On May 21, 2020, FEUS submitted a Self-Report stating it was noncompliant with PRC-019-2 R1 and PRC-024, R2. Specifically, FEUS did not coordinate an automatic voltage regulator (AVR) with primary and backup Protection System devices for a 104 MVA combined-cycle generating unit. FEUS did not set the in-service limiters to operate before the Protection System of the applicable unit in order to avoid disconnecting the generator unnecessarily. The applicable in-service Protection System devices were not set to operate to isolate or de-energize equipment in order to limit the extent of damage when operating conditions exceed equipment capabilities or stability limits. Additionally, as a GO, it was noncompliant with PRC-024-2 R2 in that, FEUS did not properly set its undervoltage protective relaying setpoints to not trip within the “no trip zone,” as required by Attachment 2 of the Standard.
PRC-019-2, R1
Cause
The root cause was attributed to FEUS not reviewing the quality of the settings recommended by a third-party contractor. Thus, when FEUS implemented the recommended settings, the Protection System devices were not coordinated to isolate or de-energize the combined cycle facility to limit the extent of damage when operating conditions exceeded equipment capabilities or stability limits.
This violation began on July 1, 2016, when the Standard became mandatory and enforceable, and ended on October 23, 2020, when FEUS adjusted the AVR over-excitation limiter (OEL) and over-excitation monitor (OEM) settings for its 104 MVA combined-cycle generating unit.
Risk Determination
The violation posed a moderate risk and did not pose a serious or substantial risk to the reliability of the Bulk Power System (BPS). In this instance, FEUS failed to coordinate the voltage regulating system controls, (including in-service limiters and protection functions) with the applicable equipment capabilities and settings of the applicable Protection System devices and functions, for one 104 MVA generating unit, as required by PRC-019-2 R1; R1.1; R1.1.2.
Such failure could have resulted in equipment damage to FEUS’s combined cycle generation facility due to the applicable Protection System devices not isolating or de-energizing the Facilities when operating conditions exceeded equipment capabilities or stability limits. However, as compensation, the size of the 104 MVA unit reduced the likelihood that failing to coordinate the AVR and Protection System devices would have had a significant impact on the reliability of the BPS. Furthermore, though FEUS did not coordinate the Protection System devices to operate to isolate or de-energize the unit to limit the extent of damage, it did set the AVR to operate before the unit’s Protection System devices to prevent unnecessarily disconnecting the unit, as required by PRC-019-2 R1.1.1. In addition, FEUS confirmed that it has suffered no equipment damage as a result of the instant violation.
Penalty Determination
WECC did not apply mitigating credit for FEUS’s Internal Compliance Program (ICP). FEUS did have a documented ICP; however, WECC determined that it was not effective in remediating the violations herein during previous mitigation efforts.
FEUS’s relevant compliance history regarding PRC-019-2 R1 and PRC-024-2 were not remediated. The violations herein demonstrate that some of the generating units that were involved in the previous instances of noncompliance and are involved in the instant violation. Furthermore, though the previous mitigation has thus far prevented new, distinct instances from occurring, the previous remediation and mitigation efforts were not effective in ending the original instance of noncompliance with PRC-019-2 and PRC-024-2.
PRC-024, R2
Cause
The root cause was attributed to FEUS not reviewing the quality of the settings recommended by a third-party contractor. The third-party contractor used the incorrect Point of Interconnection (POI) leading to incorrect setting recommendations. Thus, when FEUS implemented the recommended settings, the voltage protective relays were not set not to trip within the “no trip zone.”
This violation issue began on July 1, 2016, when the Standard became mandatory and enforceable, and ended on October 23, 2020, when FEUS adjusted the undervoltage relay setpoints for its 104 MVA combined-cycle generating unit.
Risk Determination
This violation posed a moderate risk and did not pose a serious or substantial risk to the reliability of the Bulk Power System (BPS). In this instance, FEUS failed to set its protective relaying such that the generator voltage protective relaying did not trip the applicable generating unit as a result of a voltage excursion (at the point of interconnection) caused by an event on the transmission system external to the generating plant that remains within the “no trip zone” of PRC-024 Attachment 2.
Such failure could have resulted in deteriorated system response following a voltage excursion which could subsequently cause equipment damage, cascading, system instability, or system separation. However, as compensation, the size of the 104 MVA unit reduced the likelihood that tripping within the “no trip zone” during a voltage excursion would have had a significant impact on the reliability of the BPS. Additionally, all the unit’s PRC-024-2 R2 overvoltage relay setpoints were set in accordance with the Standard, therefore the generating unit would have appropriately ridden through an overvoltage excursion. In addition, FEUS confirmed that it has suffered no equipment damage as a result of the instant violation.
Penalty Determination
WECC did not apply mitigating credit for FEUS’s Internal Compliance Program (ICP). Although FEUS did have a documented ICP, WECC determined that it was not effective in remediating the violations herein during previous mitigation efforts.
FEUS’s relevant compliance history regarding PRC-019-2 R1 and PRC-024-2 were not remediated. The violations herein demonstrate that some of the generating units that were involved in the previous instances of noncompliance and are involved in the instant violation. Furthermore, though the previous mitigation has thus far prevented new, distinct instances from occurring, the previous remediation and mitigation efforts were not effective in ending the original instance of noncompliance with PRC-019-2 and PRC-024-2.
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