NERC FFT Reports: Reliability Standard CIP-001-1a | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard CIP-001-1a

NERC FFT Reports: Reliability Standard CIP-001-1a

White & Case NERC Database

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: CIP-001-1a

Requirement: R3

Region: SERC

Issue: Following a self-report, SERC determined that FFT Entity did not provide its operating personnel with sabotage response guidelines in violation of R3.

Finding: SERC found that this issue constituted only a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because FFT Entity is a minimal size facility that is connected radially to the BPS at three interconnection points, and the interconnecting TO/TOP has procedures pursuant to CIP-001-1 that would ensure sabotage activities affecting the BPS would be recognized and reported by the TO/TOP. Moreover, FFT Entity does not own or operate any BPS facilities.

Find, Fix and Track Entity, Docket No. RC12-6 (December 30, 2011)

Reliability Standard: CIP-001-1a

Requirement: R1, R2, R3, R4

Region: ReliabilityFirst

Issue: FFT Entity submitted a self-certification detailing issues with CIP-001-1a R1, R2, R3 and R4. First, FFT Entity had no procedures in place for the recognition of and for making its operating personnel aware of sabotage events on its facilities and multi-site sabotage affecting larger portions of the Interconnection, as set forth in R1. Second, FFT Entity had no guidelines in place for the communication of information concerning sabotage events to appropriate parties in the Interconnection, as set forth in R2. Third, FFT Entity did not give its operating personnel sabotage response guidelines, including personnel to contact, for reporting disturbances due to sabotage events, as set forth in R3. Finally, FFT Entity did not establish communications contacts with local FBI officials and develop reporting procedures as appropriate to its circumstances, as set forth in R4.

Finding: ReliabilityFirst found the issue constituted a minimal risk to BPS reliability because FFT Entity trained its site personnel and operational personnel to recognize and report any sabotage event or potential sabotage event. And, FFT Entity did maintained an emergency contact list that included local authorities’ contact information.

NAES Corporation - Lockport (NAES Lockport), Docket No. RC13-9, May 30, 2013

Reliability Standard: CIP-001-1a

Requirement: 2

Region: NPCC

Issue: Further to a Compliance Audit, NPCC determined that NAES Lockport, as a GOP, had an issue with R2 because it did not have procedures to direct communication of information regarding sabotage reporting to appropriate parties in the Interconnection.

Finding: NPCC determined that the issue posed a minimal risk to the BPS because NAES Lockport had directed communications with parties in the Interconnection when necessary by using the Plant Managers Standing Orders and because information regarding sabotage events would be communicated in the same manner

PowerSmith Cogeneration Project, LP, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: CIP-001-1a

Requirement: R2

Region: SPP

Issue: PowerSmith Cogeneration Project, LP (Powersmith), as a GO, self-reported that its sabotage reporting procedures did not include its TOP as an appropriate party in the Interconnection that Powersmith needs to communicate information about sabotage events to.

Finding: SPP found that this issue constituted only a minimal risk to the BPS. Powersmith did have sabotage reporting procedures in place, including provisions to communicate sabotage information to its RC and BA. In addition, Powersmith’s operating personnel know how to respond to sabotage events.

Settlers Trail Wind Farm LLC (STWF), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: CIP-001-1a

Requirement: R4

Region: SERC

Issue: STWF, a GOP, submitted a self-certification explaining a violation of CIP-001-1a because it did not have communications set up with the local FBI office for sabotage reporting. STWF is physically located in Iroquois County, Illinois; however, the contact information for sabotage reporting in use by STWF was based on the Texas location of the dispatch center responsible for GOP functions. It was not until August 2011 that STWF adopted a new sabotage reporting procedure with the local FBI contacts included.

Finding: The violation was deemed by SERC to pose minimal risk to BPS reliability because the FBI contact in Texas could have alerted the Illinois FBI, if needed. SWTF updated its sabotage reporting procedure prior to commercial operation. In addition, the STWF facility has a combined capacity of only 150 MW.