MidAmerican Energy Company (MEC) Noncompliant with FAC-009-1 R1 resulting in $82,000 Penalty

Summary:

MidAmerican Energy Company (MEC) submitted a Self-Report stating that, as a Transmission Owner, it was noncompliant with FAC-009-1 R1. The Entity reported that it had ratings documentation errors for components of its Facilities that constituted a noncompliance with FAC-009-1 R1, as the Facility Ratings (FR) were not consistent with its associated Facility Ratings Methodology (FRM). The Entity identified 21 FRs errors during an internal review. The Entity subsequently performed an Extent of Condition (EOC), discovering an additional 68 FRs errors, for a total of 89 FRs errors. Those errors affected the most limiting element of a Facility, causing the overall FRs to be either higher or lower than the rating of the most limiting element.

Additional Discussion:

Cause

The cause of the noncompliance was the Entity’s inadequate process for reviewing ratings and facility components. For its affected jumper components, the Entity failed to consider industry standards for substation bus design (IEEE Std. 605-2008) and for reducing equipment loss of life (IEEE Std. C57.19) as required by its FRM. Additionally, for its other affected Facility components, the Entity failed to update the primary drawings used for FRs after changes to the equipment were made in the field.

Mitigation

To mitigate this violation, the Entity:

• Adjusted all FRs changes for BES facilities with its Control Center and Reliability Coordinator;
• Enhanced substation engineering quality assurance review checklists were developed and completed;
• Trained personnel on the enhanced quality assurance review checklist;
• Completed historical documentation reviews for all remaining BES Transmissions Facilities;
• Completed nameplate reviews for all 161kV and 345kV substations;
• Completed pre-commission checklists to identify and actively communicate design changes during construction; and
• Instituted annual field reviews and completed reviews for 2018 and 2019.

MRO verified the completion of all mitigation activity.

Disposition

MRO considered the Entity’s compliance history and determined that there were no relevant instances of noncompliance. MRO provided mitigating credit for cooperation, self-reporting, admission, settlement, and the internal compliance program.
This issue resulted in a penalty of $82,000.