Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)
Reliability Standard: EOP-001-0
Requirement: R3.3/3.4, R4, R5
Region: FRCC
Issue: FFT Entity self-reported that it did not possess sufficient documentation showing that it had developed, maintained and implemented load shedding and system restoration plans (R3.3/3.4). FFT Entity also self-reported that it did not have adequate documentation of a communications protocol procedure for emergencies (R4). In addition, FFT Entity did not include in its emergency plan a provision, as required, on appealing to customers to use alternate fuels (R5).
Finding: FRCC found that these issues constituted only a minimal risk to BPS reliability. In regards to R3.3/3.4, FFT Entity implemented a load reduction schedule in its SCADA system and its system operators are authorized to restore the system and to shed load in order to maintain Interconnection Reliability Operating Limits and System Operating Limits. In terms of R4, FRCC found, based on other company documents, that FFT Entity’s system operators would have enacted the necessary communication during an emergency. In terms of R5, FFT Entity included all of the other required provisions in its emergency plan and has no large industrial or commercial users. Furthermore, FFT Entity is a relatively small entity.
Find, Fix and Track Entity, FERC Docket No. RC12-1 (October 31, 2011)
Reliability Standard: EOP-001-0
Requirement: R6
Region: FRCC
Issue: During a compliance audit, FRCC found that FFT Entity, for 16 months, did not provide its emergency generating capacity shortage plan, its system restoration plan, and its firm load shed plan to its RC and neighboring TOPs and BAs. In addition, FFT Entity did not, for 19 months, give its response to the transmission limit violations plan and its contingencies plan to its RC and neighboring TOPs and BAs.
Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity did have restoration plans in place and was able to provide them on request. In addition, FFT Entity’s staff had received training on how to execute the restoration plans.
Indianapolis Power & Light Company (IPL), Docket No. RC13-1 (October 31, 2012)
Reliability Standard: EOP-001-0
Requirement: 6
Region: RFC
Issue: IPL, a BA and TOP, submitted a self-report in May 2012 reporting non-compliance with EOP-001-1 because it failed to perform an annual review of its Transmission System Emergency Operating Plan as required by the Reliability Standard.
Finding: The issue was deemed by RFC to pose minimal risk to BPS reliability because the changes made to the Plan since its last review were organizational name changes and updated distribution lists. Also, many parts of the plan existed within other emergency plans that IPL had properly reviewed and updated annually.
