Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)
Reliability Standard: PER-002-0
Requirement: R3.4
Region: FRCC
Issue: FFT Entity self-reported that it did not possess sufficient documentation showing that all of its training staff had instructional capabilities.
Finding: FRCC found that this issue constituted only a minimal risk to BPS reliability since FFT Entity’s instructors had sufficient operational capabilities (as well as having one employee who possessed the required instructional capabilities). Furthermore, FFT Entity is a relatively small entity.
Find, Fix and Track Entity, FERC Docket No. RC12-1 (October 31, 2011)
Reliability Standard: PER-002-0
Requirement: R1, R4, R3/3.4
Region: FRCC
Issue: During a compliance audit, FRCC determined that FFT Entity was unable to demonstrate, for a 31-month period, that it appropriately trained its operating personnel (R1). FRCC determined that FFT Entity, for two years, did not provide all of its operating personnel with all of the required training needed to satisfy the requirements for qualified operating personnel (R4). FRCC also found that FFT Entity could not, for a 19-month period, identify all of its training staff and demonstrate, for a one-year period, that its training staff had sufficient knowledge of system operations and instructional capabilities (R3/3.4).
Finding: FRCC found that the issues only constituted a minimal risk to BPS reliability. In regards to R1 and R4, FFT Entity’s operating personnel were NERC-certified operators who satisfied the annual mandated 32 hours of emergency operating training as well as receiving training on system restoration procedures. Even though 2 out of FFT Entity’s 9 system operators did not timely complete a few of the other required training topics, all of the system operators maintained their certification. In regards to R3/3.4, FFT Entity used subject matter experts to train its operators and conducted training by committee. In addition, all of the training staff was judged to be competent in their knowledge of system operations.
Find, Fix and Track Entity, Docket No. RC12-7-000 (January 31, 2012)
Reliability Standard: PER-002-0
Requirement: R3.1
Region: NCEA
Issue: NCEA determined FFT Entity violated PER-002-0 R3.1 because it did not ensure that third-party entities that were performing tasks on its behalf met the requirements of this Standard. The third party at issue failed to prove that its training program properly defined objectives based on entity operating procedures. Instead, the third party used a vendor to set training objectives based on NERC Standards.
Finding: This issue posed only a moderate risk to the reliability of the BPS because, in a subsequent spot check, NCEA found no evidence of noncompliance.
Northern Indiana Public Service Company (NIPSCO), Docket No. RC12-16-000 (September 28, 2012)
Reliability Standard: PER-002-0
Requirement: 3
Region: ReliabilityFirst
Issue: Stemming from a compliance audit of NIPSCO conducted between December 6 and December 13, 2011, ReliabilityFirst determined the company, operating as a Balancing Authority and Transmission Operator, violated PER-002-0/3.1 and 3.4 for, respectively, failing to document Regional Reliability Organization standards, entity operating procedures and applicable regulatory requirements and failing to adequately identify its training staff in its training program.
Finding: ReliabilityFirst determined this issue posed only a minimal risk to the reliability of the BPS because the violation was limited to a documentation error. While NIPSCO did lack documentation establishing the objectives and identifying the trainers in the training program, the existing training materials did address the objectives described in the Standard and the company's training staff was sufficient as evidenced by their variety of tenure, industry experience, and completion of Midwest ISO's "Train-the-Trainer" series.
