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NERC Case Notes: Reliability Standard COM-002-4

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NP20-1-000: Peak Reliability (PEAK)

Reliability Standard: COM-002-4; IRO-001-4; EOP-006-2; EOP-006-2; IRO-005-3.1a

Requirement:  R5; R1; R7; R8; R3

Violation ID: WECC2017018677; WECC2017018678; WECC2017018679; WECC2017018680; WECC2017018486

Method of Discovery: Self-Report

Violation Risk Factor: High; High; High; High; High

Violation Severity Level: Moderate; Severe; Severe; Severe; Severe

Region: WECC

Issue:  PEAK was responsible for coordinating the resynchronization and restoration of two islanded transmission systems after a large Transmission Operator, for which PEAK is the RC, took one of two 500 kV tie lines between two transmission areas out of service to perform planned maintenance. When the transmission areas were out of service, PEAK's RC system operator gave operating instructions to the US and Canadian Transmission Operators (TOPs) that operate the transmission systems; however, the communication and execution of the operating instructions were inconsistent with PEAK's communication protocol procedure used for system restoration and the requirements of four Reliability Standards. As the RC system operator attempted to restore the islanded transmission systems, he did not follow PEAK's Interconnection Restoration Plan and Checklist as trained during RC restoration drills. Additionally, before issuing the operating instructions, the RC system operator did not determine if it was appropriate to resynchronize the transmission systems by ensuring that the Bulk Electric System (BES) frequency was stable in both areas, the tie schedules had been curtailed, and the resynchronization had been done in accordance with PEAK's Interconnection Restoration Plan and Checklist. This ineffective coordination, as well as uncoordinated schedule cuts, accompanied by associated generation increases in the remaining Interconnection, led to BES frequency remaining below 60 Hz for an additional 11 minutes after resynchronization. 

The fifth violation resolved in the Settlement Agreement was independent of the event on October 16, 2017, and was due to PEAK's failure to disseminate space weather alerts to its entities.

Finding: The penalty was determined to be appropriate as WECC considered violations as repeat noncompliance, PEAK self-reported four of the five violations in a timely manner, PEAK was cooperative throughout the compliance enforcement process, PEAK accepted responsibility and admitted to these violations; the violations in the aggregate posed a substantial risk to the system.

Penalty: $2,300,000

Duration of Violation: 10/16/2017 (first four violations); 6/22/2015 - 9/27/2017 (fifth violation)

FERC Order: Issued October 21, 2019 (Settlement Agreement)