Find, Fix and Track Entity, Docket No. RC12-7-000 (January 31, 2012)
Reliability Standard: PER-003-0
Requirement: R1
Region: NCEA
Issue: NCEA determined FFT Entity violated PER-003-0 R1 because it did not include in its methodology or assessment the CIP assets of third-party entities that were performing tasks on its behalf. As such, because of different compliance schedules, there were gaps in time where these assets were not in compliance. Specifically, four third parties violated the Standard in the following ways:
(1) Three third-party entities failed to staff all positions responsible for real-time operating of the interconnected BES with NERC-certified personnel. All three of the third-party entities’ subject matter experts (SME) reported that non-certified operators performed transmission switching without oversight from a NERC-certified operator.
(2) The fourth third party entity did not have a NERC-certified operator on duty at all times. As such, non-certified operators performed transmission switches without oversight from a NERC-certified operator.
Finding: This issue posed only a moderate risk to the BPS because NCEA determined the noncompliance was mitigated by the following factors. Regarding the three entities that did not staff all operating positions with NERC-certified operators; only 3 of the 21 positions were staffed by uncertified operators. Furthermore, the third-party entities confirmed that the uncertified operators were in the process of obtaining the required certification through a defined 5-year program. As additional precautions, all planned facility outages were reviewed and approved by NERC-certified personnel; non-certified operators conducted transmission switches under supervision of a NERC-certified operator as stipulated in the certification program; and at least one NERC-certified dispatcher was in the operations center at all times. The fourth third-party entity is a municipal electric department serving a municipality of less than 100,000 people. According to the municipality’s 2009 annual report, the third party provided 64,000 to 65,000 MWh of energy per month to 37,000 to 38,000 accounts between 2008 and 2009.
Horse Hollow Generation Tie, LLC, FERC Docket No. RC12-11 (April 30, 2012)
Reliability Standard: PER-003-0
Requirement: R1
Region: TRE
Issue: Horse Hollow Generation Tie, LLC (HHGT) self-reported that, on the date its registration as a TOP came into effect, three (out of 4) of its operators were not NERC-certified.
Finding: TRE found that this issue constituted only a minimal risk to the BPS. The three operators had previous experience conducting transmission operation functions with ERCOT. In addition, HHGT sent week-ahead work plans to ERCOT every week that contained information on the status of all equipment affecting the power flow on HHGT’s 345 kV line and the line capability. HHGT also informed the ERCOT shift supervisor of forced outages and other information affecting real-time operations.
ISO-NE, FERC Docket No. RC12-11 (April 30, 2012)
Reliability Standard: PER-003-0
Requirement: R1/1.1
Region: NPCC
Issue: In January 2012, ISO-NE, as an RC, self-reported that, as a result of an administrative error, one of its operators was not NERC-certified during a six-hour proficiency watch that occurred on December 28, 2010. Even though the operator in question had completed the 200 training hours needed for re-certification, he had not formally renewed his Reliability Coordinator re-certification.
Finding: NPCC found that this issue constituted only a minimal risk to the BPS since the relevant operator had finished all of the required training. The operator only had to deal with an administrative issue to complete the renewal of his NERC Certification.
JEA, Docket No. RC12-14 (July 30, 2012)
Reliability Standard: PER-003-0
Requirement: 1
Region: FRCC
Issue: JEA, a BA and TOP, submitted a self-report in April 2012 stating that one of its BES system operators had not paid her annual NERC recertification fee and therefore received an RC certification suspension and revocation. The relevant employee had operated the BES without the required certification from March 17, 2011 to April 3, 2012.
Finding: The issue was deemed by FRCC to pose minimal risk to BPS reliability because the individual was an experience system operator and had been NERC RC certified since 2006 and had all of the required training hours for NERC RC certification.
