NERC FFT Reports: Reliability Standard COM-002-2


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Eagle Point Power Generation, LLC (Eagle Point), Docket No. RC13-10, June 27, 2013

Reliability Standard: COM-002-2

Requirement: R1

Region: RFC

Issue: Eagle Point, as a GO, self-reported an issue with COM-002-2 R1 to RFC when it found that its list of communications for the Eagle Point facility failed to include a complete list of all voice communications (including cell phones), and data communications (including email and internet communication).

Finding: RFC determined that the issue posed a minimal risk to the reliability of the BPS because since Eagle Point’s transition in ownership in April, 2012, the GO had some communications in place, which were staffed and available to address real-time emergencies.

Find, Fix and Track Entity, FERC Docket No. RC12-1 (October 31, 2011)

Reliability Standard: COM-002-2

Requirement: R2

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity, in 3 instances related to Mvar adjustments, did not have the GOP that received its directives repeat back the information correctly and FFT Entity did not acknowledge the response as correct or resolve the misunderstandings.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity, as a TOP, issued clear and definitive instructions. In addition, the directives were only directed towards FFT Entity’s own generators (and those generators were continuously being monitored by FFT Entity’s Energy Management System). In addition, FFT Entity has less than 700 MW of capacity and is only connected to the BPS at 230 kV.

Find, Fix and Track Entity, Docket No. RC12-7-000 (January 31, 2012)

Reliability Standard: COM-002-2

Requirement: R2

Region: ReliabilityFirst

Issue: During a compliance audit, ReliabilityFirst determined FFT Entity failed on five separate instances to issue a directive to a third party as required in COM-002-2 R2. In four of those instances, FFT Entity’s directives were not clear and concise. In the fifth, FFT Entity did not repeat back a directive or acknowledge the response as correct.

Finding: ReliabilityFirst determined that this issue posed only a minimal risk to the reliability of the BPS because the five directives in question were related to VAR-001-1 R12’s requirement to take direct corrective action when reactive resources are insufficient. While FFT Entity did not meet the requirements of COM-002-2 R2, it did take the proper direct corrective action and did not have issues related to insufficient amounts of reactive support. Moreover, FFT Entity’s breach of COM-002-2 R2 is mitigated by two reasons. First, FFT Entity is not subject to the Standard because it is no longer registered on the NERC Compliance Registry as a Transmission Operator or Balancing Authority. Second, FFT Entity had a communication procedure where employees were trained to follow three-part communication when issuing directives regarding system reliability maters.