NERC Case Notes: Reliability Standard EOP-005-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard EOP-005-2

NERC Case Notes: Reliability Standard EOP-005-2

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Calpine, FERC Docket No. NP16-20 (May 31, 2016)

Reliability Standard: EOP-005-2

Requirement: R14

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: RFC

Issue: Calpine Corporation (Calpine), a GO, was found to be in violation of EOP-005-2 R14 during a Compliance Audit conducted from September 14, 2015 through September 23, 2015. Although Calpine provided procedures for testing its blackstart resources, it could not produce documented procedures for starting each blackstart resource and energizing a bus during restoration for 10 of 16 sampled blackstart resources.

Since the Compliance Audit, Calpine has retired 8 of the units and PJM Interconnection LLC (PJM) elected to discontinue its blackstart service from five of Calpine's units due to their small size.

Finding: RFC found the violation posed a moderate risk to BPS reliability. Although the lack of procedures created a risk that if a blackout, or partial blackout, occurred, Calpine's blackstart resources would not be able to start and energize a bus, as required by the TO's System Operation Plan, the risk was partially reduced because Calpine offered evidence demonstrating that the operators were familiar with the blackstart resources, were able to run and test them during normal system conditions, and that many of the operators participated in PJM's and local utility's restoration drills.

The duration of the violation was July 1, 2013 (when the standard became mandatory and enforceable) through October 13, 2015 (when the mitigation plan was completed). To mitigate this violation, Calpine: 1) reviewed current fleet-wide and plant-specific blackstart procedures for all active Calpine blackstart resources and updated them as necessary; and 2) revised its fleet-wide and plant-specific blackstart procedures to incorporate the RFC audit team's recommendations. RFC considered Calpine's internal compliance program and cooperation to be mitigating factors.

Penalty: $20,000 (combined with violation of R17, R17.1 and R17.2)

FERC Order: Issued May 31, 2016 (no further review)

Calpine, FERC Docket No. NP16-20 (May 31, 2016)

Reliability Standard: EOP-005-2

Requirement: R17; R17.1, R17.2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: RFC

Issue: Calpine Corporation (Calpine), a GO, was found to be in violation of EOP-005-2 R17, R17.1, and R17.2 during a Compliance Audit conducted from September 14, 2015 through September 23, 2015. For the nine individual operators sampled, Calpine did not submit evidence that it provided a minimum of two hours of training on its system restoration plan every two calendar years for operating personnel responsible for the startup of its blackstart resource generation units and energizing a bus. Additionally, because Calpine also violated EOP-005-2 R14 by not having documented procedures for starting each blackstart resource, it could not provide training on those procedures as required by EOP-005-2 R17.2.

Finding: RFC found the violation posed a moderate risk to BPS reliability. Although the lack of training created a risk that if a blackout, or partial blackout, occurred, Calpine's blackstart resources would not be able to start and energize a bus, as required by the TO's System Operation Plan, the risk was partially reduced because Calpine offered evidence demonstrating that the operators were familiar with the blackstart resources, were able to run and test them during normal system conditions, and that many of the operators participated in PJM's and local utility's restoration drills.

The duration of the violation was July 1, 2013 (when the standard became mandatory and enforceable) through October 29, 2015 (when the mitigation plan was completed). To mitigate this violation, Calpine: 1) disseminated the revised fleet-wide and plant-specific blackstart procedures to each blackstart facility plant manager; 2) sent each blackstart facility plant manager revised training sign-up sheets to be executed by each individual upon completion of training, and an attestation to be executed by the blackstart facility plant manager verifying that training was conducted; 3) (a) discussed the required training sessions on both the revised fleet-wide and plant-specific blackstart procedures for all blackstart facility personnel; and (b) reviewed Calpine's obligation to maintain proper evidence of training of blackstart facility personnel on the revised procedures, during a regularly scheduled monthly compliance conference call with plant managers; 4) plant managers conducted requisite two-hour training on blackstart restoration at each blackstart facility; and 5) reviewed evidence of training for each Blackstart facility and created an electronic record of such training.. RFC considered Calpine's internal compliance program and cooperation to be mitigating factors.

Penalty: $20,000 (combined with violation of R14)

FERC Order: Issued May 31, 2016 (no further review)