plant personnel and review the Protection System tracking spreadsheet to ensure there is a plan in place to cover any upcoming PRC-005 related maintenance and any other NERC related plant items or activities.

Disposition

SERC considered LEPA’s compliance history to be an aggravating factor. SERC is considering two separate prior noncompliances as aggravating the disposition track: SPP2017018290 and 2021-00574. Although SPP2017018290 was a Compliance Exception, SERC is elevating the disposition track in part because of this prior due to the fact that the mitigating activities included the creation of a spreadsheet list of all PRC-005 devices. LEPA either failed to maintain this spreadsheet from 2019 forward or failed to identify all required PRC-005 devices in 2019. This list should have directly prevented the instant noncompliance. For 2021-00574, LEPA stated that it failed to conduct a thorough walk-down for the previous noncompliance’s EOC as LEPA was unable to conduct a comprehensive walk-down while the unit was online, which is why it did not discover these occurrences during the prior noncompliance. LEPA failed to complete the walk-down when the unit was offline. Therefore, SERC is elevating the filing track for both SPP2017018290 and 2021-00574.

In addition, SERC is imposing a non-monetary sanction on LEPA. LEPA’s Chief Executive Officer must sign the settlement agreement as a direct sanction. It is critical for the executive leadership to continue to support and be fully engaged in LEPA’s effort to improve its security and compliance posture. This continued involvement will ensure continued success in its compliance program.

Other Factors: Although LEPA self-reported the Alleged Violation, LEPA only self-reported the Alleged Violation after receiving an audit notification letter from SERC. Effective oversight of the reliability and resilience of the BES depends upon self-reporting by Registered Entities. Since LEPA identified the Alleged Violation on June 27, 2022, but did not timely self-report the Alleged Violation to SERC until January 30, 2023, which was after it received notice of an upcoming audit, SERC is not providing self-reporting credit.

Although LEPA has been cooperative with SERC throughout the enforcement process relating to this Alleged Violation, it inhibited the timely processing of this Alleged Violation by providing SERC with incorrect information and evidence containing numerous discrepancies. Therefore SERC is not providing cooperation credit.

The violation was disposition as a Spreadsheet Notice of Penalty (SNOP) in the amount of $0.