MidGa notified SERC that it was noncompliant with PRC-005-2 R3. MidGa failed to test its Current Transformers (CTs) and Potential Transformers (PTs), as required by PRC-005-2 R3, Table 1-3.
Carlyle, Cogentrix’s parent organization, purchased MidGa in 2015. During 2015-2016, Cogentrix restructured its entire support organization. In 2017-2018, the Cogentrix NERC team supported seven NERC audits. As a result, MidGa’s internal audit process was deferred to 2019. On July 30, 2019, while performing an internal audit, the Director of Reliability Standards Compliance (the “Director”) identified concerns with MidGa’s PTs associated with the auxilary transformer and also discovered neutral ground CTs not being tested. Following this review, staff realized that MidGa’s PRC-005 Tracking Spreadsheet did not include 23 CTs and PTs, so they added the CTs and PTs to the maintenance and testing list for 2019. On October 23, 2019, MidGa completed the maintenance and testing activities for the 23 CTs and PTs. On February 17, 2021, staff confirmed with the vendor that the CTs and PTs were not tested since June 1, 1998, the plant’s commissioning date. With PRC-005-2 implementation on April 1, 2015, MidGa started to test their CTs and PTs but failed to test the PTs associated with the auxiliary transformer and the neutral ground CTs. The facility did not have any indication that it needed to change its practices because the previous operations and maintenance service provider did not properly consider the Standard’s implementation requirements.
MidGa performed an extent-of-condition assessment in which the Director reviewed the PRC-005 program. The Director performed a detailed component-by-component review of the one and three-line relay diagrams, using the current PRC-005 device listing at the time, to ensure program documentation identified and included all required devices. MidGa also documented functional test paths for each lockout device that aided in the direct current control circuitry review. For each component, the Director reviewed all available maintenance and test records to verify MidGa completed the proper testing in accordance with the Standard’s activity scope and per the implementation plan timing requirements. The review did not identify any additional instances of noncompliance.
The cause for this noncompliance was an ineffective program. MidGa failed to allot sufficient time for task preparation and testing of the CTs and PTs.
This noncompliance started on April 1, 2015, when the Standard and Requirement became enforceable and MidGa did not test its CTs and PTs, and ended on October 23, 2019, when it tested the CTs and PTs in accordance with PRC-005-2 R3, Table 1-3.
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