NERC Case Notes: Reliability Standard TOP-006-2 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard TOP-006-2

NERC Case Notes: Reliability Standard TOP-006-2

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

Unidentified Registered Entity, FERC Docket No. NP15-24-000 (April 30, 2015)

Reliability Standard: TOP-006-2

Requirement: R1

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: ReliabilityFirst

Issue: URE submitted four Self-Reports to ReliabilityFirst, stating it had violations of CIP-007-3a R3, and TOP 006-2 R1, R2 and R5. URE's transmission operation control center (TOCC) experienced ECS failure for a duration of 91 minutes, resulting in loss of monitoring and control. This was a result of URE's failure to assess a released upgrade. The violation of CIP-007 R3a was due to URE's failure to track, evaluate, test and install all software patches, and to identify compensating measures when patches were not installed. The TOP-006-2 R1 violation was the result of URE's failure to monitor and inform the Reliability Coordinator of all available transmission resources. The TOP-006-2 R2 violation was a result of URE's failure to monitor applicable transmission line status, real and reactive power flows, voltage, and status of rotating and static reactive resources. The violation of TOP-006-2 R5 was the result of URE's failure to use monitoring equipment to communicate important changes in operating condition and a need for corrective action to operating staff.

Finding: ReliabilityFirst determined that the violation posed a serious or substantial risk because the inadequately tested patch caused an interruption of 91 minutes. The CIP violation lasted for a prolonged period of time and the TIP violation lasted 91 minutes. URE neither admitted nor denied the violations. In approving the settlement, the NERC considered URE's compliance history and the serious risk of all but one of the violations as aggravating factors. As mitigating factors, the NERC considered URE's (1) pre-violation compliance program, (2) self-reporting of four violations, (3) cooperation throughout the enforcement process, (5) lack of attempts or intentions to conceal the violations, (4) commitment to a comprehensive mitigation plan, (5) improvements in CIP compliance and permission for future ReliabilityFirst spot checks, (6) allowance of on-site risk management and compliance implementation reviews. URE's mitigation plan obliged URE, among other things, to (1) include steps to transfer communication between control centers in the action plan and (2) improve synchrophasor usage.

Penalty: $150,000 (aggregate for 18 violations)

FERC Order: Issued May 29, 2015 (no further review)

Unidentified Registered Entity, FERC Docket No. NP15-24-000 (April 30, 2015)

Reliability Standard: TOP-006-2

Requirement: R2

Violation Risk Factor: High

Violation Severity Level: Severe

Region: ReliabilityFirst

Issue: URE submitted four Self-Reports to ReliabilityFirst, stating it had violations of CIP-007-3a R3, and TOP 006-2 R1, R2 and R5. URE's transmission operation control center (TOCC) experienced ECS failure for a duration of 91 minutes, resulting in loss of monitoring and control. This was a result of URE's failure to assess a released upgrade. The violation of CIP-007 R3a was due to URE's failure to track, evaluate, test and install all software patches, and to identify compensating measures when patches were not installed. The TOP-006-2 R1 violation was the result of URE's failure to monitor and inform the Reliability Coordinator of all available transmission resources. The TOP-006-2 R2 violation was a result of URE's failure to monitor applicable transmission line status, real and reactive power flows, voltage, and status of rotating and static reactive resources. The violation of TOP-006-2 R5 was the result of URE's failure to use monitoring equipment to communicate important changes in operating condition and a need for corrective action to operating staff.

Finding: ReliabilityFirst determined that the violation posed a serious or substantial risk because the inadequately tested patch caused an interruption of 91 minutes. The CIP violation lasted for a prolonged period of time and the TIP violation lasted 91 minutes. URE neither admitted nor denied the violations. In approving the settlement, the NERC considered URE's compliance history and the serious risk of all but one of the violations as aggravating factors. As mitigating factors, the NERC considered URE's (1) pre-violation compliance program, (2) self-reporting of four violations, (3) cooperation throughout the enforcement process, (5) lack of attempts or intentions to conceal the violations, (4) commitment to a comprehensive mitigation plan, (5) improvements in CIP compliance and permission for future ReliabilityFirst spot checks, (6) allowance of on-site risk management and compliance implementation reviews. URE's mitigation plan obliged URE, among other things, to (1) include steps to transfer communication between control centers in the action plan and (2) improve synchrophasor usage.

Penalty: $150,000 (aggregate for 18 violations)

FERC Order: Issued May 29, 2015 (no further review)

Unidentified Registered Entity, FERC Docket No. NP15-24-000 (April 30, 2015)

Reliability Standard: TOP-006-2

Requirement: R5

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: ReliabilityFirst

Issue: URE submitted four Self-Reports to ReliabilityFirst, stating it had violations of CIP-007-3a R3, and TOP 006-2 R1, R2 and R5. URE's transmission operation control center (TOCC) experienced ECS failure for a duration of 91 minutes, resulting in loss of monitoring and control. This was a result of URE's failure to assess a released upgrade. The violation of CIP-007 R3a was due to URE's failure to track, evaluate, test and install all software patches, and to identify compensating measures when patches were not installed. The TOP-006-2 R1 violation was the result of URE's failure to monitor and inform the Reliability Coordinator of all available transmission resources. The TOP-006-2 R2 violation was a result of URE's failure to monitor applicable transmission line status, real and reactive power flows, voltage, and status of rotating and static reactive resources. The violation of TOP-006-2 R5 was the result of URE's failure to use monitoring equipment to communicate important changes in operating condition and a need for corrective action to operating staff.

Finding: ReliabilityFirst determined that the violation posed a serious or substantial risk because the inadequately tested patch caused an interruption of 91 minutes. The CIP violation lasted for a prolonged period of time and the TIP violation lasted 91 minutes. URE neither admitted nor denied the violations. In approving the settlement, the NERC considered URE's compliance history and the serious risk of all but one of the violations as aggravating factors. As mitigating factors, the NERC considered URE's (1) pre-violation compliance program, (2) self-reporting of four violations, (3) cooperation throughout the enforcement process, (5) lack of attempts or intentions to conceal the violations, (4) commitment to a comprehensive mitigation plan, (5) improvements in CIP compliance and permission for future ReliabilityFirst spot checks, (6) allowance of on-site risk management and compliance implementation reviews. URE's mitigation plan obliged URE, among other things, to (1) include steps to transfer communication between control centers in the action plan and (2) improve synchrophasor usage.

Penalty: $150,000 (aggregate for 18 violations)

FERC Order: Issued May 29, 2015 (no further review)