NERC FFT Reports: Reliability Standard COM-001-1 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard COM-001-1

NERC FFT Reports: Reliability Standard COM-001-1

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

Reliability Standard: COM-001-1

Requirement: R5

Region: FRCC

Issue: FFT Entity self-certified that it did not possess sufficient documentation of its written operating instructions and procedures for the continued operation of the system during the loss of telecommunication facilities at its control center and substations.

Finding: FRCC found that this issue constituted only a minimal risk to BPS reliability. According to other company documents, FFT Entity’s system operators were instructed, in situations where telecommunication facilities are lost, to use cell phones to maintain communications.

National Nuclear Security Administration - Los Alamos National Laboratory (NNSAL), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: COM-001-1

Requirement: R1, R2, R3, R5

Region: WECC

Issue: While conducting an internal compliance review in January 2008, NNSAL discovered compliance issues related to its role as an LSE. First, NNSAL had no documented procedures in place for using telecommunications facilities to contact and exchange operation information with its RC and BA. COM-001-1 R1 also requires an LSE to document any redundancy to telecommunications facilities and how such facilities are routed; however, NNSAL had not recorded such information. Second, NNSAL had no documented procedures related to managing, monitoring and testing communications equipment nor had it addressed equipment not used for routine communications, as required by COM-001-1 R2. Regarding R3, no means to coordinate telecommunications among surrounding areas had been formalized. Finally, NNSAL had not documented instructions and procedures to ensure continued operation in the event of the loss of telecommunications equipment as required by COM-001-1 R5.

Finding: The violations were deemed by WECC to pose minimal risk to BPS reliability because during the period of non-compliance, NNSAL had informal procedures in place for the primary and back up communication systems in the event of a loss of telecommunications equipment. Also, NNSAL only distributes power to its own service area thereby reducing the risk to BPS reliability despite it not having links to other RCs, TOPs or BAs.