Two entities managed by Cogentrix Energy will have to pay a collective $110,000 to ReliabilityFirst for violating NERC’s reliability standards, according to a settlement between the regional entity and the utilities approved by FERC (NP25-9). 

NERC filed the settlement with the commission in a notice of penalty March 31, along with a separate spreadsheet notice of penalty containing a settlement between SERC Reliability and Georgia Transmission (GTC), and another settlement between SERC and the Municipal Electric Authority of Georgia (MEAG), both for failing to maintain consistent facility ratings (NP25-10).  

FERC said in a filing April 30 that it would not further review any of the settlements, meaning the penalties for the RF violations will remain intact. Neither of the SERC settlements carried a monetary penalty. 

Communication Issues Between Cogentrix, PJM

RF’s filing involved two gas generating facilities: the 870-MW Hamilton Liberty station in Towanda, Pa., and the 773-MW Essential Power Rock Springs (EPRS) station in Rising Sun, Md. Liberty is registered with NERC as a generator owner and generator operator, while EPRS is registered as a GO, GOP and transmission owner. 

Liberty and EPRS were accused of infringing IRO-001-4 (Reliability coordination — responsibilities) and TOP-001-5 (Transmission operations), respectively. RF said both violations stemmed from “the same manager’s miscommunication [when] both entities were experiencing a phone outage,” and both were self-reported to the RE on Nov. 15, 2021.  

According to the NOP, on Sept. 16, 2021, Liberty was preparing to perform reactive testing for a 453.5-MW unit as required by MOD-025-2 (Verification and data reporting of generator real and reactive power capability and synchronous condenser reactive power capability). The test was approved by Liberty’s reliability coordinator, PJM, except for one portion.  

In its self-report, Liberty explained that Cogentrix’s Energy Management Group (EMG) “was experiencing a [voice-over-IP] phone outage that created additional confusion in the EMG to PJM communications” at the time, requiring the use of multiple cell phones that “were not utilized by PJM as intended by EMG.”  

PJM told the manager of the EMG that because of an ongoing transmission outage, the leading reactive test could not be performed at the maximum MW output. The RTO told the manager that “a lengthier stability study was required prior to performing that portion of the test.”  

However, the EMG told Liberty’s control room operator to start the test without passing along the information about PJM’s lack of approval for one portion. As a result, the operator conducted the test in full. This constituted a violation of IRO-001-4 requirement R2, which requires transmission operators, balancing authorities, distribution providers and GOPs to “comply with [their RCs’] operating instructions unless compliance … cannot be physically implemented or …such actions would violate safety, equipment, regulatory or statutory requirements.” 

Also on Sept. 16, 2021, PJM requested through the EMG that EPRS run Units 3 and 4 for economics. The EMG manager relayed this instruction to the EPRS lead operator, but the operator did not hear the request clearly. Although the operator repeated it back as an instruction to use Unit 4 only, the manager did not correct this misunderstanding.  

As a result, the EPRS operator did not start Unit 3 until called back by the EMG’s real-time desk operator to ask why the unit was not running. At this point, the EPRS operator listened to the recordings and realized he had missed the request for Unit 3 to be started. EPRS contacted PJM to notify the RTO that it had failed to bring Unit 3 online, and PJM canceled the request. 

The failure to convey PJM’s directive violated requirement R5 of TOP-001-5, which, like IRO-001-4, requires TOPs, GOPs and DPs to “comply with each operating instruction issued by” their BAs. RF assessed the TOP-001-5 infringement as a minimal risk to grid reliability. However, the RE assessed the other issue as a serious risk because performing the reactive test without a stability study could have caused the unit to trip, damaging station equipment and further jeopardizing grid reliability. 

To mitigate the miscommunications that led to the lapses, both Liberty and EPRS conducted an extent of condition review of their communications with Cogentrix’s EMG from October 2021 to January 2022 and found no further instances of failure to follow operating instructions. They also developed plans to manage communication with PJM and other plants during future phone outages by the EMG. 

RF assigned a penalty of $85,000 for the IRO-001-4 infringement, and $25,000 for the TOP-001-5 violation. 

Georgia Entities Settle Over Ratings Issues

SERC’s settlement with GTC started with a self-report filed Oct. 12, 2022. The utility indicated it was in violation of FAC-008-5 (Facility ratings). 

While reviewing drawings and equipment logs for its Bolingbroke substation, GTC found that a line elements database maintained by another registered entity did not list the correct jumpers or bus, likely the result of improper record keeping during a conversion from 68 kV to 115 kV in 1999. The utility derated the relevant line, restoring the previous rating several months later when the bus and jumpers were replaced. 

GTC then conducted a walkdown of 699 additional stations, finding 10 incorrect facility ratings that resulted in derates of up to 32%. SERC later conducted an audit in 2023 that found no additional instances of noncompliance. 

The RE assessed the root cause of the infringement as ineffective controls, primarily because of outdated procedures for communicating facility ratings that were not updated to incorporate new technologies. GTC’s mitigation activities — which are expected to be completed Dec. 31, 2025 — include updating its project review checklist to require verifying the actual transmission line ratings, completing an extent of condition review and committing to correct its internal records as necessary. 

SERC discovered MEAG’s violations — also of FAC-008-5 — through a compliance audit. The RE conducted a walkdown of MEAG’s facilities and found that some of the installed equipment was not included in the ratings table provided by the entity for one of its substations. Among the omissions were all the jumpers, along with a conductor and the name plate size of a switch at the facility. 

After the audit, SERC required MEAG to conduct a walkdown assessment of eight additional transmission stations. The utility identified one incorrectly rated element that led to a 10% derate on a 115-kV line. 

In this case, SERC attributed the misratings to a failure to follow internal controls, which meant that all applicable elements were not included in the facility rating database. MEAG committed to update its ratings database and participate in training on proper facility rating change management procedure. The utility also promised to perform walkdowns of all elements applicable to FAC-008, starting in the third quarter of 2024 and with an expected completion date of Dec. 31, 2025.