NERC FFT Reports: Reliability Standard EOP-008-0 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard EOP-008-0

NERC FFT Reports: Reliability Standard EOP-008-0

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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.

American Electric Power Service Corporation ("AEP"), FERC Docket No. FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: EOP-008-0

Requirement: 1; 1.3; 1.6

Region: RFC and SPP

Issue: RFC and SPP conducted an audit of AEP, during which it was discovered that AEP, as a TOP, had an issue with R1. AEP performs the TOP functions in RFC from two control centers and has a contingency plan for each control center in order to maintain reliability operations in the event it becomes inoperable. One facility, in New Albany, Ohio, contained a list of the critical facilities in its contingency plan, however the other facility, in Roanoke, Virginia, did have a contingency plan that contained a list of the critical facilities (per R1.3). In addition, AEP performs the BA function in SPP from the two control centers in question. AEP also performs the TOP function in SPP from the New Albany facilities, as well as facilities in Tulsa, Oklahoma and Shreveport, Louisiana. AEP has a contingency plan for each of the control centers in order to maintain reliability operations in the event the control center becomes inoperable. The contingency plan for the New Albany facility did not list the TOP or BA critical facilities (per R1.3). Furthermore, the contingency plans for the Columbus and Shreveport facilities did not contain procedures and responsibilities for providing annual training (per R1.6).

Finding: RFC and SPP found the issue posed a minimal risk to the reliability of the BPS because the risk was mitigated by the fact that the list of all critical facilities did exist (and was located in the New Albany contingency plans), even though it was not contained in several contingency plans. Additionally, AEP evidenced that it had completed the required annual training even though the requirement to provide training was not in the contingency plans.

American Electric Power Service Corp as agent for AEP Texas North Co, AEP Texas Central Co, and Public Service of Oklahoma (AEP), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: EOP-008-0

Requirement: 1; 1.3; 1.7

Region: TRE

Issue: TRE's audit of AEP on August 10, 2012 revealed that AEP, as a TOP, failed to list critical transmission facilities in its control center contingency plan, as mandated by EOP-008-0 R1.3. AEP also failed to do an annual review and an update of its 2011 control center contingency plan, violating R1.7. AEP's violation lasted from May 4, 2010, the date of AEP's registration as a TOP, to September 16, 2012, the date on which AEP did perform an annual review of its control center contingency plan and listed the critical transmission facilities.

Finding: TRE found that this issue posed a minimal risk to the reliability of the bulk power system for the following reasons: (1) as for R 1.3, TRE found that AEP did have a list of critical transmission facilities but that it had failed to put it in the contingency plan, making the violation to be a documentation issue; (2) as for R1.7, TRE found that AEP did review and update its plan within a 14 month period and there were no material changes made after the review, rendering the risk minimal to the BPS.

Brazos Electric Power Co Op, Inc. (Brazos), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: EOP-008-0

Requirement: 1

Region: Texas RE

Issue: During an audit, Texas RE found that Brazos had a remediated issue with R1, R1.1, and R1.3. Brazos failed to complete its backup control center (BUCC); Brazos plans for continuing operations in the event its control center became inoperable relied upon the construction and commissioning of a BUCC. Brazos' submitted an implementation plan that included details and milestone dates related to the construction of the BUCC and was certified as a TOP effective October 1, 2010. The revised implementation plan included a prescription for completion of its BUCC by August 31, 2011; due to technical delays arising from the installation of the communication system, Brazos was unable to complete the BUCC until October 13, 2011, resulting in a failure to comply with the Standard.

Finding: Texas RE found the issue posed a minimal risk to the reliability of the BPS because the lapse between the milestone date and actual commissioning date was inconsequential to the BUCC construction undertaking. Additionally, Brazos had an approved implementation plan and, at the time of the issue, had a backup plan in the event construction of the BUCC was delayed. Furthermore, given the circumstances, it is reasonable to conclude that Texas RE would have granted a request for extension of its Mitigation Plan if Brazos had asked.

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

Reliability Standard: EOP-008-0

Requirement: R1

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity’s plan to respond to the loss of functionality at the control center did not incorporate provisions on performing annual tests to verify the viability of the plan and provisions on annual training for operating personnel on the implementation of contingency plans.

Finding: FRCC found that this issue constituted only a minimal risk to BPS reliability since FFT Entity did have a partial plan that addressed control center loss of functionality. FFT Entity was also performing periodic tests on the plan and organizing training on the plan. Furthermore, FFT Entity is a relatively small entity.

Find, Fix, Track and Report, Docket No. RC12-2 (November 30, 2011)

Reliability Standard: EOP-008-0

Requirement: R1.7

Region: SPP

Issue: FFT Entity self-reported that, for the year 2010, it could not show it had updated or reviewed its transmission systems Emergency Operation Plans or its plan to continue reliability operations should its control center become inoperable. FFT Entity reported that it last reviewed and updated its transmission system Emergency Operations Plan in the fall of 2009.

Finding: SPP RE determined that the issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS. FFT Entity could provide a document that would be its plan for a loss of control center functionality as required by EOP-008-0 R1, however, it could not show it had been reviewed or updated for the year 2010, but FFT Entity did report that there were no substantial changes made other than updating personnel information.

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

Reliability Standard: EOP-008-0

Requirement: R1/R1.6

Region: SPP RE

Issue: During a compliance audit, SPP RE determined that FFT Entity violated EOP-008-0 R1.6 because while both of FFT Entity’s Loss of Control Center Functionality plans state that operator training must be conducted annually, they are silent as to who is responsible to ensure the training takes place.

Finding: This issue posed only a minimal risk to BPS reliability for three reasons. First, although no responsibility was assigned, annual training and drills were conducted throughout the duration of this issue. Second, FFT Entity’s plans were otherwise comprehensive and in line with the requirements of the Standards. Third, FFT Entity updated its procedures to remedy the problem.

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

Reliability Standard: EOP-008-0

Requirement: R1.5

Region: NCEA

Issue: NCEA determined FFT Entity violated EOP-008-0 R1.5 because it failed to ensure that a third-party entity performing tasks on its behalf met the requirements of this Standard. The third party at issue failed to conduct annual tests at its control center to ensure the viability of its contingency plan. During the compliance audit, FFT Entity provided evidence that tests were conducted in 2005, 2006 and 2009, but not in 2007 and 2008.

Finding: This issue posed only a moderate risk to the reliability of the BPS because missing two tests over five years caused only limited impact on the viability of the contingency plan.

Lafayette Utilities System (LAFA), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: EOP-008-0

Requirement: 1.6

Region: SPP

Issue: SPP found that LAFA violated R 1.6 of the EOP-008-0 while conducting a compliance audit in September 2011. Despite LAFA's contingency plan which mandated annual training for all personnel, LAFA could not show that three out of five of its operators went through such training for loss of the primary control center in 2009 and 2010.

Finding: SPP found that the issue posed a minimal risk to the reliability of the bulk power system for the following reasons: (1) LAFA had a contingency plan from 2009-2010 which adequately satisfied EOP-008-0, with the exception of R1.6; (2) Despite LAFA's failure to show that three of five operators didn't have annual training, they have been working for LAFA for more than five years and had received training on LAFA's contingency plan, underwent drills, before 2009; (3) After 2010, all operators received training on LAFA's contingency plan.

Louisiana Energy & Power Authority (LEPA), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: EOP-008-0

Requirement: R1.5, R1.6

Region: SPP

Issue: While conducting a Compliance Audit, SPP found that LEPA, as a BA, had a contingency plan for reliable operations should its control center become disabled, however, the plan did not have procedures and responsibilities for testing its viability. The plan also did not include procedures and responsibilities for annual training for continued assurance of the plan’s workability.

Finding: The issue was found to pose minimal risk to BPS reliability because even though LEPA’s plan was not compliant with the Standard, LEPA had provided training on the contingency plan and had available the training sign-in sheets. In addition, LEPA showed that the operator training took place yearly and the contingency plan was reviewed and updated at least semi-annually.

Midwest Energy, Inc. ("Midwest"), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: EOP-008-0

Requirement: 1.5;1.6

Region: SPP

Issue: During an audit, SPP RE discovered issues with non-compliance of R1.5 and R1.6. Midwest's plan for loss of control center functionality (Plan) stipulated the deployment of field personnel to critical facilities with the goal of communicating field conditions back to operations staff. The Plan also stated that, "[o]n an annual basis[,] System Operators and other assigned personnel will be subjected to a review of the process and procedures to be implemented in the event the Primary Control Center is lost." SPP found that while an annual training session and table top exercise were conducted with in accordance with the Plan, field personnel did not participate in the training session or in the communication exercises with operations staff, and were not deployed to the critical facilities.

Finding: SPP found the issue posed a minimal risk to the reliability of the BPS since the operations staff in charge of oversight underwent training and a table top exercise, and were prepared to respond in an emergency situation. In addition, the field personnel in question are the same individuals that inspect the critical facilities on a monthly basis, and as a result, they are familiar with the location of the critical facilities.

Northern Indiana Public Service Company (NIPSCO), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: EOP-008-0

Requirement: 1

Region: RFC

Issue: During a compliance audit in December 2011, RFC found that NIPSCO, in its role as a BA and TOP, was non-compliant with EOP-008-0 R1 because NIPSCO's Operations and Cyber Recovery Plan (Plan) to continue reliability operations if their control center becomes inoperable did not meet the requirements set forth in EOP-008-0, R1.5 and R1.6. In particular, NIPSCO's Plan states "[t]he Electric Transmission Department is to coordinate tests, at least annually, of this recovery plan. Operating personnel shall review and undergo training at least annually on the procedures and responsibilities contained within this plan." RFC stated that the two sentences show that the Plan did not have procedures and responsibilities for conducting periodic tests, at least annually, or for providing annual training pursuant to EOP-008-0 R1.5 and R1.6.

Finding: The issue was deemed by RFC to pose minimal risk to BPS reliability which was mitigated by the fact the issue is document related. NIPSCO was conducting the annual testing to show the Plan's viability and was training operating personnel; however, it failed to document requirements of EOP-008-0 R1.5 and R1.6 in its Plan.

Wolverine Power Supply Cooperative, Inc. (Wolverine), Docket No. RC13-6-000 (February 28, 2013)

Reliability Standard: EOP-008-0

Requirement: 1/1.3

Region: RFC

Issue: During a compliance audit in May 2012, RFC found that the contingency plan document in use by Wolverine, as a TOP, was not complete as to monitoring or control of all components of its control center in the event the control center were to become inoperable.

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 of Wolverine's small footprint, and Wolverine has no critical transmission facilities. Also, even though the document was incomplete, certain components under R1.3 are not applicable to Wolverine.