November 25, 2014 VIA ELECTRONIC FILING Ms. Kimberly

November 25, 2014

VIA ELECTRONIC FILING

Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426

Re: NERC Full Notice of Penalty regarding Pacific Gas and Electric Company, FERC Docket No. NP15-_-000

Dear Ms. Bose:

The North American Electric Reliability Corporation (NERC) hereby provides this Notice of Penalty1 regarding Pacific Gas and Electric Company (PGAE), NERC Registry ID# NCR05299,2 in accordance with the Federal Energy Regulatory Commission’s (Commission or FERC) rules, regulations, and orders, as well as NERC’s Rules of Procedure including Appendix 4C (NERC Compliance Monitoring and Enforcement Program (CMEP)).3

PGAE is a California company that serves as a natural gas provider and electric utility to approximately 15 million people throughout central and northern California with 5.1 million electric customer accounts and 4.3 million natural gas customer accounts. PGAE serves an area of 70,000 square miles with 141,215 circuit miles of electric distribution lines, 18,616 circuit miles of interconnected

1 Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability Standards (Order No. 672), III FERC Stats. & Regs. ¶ 31,204 (2006); Notice of New Docket Prefix “NP” for Notices of Penalty Filed by the North American Electric Reliability Corporation, Docket No. RM05-30-000 (February 7, 2008). See also 18 C.F.R. Part 39 (2014). Mandatory Reliability Standards for the Bulk-Power System, FERC Stats. & Regs. ¶ 31,242 (2007) (Order No. 693), reh’g denied, 120 FERC ¶ 61,053 (2007) (Order No. 693-A). See 18 C.F.R § 39.7(c)(2). 2 PGAE was included on the NERC Compliance Registry as a Distribution Provider, Generator Owner, Generator Operator, Load-Serving Entity, Purchasing-Selling Entity, Resource Provider, Transmission Owner, Transmission Operator, and Transmission Planner on June 17, 2007. 3 See 18 C.F.R § 39.7(c)(2) and 18 C.F.R § 39.7(d).

3353 Peachtree Road NE Suite 600, North Tower Atlanta, GA 30326 404-446-2560 | www.nerc.com

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 2

transmission lines, 42,141 miles of natural gas distribution pipelines, and 6,438 miles of transportation pipelines.

This Notice of Penalty is being filed with the Commission because, based on information from WECC, PGAE does not dispute the violations4 of VAR-002-2b R2 and R3, and the proposed one hundred three thousand five hundred dollar ($103,500) penalty to be assessed to PGAE. Accordingly, the violations identified as NERC Violation Tracking Identification Numbers WECC2014013735 and WECC2014013771 are Confirmed Violations, as that term is defined in the NERC Rules of Procedure and the CMEP.

Statement of Findings Underlying the Violations

This Notice of Penalty incorporates the findings and justifications set forth in the Notice of Confirmed Violation and Proposed Penalty or Sanction (NOCV) issued by WECC on September 15, 2014. The details of the findings and basis for the penalty are set forth in the NOCV and herein. This Notice of Penalty filing contains the basis for approval of the NOCV by the NERC Board of Trustees Compliance Committee (NERC BOTCC). In accordance with Section 39.7 of the Commission’s regulations, 18 C.F.R. § 39.7 (2013), NERC provides the following summary table identifying each violation of a Reliability Standard resolved by the NOCV, as discussed in greater detail below.

Reliability Applicable Total NERC Violation ID Req. VRF/VSL* Std. Function(s) Penalty Medium/ WECC2014013735 R2 Severe VAR-002-2b GOP5 $103,500 Medium/ WECC2014013771 R3: 3.1 High *Violation Risk Factor (VRF) and Violation Severity Level (VSL)

VAR-002-2b R2 (WECC2014013735)

On April 24, 2014, PGAE submitted a Self-Report to WECC stating that on two separate occasions, PGAE failed to follow a temporary voltage schedule set by its Transmission Operator (TOP). The first instance occurred when PGAE’s TOP issued a temporary voltage schedule on March 15, 2014, directing that it be maintained until 7:00 a.m. on March 17, 2014. PGAE did not return to the normal voltage schedule

4 For purposes of this document, each violation at issue is described as a “violation,” regardless of its procedural posture and whether it was a possible, alleged or confirmed violation. 5 The Notice of Confirmed Violation lists the applicable functions as both Generator Operator and Generator Owner.

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 3 until 1:03 p.m. on March 17, 2014. The second instance occurred when PGAE’s TOP issued a temporary voltage schedule on March 21, 2014, directing that it be maintained until 7:00 a.m. on March 24, 2014. On March 23, 2014, however, PGAE operated a combustion turbine at a higher voltage than ordered by the TOP between 4:42 p.m. and 5:39 p.m.

WECC determined PGAE failed to meet the directed values for a total of more than 75 minutes when directed by the TOP to maintain the generator voltage or Reactive Power schedule.

WECC determined the duration of the violation to be on two separate occasions on March 17, 2014 and March 24, 2014 lasting a total of 75 minutes when PGAE failed to maintain the generator voltage or Reactive Power schedule as directed by its TOP.

WECC determined that this violation posed a minimal and not serious or substantial risk to the reliability of the bulk power system (BPS). Although the failure to maintain its voltage schedule could potentially result in PGAE being unable to respond to voltage excursions as expected by the TOP, PGAE has implemented preventative measures to help prevent instability or reductions in transmission and/or generation. First, PGAE implements modern excitation systems with voltage limiters that act to maintain generator output voltage within capability curves of the generator, thereby preventing generator trips. As detective controls, PGAE has implemented a Disturbance Control Standard (DCS) to monitor generator status and metered quantities that provide alarms for voltage levels. In addition, PGAE’s operators discovered the voltage discrepancies on the same day and acted to correct the condition while also notifying the TOP, evidencing strong detection and corrective controls. Also, as a compensating measure, PGAE implements multiple generators on the same 230 kV bus, which helps to provide voltage support in accordance with the voltage schedule. Finally, given the relatively low output of the generation stations and the small amount of voltage differential, there would be minimal generation of Mvars.

PGAE’s Mitigation Plan (WECCMIT010824) to address this violation was submitted to WECC on July 10, 2014 with a proposed completion date of December 31, 2014.

PGAE’s Mitigation Plan requires PGAE to: 1. issue the appropriate level of formal discipline and coaching for the generator operators involved; 2. establish a twice-daily voltage schedule conference call between PGAE's grid control center and PGAE generating facilities;

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 4

3. require generator operators to communicate the temporary schedule using three-part communication and generate a shift turnover log at all shift changes while temporary voltage schedules are in effect; 4. require all generator operators to review shift turnover requirements and procedures for maintaining network voltage schedules; and 5. require all generator operators to review a letter from PGAE transmission system operations regarding voltage schedules for their facilities and the voltage conversion tables for their facilities.

VAR-002-2b R3 (WECC2014013771)

On May 8, 2014, PGAE submitted a Self-Report to WECC stating that PGAE failed to notify its TOP within thirty minutes of a change in the status of the automatic voltage regulator (AVR). Specifically, PGAE reported that an AVR was in manual mode for 157 minutes before PGAE notified its TOP of the outage.

On February 17, 2014, a 230 kV transmission line relay and testing interrupted the line causing an outage and a generation unit AVR to switch into manual mode. An alarm triggered to alert PGAE to the change in mode, but the operator was not aware of the reason for the alarm because he acknowledged it simultaneously with 26 other alarms. The AVR continued to operate in manual mode for 157 minutes before PGAE realized the AVR status, at which time PGAE returned the AVR to automatic mode and notified the TOP of the AVR status change.

WECC determined the duration of the violation to be on February 17, 2014, when PGAE failed to notify its TOP of the AVR status change.

WECC determined that this violation posed a minimal and not serious or substantial risk to the reliability of the BPS. Although the failure to notify the TOP of a change in AVR status could potentially result in PGAE’s inability to respond to voltage excursions, there were elements in place that mitigated the potential risk. First, the generator at issue was on the same bus as many other generators running AVRs in automatic, which would mitigate any voltage excursions. In addition, PGAE uses modern excitation systems with voltage limiters, which would have acted to maintain generator output voltage within the capability curves of the generator, thereby preventing a generator trip. Finally, PGAE uses a DCS to monitor generator status and metered quantities, which provides alarms for voltage levels.

PGAE’s Mitigation Plan (WECCMIT010821) to address this violation was submitted to WECC on July 10, 2014 with a proposed completion date of July 30, 2014.

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 5

PGAE’s Mitigation Plan required PGAE to: 1. establish a new supervisory control and data acquisition (SCADA) alarm group with the highest priority for both AVR and power system stabilizer status changes. The audible portion of the new alarm group is distinct and takes priority over less critical alarms to enhance situational awareness; 2. start a pilot program to evaluate the effectiveness of the new alarm priority; and 3. implement the alarm program at the remaining PGAE hydro generator control rooms after the pilot alarm program proved to be effective.

PGAE certified on July 10, 2014 that the above Mitigation Plan requirements were completed on July 2, 2014. As evidence of completion of its Mitigation Plan, PGAE submitted the following: 1. SuperCritical AlarmsFinalv2.xlsx, which is a spreadsheet that includes dates associated with SCADA point installation for multiple facilities; and 2. screen shots of maintenance management system work orders.

On August 28, 2014, WECC verified that PGAE’s Mitigation Plan was complete.

Regional Entity’s Basis for Penalty

WECC assessed a penalty of one hundred three thousand five hundred dollars ($103,500) for the referenced violations. In reaching this determination, WECC considered the following factors: 1. the violations constituted PGAE’s third instance of noncompliance with VAR-002 R2 and the second instance of noncompliance with VAR-002 R3. WECC considered PGAE’s compliance history as an aggravating factor in the penalty determination, as discussed in detail in the NOCV; 2. PGAE had an internal compliance program at the time of the violation which WECC considered a mitigating factor, as discussed in detail in the NOCV; 3. PGAE self-reported the violations; 4. PGAE was cooperative throughout the compliance enforcement process; 5. there was no evidence of any attempt to conceal a violation nor evidence of intent to do so; 6. the violations posed a minimal risk but did not pose a serious or substantial risk to the reliability of the BPS, as discussed above; and

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 6

7. there were no other mitigating or aggravating factors or extenuating circumstances that would affect the assessed penalty.

After consideration of the above factors, WECC determined that, in this instance, the penalty amount of one hundred three thousand five hundred dollar ($103,500) is appropriate and bears a reasonable relation to the seriousness and duration of the violations.

Statement Describing the Assessed Penalty, Sanction or Enforcement Action Imposed6

Basis for Determination

Taking into consideration the Commission’s direction in Order No. 693, the NERC Sanction Guidelines and the Commission’s July 3, 2008, October 26, 2009 and August 27, 2010 Guidance Orders,7 the NERC BOTCC reviewed the NOCV and supporting documentation on November 11, 2014 and approved the NOCV. In approving the NOCV, the NERC BOTCC reviewed the applicable requirements of the Commission-approved Reliability Standards and the underlying facts and circumstances of the violations at issue.

The NERC BOTCC approved the NOCV and believes that the assessed penalty of one hundred three thousand five hundred dollar ($103,500) is appropriate for the violations and circumstances at issue, and is consistent with NERC’s goal to promote and ensure reliability of the BPS.

Pursuant to 18 C.F.R. § 39.7(e), the penalty will be effective upon expiration of the 30-day period following the filing of this Notice of Penalty with FERC, or, if FERC decides to review the penalty, upon final determination by FERC.

Attachments to be Included as Part of this Notice of Penalty

The attachments to be included as part of this Notice of Penalty are the following documents:

a) PGAE’s NOCV dated September 15, 2014, included as Attachment A;

6 See 18 C.F.R. § 39.7(d)(4). 7 North American Electric Reliability Corporation, “Guidance Order on Reliability Notices of Penalty,” 124 FERC ¶ 61,015 (2008); North American Electric Reliability Corporation, “Further Guidance Order on Reliability Notices of Penalty,” 129 FERC ¶ 61,069 (2009); North American Electric Reliability Corporation, “Notice of No Further Review and Guidance Order,” 132 FERC ¶ 61,182 (2010).

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 7

b) PGAE’s Response to the Notice of Alleged Violation and Proposed Penalty or Sanction dated September 11, 2014, included as Attachment B; c) PGAE’s Self-Report for VAR-002-2b R2 dated April 24, 2014, included as Attachment C; d) PGAE’s Self-Report for VAR-002-2b R3.1 dated May 8, 2014, included as Attachment D; e) PGAE’s Mitigation Plan designated as WECCMIT010824 for VAR-002-2b R2 submitted July 10, 2014, included as Attachment E; f) PGAE’s Mitigation Plan designated as WECCMIT010821 for VAR-002-2b R3.1 submitted July 10, 2014, included as Attachment F; g) PGAE’s Certification of Mitigation Plan Completion for VAR-002-2b R3.1 submitted July 10, 2014, included as Attachment G; and h) WECC’s Verification of Mitigation Plan Completion for VAR-002-2b R3.1 dated August 28, 2014, included as Attachment H.

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 8

Notices and Communications: Notices and communications with respect to this filing may be addressed to the following:

Gerald W. Cauley Sonia C. Mendonςa* President and Chief Executive Officer Associate General Counsel and Senior North American Electric Reliability Director of Enforcement Corporation North American Electric Reliability 3353 Peachtree Road NE Corporation Suite 600, North Tower 1325 G Street N.W. Atlanta, GA 30326 Suite 600 (404) 446-2560 Washington, DC 20005 (202) 400-3000 Charles A. Berardesco* (202) 644-8099 – facsimile Senior Vice President and General Counsel [email protected] North American Electric Reliability Corporation Edwin G. Kichline* 1325 G Street N.W., Suite 600 Senior Counsel and Associate Director, Washington, DC 20005 Enforcement Processing (202) 400-3000 North American Electric Reliability (202) 644-8099 – facsimile Corporation [email protected] 1325 G Street N.W. Suite 600 Jim Robb* Washington, DC 20005 Chief Executive Officer (202) 400-3000 Western Electricity Coordinating Council (202) 644-8099 – facsimile 155 North 400 West, Suite 200 [email protected] Salt Lake City, UT 84103 (801) 883-6853 Constance White* [email protected] Vice President of Compliance Western Electricity Coordinating Council 155 North 400 West, Suite 200 Salt Lake City, UT 84103 (801) 883-6885 (801) 883-6894 – facsimile [email protected]

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 9

Ruben Arredondo* Geisha Williams* Senior Legal Counsel Executive Vice President, Electric Operations Western Electricity Coordinating Council Pacific Gas and Electric Company 155 North 400 West, Suite 200 77 Beale Street Salt Lake City, UT 84103 Mail Code B32 (801) 819-7674 San Francisco, CA 94105 (801) 883-6894 – facsimile (415) 973-4141 [email protected] [email protected]

Chris Luras* John Hagen* Director of Compliance Risk Analysis & Manager, NERC Compliance Enforcement Pacific Gas and Electric Company Western Electricity Coordinating Council 77 Beale Street 155 North 400 West, Suite 200 Mail Code B32 Salt Lake City, UT 84103 San Francisco, CA 94105 (801) 883-6887 (415) 973-7356 (801) 883-6894 – facsimile (415) 973-0900- facsimile [email protected] [email protected]

*Persons to be included on the Commission’s service list are indicated with an asterisk. NERC requests waiver of the Commission’s rules and regulations to permit the inclusion of more than two people on the service list.

NERC Notice of Penalty Pacific Gas and Electric Company November 25, 2014 Page 10

Conclusion

NERC respectfully requests that the Commission accept this Notice of Penalty as compliant with its rules, regulations, and orders.

Respectfully submitted,

/s/ Edwin G. Kichline Gerald W. Cauley Edwin G. Kichline* President and Chief Executive Officer Senior Counsel and Associate Director, North American Electric Reliability Corporation Enforcement Processing 3353 Peachtree Road NE North American Electric Reliability Suite 600, North Tower Corporation Atlanta, GA 30326 1325 G Street N.W. (404) 446-2560 Suite 600 Washington, DC 20005 Charles A. Berardesco (202) 400-3000 Senior Vice President and General Counsel (202) 644-8099 - facsimile North American Electric Reliability Corporation [email protected] 1325 G Street N.W., Suite 600 Washington, DC 20005 Sonia C. Mendonςa (202) 400-3000 Associate General Counsel and Senior (202) 644-8099 – facsimile Director of Enforcement [email protected] North American Electric Reliability Corporation 1325 G Street N.W. Suite 600 Washington, DC 20005 (202) 400-3000 (202) 644-8099 – facsimile [email protected]

cc: Pacific Gas and Electric Company Western Electricity Coordinating Council

Attachments

Attachment A

PGAE’s NOCV dated September 15, 2014

Chris Luras

Director of Compliance Risk Analysis and Enforcement

(801) 883-6887 [email protected]

Notice of Confirmed Violation

To: Geisha Williams Executive Vice President, Electric Operations Pacific Gas and Electric Company

From: Chris Luras Director of Compliance Risk Analysis and Enforcement Western Electricity Coordinating Council

Date: September 15, 2014

Re: Notice of Confirmed Violation ______

I. Introduction

In accordance with Section 5.2 of the Western Electricity Coordinating Council Compliance Monitoring and Enforcement Program (“CMEP”), the Western Electricity Coordinating Council (“WECC”) hereby notifies Pacific Gas and Electric Company (“PGAE”) of Confirmed Violations of the North American Electric Reliability Corporation Reliability Standards (“Reliability Standards”) and the penalties for such violations.

II. Applicable Law

WECC issues this Notice of Confirmed Violation (“Notice”) to PGAE in accordance with the CMEP, the Federal Energy Regulatory Commission’s (“FERC”) rules, regulations, and orders, and with the North American Electric Reliability Corporation (“NERC”) Rules of Procedure.

III. Disclosure Notice

NERC may include information from this Notice, and any statement submitted by PGAE in response to it, as part of the public record unless PGAE marks specific information as Confidential Critical Energy Infrastructure Information (“CEII”) or Confidential Information in accordance with NERC’s Rules of Procedure Section 1500 or the Applicable Governmental Authority’s regulations, rules, and orders. It is PGAE’s responsibility as a Registered Entity to identify any confidential information contained in

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Notice of Confirmed Violation Pacific Gas and Electric Company September 15, 2014 Page 2 this Notice of Confirmed Violation and to provide supporting justification for designating it as such within five business days after the date of this Notice.

IV. Confirmed Violations

Standard Requirement NERC Violation ID WECC Violation ID VAR-002-2b R2 WECC2014013735 WECC2014-613499 VAR-002-2b R3 WECC2014013771 WECC2014-613517

This Notice addresses the Alleged Violations set forth in the Notice of Alleged Violation issued by WECC on August 11, 2014. PGAE responded to the Notice of Alleged Violation on September 11, 2014 (“Response”). In the Response, PGAE “elect[ed] to accept the Alleged Violations and Proposed Sanctions.” As described in Attachment 1, PGAE submitted and implemented a mitigation plan to correct the violations addressed herein.

In accordance with the NERC Rules of Procedure and the CMEP, the Alleged Violations addressed in the Notice of Alleged Violation are now Confirmed Violations. A summary of the facts and evidence supporting each Confirmed Violation are set forth in Attachment 1.

V. Proposed Penalty or Sanction

In this action, WECC is exercising its discretion to assess a $103,500 penalty against PGAE for the Confirmed Violations listed in Attachment 1.

WECC’s determination of penalties is guided by the statutory requirement codified at 16 U.S.C. § 824o(e)(6) that any penalty imposed “shall bear a reasonable relation to the seriousness of the violation and shall take into consideration the efforts of [the Registered Entity] to remedy the violation in a timely manner.” In addition, WECC considers the direction of the Commission provided in Order No. 693, the NERC Sanction Guidelines, the Commission’s Policy Statement on Enforcement, the Commission’s July 3, 2008 Guidance Order, the Commission’s August 27, 2010 Guidance Order, and all other applicable guidance from NERC and FERC.

To determine a penalty or sanction, WECC considers various factors including, but not limited to: (1) Violation Risk Factor; (2) Violation Severity Level, (3) risk to the reliability of the Bulk Power System (“BPS”), including the seriousness of the violation; (4) Violation Time Horizon (5) the violation’s duration; (6) the Registered Entity’s compliance history; (7) the Registered Entity’s self-reports and voluntary corrective action; (8) the degree and quality of cooperation by the Registered Entity in the audit or investigation process, and in any remedial action; (9) the quality of the Registered Entity’s compliance program; (10) any attempt by the Registered Entity to conceal the violation or any related information; (11) whether the violation was intentional; (12) any

WESTERN ELECTRICITY COORDINATING COUNCIL • WWW.WECC.BIZ 155 NORTH 400 WEST • SUITE 200 • SALT LAKE CITY • UTAH • 84103 • PH 801.582.0353 • FX 801.883.6894 Notice of Confirmed Violation Pacific Gas and Electric Company September 15, 2014 Page 3

other relevant information or extenuating circumstances; and (13) the Registered Entity’s ability to pay a penalty, as applicable.

VI. Process Governing Confirmed Violations of Reliability Standards

In accordance with CMEP Section 8.0, WECC is providing a copy of this Notice to NERC for its review and consideration. A Registered Entity may submit a statement to NERC to accompany WECC’s filing. The Registered Entity must provide this statement within five business days after the date of the Notice of Confirmed Violation. The Registered Entity’s statement can be the same statement it filed in response to WECC’s Notice of Alleged Violation. The statement must be written on company letterhead and an officer, employee, attorney, or other authorized representative of the Registered Entity must sign it.

The proposed penalty or sanction set forth in this Notice is subject to review and revision by NERC. If the NERC Board of Trustees Compliance Committee (“Committee”) approves the Notice of Confirmed Violation as submitted by WECC, or as modified by the Committee, NERC will submit a Notice of Penalty (“NOP”) to FERC or any other Applicable Governmental Authority, and send copies of the NOP to the Registered Entity and WECC. WECC’s proposed penalty or sanction will be effective upon expiration of the 30 day period following NERC’s filing of the NOP with FERC, unless FERC decides to review the NOP. If FERC reviews the NOP, the proposed penalty or sanction will not become effective until FERC makes a final determination. FERC and any other Applicable Governmental Authority may approve, reject, or modify the findings and/or penalties or sanctions set forth in the NOP.

VII. Conclusion

Any questions regarding this Notice of Confirmed Violation issued by WECC should be directed to Haley Sousa, Enforcement Analyst, at 801-819-7625 or [email protected]. In any correspondence, please provide the name and contact information of a PGAE representative who is authorized to address the above-listed Confirmed Violations. Please also list the relevant NERC Violation Tracking Identification Numbers in any correspondence.

Respectfully submitted,

Chris Luras Director of Compliance Risk Analysis and Enforcement

cc: NERC Enforcement

Enclosure: Attachment 1 – Supporting Information for each Violation

Attachment 1 – Supporting Information for each Violation

I. NERC RELIABILITY STANDARD VAR-002-2b REQUIREMENT 2

NERC VIOLATION ID: WECC2014013735 WECC VIOLATION ID: WECC2014-613499

1. NERC Reliability Standard VAR-002-2b Requirement 2 states:

Unless exempted by the Transmission Operator, each Generator Operator shall maintain the generator voltage or Reactive Power schedule (within applicable Facility Ratings as directed by the Transmission Operator.

R2.1 - When a generator’s automatic voltage regulator is out of service, the Generator Operator shall use an alternative method to control the generator voltage and reactive output to meet the voltage or Reactive Power schedule directed by the Transmission Operator.

R2.2 - When directed to modify voltage, the Generator Operator shall comply or provide an explanation of why the schedule cannot be met.

SUMMARY

2. PGAE failed to maintain voltage schedules as prescribed by the Transmission Operator (“TOP”). APPLICABILITY

3. PGAE is registered on the NERC Compliance Registry as a Distribution Provider, Generator Operator, Generator Owner, Load-Serving Entity, Purchasing-Selling Entity, Resource Planner, Transmission Operator, Transmission Owner, and a Transmission Planner. PGAE is required to demonstrate compliance with VAR-002 in its capacity as a Generator Owner and Generator Operator.

VIOLATION FACTS

4. On April 24, 2014, PGAE submitted a Self-Report citing possible noncompliance with VAR-002-2b R2. Specifically, PGAE reported that on two separate occasions, PGAE failed to follow a temporary voltage schedule set by PGAE’s TOP.

5. On May 27, 2014, a WECC SME reviewed the Self-Report and discussed the possible noncompliance with PGAE. The SME determined that the first instance of possible noncompliance occurred on March 17, 2014. Specifically, PGAE’s TOP issued a temporary voltage schedule on March 15, 2014, and ordered that it be maintained until 07:00 on March 17, 2014. However, PGAE did not return to the normal voltage

schedule until 13:03 on March 17, 2014. The second instance of possible noncompliance occurred on March 24, 2014. Specifically, PGAE’s TOP issued a temporary voltage schedule on March 21, 2014 and ordered that it be maintained until 07:00 on March 24, 2014. However, on March 23, 2014, PGAE operated a combustion turbine at a higher voltage than mandated by the TOP between 16:42 and 17:39. The SME determined that PGAE has a possible violation of VAR-002-2b R2, and forwarded the findings to Enforcement for review.

6. Enforcement reviewed the Self-Report and the SMEs findings and determined that PGAEs failure to maintain voltage schedules as prescribed by the TOP is an Alleged Violation of VAR-002-2b R2. Enforcement further determined that the violation occurred on March 17, 2014 and March 24, 2014.

DESCRIPTION OF MITIGATION ACTIVITY

7. On July 10, 2014, PGAE submitted a mitigation plan addressing the Alleged Violation. That mitigation plan requires PGAE to: 1) issue the appropriate level of formal discipline and coaching for the generator operators involved; 2) establish a twice daily voltage schedule conference call between PGAE's Grid Control Center and PGAE Generating facilities; 3) while temporary voltage schedules are in effect, the generator operators will be required to communicate the temporary schedule using 3 part communication and generate a shift turnover log at all shift changes; 4) all generator operators are to review procedures for shift turnover requirements; 5) all generator operators are to review procedures for maintaining network voltage schedules; 6) all generator operators are to review the letter from PGAE's Transmission System Operations regarding voltage schedules for their facilities; and 7) all generator operators are to review voltage conversion tables for their facilities. PGAE anticipates these mitigating activities will be complete by December 31, 2014. WECC has not yet reviewed or accepted PGAE’s mitigation plan.

RELIABILITY IMPACT STATEMENT

8. PGAE failed to maintain its voltage schedule. Failure to do so can lead to voltage instability resulting from discrepancies between generator output and TOP voltage expectations. However, PGAE has implemented preventative measures to help prevent instability or reductions in transmission and/or generation. PGAE implements modern excitation systems with voltage limiters that act to maintain generator output voltage within capability curves of the generator, thereby preventing generator trips. As detective controls, PGAE has implemented a DCS to monitor generator status and metered quantities which provide alarms for voltage levels. PGAE’s strong detection and corrective controls are evidenced by the operators discovering the voltage discrepancies on the same day and acting to correct the condition while also notifying the TOP. As a compensating measure, PGAE implements multiple generators on the same 230 kV bus which helps to provide voltage support in accordance with the voltage schedule. Finally, given the relatively low output of the generation stations and the

small amount of voltage differential, there would be minimal generation of MVARs. For these reasons, WECC determined this violation posed minimal risk to the reliability of the BES. PROPOSED PENALTY OR SANCTION

9. Violation Risk Factor (“VRF”) and Violation Severity Level (“VSL”): According to the NERC VRF Matrix of February 21, 2014, this violation has a “Medium” VRF. Enforcement determined that this violation warranted a “Severe” VSL. Enforcement assesses VSLs based on NERC’s VSL Matrix of April 2, 2014. In this case, Enforcement assessed a “Severe” VSL because when directed by the TOP to maintain the generator voltage or reactive power schedule, PGAE failed to meet the directed values for more than 75 minutes.

10. Based on the above-described VRF and VSL, the Base Penalty Table of the NERC Sanction Guidelines sets forth a Base Penalty Range for this violation of $10,000 to $335,000.

11. The proposed penalty for this violation is $72,000.

12. Penalty Rationale: Enforcement determined that the proposed penalty is appropriate for the following reasons:

a. The VRF is “Medium” and the VSL is “Severe” for this violation.

b. WECC determined this violation posed minimal risk to the reliability of the BES.

c. The violation duration is as described above.

13. Enforcement applied a mitigating factor for the following reasons:

a. PGAE “Self-Reported” this violation.

b. Upon undertaking the actions outlined in the mitigation plan, PGAE took voluntary corrective action to remediate this violation.

c. WECC reviewed PGAE’s Internal Compliance Program (“ICP”). WECC found that: PGAE established a NERC Reliability Standards Compliance Program (ICP) and a NERC Compliance Governance Committee in November 2010. The ICP and Compliance Committee demonstrate PGAE’s commitment to maintaining a culture that encourages compliance. This includes clearly communicating roles and responsibilities, establishing processes to identify potential compliance problems, prompt implementation of corrective measures when necessary, and providing appropriate training. Best practices within PGAE’s ICP include a fully

staffed and trained compliance department, compliance tracking solutions, self-audits and annual ICP evaluation.

14. Enforcement applied an aggravating factor for the following reasons:

a. This was PGAE’s third violation of VAR-002 R2. PGAE’s first violation, given Violation ID # WECC201102398, occurred in 2011 as the result of a Self-Certification. In this first instance, PGAE allowed voltage to drift outside the tolerance band specified by the TOP for one hour. This first instance has similar facts and circumstances as the current violation.

b. PGAE’s second violation, given Violation ID # WECC2012010181, occurred in 2012 as a result of a Self-Report. In this 2012 instance, PGAE failed to follow the voltage control schedule mandated by its TOP for three and a half hours. This second instance has similar facts and circumstances as the current violation.

15. Enforcement determined there were no other aggravating factors warranting a penalty higher than the proposed penalty. PGAE was cooperative throughout the process. PGAE did not fail to complete any applicable compliance directives. There was no evidence of any attempt by PGAE to conceal the violation. There was no evidence that PGAE’s violation was intentional.

II. NERC RELIABILITY STANDARD VAR-002-2b REQUIREMENT 3

NERC VIOLATION ID: WECC2014013771 WECC VIOLATION ID: WECC2014-613517

16. NERC Reliability Standard VAR-002-2b Requirement 3 states:

Each Generator Operator shall notify its associated Transmission Operator as soon as practical, but within 30 minutes of any of the following:

R3.1 - A status or capability change on any generator Reactive Power resource, including the status of each automatic voltage regulator and power system stabilizer and the expected duration of the change in status or capability.

R3.2 - A status or capability change on any other Reactive Power resources under the Generator Operator’s control and the expected duration of the change in status or capability.

SUMMARY

17. PGAE failed to notify its TOP within thirty minutes of a change in status of the automatic voltage regulator (“AVR”).

APPLICABILITY

18. PGAE is registered on the NERC Compliance Registry as a Distribution Provider, Generator Operator, Generator Owner, Load-Serving Entity, Purchasing-Selling Entity, Resource Planner, Transmission Operator, Transmission Owner, and a Transmission Planner. PGAE is required to demonstrate compliance with VAR-002 in its capacity as a Generator Owner and Generator Operator.

VIOLATION FACTS

19. On May 8, 2014, PGAE submitted a Self-Report citing possible noncompliance with VAR-002-2b R3. Specifically, PGAE reported that an AVR at the Powerhouse was in manual mode for 157 minutes before PGAE notified its Transmission Operator (“TOP”) of the outage.

20. On May 27, 2014, a WECC SME reviewed the Self-Report and discussed the possible noncompliance with PGAE. The SME determined that on February 17, 2014, PGAE lost a 230kV transmission line, causing a generation unit AVR to switch into manual mode. An alarm triggered to alert PGAE to the change in mode, but the operator acknowledged the alarm together with twenty-six other alarms. The AVR continued to operate in manual mode for 157 minutes before PGAE realized the AVR

status, at which time the PGAE returned the AVR to automatic mode and notified the TOP of the AVR status change. The SME determined that PGAE has a possible violation of VAR-002-2b R3, and forwarded the findings to Enforcement for review.

21. Enforcement reviewed the Self-Report and the SMEs findings. Enforcement determined that PGAE’s failure to notify the TOP after a change in AVR status for 157 minutes is an Alleged Violation of VAR-002-2b R3. Enforcement further determined that the violation occurred on February 17, 2014.

DESCRIPTION OF MITIGATION ACTIVITY

22. On July 10, 2014, PGAE submitted a mitigation plan to address the possible noncompliance with VAR-002-2b R3. Prior to submittal of the mitigation plan, PGAE initiated a pilot program to test the effectiveness of a new SCADA alarm that gives the highest priority to AVR and PSS status Fchanges. The new alarm has a distinct sound and takes priority over less critical alarms in order to enhance situational awareness of operators. PGAE found the pilot program to be effective at those control centers in which it was implemented. PGAE’s mitigation plan requires PGAE to implement the pilot program at all other hydro generator control rooms. PGAE submitted a Certificate of Mitigation Plan Completion on July 10, 2014. WECC has not yet reviewed PGAE’s mitigation plan or verified completion.

RELIABILITY IMPACT STATEMENT

23. PGAE failed to notify the TOP of its AVR change in status. Such failure could potentially result in the inability of the generator to respond to voltage excursions as expected by the TOP. However, this generator was on the same bus as many other generators running AVRs in automatic, which would mitigate any voltage excursions. As a preventative control to help prevent PGAE’s inability to respond to voltage excursions, PGAE implements modern excitation systems with voltage limiters which would act to maintain generator output voltage within the capability curves of the generator, thereby preventing a generator trip. As a detective measure, PGAE implements a DCS to monitor generator status and metered quantities which provide alarms for voltage levels. Also, PGAE employs a generator start-up checklist that requires verification of AVR and PSS in automatic control. Finally, PGAE communicates with the TOP twice daily to discuss generation and transmission issues and the TOP could utilize the call to communicate voltage discrepancies. For these reasons, WECC determined this violation posed minimal risk to the reliability of the BES. PROPOSED PENALTY OR SANCTION

24. Violation Risk Factor (“VRF”) and Violation Severity Level (“VSL”): According to the NERC VRF Matrix of February 21, 2014, this violation has a “Medium” VRF. Enforcement determined that this violation warranted a “High” VSL. Enforcement assesses VSLs based on NERC’s VSL Matrix of April 2, 2014. In this case,

Enforcement assessed a “High” VSL because PGAE failed to notify the Transmission Operator within 30 minutes of the information as specified in either R3.1 or R3.2.

25. Based on the above-described VRF and VSL, the Base Penalty Table of the NERC Sanction Guidelines sets forth a Base Penalty Range for this violation of $6,000 to $200,000.

26. The proposed penalty for this violation is $31,500.

27. Penalty Rationale: Enforcement determined that the proposed penalty is appropriate for the following reasons:

a. The VRF is “Medium” and the VSL is “High” for this violation.

b. WECC determined this violation posed minimal risk to the reliability of the BES.

c. The violation duration is as described above.

28. Enforcement applied a mitigating factor for the following reasons:

a. PGAE “Self-Reported” this violation.

b. Upon undertaking the actions outlined in the mitigation plan, PGAE took voluntary corrective action to remediate this violation.

29. Enforcement applied an aggravating factor for the following reason:

a. This was PGAE’s second violation of VAR-002 R3. In 2010, PGAE had a violation of this Standard, given Violation ID# WECC201001969, in which PGAE failed to notify the TOP of a change in status of the Power System Stabilizer (“PSS”). The PSS had been out of service for twenty-six hours

before the TOP was notified of the change in status. The facts and circumstances of the previous violation are similar to the current violation.

30. Enforcement determined there were no other aggravating factors warranting a penalty higher than the proposed penalty. PGAE was cooperative throughout the process. PGAE did not fail to complete any applicable compliance directives. There was no evidence of any attempt by PGAE to conceal the violation. There was no evidence that PGAE’s violation was intentional. WECC is not aware of any violations of this Reliability Standard by PGAE affiliates or any involvement in PGAE’s activities such that this violation by PGAE should be treated as recurring conduct.

WESTERN ELECTRICITY COORDINATING COUNCIL • WWW.WECC.BIZ 155 NORTH 400 WEST • SUITE 200 • SALT LAKE CITY • UTAH • 84103 • PH 801.582.0353 • FX 801.883.6894

Attachment B

PGAE’s Response to the Notice of Alleged Violation and Proposed Penalty or Sanction dated September 11, 2014

Attachment C

PGAE’s Self-Report for VAR-002-2b R2 dated April 24, 2014

Western Electricity Coordinating Council April 25, 2014 Self Report - 2014

Entity Name: Pacific Gas and Electric Company (PGAE)

NERC ID: NCR05299 Active: Yes Violation Started in Program Year: 2014 Standard: VAR-002-2b Requirement: R2 Date Submitted: April 24, 2014 Has this violation previously No been reported or discovered?:

Entity Information: Joint Registration Organization (JRO) ID: Coordinated Functional Registration (CFR) ID:

Contact Name: Glenn Rounds Contact Phone: 5592466069 Contact Email: [email protected] Violation:

Violation Start Date: March 17, 2014 End/Expected End Date: March 17, 2014 Region Initially Determined a Violation On: Reliability Functions: Generator Operator (GOP)

Is Possible Violation still No occurring?: Has this Possible Violation No been reported to other Regions?: Which Regions: Date Reported to Regions:

Detailed Description and On 3/15/14 @ 08:47 PG&E Grid Control Center (GCC), issued a temporary Cause of Possible Violation: voltage schedule to the generator operator located at Drum Hydro Switching Center to maintain 235kV on the Ralston Powerhouse 230kV bus until 0700 the on 3/17/14. At 1303 on 3/17/14 the Drum Hydro Switching Center generator operator realized that he did not return the voltage to the normal schedule of 237kV. At that time the generator operator notified PG&E's GCC transmission operator that Ralston Powerhouse had not been operating at the correct voltage schedule since 0700 and at 1303 returned to the correct voltage schedule. The GCC transmission operator stated that there were no impacts to the BES voltage in that area.

Ralston Powerhouse consists of a single generator unit with a capacity of 88 MVA. The Powerhouse is located 60 miles northeast of Sacramento, California.

A similar event occurred at the Gateway Generating Station on 3/23/14.

Page 1 of 3 04/25/2014 Western Electricity Coordinating Council April 25, 2014 Self Report - 2014

At 1642, the steam turbine reached a dispatch load but its voltage was at 234kV. The steam turbine operated in this mode until 1739 which was discovered by the previous night shift operators that took shift at 1700. At that time the generator operator informed the GCC transmission operator that the unit was not following the correct voltage schedule since 1642 and that he had changed the voltage set-point to operate at the correct voltage schedule.

Gateway Generating Station is a combined cycle generating facility consisting of 2 combustion turbines (CTs) and 1 steam turbine with a maximum capability of 600 MW. Gateway Generating Station is located in Antioch, California which is approximately 45 miles northeast of San Francisco California.

Mitigating Activities: Description of Mitigating The following mitigation activities and preventative measures have been Activities and Preventative initiated. Measure: 1. Establish a voltage schedule conference call between all PG&E Generating facilities and PG&E Grid Control Center to occur at 0700 and 1900. The purpose of the call is to discuss current voltage schedules at all PG&E generating facilities. 2. While in effect, all voltage schedules given by the GCC that deviate from the normal 24 hour schedule will be communicated between the generator operators, using three way communication, during shift turnover. This communication will also be identified as a shift turnover log item. 3. All generator operators to review TD-1466P-01 for shift turnover requirements. 4. Issue appropriate level of formal discipline for generator operators involved with the events. 5. All generator operators to review PG-1210S (Generator Operation for Maintaining Network Voltage Scheduled) 6. All generator operators to review letter from PG&E Transmission Operations, regarding voltage schedules for their facilities. 7. All generator operators to review Voltage Conversion Tables for their facilities

Date Mitigating Activities Completed:

Impact and Risk Assessment:

Potential Impact to BPS: Minimal Actual Impact to BPS: Minimal Description of Potential and There was minimal impact to the BES due to the system loading at the time Actual Impact to BPS: and other generating units online in both areas. The 230kV voltage for both events was within acceptable operating limits before and after the voltages at both locations were adjusted to meet the temporary voltage schedules.

Page 2 of 3 04/25/2014 Western Electricity Coordinating Council April 25, 2014 Self Report - 2014

Risk Assessment of Impact to Both events are considered low risk because the voltages in each area were BPS: within acceptable operating limits before and after voltages were corrected. In addition, the concentration of other generation facilities in both areas also supports a low-risk assessment.

Additional Entity Comments:

Additional Comments From Comment User Name No Comments

Additional Documents From Document Name Description Size in Bytes No Documents

Page 3 of 3 04/25/2014

Attachment D

PGAE’s Self-Report for VAR-002-2b R3.1 dated May 8, 2014

Western Electricity Coordinating Council May 08, 2014 Self Report - 2014

Entity Name: Pacific Gas and Electric Company (PGAE)

NERC ID: NCR05299 Active: Yes Violation Started in Program Year: 2014 Standard: VAR-002-2b Requirement: R3.1 Date Submitted: May 08, 2014 Has this violation previously No been reported or discovered?:

Entity Information: Joint Registration Organization (JRO) ID: Coordinated Functional Registration (CFR) ID:

Contact Name: Glenn Rounds Contact Phone: 5592466069 Contact Email: [email protected] Violation:

Violation Start Date: February 17, 2014 End/Expected End Date: February 17, 2014 Region Initially Determined a Violation On: Reliability Functions: Generator Operator (GOP)

Is Possible Violation still No occurring?: Has this Possible Violation No been reported to other Regions?: Which Regions: Date Reported to Regions:

Detailed Description and The Pit #6 Powerhouse (PH) Unit 2 AVR was out of service for 157 minutes Cause of Possible Violation: before notification was made to the transmission operator at PG&Eâ€™s Grid Control Center (GCC).

At 1236, on 2/17/2014 the Pit#5 â€“ Round Mountain #1-230kV line relayed and tested NG which interrupted the Pit #5 PH and Cove Road PH. The generator operatorâ€™s operating station switched over to the UPS as a result of the outage so the generator operator was temporarily in the dark. The outage also caused the Pit #6 PH Unit 2 AVR to go to manual mode which triggered an alarm. The Pit #5 PH generator operator acknowledged all the alarms (27 in total) but was not aware of the Pit #6 PH Unit 2 AVR status because he acknowledged all the alarms simultaneously. The single generator operator was operating Pit#5 PH, Pit #6 PH, Pit #7 PH and James B. Black PH when this event occurred. The operator then took the necessary action following a PH separation. The operator prepared the Pit #5 Unit 1 to parallel which occurred at 1321 in addition to preparing an emergency switch log to assist the GCC in clearing the Pit#5-Round Mountain #1-230kV line to make repairs. At 1459 a Roving Operator contacted the Pit #5 PH generator operator informing him that the Pit #6 PH Unit 2 was not in AVR mode. The AVR was put in service at that time. At 1513, PG&Eâ€™s GCC was notified which was 157 minutes after the AVR changed status.

The Pit #6 PH Unit 2 is rated at 44 MVA and is located on the Pit River in the

Page 1 of 3 05/08/2014 Western Electricity Coordinating Council May 08, 2014 Self Report - 2014

North Central Area of California.

Mitigating Activities: Description of Mitigating A new SCADA alarm group with the highest priority was established for both Activities and Preventative AVR and PSS status changes. The audible portion of the new alarm group is Measure: distinct and takes priority over less critical alarms to enhance situational awareness. A pilot program to evaluate the effectiveness of the new alarm priority began on 4/2/2014 at Pit 5 PH generator control room which has SCADA control and alarms for the following powerhouses: Pit#5 PH, Pit #6 PH, and Pit #7 PH and James B. Black PH. The pilot alarm program has proven to be effective and will be implemented at the remaining PG&E hydro generator control rooms by 7/30/2014.

Date Mitigating Activities Completed:

Impact and Risk Assessment:

Potential Impact to BPS: Minimal Actual Impact to BPS: Minimal Description of Potential and There was no impact to the Bulk Power System as a result of the Pit #6 PH Actual Impact to BPS: Unit 2 AVR being out of service for 157 minutes. This is primarily due to the size of Pit #6 PH Unit 2 compared to the cumulative size (over 700 MVA) of the other generating units connected to the 230kV system in the Pit River Area.

The 230kV voltage varied between 236kV and 238kV prior to the event, during the event and after the AVR was returned to service.

Risk Assessment of Impact to This event is considered low risk because it is not common for an AVR to BPS: change modes when there is a close proximity transmission line fault that causes a line to trip. In addition a single unitâ€™s AVR support for voltage in this particular area is minimal due to the magnitude of other generating units in the area.

Additional Entity Comments:

Additional Comments From Comment User Name No Comments

Page 2 of 3 05/08/2014 Western Electricity Coordinating Council May 08, 2014 Self Report - 2014

Additional Documents From Document Name Description Size in Bytes No Documents

Page 3 of 3 05/08/2014

Attachment E

PGAE’s Mitigation Plan designated as WECCMIT010824 for VAR-002-2b R2 submitted July 10, 2014

Western Electricity Coordinating Council July 14, 2014

Mitigation Plan

Registered Entity: Pacific Gas and Electric Company

Mit Plan Code NERC Violation ID Requirement Violation Validated On Mit Plan Version null WECC2014013735 VAR-002-2b R2 06/02/2014 1

Mitigation Plan Submitted On: July 10, 2014 Mitigation Plan Accepted On: Mitigation Plan Proposed Completion Date: December 31, 2014 Actual Completion Date of Mitigation Plan: Mitigation Plan Certified Complete by PGAE On: Mitigation Plan Completion Verified by WECC On: Mitigation Plan Completed? (Yes/No): No

Page 1 of 8 07/14/2014 Western Electricity Coordinating Council July 14, 2014

Section A: Compliance Notices Section 6.2 of the NERC CMEP sets forth the information that must be included in a Mitigation Plan. The Mitigation Plan must include:

(1) The Registered Entity's point of contact for the Mitigation Plan, who shall be a person (i) responsible for filing the Mitigation Plan, (ii) technically knowledgeable regarding the Mitigation Plan, and (iii) authorized and competent to respond to questions regarding the status of the Mitigation Plan. This person may be the Registered Entity's point of contact described in Section B. (2) The Alleged or Confirmed Violation(s) of Reliability Standard(s) the Mitigation Plan will correct. (3) The cause of the Alleged or Confirmed Violation(s). (4) The Registered Entity's action plan to correct the Alleged or Confirmed Violation(s). (5) The Registered Entity's action plan to prevent recurrence of the Alleged or Confirmed violation(s). (6) The anticipated impact of the Mitigation Plan on the bulk power system reliability and an action plan to mitigate any increased risk to the reliability of the bulk power-system while the Mitigation Plan is being implemented. (7) A timetable for completion of the Mitigation Plan including the completion date by which the Mitigation Plan will be fully implemented and the Alleged or Confirmed Violation(s) corrected. (8) Implementation milestones no more than three (3) months apart for Mitigation Plans with expected completion dates more than three (3) months from the date of submission. Additional violations could be determined or recommended to the applicable governmental authorities for not completing work associated with accepted milestones. (9) Any other information deemed necessary or appropriate. (10) The Mitigation Plan shall be signed by an officer, employee, attorney or other authorized representative of the Registered Entity, which if applicable, shall be the person that signed the Self Certification or Self Reporting submittals. (11) This submittal form may be used to provide a required Mitigation Plan for review and approval by regional entity(ies) and NERC.

• The Mitigation Plan shall be submitted to the regional entity(ies) and NERC as confidential information in accordance with Section 1500 of the NERC Rules of Procedure.

• This Mitigation Plan form may be used to address one or more related alleged or confirmed violations of one Reliability Standard. A separate mitigation plan is required to address alleged or confirmed violations with respect to each additional Reliability Standard, as applicable.

• If the Mitigation Plan is accepted by regional entity(ies) and approved by NERC, a copy of this Mitigation Plan will be provided to the Federal Energy Regulatory Commission or filed with the applicable governmental authorities for approval in Canada.

• Regional Entity(ies) or NERC may reject Mitigation Plans that they determine to be incomplete or inadequate.

• Remedial action directives also may be issued as necessary to ensure reliability of the bulk power system.

• The user has read and accepts the conditions set forth in these Compliance Notices.

Page 2 of 8 07/14/2014 Western Electricity Coordinating Council July 14, 2014 Section B: Registered Entity Information B.1 Identify your organization:

Entity Name: Pacific Gas and Electric Company NERC Compliance Registry ID: NCR05299 Address: 77 Beale Street San Francisco CA 94105

B.2 Identify the individual in your organization who will serve as the Contact to the Regional Entity regarding this Mitigation Plan. This person shall be technically knowledgeable regarding this Mitigation Plan and authorized to respond to Regional Entity regarding this Mitigation Plan:

Name: Glenn Rounds Title: Principal Transmission Compliance Engineer Email: [email protected] Phone: 559-246-6069

Page 3 of 8 07/14/2014 Western Electricity Coordinating Council July 14, 2014

Section C: Identification of Reliability Standard Violation(s) Associated with this Mitigation Plan

C.1 This Mitigation Plan is associated with the following violation(s) of the reliability standard listed below:

Violation ID Date of Violation Requirement Requirement Description WECC2014013735 03/17/2014 VAR-002-2b R2 Unless exempted by the Transmission Operator, each Generator Operator shall maintain the generator voltage or Reactive Power schedule (within applicable Facility Ratings as directed by the Transmission Operator. C.2 Brief summary including the cause of the violation(s) and mechanism in which it was identified above: On 3/15/14 @ 08:47 PG&E Grid Control Center (GCC), issued a temporary voltage schedule to the generator operator located at Drum Hydro Control Center to maintain 235kV on the Ralston Powerhouse 230kV bus until 0700 the on 3/17/14. At 1303 on 3/17/14 the Drum Hydro Generator Control Center generator operator realized that he did not return the voltage to the normal schedule of 237kV. At that time the generator operator notified PG&E's GCC transmission operator that Ralston Powerhouse had not been operating at the correct voltage schedule since 0700 and at 1303 returned to the correct voltage schedule. The GCC transmission operator stated that there were no impacts to the BES voltage in that area.

A similar event occurred at the Gateway Generating Station on 3/23/14.

On 03/21/14 at 19:22 the Gateway Generating Station received a temporary voltage schedule to maintain 2 kV under its normal schedule (230-232kV) until 03/24 at 07:00 from the PG&E GCC transmission operator. On 3/23/14 new operators took the day-shift and were not aware of the temporary voltage schedule. At 14:00 on 3/23/14 the unit began start-up using one of the CTs . The CT voltage during start-up was operating at the correct voltage schedule. At 1642, the steam turbine reached a dispatch load but its voltage was at 234kV. The steam turbine operated in this mode until 1739 which was discovered by the previous night shift operators that took shift at 1700. At that time the generator operator informed the GCC transmission operator that the unit was not following the correct voltage schedule since 1642 and that he had changed the voltage set-point to operate at the correct voltage schedule. C.3 Provide any relevant information regarding the identification of the violation(s) associated with this Mitigation Plan: The operators in both events had started a new shift and were unaware of the voltage schedule change at shift change.

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Section D: Details of Proposed Mitigation Plan

D.1 Identify and describe the action plan, including specific tasks and actions that your organization is proposing to undertake, or which it undertook if this Mitigation Plan has been completed, to correct the violation(s) identified above in Section C.1 of this form:

Issue the appropriate level of formal discipline and coaching for the generator operators involved. Establish a twice daily voltage schedule conference call between PG&E's Grid Control Center and PG&E Generating facilities. While temporary voltage schedules are in effect the generator operators will be required to communicate the temporary schedule using 3 part communication and generate a shift turnover log at all shift changes. All generator operators to review TD-1466P-01 for shift turnover requirements. All generator operators to review PG- 1210S (Generator Operation for Maintaining Network Voltage Schedules). All generator operators to review letter from PG&E's Transmission System Operations regarding voltage schedules for their facilities. All generator operators to review voltage conversion tables for their facilities.

D.2 Provide the timetable for completion of the Mitigation Plan, including the completion date by which the Mitigation Plan will be fully implemented and the violations associated with this Mitigation Plan are corrected:

Proposed Completion date of Mitigation Plan: December 31, 2014

D.3 Milestone Activities, with completion dates, that your organization is proposing for this Mitigation Plan:

*Proposed Completion Date Actual Completion Milestone Activity Description (Shall not be greater Date than 3 months apart) Generator Operator Review of TD- All generator operators will review TD- 08/29/2014 1466P-01 (Shift Turnover 1466P-01 (Shift Turnover Requirements) Requirements). Review participation will be documented. Generator Operator Review of PG- All generator operators will review PG- 08/29/2014 1210S (Generator Operation for 1210S. Review participation will be maintaining Network Voltage documented. Schedules. Generator Operator Review of All generator operators will review the 08/29/2014 PG&E's Transmission System PG&E's Transmission System Operations Voltage Schedule for their Operations Voltage Schedule for their facilities facilities. Review participation will be documented. Generator Operator Review of All generator operators will review the 08/29/2014 Voltage Conversion Tables for their voltage conversion tables for their facilities facilities. Review participation will be documented. Quality Assurance Reviews of Quality Assurance Reviews will be 10/01/2014 Generator Operator shift turnover performed quarterly on Generator Operator shift turnover communications and logging. The reviews will begin during the 3rd Quarter of 2014. All reviews will be documented and shared with the leadership team.

Page 5 of 8 07/14/2014 Western Electricity Coordinating Council July 14, 2014

*Proposed Completion Date Actual Completion Milestone Activity Description (Shall not be greater Date than 3 months apart) Voltage Schedule Conference Calls Establish a twice daily voltage schedule 12/31/2014 conference call to discuss generator voltage schedule with PG&E's Grid Control Center. The effectiveness of the calls will be evaluated after 6 months.

D.4 Additional Relevant Information (Optional)

Page 6 of 8 07/14/2014 Western Electricity Coordinating Council July 14, 2014 Section E: Interim and Future Reliability Risk

E.1 Abatement of Interim BPS Reliability Risk While your organization is implementing the Mitigation Plan proposed in Section D of this form, the reliability of the Bulk Power System may remain at higher risk or be otherwise negatively impacted until the plan is successfully completed. To the extent they are, or may be, known or anticipated: (i) identify any such risks or impacts; and (ii) discuss any actions that your organization is planning to take or is proposing as part of the Mitigation Plan to mitigate any increased risk to the reliability of the bulk power system while the Mitigation Plan is being implemented:

The generator operators at the locations where the violations took place have reviewed the items identified in the mitigation plan. The voltage schedule conference calls began 5/1/2014.

E.2 Prevention of Future BPS Reliability Risk Describe how successful completion of the Mitigation Plan as laid out in Section D of this form will prevent or minimize the probability that your organization incurs further violations of the same or similar reliability standards requirements in the future: The ongoing emphasis on maintaining the correct voltage schedule will help to ensure similar violations will not occur. E.3 Your organization may be taking or planning other action, beyond that listed in the Mitigation Plan, as proposed in Section D.1, to prevent or minimize the probability of incurring further violations of the same or similar standards requirements listed in Section C.1, or of other reliability standards. If so, identify and describe any such action, including milestones and completion dates:

Page 7 of 8 07/14/2014 Western Electricity Coordinating Council July 14, 2014

Section F: Authorization

An authorized individual must sign and date the signature page. By doing so, this individual, on behalf of your organization:

(a) Submits the Mitigation Plan, as laid out in Section D, to the Regional Entity for acceptance and approval by NERC, and

(b) If applicable, certifies that the Mitigation Plan, as laid out in Section D of this form, was completed (i) as laid out in Section D of this form and (ii) on or before the date provided as the 'Date of Completion of the Mitigation Plan' on this form, and

1. I am Executive Vice President of Electric Operations of Pacific Gas and Electric Company

2. I am qualified to sign this Mitigation Plan on behalf of Pacific Gas and Electric Company

3. I have read and understand Pacific Gas and Electric Company's obligations to comply with Mitigation Plan requirements and ERO remedial action directives as well as ERO documents, including, but not limited to, the NERC Rules of Procedure and the NERC CMEP currently in effect or the NERC CMEP-Province of Manitoba, Schedule B currently in effect, whichever is applicable.

4. I have read and am familiar with the contents of the foregoing Mitigation Plan.

5. Pacific Gas and Electric Company Agrees to be bound by, and comply with, this Mitigation Plan, including the timetable completion date, as accepted by the Regional Entity, NERC, and if required, the applicable governmental authorities in Canada.

Authorized Individual Signature: (Electronic signature was received by the Regional Office via CDMS. For Electronic Signature Policy see CMEP.) Authorized Individual Name: Geisha Williams

Title: Executive Vice President of Electric Operations Authorized On: July 08, 2014

Page 8 of 8 07/14/2014

Attachment F

PGAE’s Mitigation Plan designated as WECCMIT010821 for VAR-002-2b R3.1 submitted July 10, 2014

Western Electricity Coordinating Council July 10, 2014

Mitigation Plan

Registered Entity: Pacific Gas and Electric Company

Mit Plan Code NERC Violation ID Requirement Violation Validated On Mit Plan Version null WECC2014013771 VAR-002-2b R3 06/11/2014 1

Mitigation Plan Submitted On: July 10, 2014 Mitigation Plan Accepted On: Mitigation Plan Proposed Completion Date: July 30, 2014 Actual Completion Date of Mitigation Plan: Mitigation Plan Certified Complete by PGAE On: July 10, 2014 Mitigation Plan Completion Verified by WECC On: Mitigation Plan Completed? (Yes/No): No

Page 1 of 7 07/10/2014 Western Electricity Coordinating Council July 10, 2014

Section A: Compliance Notices Section 6.2 of the NERC CMEP sets forth the information that must be included in a Mitigation Plan. The Mitigation Plan must include:

• The Mitigation Plan shall be submitted to the regional entity(ies) and NERC as confidential information in accordance with Section 1500 of the NERC Rules of Procedure.

• Regional Entity(ies) or NERC may reject Mitigation Plans that they determine to be incomplete or inadequate.

• Remedial action directives also may be issued as necessary to ensure reliability of the bulk power system.

• The user has read and accepts the conditions set forth in these Compliance Notices.

Page 2 of 7 07/10/2014 Western Electricity Coordinating Council July 10, 2014 Section B: Registered Entity Information B.1 Identify your organization:

Entity Name: Pacific Gas and Electric Company NERC Compliance Registry ID: NCR05299 Address: 77 Beale Street San Francisco CA 94105

Name: Glenn Rounds Title: Principal Transmission Compliance Engineer Email: [email protected] Phone: 559-246-6069

Page 3 of 7 07/10/2014 Western Electricity Coordinating Council July 10, 2014

Section C: Identification of Reliability Standard Violation(s) Associated with this Mitigation Plan

C.1 This Mitigation Plan is associated with the following violation(s) of the reliability standard listed below:

Violation ID Date of Violation Requirement Requirement Description WECC2014013771 02/17/2014 VAR-002-2b R3 Each Generator Operator shall notify its associated Transmission Operator as soon as practical, but within 30 minutes of any of the following: C.2 Brief summary including the cause of the violation(s) and mechanism in which it was identified above: The Pit #6 Powerhouse (PH) Unit 2 AVR was out of service for 157 minutes before notification was made to the transmission operator at PG&E's Grid Control Center (GCC). At 1236, on 2/17/2014 the Pit#5 - Round Mountain #1-230kV line relayed and tested NG which interrupted the Pit #5 PH and Cove Road PH. The outage also caused the Pit #6 PH Unit 2 AVR to go to manual mode which triggered an alarm. The Pit #5 PH generator operator acknowledged all the alarms (27 in total) but was not aware of the Pit #6 PH Unit 2 AVR status because he acknowledged all the alarms simultaneously. At 1459 a Roving Operator contacted the Pit #5 PH generator operator informing him that the Pit #6 PH Unit 2 was not in AVR mode. The AVR was put in service at that time. At 1513, PG&E's GCC was notified which was 157 minutes after the AVR changed status.

C.3 Provide any relevant information regarding the identification of the violation(s) associated with this Mitigation Plan: The Roving Operators mentioned in the summary visit each Power House facility daily which allowed the Roving Operator in this case to identify an alarm that was not detected at the Generator Operations Center at PG&E's Pit #5 Power House.

Page 4 of 7 07/10/2014 Western Electricity Coordinating Council July 10, 2014

Section D: Details of Proposed Mitigation Plan

A new SCADA alarm group with the highest priority was established for both AVR and PSS status changes. The audible portion of the new alarm group is distinct and takes priority over less critical alarms to enhance situational awareness. A pilot program to evaluate the effectiveness of the new alarm priority began on 4/2/2014 at Pit 5 PH Generator Operations Center which has SCADA control and alarms for the following powerhouses: Pit#5 PH, Pit #6 PH, Pit #7 PH and James B. Black PH. The pilot alarm program has proven to be effective and will be implemented at the remaining PG&E hydro generator control rooms by 7/30/2014. D.2 Provide the timetable for completion of the Mitigation Plan, including the completion date by which the Mitigation Plan will be fully implemented and the violations associated with this Mitigation Plan are corrected:

Proposed Completion date of Mitigation Plan: July 30, 2014

D.3 Milestone Activities, with completion dates, that your organization is proposing for this Mitigation Plan:

*Proposed Completion Date Actual Completion Milestone Activity Description (Shall not be greater Date than 3 months apart) New SCADA Alarm Group for AVR The new AVR/PSS Status SCADA 07/30/2014 07/02/2014 and PSS Status alarm will give the highest priority and contain a distinct audible alarm component for all AVR and PSS status changes. The new AVR/PSS Status SCADA Alarms will be installed at all PG&E Hydro Generator Operations Centers. A pilot program to evaluate the effectiveness was completed on 5/9/2014.

D.4 Additional Relevant Information (Optional)

Page 5 of 7 07/10/2014 Western Electricity Coordinating Council July 10, 2014 Section E: Interim and Future Reliability Risk

The new SCADA alarm group was installed at the Pit 5 PH Generator Operations Center on 4/2/2014. Pit 5 PH Generator Operations Center has control of Pit#5 PH, Pit #6 PH, Pit#7 PH and James B. Black PH.

E.3 Your organization may be taking or planning other action, beyond that listed in the Mitigation Plan, as proposed in Section D.1, to prevent or minimize the probability of incurring further violations of the same or similar standards requirements listed in Section C.1, or of other reliability standards. If so, identify and describe any such action, including milestones and completion dates:

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Section F: Authorization

An authorized individual must sign and date the signature page. By doing so, this individual, on behalf of your organization:

(a) Submits the Mitigation Plan, as laid out in Section D, to the Regional Entity for acceptance and approval by NERC, and

1. I am Executive Vice President of Electric Operations of Pacific Gas and Electric Company

2. I am qualified to sign this Mitigation Plan on behalf of Pacific Gas and Electric Company

4. I have read and am familiar with the contents of the foregoing Mitigation Plan.

Authorized Individual Signature: (Electronic signature was received by the Regional Office via CDMS. For Electronic Signature Policy see CMEP.) Authorized Individual Name: Geisha Williams

Title: Executive Vice President of Electric Operations Authorized On: July 08, 2014

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Attachment G

PGAE’s Certification of Mitigation Plan Completion for VAR-002-2b R3.1 submitted July 10, 2014

Western Electricity Coordinating Council July 10, 2014

Certification of Mitigation Plan Completion

Submittal of a Certification of Mitigation Plan Completion shall include data or information sufficient for the Regional Entity to verify completion of the Mitigation Plan. The Regional Entity may request additional data or information and conduct follow-up assessments, on-site or other Spot Checking, or Compliance Audits as it deems necessary to verify that all required actions in the Mitigation Plan have been completed and the Registered Entity is in compliance with the subject Reliability Standard. (CMEP Section 6.6)

Registered Entity Name: Pacific Gas and Electric Company NERC Registry ID: NCR05299 NERC Violation ID(s): WECC2014013771 Mitigated Standard Requirement(s): VAR-002-2b R3, Scheduled Completion as per Accepted Mitigation Plan: July 30, 2014 Date Mitigation Plan completed: July 02, 2014 WECC Notified of Completion on Date: July 10, 2014 Entity Comment:

I certify that the Mitigation Plan for the above named violation(s) has been completed on the date shown above and that all submitted information is complete and correct to the best of my knowledge.

Name: Geisha Williams Title: Executive Vice President of Electric Operations Email: [email protected] Phone: 1 (415) 973-4141

Authorized Signature Date (Electronic signature was received by the Regional Office via CDMS. For Electronic Signature Policy see CMEP.)

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Attachment H

WECC’s Verification of Mitigation Plan Completion for VAR-002-2b R3.1 dated August 28, 2014