SERC determined that BES was noncompliant with PRC-005-6 R3. BES failed to maintain two relays in accordance with the PRC-005-6 implementation plan (IP). During a compliance audit that concluded on May 27, 2021, SERC identified two relays that were not maintained in accordance with the PRC-005-6 implementation plan (IP). In addition BES had a failed test on a carrier blocking relay that was left out of tolerance upon completion of testing. On May 2, 2021, as part of independent sampling, BES provided a download of its relay database which included a list of its Protection System components along with the version under which they were being maintained as well as the last and the next test dates. Upon review of the spreadsheets, SERC identified two relays with a maximum allowable intervals of six years were not maintained and transitioned to PRC-005-6 as directed by the IP and informed BES of the missed dates. The audit team requested BES to provide the most recent test record for these components. The most recent test records indicated the components were tested on April 6 and April 7, 2021, respectively. Per the IP, these components should have transitioned to PRC-005-6 by April 1, 2021. In addition, BES failed to remediate a failed 230kV carrier relay. BES performed maintenance on the relay, however, and accepted the out of tolerance “as left” test for two components of the relay of 7.41 percent and 12.28 percent, knowing the relay was due to be replaced. The maximum allowable tolerance band is +/- 5 percent. BES had an engineering firm perform an analysis and study and determined that even though the relay components were out of tolerance, the relay was still coordinated and would operate as designed.
BES performed an extent of condition review consisting of a 100-percent walk-down of all six low-impact facilities. BES has a total of 779 assets within its PRC-005 protection system maintenance program (PSMP). BES review did not identify any additional instances of noncompliance. BES has no medium- or high-impact facilities.
This noncompliance started on October 24, 2019, when BES failed to remediate the carrier blocking relay after the failed test; and ended on September 21, 2021, when BES placed the carrier blocking relay on its Unresolved Maintenance Issues list until the relay can be replaced under a capital project.
The cause for this noncompliance was the lack of an internal control. Specifically, BES did not have an internal control associated with its relay database to alert for upcoming maintenance and compliance dates.
SERC considered BES’s compliance history and determined there were three relevant instances of noncompliance that should not serve as a basis for penalty: FRCC2015014944, FRCC2013013268, and FRCC200910005.
The issue was resolved as a Compliance Exception (CE).
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