NERC FFT Reports: Reliability Standard EOP-008-1 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard EOP-008-1

NERC FFT Reports: Reliability Standard EOP-008-1

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Find, Fix and Track Entity, Docket No. RC12-6 (December 30, 2011)

Reliability Standard: EOP-008-1

Requirement: R1/1.3/1.5/1.6

Region: RFC

Issue: While conducting a compliance audit, RFC found that FFT Entity’s contingency plan was incomplete and did not have all information required by the Standard to ensure operations are not disputed in the event the control center became inoperable. FFT Entity’s initial and revised contingency plans did not address generation control or recording of significant power system events, as required by R1.3. FFT Entity’s initial contingency plan did not set forth procedures or responsibilities for periodic testing of the plan’s viability, as required by R1.5. FFT Entity also did not have procedures and responsibilities outlined regarding annual training for employees on plan implementation, as required by R1.6.

Finding: RFC found the violation constituted a minimal risk to BPS reliability which was mitigated by certain factors. First, even though the contingency plan was incomplete, FFT Entity knew the requirements of the Standard and its back up center was used to run and tests, which were logged, that balanced generation and demand from the back-up center using Automatic Generation Control (AGC). Also, at least annually, FFT Entity operated from the back-up center. Second, the contingency plan was not used during the violation period. Third, periodic tests were performed during the year during which control staff members received training. Fourth, the initial plan was not in effect for a long time period and since activities required by R1.5 and R1.6 are undertaken annually, the contingency plan had no real impact on whether the activities were completed yearly.

Texas-New Mexico Power Co (TNMP), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: EOP-008-1

Requirement: R1

Region: TRE

Issue: While conducting an audit of TNMP, TRE found that TNMP, as a TOP, lacked documentation outlining short-term provisions for continued reliable operations in the event the primary control center was disabled. Specifically, TNMP had no written procedures on actions to be taken within one hour of the time a contingency plan was set in place. A later version of TNMP’s contingency plan sufficiently set forth the requirements of this Standard.

Finding: The issue was found to pose minimal risk to BPS reliability because it is documentation related and TNMP was found to have adequate procedures in place for continued operations, however, the procedures had not been documented until two and half months after TNMP’s registration as a TOP.