NERC FFT Reports: Reliability Standard EOP-005-1 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard EOP-005-1

NERC FFT Reports: Reliability Standard EOP-005-1

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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.

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

Reliability Standard: EOP-005-1

Requirement: R1, R4

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity’s emergency plan did not address loss of communication power supplies as required (R1). FRCC also determined that FFT Entity did not have a complete plan in place to respond to the loss of functionality at the control center (R4).

Finding: FRCC found that these issues constituted only a minimal risk to BPS reliability. In terms of R1, FRCC found, based on other company documents, that FFT Entity’s system operators would have enacted the needed communications for an emergency. The system operators also had multiple communication methods and would be able to respond to any loss of communication power supplies by using an alternate communication path. For R4, after April 29, 2008, FFT Entity did have a partial plan that addressed control center loss of functionality. Furthermore, FFT Entity is a relatively small entity.

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

Reliability Standard: EOP-005-1

Requirement: R4

Region: FRCC

Issue: During a compliance audit, FRCC found that FFT Entity, for 16 months, did not coordinate restoration plans with its RC, neighboring TOPs and BAs.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity did have restoration plans in place and was able to provide them on request. In addition, FFT Entity’s staff had received training on how to execute the restoration plans.

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

Reliability Standard: EOP-005-1

Requirement: R6

Region: SPP

Issue: FFT Entity self-reported that one of its system operators (out of 7) did not receive the required training on FFT Entity’s system restoration plan in 2009.

Finding: SPP found that the issue constituted only a minimal risk to BPS reliability. The relevant system operator had been a dispatcher with FFT Entity for 12 years and he received the 2009 training once the oversight was discovered. In addition, all of the other system operators had received the required system restoration plan training in 2009 and no incidents that implicated the training occurred during the course of the violation.

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

Reliability Standard: EOP-005-1

Requirement: R7

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity did not, for two years, conduct actual testing or simulation to verify its restoration procedure.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since the FFT Entity’s restoration procedure was used by its operators in tabletop training.

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

Reliability Standard: EOP-005-1

Requirement: R7

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity, for three years, did not conduct actual testing or simulation to verify its restoration procedure.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity operates less than 50 miles of 138 kV transmission lines and has no black start capability. In addition, FFT Entity uses its restoration procedures as part of the training for its operators.

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

Reliability Standard: EOP-005-1

Requirement: R7

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity had not conducted actual testing or simulation for 33 months to verify its restoration procedure.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity, a TOP, only operates less than 50 miles of 138 kV transmission lines and does not have black start capability. In addition, FFT Entity used its restoration procedure in tabletop training for its operators.

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

Reliability Standard: EOP-005-1

Requirement: R7

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity had not conducted actual testing or simulation for 40 months to verify its restoration procedure.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity had a documented restoration procedure in place and the procedure was used for operator training.

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

Reliability Standard: EOP-005-1

Requirement: R1

Region: SPP RE

Issue: During a compliance audit, SPP RE determined FFT Entity violated EOP-005-1 R1 because it failed to document that all of its system operators annually received System Restoration training as required by Attachment 1 to the Standard.

Finding: This issue posed only a minimal risk to the reliability of the BPS because FFT Entity could provide documentation proving that all system operators had performed multiple system restoration training simulations. As such, SPP RE determined each of the system operators was familiar with system restoration.

Memphis Light, Gas and Water Division (MLGW), Docket No. RC13-10, June 27, 2013

Reliability Standard: EOP-005-1

Requirement: R2

Region: SERC

Issue: MLGW, as a TOP, self-reported an issue with EOP-005-1 R2 to SERC when it found that it had failed to update its restoration plan in 2012 after having identified the need for certain revisions following a restoration drill in 2011. Such revisions included changes to account for improvements and the new Collierville gate station, and a change in the path used to re-energize the system from a gate to the interchange.

Finding: SERC determined that the issue posed a minimal risk to the reliability of the BPS for numerous reasons including: (1) if MLGW’s restoration was unable to follow the prescribed path prescribed by Tennessee Valley Authority (TVA) that was directing the restoration of the MLGW transmission system, TVA would have directed circuit and load restoration through another path; (2) MLGW does not have any blackstart resources in its TOP area and its restoration plan does not require cranking paths to restore station services to any other generators in its TOP area; and (3) the TOP’s transmission facilities are not part of any other TOP-defined cranking paths.

Midwest Energy, Inc. (Midwest), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: EOP-005-1

Requirement: 6

Region: SPP RE

Issue: Midwest self-reported that it could not verify the participation in annual system restoration training exercises for three of its system operators during 2011, in compliance with R6. One system operator did not complete the annual restoration training. Two other system operators received restoration training in 2011, however, at the time they were not certified as system operators; consequently, the training was not documented since the operators were not registered in the SPP RTO Learning Management System (LMS).

Finding: SPP RE found the issue posed a minimal risk to the reliability of the BPS since the system operator lacking annual system restoration training had already participated in SPP RTO regional restoration drills in 2009 and 2010, as well as finished 32 hours of emergency operations training from other training resources. The two other system operators complied with restoration training but failed to have it formally documented in the LMS.

Northern Indiana Public Service Company (NIPSCO), Docket No. RC13-10, June 27, 2013

Reliability Standard: EOP-005-1

Requirement: R4; R7

Region: RFC

Issue: Further to a Compliance Audit, RFC found that NIPSCO had issues with EOP-005-1 R4 and R7. Regarding R4, RFC found that NIPSCO, as a TOP, had failed to coordinate its restoration plans with all the GOs (specifically the Independent Power Producers (IPPs)) within its area. Regarding R7, RFC found that NIPSCO, as a TOP and BA, had failed to use testing or simulation to verify that each restoration procedure that uses intertie assistance were safe and effective in the restoration of its system. Although NIPSCO tested and verified its primary restoration procedure (its black start procedure), seven attachments included in its black start procedure consisted of restoration procedures using intertie assistance. While NIPSCO tested and verified its primary intertie restoration procedure, it failed to test the remaining six intertie restoration procedures.

Finding: RFC determined that the issues posed a minimal risk to the reliability of the BPS for numerous reasons. Regarding R4, the IPPs within NIPSCO’s area do not participate in NIPSCO’s restoration plans, have no blackstart capability, and cannot unilaterally inject energy onto the BPS. In addition NIPSCO does not provide cranking power to any IPP in its area as part of its restoration plans and the TOP coordinated its restoration plan with all non-IPP GOs, Balancing Authorities, and Reliability Coordinators in its area as well as neighboring TOPs. Regarding R7, NIPSCO indeed tested and verified its black start restoration procedure and primary intertie restoration procedure as required by the Standard and pursuant to verification through simulation following the Compliance Audit, NIPSCO found that each intertie restoration procedure was a viable restoration solution for its system and would have functioned as intended.

Progress Energy Florida (PEF), Docket No. RC13-10, June 27, 2013

Reliability Standard: EOP-005-1

Requirement: R2

Region: FRCC

Issue: Further to a Compliance Audit, FRCC found that PEF, as a TOP, had issue with EOP-005-1 R2 because it had not updated its restoration plan after making a change to its power system network by changing a loop section of its sample restoration plan provided to the system operators following the removal of a 115 kV line.

Finding: FRCC determined that the issue posed a minimal risk to the reliability of the BPS because it was a documentation issue and because simulations showed that the flexibility of the restoration plan allows for the closing of alternate lines