Reliability Standard: TOP-002-2b
Violation Risk Factor: Medium
Violation Severity Level: Severe
Region: Texas RE
Issue: Texas RE, during a compliance audit, found that CCI SH had not fulfilled the Balancing Authority's standing request for biennial results of reactive capability verifications.
Finding: Texas RE found that this issue posed a moderate, but not a serious or substantial, risk to BPS reliability. Two of the plant's four units were Blackstart resources. By failing to regularly perform reactive capability tests, CCI SH had not ensured that it could provide voltage support when called upon during a Blackstart. This could have delayed restoration of firm load. However, the plant's two other units had the ability to support the Blackstart and CCI SH was contracted to supply only 3.4% of ERCOT's primary Blackstart capability. To mitigate the violation, CCI SH (1) conducted the required tests and reported results to ERCOT, (2) included reactive testing in CCI SH's electronic tracking and notification system, and (3) hired a consultant to review CCI SH's internal compliance program.
Penalty: $50,000 (aggregate for 6 violations)
FERC Order: FERC approved the settlement on June 26th, 2015.