NERC FFT Reports: Reliability Standard EOP-004-1 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard EOP-004-1

NERC FFT Reports: Reliability Standard EOP-004-1

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This page contains the FFT (Find, Fix and Track) summaries. Click here to read the NOP (Notice of Penalty)/ACP (Administrative Citation of Penalty) summaries.

City of Riverside Public Utilities (City), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: EOP-004-1

Requirement: 3

Region: WECC

Issue: CYRS, as an LES, submitted a self-report explaining that it had not submitted disturbance report to NERC and WECC after its system experienced a reportable disturbance. Enforcement determined the issue began on October 27, 2007, when CYRS should have submitted its report to NERC and WECC, and ended on October 29, 2007, when CYRS did submit its report to NERC and WECC.

Finding: The issue was found to pose minimal risk to BPS reliability because CYRS notified the Department of Energy (DOE), NERC, and WECC of the disturbance affecting the entity's load within twenty-four hours. CYRS submitted the disturbance report as required by the Standard within seventy-two hours after the start time of the event to DOE, NERC, and WECC. In addition, CYRS restored all load within four hours of the disturbance and it did not trip off any generation or affect any WECC interconnection.

Duke Energy Corporation (Duke), Docket No. RC13-6-000 (February 28, 2013)

Reliability Standard: EOP-004-1

Requirement: 3

Region: RFC

Issue: On June 29, 2012, the Duke system experienced a power outage affecting more than 50,000 customers, which is a reportable incident pursuant to EOP-004-1. Although Duke submitted a preliminary report of the incident to the Department of Energy, when it went to submit the final report, it discovered that an issue with its software had prevented the preliminary report from being submitted to NERC and RFC. Duke submitted the final report on July 2, 2012, to DOE and the preliminary and final reports to NERC and RFC on that same day. Duke self-reported in September 2012 that as a BA, GOP, LSE, and TOP it failed to comply with the incident reporting requirements of the Reliability Standard.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk. The risk to BPS operations was mitigated because Duke had submitted the preliminary report on time to DOE, and the final report was submitted soon after the storm-related outage to DOE, NERC and RFC.

Find, Fix and Track Entity, FERC Docket No. RC12-1 (October 31, 2011)

Reliability Standard: EOP-004-1

Requirement: R3/3.1

Region: RFC

Issue: FFT Entity self-reported that it did not timely submit, within the 24-hour reporting period, a report to RFC and NERC on storm-related outages that caused more than 50,000 customers to be without power for more than one hour.

Finding: RFC found that the issue constituted a minimal risk to BPS reliability since the reportable incident was related to the storm outages. In addition, FFT Entity submitted the preliminary report on the incident to the U.S. Department of Energy within 48 hours after the incident occurred.

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

Reliability Standard: EOP-004-1

Requirement: R3

Region: MRO

Issue: FFT Entity self-reported that it had not submitted to MRO and NERC a preliminary written report within 24 hours of a reportable incident.

Finding: MRO found the issue constituted a minimal risk to BPS reliability because FFT Entity analyzed the service disruption and carried out the necessary repairs to address the cause of the disruption. FFT Entity also provided a preliminary written report to MRO and NERC.

Find, Fix and Track Entity, Docket No. RC12-7-000 (January 31, 2012)

Reliability Standard: EOP-004-1

Requirement: R3/R3.1

Region: ReliabilityFirst

Issue: FFT Entity self-reported a breach of EOP-004-1 R3.1 because it failed to provide ReliabilityFirst and NERC a copy of the Preliminary Report it had submitted to the DOE within the 24-hour window required by the Standard. The report, detailing a storm that resulted in a loss of power to more than 50,000 customers, was submitted 88 hours after the 24-hour period expired. In a subsequent internal review, FFT Entity also identified another storm two years prior, where it submitted the final DOE report two days late and has no record of providing copies of that Preliminary Report to ReliabilityFirst or NERC.

Finding: ReliabilityFirst determined that the issue posed only a minimal risk to the reliability of the BPS for two reasons. First, both incidents were storm-related, and FFT Entity submitted Preliminary Reports to the DOE within 48 hours of each incident. Second, regarding the more recent storm, FFT Entity provided ReliabilityFirst and NERC a copy of the Preliminary Report within four days. FFT Entity also remedied its error from the earlier storm by providing the Preliminary Report for that storm to ReliabilityFirst and NERC.

Owensboro, KY Municipal Utilities (OMU), Docket No. RC13-7-000 (March 27, 2013)

Reliability Standard: EOP-004-1

Requirement: 3

Region: SERC

Issue: Prior to a compliance audit, OMU submitted a self-report to SERC regarding a compliance issue with EOP-004-1. Specifically, OMU, a registered LSE, reported that it had not provided a preliminary report, as required, to DOE, NERC and SERC after a reportable event during which OMU was unable to buy power from the market to replace the loss of a unit taken offline due to a tube leak. OMU eventually lowered its system voltage and asked customers to reduce usage after an Energy Emergency Alert (EEA) had been issued by its Reliability Coordinator (RC) in response to unsuccessful attempts to resolve the capacity deficiency.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk because OMU was in direct communication with its RC, Balancing Authority and neighboring TOPs for the duration of the event, and OMU followed all EEA directives.

PPL Electric Utilities Corporation, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: EOP-004-1

Requirement: R3

Region: RFC

Issue: PPL Electric Utilities Corporation ("PPL EU"), as a LSE, self-reported that it had not provided RFC and NERC with a copy of the preliminary written report that it submitted to the U.S. Department of Energy regarding a storm in August 2011 that caused more than 50,000 of its customers to lose power for more than one hour.

Finding: RFC found that this issue constituted only a minimal risk to the BPS. PPL EU did have procedures in place to submit reports on reportable incidents to NERC and RFC, which it successfully followed in response to reportable incidents in May 2011 and October 2011. PPL EU’s failure to submit the report on the August 2011 incident to NERC and RFC was an isolated incident caused by human error.

Unidentified Registered Entity (URE), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: EOP-004-1

Requirement: 3.1

Region: TRE

Issue: URE filed a self-report disclosing that it had not timely given TRE or NERC a preliminary documented report of a loss of more than 1,000 MW of generation that was caused by an inadvertent trip that happened on some of URE’s units. The loss of generation caused ERCOT’s system frequency to drop, but ERCOT responded to the incident within 15 minutes, less time than that required for system restoration. URE was required to report the issue within 24 hours of occurrence; however, URE did not provide TRE and NERC a Preliminary Disturbance Report detailing the event until 10 days later. URE has reported all similar generation loss events within the required time frame set forth in EOP-004-1 R3.1.

Finding: The issue was deemed by TRE to pose minimal risk to BPS reliability because URE had notified ERCOT of the event via telephone not long after it happened, and ERCOT submitted the required information to both TRE and NERC. Even though the information eventually provided by URE was required, in this instance, it was redundant to the information ERCOT provided TRE and NERC. The issue was ultimately determined to be documentation related. URE implemented processes to ensure all reportable events are documented and information promptly provided to the appropriate parties. In addition, no reliability issues arose during the relevant time period.