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NERC Case Notes: Reliability Standard EOP-008-1

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Arlington Valley, LLC - AVBA, FERC Docket No. NP13-9 (December 31, 2012)

Reliability Standard: EOP-008-1

Requirement: 1

Violation Risk Factor: High

Violation Severity Level: Severe

Region: WECC

Issue: AVBA self-reported, as a TOP, that it did not have a sufficient plan in place that provides for the continuation of operation when there is a loss of control room functionality. Instead, AVBA called for the plant to shut down if the plant control room became inoperable.

Finding: WECC found that the EOP-008-1 violation only constituted a minimal risk to BPS reliability. Constellation Energy Control and Dispatch (CECD), in its role as AVBA's BA Service Agent, had a plan that AVBA would follow in the event of the loss of control room functionality. The duration of the EOP-008-1 R1 violation was from November 5, 2007 through March 1, 2009. AVBA stipulated to the violations. In approving the settlement agreement, the NERC BOTCC considered the fact that these violations were AVBA's first violations of the relevant Reliability Standards; the violations were not intentional and were promptly mitigated once discovered; and AVBA was cooperative during the enforcement process and did not conceal the violations. In addition, all but one of AVBA's violations did not constitute a serious or substantial risk to BPS reliability.

Penalty: $60,000 (aggregate for 43 violations)

FERC Order: Issued January 30, 2013 (no further review)