NERC FFT Reports: Reliability Standard CIP-002-3a


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Texas Medical Center Central Heating and Cooling Services Corp (TECO), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: CIP-002-3a

Requirement: 1; 3

Region: TRE

Issue: TECO, as a GO, self-reported a redressed violation of R1 of CIP-001-2a to TRE on August 28, 2012. The violation involved TECO's procedures, which did not meet the mandates for making operating personnel recognize and become aware of sabotage events. The duration of violation was from October 1, 2011, the date on which TECO first was mandated to comply with the standard, to August 2, 2012, the date on which TECO updated its sabotage reporting procedures. TECO also self-reported a violation of R3 of CIP-001-2a to TRE on August 28, 2012, for the failure to make available sabotage response guidelines, e.g., contact person, to the operating personnel. The duration of this violation was from October 1, 2011 to November 19, 2012, when operating personnel received an updated sabotage reporting procedure.

Finding: TRE found that this issue posed a minimal risk to the reliability of the bulk power system for the following reasons: (1) TECO's generation unit, at 48MW, supplies a low amount of power that would not be threatening to the BPS even in case of a potential failure; (2) because TECO had security procedures before August 2, 2012, which included bomb threat emergency and violent act emergency, as well as notification of operating personnel, its personnel was determined to be prepared in case of a sabotage act, although the procedures failed to address the specific mandates of CIP-001-2a R1.