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116-390 Village Blvd. Princeton, NJ 08540 609.452.8060 | www.nerc.com

April 29, 2011 Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Re: NERC Abbreviated Notice of Penalty regarding American Municipal Power Inc.,

FERC Docket No. NP11-__-000 Dear Ms. Bose: The North American Electric Reliability Corporation (NERC) hereby provides this Abbreviated Notice of Penalty (NOP) regarding American Municipal Power Inc. (AMP), with information and details regarding the nature and resolution of the violations1 discussed in detail in the Settlement Agreement (Attachment a) and the Disposition Documents (Attachment b), in accordance with the Federal Energy Regulatory Commission’s (Commission or FERC) rules, regulations and orders, as well as NERC Rules of Procedure including Appendix 4C (NERC Compliance Monitoring and Enforcement Program (CMEP)).2

This NOP is being filed with the Commission because ReliabilityFirst Corporation (ReliabilityFirst) and AMP have entered into a Settlement Agreement to resolve all outstanding issues arising from ReliabilityFirst’s determination and findings of the enforceable violations of PRC-005-1 R2, FAC-008-1 R1/1.2.1 and FAC-009-1 R1. According to the Settlement Agreement, AMP neither admits nor denies the violations, but has agreed to the assessed penalty of twenty-five thousand dollars ($25,000), in addition to other remedies and actions to mitigate the instant violations and facilitate future compliance under the terms and conditions of the Settlement Agreement. Accordingly, the violations identified as NERC Violation Tracking

1 For purposes of this document, each violation at issue is described as a “violation,” regardless of its procedural posture and whether it was a possible, alleged or confirmed violation. 2 Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability Standards (Order No. 672), III FERC Stats. & Regs. ¶ 31,204 (2006); Notice of New Docket Prefix “NP” for Notices of Penalty Filed by the North American Electric Reliability Corporation, Docket No. RM05-30-000 (February 7, 2008). See also 18 C.F.R. Part 39 (2010). Mandatory Reliability Standards for the Bulk-Power System, FERC Stats. & Regs. ¶ 31,242 (2007) (Order No. 693), reh’g denied, 120 FERC ¶ 61,053 (2007) (Order No. 693-A). See 18 C.F.R § 39.7(c)(2).

NERC Notice of Penalty American Municipal Power Inc. April 29, 2011

Identification Numbers RFC201000238, RFC201000651 and RFC201000652 are being filed in accordance with the NERC Rules of Procedure and the CMEP. Statement of Findings Underlying the Violations This NOP incorporates the findings and justifications set forth in the Settlement Agreement executed on January 5, 2011, by and between ReliabilityFirst and AMP. The details of the findings and the basis for the penalty are set forth in the Disposition Documents. This NOP filing contains the basis for approval of the Settlement Agreement by the NERC Board of Trustees Compliance Committee (NERC BOTCC). In accordance with Section 39.7 of the Commission’s regulations, 18 C.F.R. § 39.7, NERC provides the following summary table identifying each violation of a Reliability Standard resolved by the Settlement Agreement, as discussed in greater detail below.

NOC ID NERC

Violation ID

Reliability Std.

Req. (R) VRF Duration

Total Penalty

($)

NOC-760

RFC201000238 PRC-005-1 2 High3 6/18/07 – 3/31/11

25,000 RFC201000651 FAC-008-1 1/1.2.1 Medium4 6/18/07 – 2/18/11

RFC201000652 FAC-009-1 1 Medium 6/18/07 – 3/18/11

The text of the Reliability Standards at issue and further information on the subject violations are set forth in the Disposition Documents. PRC-005-1 R2 - OVERVIEW As a result of a Self-Report submitted by AMP on January 18, 2010, ReliabilityFirst determined that AMP, as a Generator Owner (GO), did not perform maintenance and testing within the intervals specified in its Protection System5

maintenance and testing program on 15 of its estimated 175 Protection System devices, and did not fully document the implementation of its Protection System maintenance and testing program.

3 PRC-005-1 R2 has a “Lower” Violation Risk Factor (VRF); R2.1 and R2.2 each have a “High” VRF. During a final review of the standards subsequent to the March 23, 2007 filing of the Version 1 VRFs, NERC identified that some standards requirements were missing VRFs; one of these include PRC-005-1 R2.1. On May 4, 2007, NERC assigned PRC-005 R2.1 a “High” VRF. In the Commission’s June 26, 2007 Order on Violation Risk Factors, the Commission approved the PRC-005-1 R2.1 “High” VRF as filed. Therefore, the “High” VRF was in effect from June 26, 2007. In the context of this case, ReliabilityFirst determined that the violation related to both R2.1 and R2.2, and therefore a “High” VRF is appropriate. 4 FAC-008-1 R1, R1.3 and R1.3.5 each have a “Lower” VRF; R1.1, R1.2, R1.2.1, R1.2.2, R1.3.1-R1.3.4 each have a “Medium” VRF. When NERC filed VRFs it originally assigned FAC-008-1 R1.1, R1.2, R1.2.1 and R1.2.2 “Lower” VRFs. The Commission approved the VRFs as filed; however, it directed NERC to submit modifications. NERC submitted the modified “Medium” VRFs and on February 6, 2008, the Commission approved the modified “Medium” VRFs. Therefore, the “Lower” VRFs for FAC-008-1 R1.1, R1.2, R1.2.1 and R1.2.2 were in effect from June 18, 2007 until February 6, 2008 when the “Medium” VRFs became effective. 5 The NERC Glossary of Terms Used in Reliability Standards defines Protection System as “Protective relays, associated communication systems, voltage and current sensing devices, station batteries and DC control circuitry.”


FAC-008-1 R1/1.2.1 - OVERVIEW After completing a Compliance Audit from September 10, 2010 through September 30, 2010 (Audit), ReliabilityFirst determined that AMP, as a GO, did not document the methodologies used to determine Facility Ratings for transmission conductors, transformers, relay protective devices and terminal equipment. FAC-009-1 R1 - OVERVIEW After completing the Audit, ReliabilityFirst determined that AMP, as a GO, did not establish Facility Ratings for AMP’s solely and jointly owned terminal equipment and delay protective devices (including relays and voltage and current sensing devices), and AMP did not identify the most limiting elements, consistent with its associated Facility Ratings Methodology. Statement Describing the Assessed Penalty, Sanction or Enforcement Action Imposed6

Basis for Determination Taking into consideration the Commission’s direction in Order No. 693, the NERC Sanction Guidelines, the Commission’s July 3, 2008, October 26, 2009 and August 27, 2010 Guidance Orders,7

the NERC BOTCC reviewed the Settlement Agreement and supporting documentation on March 11, 2011. The NERC BOTCC approved the Settlement Agreement, including ReliabilityFirst’s assessment of a twenty-five thousand dollar ($25,000) financial penalty against AMP and other actions to facilitate future compliance required under the terms and conditions of the Settlement Agreement. In approving the Settlement Agreement, the NERC BOTCC reviewed the applicable requirements of the Commission-approved Reliability Standards and the underlying facts and circumstances of the violations at issue.

In reaching this determination, the NERC BOTCC considered the following factors:

1. the violations constituted AMP’s first occurrence of violation of the subject NERC Reliability Standards;

2. AMP self-reported the violation of PRC-005-1 R2;

3. ReliabilityFirst reported that AMP was cooperative throughout the compliance enforcement process;

4. AMP had a compliance program at the time of the violations which ReliabilityFirst considered a mitigating factor, as discussed in the Common Disposition Document;

5. there was no evidence of any attempt to conceal a violation nor evidence of intent to do so;

6 See 18 C.F.R. § 39.7(d)(4). 7 North American Electric Reliability Corporation, “Guidance Order on Reliability Notices of Penalty,” 124 FERC ¶ 61,015 (2008); North American Electric Reliability Corporation, “Further Guidance Order on Reliability Notices of Penalty,” 129 FERC ¶ 61,069 (2009); North American Electric Reliability Corporation, “Notice of No Further Review and Guidance Order,” 132 FERC ¶ 61,182 (2010).


6. ReliabilityFirst determined that the violations posed a minimal risk and did not pose a serious or substantial risk to the reliability of the bulk power system (BPS), as discussed in the Disposition Documents; and

7. ReliabilityFirst reported that there were no other mitigating or aggravating factors or extenuating circumstances that would affect the assessed penalty.

For the foregoing reasons, the NERC BOTCC approves the Settlement Agreement and believes that the assessed penalty of twenty-five thousand dollars ($25,000) is appropriate for the violations and circumstances at issue, and is consistent with NERC’s goal to promote and ensure reliability of the BPS. Pursuant to 18 C.F.R. § 39.7(e), the penalty will be effective upon expiration of the 30 day period following the filing of this NOP with FERC, or, if FERC decides to review the penalty, upon final determination by FERC. Attachments to be included as Part of this Notice of Penalty The attachments to be included as part of this NOP are the following documents:

a) Settlement Agreement by and between ReliabilityFirst and AMP executed January 5, 2011,8

i. AMP’s Self-Report for PRC-005-1 R2 dated January 18, 2010, included as Attachment A to the Settlement Agreement;

included as Attachment a;

ii. ReliabilityFirst’s Summary for Possible Violation for FAC-008-1 R1 dated October 1, 2010, included as Attachment B to the Settlement Agreement;

iii. ReliabilityFirst’s Summary for Possible Violation for FAC-009-1 R1 dated October 1, 2010, included as Attachment C to the Settlement Agreement;

iv. AMP’s Mitigation Plan MIT-07-3111 for PRC-005-1 R2 submitted November 19, 2010, included as Attachment D to the Settlement Agreement;

v. AMP’s Mitigation Plan MIT-07-3113 for FAC-008-1 R1 submitted November 19, 2010, included as Attachment E to the Settlement Agreement;

vi. AMP’s Mitigation Plan MIT-07-3114 for FAC-009-1 R1 submitted November 19, 2010, included as Attachment F to the Settlement Agreement;

b) AMP’s Certification of Mitigation Plan Completion for PRC-005-1 R2 dated March 31, 2011, included as Attachment b;

c) AMP’s Certification of Mitigation Plan Completion for FAC-008-1 R1 dated February 24, 2011, included as Attachment c;

d) AMP’s Certification of Mitigation Plan Completion for FAC-009-1 R1 dated March 18, 2011, included as Attachment d;

8 The Settlement Agreement incorrectly states that ReliabilityFirst accepted AMP’s Mitigation Plans for PRC-005-1 R2, FAC-008-1 R1 and FAC-009-1 R1 on December 3, 2010; the correct date was December 1, 2010.


e) ReliabilityFirst’s Verification of Mitigation Plan Completion for PRC-005-1 R2 dated April 20, 2011, included as Attachment e;

f) ReliabilityFirst’s Verification of Mitigation Plan Completion for FAC-008-1 R1 dated March 7, 2011, included as Attachment f; and

g) ReliabilityFirst’s Verification of Mitigation Plan Completion for FAC-009-1 R1 dated April 5, 2011, included as Attachment g.

h) Common Disposition Document, included as Attachment h;

i. Disposition Document for PRC-005-1 R2, included Attachment h-1; and

ii. Disposition Document for FAC-008-1 R1 and FAC-009-1 R1, included as Attachment h-2.

A Form of Notice Suitable for Publication9

A copy of a notice suitable for publication is included in Attachment i.

9 See 18 C.F.R. § 39.7(d)(6).


Notices and Communications Notices and communications with respect to this filing may be addressed to the following:

Gerald W. Cauley President and Chief Executive Officer David N. Cook* Sr. Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540-5721 (609) 452-8060 (609) 452-9550 – facsimile [email protected] Kevin Koloini* Director of Reliability Standards Compliance American Municipal Power Inc. 1111 Schrock Road, Suite 100 Columbus, OH 43229 (614) 540-0857 (614) 540-1113 – facsimile [email protected] Tim Walton* American Municipal Power Inc. 2600 Airport Drive Columbus, OH 43219 (614) 337-6222 (614) 416-0342 – facsimile [email protected] Terry Leach* Vice President of Risk Control American Municipal Power Inc. 1111 Schrock Road, Suite 100 Columbus, OH 43229 (614) 540-1111 [email protected] Margaret E. McNaul* Associate Thompson Coburn LLP 1909 K Street, N.W. Suite 600 Washington, DC 20006-1167 (202) 585-6940 (202) 508-1036 – facsimile [email protected]

Rebecca J. Michael* Associate General Counsel for Corporate and Regulatory Matters North American Electric Reliability Corporation 1120 G Street, N.W. Suite 990 Washington, DC 20005-3801 (202) 393-3998 (202) 393-3955 – facsimile [email protected] Robert K. Wargo* Director of Enforcement and Regulatory Affairs ReliabilityFirst Corporation 320 Springside Drive, Suite 300 Akron, OH 44333 (330) 456-2488 [email protected] L. Jason Blake* Managing Enforcement Attorney ReliabilityFirst Corporation 320 Springside Drive, Suite 300 Akron, OH 44333 (330) 456-2488 [email protected] Michael D. Austin* Associate Attorney ReliabilityFirst Corporation 320 Springside Drive, Suite 300 Akron, OH 44333 (330) 456-2488 [email protected] Kristina C. Sims* Associate Attorney ReliabilityFirst Corporation 320 Springside Drive, Suite 300 Akron, OH 44333 (330) 456-2488 [email protected]


*Persons to be included on the Commission’s service list are indicated with an asterisk. NERC requests waiver of the Commission’s rules and regulations to permit the inclusion of more than two people on the service list.

Conclusion Accordingly, NERC respectfully requests that the Commission accept this Abbreviated NOP as compliant with its rules, regulations and orders.

Respectfully submitted, /s/ Rebecca J. Michael Gerald W. Cauley President and Chief Executive Officer David N. Cook Sr. Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540-5721 (609) 452-8060 (609) 452-9550 – facsimile [email protected]

Rebecca J. Michael Associate General Counsel for Corporate and Regulatory Matters North American Electric Reliability

Corporation 1120 G Street, N.W. Suite 990 Washington, DC 20005-3801 (202) 393-3998 (202) 393-3955 – facsimile [email protected]

cc: American Municipal Power Inc. ReliabilityFirst Corporation Attachments

Attachment a

Settlement Agreement by and between ReliabilityFirst and AMP executed January 5,

2011

In re: AMERICAN MUNICIPAL POWER,INC.

NERC Registry ID No. NCR00683

) ) ) ) ) ) ) )

Docket Nos. RFC201000238; RFC201000651;and RFC201000652

NERC Reliability Standards: PRC-005-1, Requirement 2; FAC-008-1, Requirement 1.2; and FAC-009-1, Requirement 1

SETTLEMENT AGREEMENT BETWEEN

RELIABILITYFIRST CORPORATION AND

AMERICAN MUNICIPAL POWER, INC.

I. INTRODUCTION

I. ReliabilityFirst Corporation ("ReliabilityFirst") and American Municipal Power, Inc. ("AMP") enter into this Settlement Agreement ("Agreement") to resolve alleged violations by AMP of the NERC Reliability Standards PRC-005-1, Requirement 2; FAC-008-1, Requirement 1.2; and FAC-009-1, Requirement 1.

II. STIPULATION OF FACTS

2. AMP and ReliabilityFirst agree and stipulate to this Agreement in its entirety. The facts stipulated herein are stipulated solely for the purpose of resolving between AMP and ReliabilityFirst the subject matter of this Agreement and do not constitute admissions or stipulations for any purpose. AMP neither admits nor denies the violation of the Reliability Standards addressed herein and agrees to the terms of this Agreement solely for the purpose of resolving all outstanding issues relating to the such violations.

A. Background.

3. AMP is a nonprofit Ohio corporation organized in 1971. The members of AMP are all municipalities that own and operate electric utility systems. AMP is either a full or partial requirements supplier of electric energy for certain of its members. AMP's primary purpose is to assist its member communities in meeting their electric and energy needs. This purpose is served in a number of ways, including through the ownership of electric generating facilities, scheduling and dispatch of member-owned generation, and through power supply and transmission

Docket Nos. RFC201000238, e/ al. Page I ofll

arrangements with third parties. AMP serves 128 public power member communities: 82 in Ohio, 30 in Pennsylvania, six in Michigan, five in Virginia, three in Kentucky, and two in West Virginia. These member communities serve more than 570,000 customers.

4. ReliabilityFirst confirmed that AMP is registered on the NERC Compliance Registry as a Generator Owner, Generator Operator, Load-Serving Entity, Purchasing-SeIling Entity, and Resource Planner in the ReIiabilityFirst region with the NERC Registry Identification Number NCR00683. Therefore, AMP, in its capacity as a Generator Owner, is subject to compliance with the NERC Reliability Standards PRC-005-1, R2; FAC-008-1, R1.2; and FAC-009-1, Rl.

B. Alleged Violation ofPRC-005-l, R2 - RFC20l000238.

5. PRC-005-1, R2 states:

R2. Each ... Generator Owner that owns a generation Protection System shaIl provide documentation of its Protection System maintenance and testing program and the implementation of that program to its Regional Reliability Organization on request (within 30 calendar days). The documentation ofthe program implementation shaIl include:

R2.l. Evidence Protection System devices were maintained and tested within the defined intervals.

R2.2. Date each Protection System device was last tested/maintained.

6. On January 18, 2010, AMP submitted a Violation Self-Reporting Form disclosing possible non-compliance with PRC-005-1, R2. See, Attachment A, Compliance Monitoring and Enforcement Program Violation Self-Reporting Form.

7. AMP submitted a self-report because it determined that, although AMP was testing and maintaining its generator Protection Systems, it was not performing such testing and maintenance in accordance with the intervals specified in its Protection System maintenance and testing program.

8. AMP's program incorporates by reference the testing and maintenance intervals and procedures in the American National Standard Institute, Intemational Electrical Testing Association Standard for Maintenance Testing Specifications for Electrical Power Distribution Equipment and Systems (the "NETA Manual"). The NETA Manual establishes va.ryingtesting tirid'maintenance intervals for different testing and maintenance activities depending upon the type of Protection System equipment being tested and/or maintained. The NET A Manual specified visual inspections as often as once per month. Although AMP has done visual inspections

Docket Nos. RFC201000238, ef al. Page 2 of II

in connection with its testing and maintenance activities and during rounds, such inspections were not documented according to the intervals specified in the AMP Program.

9. AMP lacked maintenance and testing records for 15 out of its estimated 175 (S.6%) Protection System devices. As a result, ReliabilityFirst alleges that AMP did not maintain documentation establishing that these 15 devices were maintained and tested within their defined intervals in violation ofPRC-005-I, R2.I. Additionally, ReliabilityFirst alleges that AMP did not maintain documentation establishing the date that these 15 devices were last tested and maintained in violation of PRC-005-I, R2.2. Therefore, as to these 15 devices, ReliabilityFirst alleges that AMP violated PRC-005-I, R2.I and R2.2.

10. As to approximately 160 of its estimated 175 Protection System devices (91.4% of the total devices); AMP has tested and maintained such devices within the past four years and maintains documentation of those testing and maintenance activities and the dates that the devices were last tested and maintained. However, the testing and maintenance intervals reflected in AMP's documentation do not conform to the testing and maintenance intervals specified in the NETA Manual. For visual inspections on these devices, although AMP represents that visual inspections were performed, AMP did not document these inspections. Thus, ReliabilityFirst alleges that AMP's evidence does not demonstrate that its Protection System devices were tested and maintained in accordance with the intervals specified in AMP's program as required by PRC-005-I, R2.1.

11. ReliabilityFirst alleges that AMP violated PRC-005-I, R2 by failing to fully 40cument the implementation of its Protection System maintenance and testing program.

C. Alleged Violation ofFAC-008-1, Rl.2 - RFC201000651.

12. FAC-OOS-I, RI states

Rl. The ... Generator Owner shall each document its current methodology used for developing Facility Ratings (Facility Ratings Methodology) of its solely and jointly owned Facilities. The methodology shall include all ofthe following:

Docket Nos. RFC201000238, e/ al.

*****

R1.2. The method by which the Rating (ofmajorBES equipment that comprises a Facility) is determined.

R1.2.1. The scope of equipment addressed shall include, but not be limited to, generators, transmission conductors, transformers, relay protective devices,

Page 3 of 11

tenninal equipment, and series and shunt compensation devices.

*****

13. During ReliabilityFirst's compliance audit of AMP, which occurred September 10,2010 through September 30,2010, ReliabilityFirst identified a Possible Violation of Reliability Standard FAC-008-1, R1.2. See, Attachment B, Summary for Possible Violation. Specifically, ReliabilityFirst alleges that although the scope of AMP's Facility Ratings Methodology is defined to include generators, transmission conductors, transfonners, relay protective devices, tenninal equipment, and series and shunt compensation devices, the methodology does not define methods for rating transmission conductors, transfonners, relay protective devices, and tenninal equipment.

14. ReliabiIityFirst alleges that AMP violated F AC-008-1, RI.2 by failing to document the methodologies used to detennine for transmission conductors, transfonners, relay protective devices, and tenninal equipment.

D. Alleged Violation ofFAC-009-1, Rl- RFC201000652.

15. FAC-009-1, Rl states

Rl. The ... Generator Owner shall each establish Facility Ratings for its solely and jointly owned Facilities that are consistent with the associated Facility Ratings Methodology.

16. During ReliabilityFirst's compliance audit of AMP, which occured from September 10, 2010 through September 30,2010, ReliabilityFirst identified a Possible Violation of Reliability Standard FAC-009-1, Rl. See, Attachment C, Summary for Possible Violation. ReliabilityFirst alleges that AMP failed to establish facility ratings for certain solely and jointly owned equipment types that are consistent with its associated Facility Ratings Methodology.

17. Although AMP provided ReliabiIityFirst with three tables of data intended to serve as the requisite Facility Ratings documentation, ReliabilityFirst alleges that these tables do not identify ratings for AMP's solely and jointly owned tenninal equipment and relay protective devices (including relays and voltage and current sensing devices) and do not identify the most limiting element. AMP's Facility Ratings document AMP's ratings for its solely and jointly owned generators, transfonners, and substation buses.

18. ReliabilityFirst alleges that AMP violated FAC-009"1, Rl by failing to establish ratings values for tenninal equipment and relay protective devices.

Docket Nos. RFC20 I 00023 8, e/ al. Page 4 ofll

III. DURATION, RISK CONSIDERATIONS, AND COMPLIANCE CULTURE

A. Duration and Risk Considerations for PRC-005-1, R2 - RFC201000238.

19. PRC-005-1, R2 has a Violation Risk Factor ("VRF") of "Lower," consistent with the VRF Matrix promulgated by NERC. However, the facts implicate both Sub-Requirements 2.1 and 2.2, which each carry a VRF of "High." Therefore, ReliabilityFirst applies a "High" VRF. Applying the facts ofthis alleged violation to the Violation Severity Level ("VSL") Matrix promulgated by NERC, ReliabilityFirst determined that a VSL of "Severe" is appropriate.

20. The duration of this alleged violation is from June 18,2007, the date AMP was required to comply with PRC-005-1, to March 31, 2011, the date on which AMP will complete all Protection System maintenance and testing, as described in its mitigation plan for this alleged violation.

21. This alleged violation did not pose a serious or substantial risk to the reliability of the bulk electric system. AMP has documentation establishing that approximately 160 (or 91 %) of its estimated 175 Protection System devices were tested and maintained within the past four years. Although this does not strictly comport with the intervals specified in AMP's testing and maintenance program, AMP was performing Protection System testing and maintenance activities at intervals that are consistent with typical industry practice.' AMP's testing and maintenance documentation demonstrates that all Protection System devices were functioning properly. Additionally, AMP asserts that it also performed visual inspections. During these visual inspections, AMP identified no issues or problems with the devices.

B. Duration and Risk Considerations for FAC-008-1, Rl.2 - RFC201000651.

22. FAC-008-1, R1, has a VRF of "Lower," consistent with the VRF Matrix promulgated by NERC. However, the facts implicate Sub-Requirement 1.2, which carries a VRF of "Medium. " Therefore, ReliabilityFirst applies a "Medium" VRF. Applying the facts ofthis alleged violation to the VSL Matrix promulgated by NERC, ReliabilityFirst determined that a VSL of "Severe" is appropriate.

23. The duration ofthis alleged violation is from June 18, 2007, the date AMP was required to complywithFAC-008-1, to February 19, 2011, the date on which AMP will finalize an updated Facility Ratings Methodology, as described in its mitigation plan for this alleged violation.

I For example, the NETA Manual specifies a one-year testing interval for mechanical and electrical testing compared to the industry standard range of three to six year intervals.

Docket Nos. RFC20 I 00023 8, e/ al. Page 5 ofll

24. This alleged violation did not pose a serious or substantial risk to the reliability of the bulk electric system. AMP facilities were operating with partially-established Facility Ratings. AMP also identified the most limiting element in its methodology as the most limiting applicable equipment rating of the individual equipment that comprises the facility. Additionally, once AMP completes its mitigation plan and adequately documents its methodology, the equipment that constitutes the most limiting element will not change.

C. Duration and Risk Considerations for FAC-009-1, Rl- RFC201000652.

. D.

25. FAC-009-1, RI, has a VRF of "Medium," consistent with the VRF Matrix promulgated by NERC. Applying the facts of this alleged violation to the VSL Matrix promulgated by NERC, ReliabilityFirst determined that a VSL of "High" is appropriate.

26. The duration ofthis alleged violation is from June 18, 2007, the date AMP was required to comply with FAC-009-1, to March 19,2011, the date on which AMP will update its Facility Ratings, as described in its mitigation plan for this alleged violation.

27. This alleged violation did not pose a serious or substantial risk to the reliability of the bulk electric system. AMP did provide ratings for generators, transformers, transmission conductors, and substation buses. Additionally, although AMP did not document the most limiting element, AMP operated with the knowledge ofthe identity ofthe most limiting element as defined in its methodology.

AMP's Culture of Compliance .

28. ReliabilityFirst considered certain aspects of AMP's internal compliance program as mitigating factors. For example, AMP senior management is actively involved in AMP's compliance activities. Specifically, the individuals responsible for day-to-day oversight of compliance activities at AMP include the Vice President of Risk Control and the Director of Reliability Standards Compliance, who regularly brief AMP's Chief Executive Officer and Board of Trustees regarding compliance matters. AMP's Vice President of Risk Control has direct access and regularly reports to AMP's Chief Executive Officer and Board of Trustees, and AMP's Director of Reliability Standards Compliance has access to AMP's Board of Trustees.

29. AMP's internal compliance program is managed independently from departments within AMP that are assigned responsibility for substantive compliance with Reliability Standards. AMP's Director of Reliability Standards Compliance has no involvement with AMP's generation, marketing, operations, planning, and/or regulatory departments from a compliance perspective except for activities related to administration of AMP's internal compliance program. AMP's Director of Reliability Standards Compliance reports directly to AMP's Vice President of Risk

DockelNos. RFC201000238, etal. Page 6 of 11

~ '-

Control who, as discussed above, has direct access and reports to AMP's Chief Executive Officer and Board of Trustees.

30. AMP's internal compliance program also contains measures to detect and prevent compliance issues, including violations of Reliability Standards. Examples of these measures include performance of an annual internal compliance review, employee training in areas covered by the Reliability Standards, and the dedication of one full-time employee to the administration of AMP's Reliability Standards compliance activities. AMP operations personnel and supervisors responsible for substantive compliance with the Reliability Standards are also actively involved in developing policies and procedures to document compliance with applicable Reliability Standards.

31. ReliabilityFirst also considered the following as mitigating factors: (a) AMP self-reported the alleged violation of PRC-005-1, R2; and (b) AMP has submitted mitigation plans to correct the alleged violations.

32. AMP has no prior or presently pending violations of any Reliability Standards within the ReliabilityFirst region or within the SERC Reliability Corporation region, the only other Regional Entity with which AMP is registered. AMP has no affiliates included on the NERC Compliance Registry.

IV. MITIGATING ACTIONS, REMEDIES, AND SANCTIONS

A. Mitigating Actions for PRC-005-1, R2 - RFC201000238.

33. On November 19,2010, AMP submitted to ReliabilityFirst a mitigation plan to . address the alleged violation of PRC-005-1, R2 set forth in this Agreement. See, NERC Mitigation Plan ID # MIT-07-3111, (attached as Attachment D). On December 3, 2010, ReliabilityFirst accepted this mitigation plan, and on December 13,2010, NERC approved and submitted it to the Federal Energy Regulatory Commission (the "Commission") on December 14, 2010 as confidential, non-public information.

34. In this mitigation plan, AMP outlined actions necessary to mitigate the alleged violation. AMP has committed to evaluate its testing and maintenance intervals and procedures; revise the program as necessary; verity that Protection System equipment has been tested and maintained; perform additional testing and maintenance as needed; and provide additional training to personnel.

35. Pursuant to Section 6.6 ofthe ReliabilityFirst Compliance Monitoring and Enforcement Program ("CMEP"), ReliabilityFirst will verity AMP's completion ofthis mitigation plan ahd'promptly report its completion to NERC.

B. Mitigating Actions for FAC-008-1, R1.2 - RFC201000651.

Docket Nos. RFC201 000238, et al. Page 7 ofll

36. On November 19,2010, AMP submitted to ReliabilityFirst a mitigation plan to address the alleged violation of FAC-008-1, RI.2 set forth in this Agreement. See NERC Mitigation Plan ID # MIT-07-3113, (attached as Attachment E). On December 3,2010, ReliabilityFirst accepted this mitigation plan, and on December 13,2010, NERC approved and submitted it to the Commission on December 14, 2010 as confidential, non-public information.

37. In this mitigation plan, AMP outlined actions necessary to mitigate the alleged violation. AMP has committed to modify its existing Facility Ratings Methodology to clearly document its methodology for rating transmission conductors, transformers, relay protective devices, and terminal equipment.

38. Pursuant to Section 6.6 of the ReliabilityFirst CMEP, ReliabilityFirst will verify AMP's completion ofthis mitigation plan and promptly report its completion to NERC.

C. Mitigating Actions for FAC-009-1, Rl- RFC201000652.

39. On November 19, 2010, AMP submitted to ReliabilityFirst a mitigation plan to address the alleged violation of F AC-009-1, R1 set forth in this Agreement. See NERC Mitigation Plan ID # MIT-07-3114, (attached as Attachment F). On December 3, 2010, ReliabilityFirst accepted this mitigation plan, and on December 13,2010, NERC approved and submitted it to the Commission on December 14, 2010 as confidential, non-public information.

40. In this mitigation plan, AMP outlined actions necessary to mitigate the alleged violation. AMP has committed to clearly document AMP's ratings for relay protective devices and terminal equipment and to explicitly identify the most limiting rating of the individual equipment that comprises a facility.

41. Pursuant to Section 6.6 of the ReliabilityFirst CMEP, ReliabilityFirst will verify AMP's completion of this mitigation plan and promptly report its completion to NERC.

D. Monetary Penalty.

42. Based upon the foregoing, AMP shall pay a monetary penalty of $25,000 to ReliabilityFirst.

43. ReliabilityFirst shall present an invoice to AMP within 20 days after the Agreement is approved by the Commission or affirmed by operation oflaw. Upon receipt, AMP shall have 30 days to remit payment. ReliabilityFirst will notify NERC if it does not timely receive the "payment from AMP.

44. If AMP fails to timely remit the monetary penalty payment to ReliabilityFirst, interest will commence to accrue on the outstanding balance, pursuant to 18 C.F.R.

Docket Nos. RFC20I000238, et at. Page 8 of! I

'-'l ;.

§ 35.19a (a)(2)(iii), on the earlier of (a) the 31't day after the date on the invoice issued by ReliabilityFirst to AMP for the monetary penalty payment or (b) the 51 st

day after the Agreement is approved by the Commission or operation of law.

v. ADDITIONAL TERMS

45. ReliabilityFirst and AMP agree that this Agreement is in the best interest of bulk electric system reliability. The terms and conditions of the Agreement are consistent with the regulations and orders of the Commission and the NERC Rules of Procedure.

46. ReliabilityFirst shall report the terms of all settlements of compliance matters to NERC. NERC will review the Agreement for the purpose of evaluating its consistency with other settlements entered into for similar violations or under similar circumstances. Based on this review, NERC will either approve or reject this Agreement. IfNERC rejects the Agreement, NERC will provide specific written reasons for such rejection and ReliabilityFirst will attempt to negotiate with AMP a revised settlement agreement that addresses NERC's concerns. Ifa settlement cannot be reached, the enforcement process shall continue to conclusion. IfNERC approves the Agreement, NERC will (a) report the approved settlement to the Commission review and approval by order or operation of law and (b) publicly post the alleged violation and the terms provided for in this Agreement.

47. This Agreement shall become effective upon the Commission's approval of the Agreement by order or operation oflaw or as modified in a manner acceptable to the parties.

48. AMP agrees that this Agreement, when approved by NERC and the Commission, shall represent a final settlement of all matters set forth herein and binds AMP to perform the actions enumerated herein. AMP expressly waives its right to any hearing or appeal concerning any matter set forth herein, unless and only to the extent that AMP contends that any NERC or Commission action constitutes a material modification to this Agreement.

49. ReliabilityFirst reserves all rights to initiate enforcement actions against AMP in accordance with the NERC Rules of Procedure in the event that AMP fails to comply with any ofthe terms or conditions of this Agreement, including failure to timely complete mitigation plans or other remedies of this Agreement. In the event AMP fails to comply with any ofthe terms or conditions ofthis Agreement, ReliabilityFirst may initiate an action or actions against AMP to the maximum extent allowed by the NERC Rules of Procedure, including, but not limited to, the imposition of the maximum statutorily allowed monetary penalty. AMP will retain all rights to defend against such action or actions in accordance with the NERC Rules of Procedure and Commission regulations.

Docket Nos. RFC201000238, ef al. Page 9 ofll

50. AMP consents to ReliabilityFirst's future use ofthis Agreement for the purpose of assessing the factors within the NERC Sanction Guidelines and applicable Commission orders and policy statements, including, but not limited to, the factor of AMP's history of violations. Such use may be in any enforcement action or compliance proceeding undertaken by NERC or any Regional Entity or both, provided, however that AMP does not consent to the use of the conclusions, determinations, and findings set forth in this Agreement as the sole basis for any other action or proceeding brought by NERC or any Regional Entity or both, nor does AMP consent to the use of this Agreement by any other party in any other action or proceeding.

51. AMP affirms that all ofthe matters set forth in this Agreement are true and correct to the best of its knowledge, information, and belief, and that it understands that ReliabilityFirst enters into this Agreement in express reliance on the representations contained herein, as well as any other representations or information provided by AMP to ReliabilityFirst during any AMP interaction with ReliabilityFirst relating to the subject matter of this Agreement.

52. Each of the undersigned warrants that he or she is an authorized representative of the entity designated below, is authorized to bind such entity, and accepts the Agreement on the entity's behalf.

53. The signatories to this Agreement agree that they enter into this Agreement voluntarily and that, other than the recitations set forth herein, no tender, offer, or promise of any kind by any member, employee, officer, director, agent, or representative of Reliability First or AMP has been made to induce the signatories or any other party to enter into this Agreement.

54. The Agreement may be signed in counterparts.

55. This Agreement is executed in duplicate, each of which so executed shall be deemed to be an original.

[SIGNATURE PAGE TO FOLLOW)

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK)

Docket Nos. RFC201 00023 8, e/ al. Page 10 ofll

Agreed to and accepted:

~~ftk.~~--RobertK.·Wargo . ~ Manager, Compliance Enforcement ReliabilityFirst Corporation

~Clo;LL Terry A. Le h . Vice President of Risk Control American Municipal Power, Inc.

Approved:

~ta.l~ President & Chief Executive Officer Relia~i1ityFirst Corporation

Docket Nos. RFCZOI000238. etal.

I ;;;..) /')/ ~CI} 0 Date

1;2../ ;2'/2--0/'0 Date I I

Date .

Page 11 of 11

Attachment A

Self-Report Form – 9-9-09 – Revision II

COMPLIANCE MONITORING AND ENFORCEMENT PROGRAM

VIOLATION SELF-REPORTING FORM

This Violation Self-Reporting Form can be used for submittals via e-mail for violations of the Reliability Standards identified by a self- assessment. 1. Date: 01/18/2010 2. Registered Entity: American Municipal Power, Inc.

3. NERC Registry ID: NCR00683 Joint Registration ID (JRO) (if applicable:)

4. Multiple Regional Registered Entity (MRRE) Regional Affiliates (if applicable:)

5. Reliability Standard PRC-005 Requirement a: 2

6. Reporting for registered function(s): GO

7. Date Violation was Discovered: 1/15/2010

Beginning Date of Violation: TBD

End or Expected End Date of Violation: ASAP Bob Wargo, Manager of Compliance Enforcement, was contacted and informed that the form would be

submitted soon on 1/18/2010. 8. Has this violation been previously reported: Yes or No

If yes, Provide NERC Violation ID number: 9. Has this violation been reported to another region(s): Yes or No

If yes, Provide Region(s): 10. Is the violation still occurring: Yes or No 11. Detail description and cause of the violation: A new formal policy was developed in 2007 that specified an interval periodicity and procedures for

generation protection systems that was not clearly articulated to plant personnel in charge of performing or contracting for maintenance and testing. Before the NERC standards became enforceable, the plant personnel had been testing generation protection devices on a five year rotation. Due to a lack of clarity in the new policy’s interval periodicity, the plants generation protection systems were mistakenly tested

x

x

x

Attachment A

Self-Report Form – 9-9-09 – Revision II

on a three year visual, mechanical and electrical cycle. In general, the intervals specified in the formal policy are for performing maintenance testing on a one year cycle. The formal policy has not been met with regards to maintenance and testing.

Due to the long history of the existing maintenance and testing program started in 1992, we can gather

sufficient data to develop a basis for modifying the policy and meeting the intent of requirement R2. 12. Violation Risk Factor: Lower ( ) – Medium ( ) – High (x ) – Not Specified ( ) Select One 13. Violation Severity Level: Lower ( x ) – Moderate ( ) – High ( ) – Severe ( ) Select One

Provide justification for this determination: Administrative based.

14. Provide a determination of the Potential Impact to the Bulk Electric System:

No impact 15. Mitigation Plan attached: Yes or No 16. Additional Comments: A mitigation plan will be developed as soon as possible. A mitigation plan will be developed as soon as possible. 17. Officer Verification: I understand that this information is being provided as required by the

ReliabilityFirst Compliance Monitoring and Enforcement Program. Any review of this violation will require all information certified on this form be supported by appropriate documentation.

Officer’s Name: Terry Leach

Title: President, Risk

E-mail address: [email protected] Phone: 614-540-1111

Primary Compliance Contact: Kevin Koloini

E-mail address: [email protected] Phone: 614-540-1111

E-mail Submittals to [email protected] Subject Line: Violation Self-Report For any questions regarding compliance submittals, please e-mail [email protected]. a. Report on a requirement basis. If the violation is to a sub requirement, or multiple sub requirements, include all sub requirements relevant to this violation.

x

Attachment A

Attachment B

5/14/2010 – Rev. 2 - Page 1 of 2

Summary for Possible Violation (PV)

Registered Entity: American Municipal Power NERC ID#: NCR00683 Compliance Monitoring Process: Compliance Audits Standard and Requirement: FAC-008-1 R1 (R1.2) Registered Function(s) in Violation: GO Initial PV Date (Actual Date Discovered): 10/1/2010 Date for Determination of Penalty/Sanction (Beginning Date of Violation): 6/17/2007 Violation Risk Factor: VRF - Medium Violation Severity Level: VSL - Level 4 Violation Reported By: Audit Team Basis for the PV: FAC-008-1 R1 : The Transmission Owner and Generator Owner shall each document its current methodology used for developing Facility Ratings (Facility Ratings Methodology) of its solely and jointly owned Facilities. The methodology shall include all of the following:

R1.2. The method by which the Rating (of major BES equipment that comprises a Facility) is determined. American Municipal Power's rating methodology does not define methods for transmission conductors, transformers, relay protective devices, and terminal equipment. American Municipal Power does not own series or shunt compensation devices.

Attachment B

5/14/2010 – Rev. 2 - Page 2 of 2

Facts and Evidence pertaining to the PV: American Municipal Power's rating methodology does not define methods for transmission conductors, transformers, relay protective devices, and terminal equipment. American Municipal Power does not own series or shunt compensation devices.

Potential Impact to Bulk Electrical System (BES): (Minimal, Moderate, or Severe) Moderate

- Provide Explanation for Potential Impact to BES: The violation involves units totaling 287 MW in 3 locations of 213 MW, 42 MW and 32MW. The location supplying 213 MW is scheduled for retirement at end of 2010. Due to this retirement and the sizes of remaining units, the impact to the BES would be moderate. REVISION HISTORY

Revision Prepared By Approved By

Date Comments

Rev. 0 Renata Fellmeth Gary Campbell 7/1/2009 New Document

Rev. 1 Renata Fellmeth Gary Campbell

9/3/2009 Changed PAV to PV. Removed the word “Alleged.”

Rev. 2 Renata Fellmeth Gary Campbell 5/14/2010 Added word “Potential” to sentences, ‘Impact to Bulk Electrical System (BES)’ and ‘Provide Explanation for Impact to BES.’ Added clarification in brackets after the following sentences: Initial PV Date’ and ‘Date for Determination of Penalty/Sanction.’

Rev. 3 Renata Fellmeth Gary Campbell 6/15/2010 Unlocked form so that the form is user friendly – cutting and pasting.

Rev. 4 Renata Fellmeth Gary Campbell 9/15/2010 Added to the distribution list.

Attachment B

Attachment C

5/14/2010 – Rev. 2 - Page 1 of 2

Summary for Possible Violation (PV)

Registered Entity: American Municipal Power NERC ID#: NCR00683 Compliance Monitoring Process: Compliance Audits Standard and Requirement: FAC-009-1 R1 Registered Function(s) in Violation: GO Initial PV Date (Actual Date Discovered): 10/1/2010 Date for Determination of Penalty/Sanction (Beginning Date of Violation): 6/17/2007 Violation Risk Factor: VRF - Medium Violation Severity Level: VSL - Level 3 Violation Reported By: Audit Team Basis for the PV: : FAC-009-1 R1 : The Transmission Owner and Generator Owner shall each establish Facility Ratings for its solely and jointly owned Facilities that are consistent with the associated Facility Ratings Methodology. Ratings values were not provided for relay protective devices (relays and voltage and current sensing devices) and terminal equipment. American Municipal Power does not own series or shunt compensation devices. American Municipal Power did not identify the most limiting element.

Attachment C

5/14/2010 – Rev. 2 - Page 2 of 2

Facts and Evidence pertaining to the PV: Ratings values were not provided for relay protective devices(relays and voltage and current sensing devices) and terminal equipment. American Municipal Power does not own series or shunt compensation devices. American Municipal Power did not identify the most limiting element.

Potential Impact to Bulk Electrical System (BES): (Minimal, Moderate, or Severe) Moderate

- Provide Explanation for Potential Impact to BES: The violation involves units totaling 287 MW in 3 locations of 213 MW, 42 MW and 32MW. The location supplying 213 MW is scheduled for retirement at end of 2010. Due to this retirement and the sizes of remaining units, the impact to the BES would be moderate.

REVISION HISTORY

Revision Prepared By Approved By

Date Comments

Rev. 0 Renata Fellmeth Gary Campbell 7/1/2009 New Document

Rev. 1 Renata Fellmeth Gary Campbell

9/3/2009 Changed PAV to PV. Removed the word “Alleged.”

Rev. 2 Renata Fellmeth Gary Campbell 5/14/2010 Added word “Potential” to sentences, ‘Impact to Bulk Electrical System (BES)’ and ‘Provide Explanation for Impact to BES.’ Added clarification in brackets after the following sentences: Initial PV Date’ and ‘Date for Determination of Penalty/Sanction.’

Rev. 3 Renata Fellmeth Gary Campbell 6/15/2010 Unlocked form so that the form is user friendly – cutting and pasting.

Rev. 4 Renata Fellmeth Gary Campbell 9/15/2010 Added to the distribution list.

Attachment C

Attachment D

Mitigation Plan Submittal Form

Date this Mitigation Plan is being submitted: 11119/2010

Section A: Compliance Notices & Mitigation Plan Requirements

Al Notices and requirements applicable to Mitigation Plans and this SubmittalForm are set forth in "Attachment A - Compliance Notices & Mitigation PlanRequirements."

A2 This form must be used to submit required Mitigation Plans for review andacceptance by ReliabilityFirst and approval by NERC.

A3 IZI I have reviewed Attachment A and understand that this Mitigation PlanSubmittal Form will not be accepted unless this box is checked.

Section B: Registered Entity Information

B.I Identify your organization.

Company Name:

Company Address:Columbus, Ohio, 43229

NERC Compliance Registry ill:

American Municipal Power, Inc.

1111 Schrock Rd., Suite 100,

NCR00683

B.2 Identify the individual in your organization who will be the Entity Contactregarding this Mitigation Plan.

Name:

Title:Compliance

Email:

Phone:

Version2.0-Released 7/11/08

Kevin Koloini

Director OfReliability Standards

[email protected]

1-614-540-1111

Page I oflO

RFC201000238

Attachment D

REll


Date this Mitigation Plan is being submitted: 11/19/2010

Section A: Compliance Notices & Mitigation Plan RequirementsA.1 Notices and requirements applicable to Mitigation Plans and this Submittal

Form are set forth in "Attachment A - Compliance Notices & Mitigation PlanRequirements."

A.2 This form must be used to submit required Mitigation Plans for review andacceptance by ReliabilityFirst and approval by NERC.

A.3 1ZI I have reviewed Attachment A and understand that this Mitigation PlanSubmittal Form will not be accepted unless this box is checked.

Section B: Registered Entity InformationB.1 Identify your organization.

Company Name:


NERC Compliance Registry ID:



NCR00683


Name:

Title:Compliance

Email:

Phone:

Version 2.0 - Released 7/11/08

Kevin Koloini


[email protected]

1-614-540-1111

Page 1 of 10



Section A: Compliance Notices & Mitigation Plan Requirements A.l Notices and requirements applicable to Mitigation Plans and this Submittal

Form are set forth in "Attachment A - Compliance Notices & Mitigation Plan Requirements."

A.2 This form must be used to submit required Mitigation Plans for review and acceptance by ReliabilityFirst and approval by NERC.

A.3 1ZI I have reviewed Attachment A and understand that this Mitigation Plan Submittal Form will not be accepted unless this box is checked.

Section B: Registered Entity Information B.I Identify your organization.

Company Name: American Municipal Power, Inc.

Company Address: 1111 Schrock Rd., Suite 100, Columbus, Ohio, 43229

NERC Compliance Registry ID: NCR00683

B.2 Identify the individual in your organization who will be the Entity Contact regarding this Mitigation Plan.

Name: Kevin Koloini

Title: Director Of Reliability Standards Compliance

Email: [email protected]

Phone: 1-614-540-1111

Version 2.0 - Released 7/11108 Page 1 of 10

FOR PUBLIC RELEASE - APRIL 29, 2011

Section C: Identification of Alleged or Confirmed Violation(s)Associated with this Mitigation Plan

C.I This Mitigation Plan is associated with the following Alleged or Confirmedviolation(s) of the reliability standard listed below.

NERC Violation Reliability Requirement Violation Alleged or Method ofID# Standard Number Risk Confirmed Detection (e.g.,

Factor Violation Audit, Self-report,Date(') Investigation)

RFC201000238 PRC-005 2 Lower 1/18/2010 Self-Report

(*) Note: TheAlleged or Confirmed VIOlation Dateshall be expressly specified by theRegistered Entity,andsnbject to modification by ReliabilityFirst, as: (i) thedate theAlleged or Confirmed violation occurred;(ii) the datethat the Alleged or Confirmed violation wasself-reported; or (iii)the datethat theAlleged orConfirmed violation hasbeendeemed to haveoccurred onby ReliabilityFirst. Questions regarding thedateto use should be directed to the ReliabilityFirst contact identified in Section G of thisform,

C.2 Identify the cause of the Alleged or Confirmed violation(s) identified above.Additional detailed information may be provided as an attachment.

During an internal compliance review, American Municipal Power, Inc.

("AMP"), determined that although it had been testing and maintaining its

generation Protection System equipment, such testing and maintenance was not

performed according to the testing and maintenance intervals specified in

AMP's Protection System Maintenance and Testing program (the "AMP

Program"). The AMP Program incorporates by reference the testing and

maintenance intervals and associated testing and maintenance procedures

specified in the International Electrical Testing Association Manual (the

"NETA Manual"), except to the extent that such intervals as established by the

Version 2.0 - Released 7/11/08 Page 2 oflO

Attachment D

REllABlltT


C.1 This Mitigation Plan is associated with the following Alleged or Confirmedviolation(s) of the reliability standard listed below.

NERC Violation Reliability Requirement Violation Alleged or Method ofID# Standard Number Risk Confirmed Detection (e.g.,

Factor Violation Audit, Self-report,Date'·) Investigation)

RFC201000238 PRe-005 2 Lower 1/18/2010 Self-Report

(*) Note: The Alleged or Corrfmned VIOlation Date shall be expressly specIfied by the RegIstered EntIty,and subject to modification by ReliabilityFirst, as: (i) the date the Alleged or Confirmed violation occurred;(ii) the date that the Alleged or Confirmed violation was self-reported; or (iii) the date that the Alleged orConfmned violation has been deemed to have occurred on by ReliabilityFirst. Questions regarding thedate to use should be directed to the ReliabilityFirst contact identified in Section G of this form.










"NETA Manual"), except to the extent that such intervals as established by the

Version 2.0 - Released 7/11/08 Page 2 of10

Section C: Identification of Alleged or Confirmed Violation(s) Associated with this Mitigation Plan

C.1 This Mitigation Plan is associated with the following Alleged or Confirmed violation(s) of the reliability standard listed below.

NERC Violation Reliability Requirement Violation Alleged or Method of ID# Standard Number Risk Confirmed Detection (e.g.,

Factor Violation Audit, Self-report, Date(·) Investigation)

RFC201000238 PRe-005 2 Lower 1/18/2010 Self-Report

(*) Note: The Alleged or Corrfmned VIOlation Date shall be expressly specIfied by the RegIstered EntIty, and subject to modification by ReliabilityFirst, as: (i) the date the Alleged or Confirmed violation occurred; (ii) the date that the Alleged or Confirmed violation was self-reported; or (iii) the date that the Alleged or Confmned violation has been deemed to have occurred on by ReliabilityFirst. Questions regarding the date to use should be directed to the ReliabilityFirst contact identified in Section G of this form.

C.2 Identify the cause of the Alleged or Confirmed violation(s) identified above. Additional detailed information may be provided as an attachment.









"NET A Manual"), except to the extent that such intervals as established by the

Version 2.0 - Released 7/11108 Page 2 of10


equipment manufacturer are more stringent than specified in the NETA Manual.

The NETA Manual establishes varying intervals for different testing and

maintenance activities depending on the type ofProtection System device. A

limited number of devices were missing documentation ofphysical maintenance

tests. Therefore, AMP does not have documentation that 100% of its Protection

System equipment was tested and/or maintained.

Note: If a formal root cause analysis evaluation was performed, submit a copyof the summary report.

C.3 Provide any additional relevant information regarding the Alleged or Confirmedviolations associated with this Mitigation Plan. Additional detailed informationmay be provided as an attachment.

During AMP's off-site compliance audit held from September 10-30,

2010, the RFC auditors reviewed AMP's compliance documentation for

Reliability Standard PRC-005-1 and informed AMP that certain communication

systems that AMP included within the scope ofAMP's Program are not, in fact,

part of the generator Protection System. Rather, these communication systems

are simply devices that facilitate data acquisition. Because such communication

systems are not Protection System devices that must be tested and maintained

pursuant to PRC-005-1, AMP will modify its equipment list to omit these

systems. AMP similarly requests that RFC update any documentation that it

has developed in connection with this self-reported violation to reflect that these

systems are not properly within the scope ofPRC-005-1, and that the lack of

documentation that these systems were tested and/or maintained does not

constitute a violation ofReliability Standard PRC-005-1.

Section D: Details of Proposed Mitigation Plan

Mitigation Plan Contents

Version 2.0 - Released 7/11/08 Page 3 of 10

Attachment D

equipment manufacturer are more stringent than specified in the NETA Manual.

The NETA Manual establishes varying intervals for different testing and

maintenance activities depending on the type ofProtection System device. A

limited number ofdevices were missing documentation ofphysical maintenance


System equipment was tested and/or maintained.






systems that AMP included within the scope ofAMP's Program are not, in fact,



systems are not Protection System devices that must b~ tested and maintained





documentation that these systems were tested andlor maintained does not

constitute a violation ofReliability Standard PRC-OOS-I.




equipment manufacturer are more stringent than specified in the NET A Manual.

The NET A Manual establishes varying intervals for different testing and

maintenance activities depending on the type of Protection System device. A

limited number of devices were missing documentation of physical maintenance


System equipment was tested andlor maintained.

Note: If a formal root cause analysis evaluation was performed, submit a copy of the summary report.

C.3 Provide any additional relevant information regarding the Alleged or Confirmed violations associated with this Mitigation Plan. Additional detailed information may be provided as an attachment.




systems that AMP included within the scope of AMP's Program are not, in fact,



systems are not Protection System devices that must b~ tested and maintained





documentation that these systems were tested andlor maintained does not

constitute a violation of Reliability Standard PRC-OOS-I.





RlEIJABllIT~.i~.... 7¥~. . ~I!!L •...... .....;. •• ~.~ .

D.l Identify and describe the action plan, including specific tasks and actions thatyour organization is proposing to undertake, or which it undertook if thisMitigation Plan has been completed, to correct the Alleged or Confirmedviolations identified above in Part C.l ofthis form. Additional detailedinformation may be provided as an attachment.

AMP has developed and begun implementation ofa mitigation plan to

correct this self-reported violation. AMP'S mitigation plan includes the

following corrective measures:

1. Evaluate testing and maintenance intervals and procedures.

2. Revise program

3. Verify that Protection System equipment has been tested and

maintained.

4. Perform additional testing/maintenance as needed.

5. Provide personnel with additional training.

Mitigation Plan Timeline and Milestones

D.2 Provide the date by which full implementation of the Mitigation Plan will be, orhas been, completed with respect to the Alleged or Confirmed violationsidentified above. State whether the Mitigation Plan has been fully implemented,and/or whether the actions necessary to assure the entity has returned to fullcompliance have been completed.

3/31/2011

D.3 Enter Key Milestone Activities (with due dates) that can be used to track andindicate progress towards timely and successful completion of this MitigationPlan.

Key Milestone Activity Proposed/Actual Completion Date*(shall not he more than 3 months apart)

Develop basis for intervals Completed 9/13/2010Modify AMP Program to match new 12/1/2010intervals and basis; implement related

procedural revisions as neededGeneral Protection System training Completed 9/22/2010

Implement additional training specific to 12/1/2010 - 2/1/2011


Attachment D

RlEIJABllIT~.i~.... 7¥~. . ~I!!L •...... .....;. •• ~.~ .

D.l Identify and describe the action plan, including specific tasks and actions thatyour organization is proposing to undertake, or which it undertook if thisMitigation Plan has been completed, to correct the Alleged or Confirmedviolations identified above in Part C.l ofthis form. Additional detailedinformation may be provided as an attachment.

AMP has developed and begun implementation ofa mitigation plan to



1. Evaluate testing and maintenance intervals and procedures.

2. Revise program


maintained.





3/31/2011


Key Milestone Activity Proposed/Actual Completion Date*(shall not he more than 3 months apart)

Develop basis for intervals Completed 9/13/2010Modify AMP Program to match new 12/1/2010intervals and basis; implement related

procedural revisions as neededGeneral Protection System training Completed 9/22/2010

Implement additional training specific to 12/1/2010 - 2/1/2011


D.l Identify and describe the action plan, including specific tasks and actions that your organization is proposing to undertake, or which it undertook if this Mitigation Plan has been completed, to correct the Alleged or Confirmed violations identified above in Part C.l ofthis form. Additional detailed information may be provided as an attaclunent.

AMP has developed and begun implementation of a mitigation plan to



I. Evaluate testing and maintenance intervals and procedures.

2. Revise program


maintained.




D.2 Provide the date by which full implementation of the Mitigation Plan will be, or has been, completed with respect to the Alleged or Confirmed violations identified above. State whether the Mitigation Plan has been fully implemented, and/or whether the actions necessary to assure the entity has returned to full compliance have been completed.

3/3112011

D.3 Enter Key Milestone Activities (with due dates) that can be used to track and indicate progress towards timely and successful completion of this Mitigation Plan.

Key Milestone Activity Proposed/Actual Completion Date* (shall not he more than 3 months apart)

Develop basis for intervals Completed 9/13/2010 Modify AMP Program to match new 121112010 intervals and basis; implement related

procedural revisions as needed General Protection System training Completed 9122/2010

Implement additional training specific to 12/112010 - 21112011

Version 2.0 - Released 7111108 Page 4 of 10


AMP Program as revisedVerify documentation of prior testing and Completed 4/2/2010

maintenance activitiesPerform additional testing Partially completed. To be completed

2/1912011Review test reports and perform 3/31/2011

maintenance ifneededProvide evidence of mitigation plan 3/31/2011

completion to RFC

(*) Note: Additional violations could be determined for not completing work associated with acceptedmilestones.


Attachment D

AMP Program as revisedVerify documentation of prior testing and Completed 4/2/2010

maintenance activitiesPerfonn additional testing Partially completed. To be completed

2/19/2011Review test reports and perfonn 3/31/2011

maintenance ifneededProvide evidence ofmitigation plan 3/31/2011

completion to RFC



AMP Program as revised Verify documentation of prior testing and Completed 4/2/2010

maintenance activities Perfonn additional testing Partially completed. To be completed

2/19/2011 Review test reports and perfonn 3/3112011

maintenance if needed Provide evidence of mitigation plan 3/3112011

completion to RFC

(*) Note: Additional violations could be determined for not completing work associated with accepted milestones.



Section E: Interim and Future Reliability Risk

Abatement ofInterim BPS Reliability Risk

E.l While your organization is implementing this Mitigation Plan the reliability ofthe Bulk Power System (BPS) may remain at higher risk or be otherwisenegatively impacted until the plan is successfully completed. To the extent theyare, or may be, known or anticipated: (i) identify any such risks or impacts; and(ii) discuss any actions that your organization is planning to take to mitigate thisincreased risk to the reliability ofthe BPS. Additional detailed informationmay be provided as an attachment.

AMP believes that the potential risk to the reliability ofthe Bulk Electric

System arising from this self-reported violation is minimal. Regular testing and

maintenance was occurring, but such testing and maintenance was simply not

within the specified intervals in AMP's Program.

Prevention of Future BPS Reliability Risk

E.2 Describe how successful completion of this Mitigation Plan by yourorganization will prevent or minimize the probability that the reliability oftheBPS incurs further risk of similar violations in the future. Additional detailedinformation may be provided as an attachment.

Upon completion of this mitigation plan, AMP will have in place a revised

program for Protection System testing and maintenance, including modified testing and

maintenance intervals, will have provided additional training to its staff, and will have

updated testing and maintenance records for all of its Protection System equipment

subject to Reliability Standard PRC-005-1. The successful completion of the mitigation

plan will continue to promote a culture of compliance and will reinforce reliability

excellence at AMP. AMP's ultimate goal is to prevent recurrence ofviolations

associated with the Protection System Maintenance and Testing (PRC-005-1) Standard.

While, as discussed above, AMP believes that the potential risks to the reliability of the

Bulk Electric System created by this self-reported violation are minimal, completion of

the steps described herein will fully mitigate those risks.


Attachment D

RlE IABI)llT


Abatement of Interim BPS Reliability Risk







E.2 Describe how successful completion of this Mitigation Plan by yourorganization will prevent or minimize the probability that the reliability of theBPS incurs further risk of similar violations in the future. Additional detailedinformation may be provided as an attachment.





subject to Reliability Standard PRC-OOS-I. The successful completion ofthe mitigation


excellence at AMP. AMP's ultimate goal is to prevent recurrence ofviolations

associated with the Protection System Maintenance and Testing (PRC-005-I) Standard.







E.l While your organization is implementing this Mitigation Plan the reliability of the Bulk Power System (BPS) may remain at higher risk or be otherwise negatively impacted until the plan is successfully completed. To the extent they are, or may be, known or anticipated: (i) identify any such risks or impacts; and (ii) discuss any actions that your organization is planning to take to mitigate this increased risk to the reliability ofthe BPS. Additional detailed information may be provided as an attachment.






E.2 Describe how successful completion of this Mitigation Plan by your organization will prevent or minimize the probability that the reliability of the BPS incurs further risk of similar violations in the future. Additional detailed information may be provided as an attachment.





subject to Reliability Standard PRC-OOS-I. The successful completion ofthe mitigation


excellence at AMP. AMP's ultimate goal is to prevent recurrence of violations

associated with the Protection System Maintenance and Testing (PRC-005-1) Standard.




Version 2.0 - Released 7111108 Page 6 oflO


Section F: Authorization

An authorized individual must sign and date this Mitigation Plan Submittal Form. Bydoing so, this individual, on behalf of your organization:

a) Submits this Mitigation Plan for acceptance by ReliabilityFirst and approval byNERC,and

b) If applicable, certifies that this Mitigation Plan was completed on or before thedate provided as the 'Date of Completion of the Mitigation Plan' on this form,and

c) Acknowledges:

I. I am Vice President of Risk Control ofAmerican Municipal Power, Inc.

2. I am qualified to sign this Mitigation Plan on behalf ofAmericanMunicipal Power, Inc.

3. I have read and am familiar with the contents of this Mitigation Plan.

4. American Municipal Power, Inc. agrees to comply with, this MitigationPlan, including the timetable completion date, as accepted byReliabilityFirst and approved byNER~

Authorized Individual Signature ~---==~'-"<.~-I-~!f----'--==-----'-Name (Print): Terry Leach

Title:

. Date:

Vice President ofRisk Control

11/19/2010

Section G: Regional Entity Contact

Please direct completed forms or any questions regarding completion of this formto the ReliabilityFirst Compliance e-mail address [email protected] indicate the company name and reference the NERC Violation ID # (ifknown) in the subject line of the e-mail. Additionally, any ReliabilityFirstCompliance Staffmember is available for questions regarding the use of thisform. Please see the contact list posted on the ReliabilityFirst Compliance webpage.

Version 2.0 - Released 7/11/08 Page 7 ofl0

Attachment D

RIELIA.BllIT

Section F: AuthorizationAn authorized individual must sign and date this Mitigation Plan Submittal Form. Bydoing so, this individual, on behalf of your organization:

a) Submits this Mitigation Plan for acceptance by ReliabilityFirst and approval byNERC, and


c) Acknowledges:

1. I am Vice President of Risk Control ofAmerican Municipal Power, Inc.



4. American Municipal Power, Inc. agrees to comply with, this MitigationPlan, including the timetable completion date, as accepted byReJiabiJityFirst and approved byNER~

Authorized Iudividual Signature~~.Name (Print): Terry Leach

Title:

. Date:


11/19/2010

Section G: Regional Entity ContactPlease direct completed forms or any questions regarding completion of this formto the ReliabilityFirst Compliance e-mail address [email protected] indicate the company name and reference the NERC Violation ill # (ifknown) in the subject line of the e-mail. Additionally, any ReliabilityFirstCompliance Staffmember is available for questions regarding the use of thisform. Please see the contact list posted on the ReliabilityFirst Compliance webpage.


Section F: Authorization An authorized individual must sign and date this Mitigation Plan Submittal Form. By doing so, this individual, on behalf of your organization:

a) Submits this Mitigation Plan for acceptance by ReliabilityFirst and approval by NERC. and

b) If applicable, certifies that this Mitigation Plan was completed on or before the date provided as the 'Date of Completion of the Mitigation Plan' on this form, and

c) Acknowledges:

1. I am Vice President of Risk Control of American Municipal Power, Inc.

2. I am qualified to sign this Mitigation Plan on behalf of American Municipal Power, Inc.


4. American Municipal Power, Inc. agrees to comply with, this Mitigation Plan, including the timetable completion date, as accepted by ReliabilityFirst and approved by NER~

Authorized Individual Signature ~ ~. Name (Print): Terry Leach

Title: Vice President of Risk Control

. Date: 11119/2010

Section G: Regional Entity Contact Please direct completed forms or any questions regarding completion of this form to the ReliabilityFirst Compliance e-mail address [email protected]. Please indicate the company name and reference the NERC Violation ID # (if known) in the subject line of the e-mail. Additionally, any ReliabilityFirst Compliance Staffmember is available for questions regarding the use of this form. Please see the contact list posted on the ReliabilityFirst Compliance web page.



Attachment A - Compliance Notices & Mitigation Plan Requirements

1. Section 6.2 ofthe CMEp1 sets forth the information that must be included in aMitigation Plan. The Mitigation Plan must include:

(1) The Registered Entity's point of contact for the Mitigation Plan, who shall be aperson (i) responsible for filing the Mitigation Plan, (ii) technicallyknowledgeable regarding the Mitigation Plan, and (iii) authorized and competentto respond to questions regarding the status of the Mitigation Plan.

(2) The Alleged or Confirmed Violation(s) ofReliability Standard(s) the MitigationPlan will correct.

(3) The cause of the Alleged or Confirmed Violation(s).

(4) The Registered Entity's action plan to correct the Alleged or ConfirmedViolation(s).

(5) The Registered Entity's action plan to prevent recurrence of the Alleged orConfrrrned violation(s).

(6) The anticipated impact of the Mitigation Plan on the bulk power systemreliability and an action plan to mitigate any increased risk to the reliability of thebulk power-system while the Mitigation Plan is being implemented.

(7) A timetable for completion of the Mitigation Plan including the completion dateby which the Mitigation Plan will be fully implemented and the Alleged orConfirmed Violation(s) corrected.

(8) Key implementation milestones no more than three (3) months apart forMitigation Plans with expected completion dates more than three (3) monthsfrom the date of submission. Additional violations could be determined for notcompleting work associated with accepted milestones.

(9) Any other information deemed necessary or appropriate.

(10) The Mitigation Plan shall be signed by an officer, employee, attorney or otherauthorized representative of the Registered Entity, which if applicable, shall bethe person that signed the Self-Certification or SelfReporting submittals.

II. This submittal form must be used to provide a required Mitigation Plan for reviewand acceptance by ReliabilityFirst and approval by NERC.

III. This Mitigation Plan is submitted to ReliabilityFirst and NERC as confidentialinformation in accordance with Section 1500 of the NERC Rilles ofProcedure.

N. This Mitigation Plan Submittal Form may be used to address one or more relatedAlleged or Confirmed violations of one Reliability Standard. A separate

I "Compliance Monitoring and Enforcement Program" ofthe Reliabilityliirst Corporation;" a copyof thecurrent versionapproved by the Federal Energy Regulatory Commission is postedon the ReliabilityFirstwebsite.

Version 2.0 - Released 7/11/08 Page 80flO

Attachment D


I. Section 6.2 ofthe CMEp l sets forth the infonnation that must be included in aMitigation Plan. The Mitigation Plan must include:



(3) The cause ofthe Alleged or Confirmed Violation(s).


(5) The Registered Entity's action plan to prevent recurrence of the Alleged orConfmned violation(s).







III. This Mitigation Plan is submitted to ReliabilityFirst and NERC as confidentialinformation in accordance with Section 1500 of the NERC Rules ofProcedure.

N. This Mitigation Plan Submittal Form may be used to address one or more relatedAlleged or Confirmed violations ofone Reliability Standard. A separate

I "Compliance Monitoring and Enforcement Program" ofthe ReliabilityFirst Corporation;" a copy of thecurrent version approved by the Federal Energy Regulatory Commission is posted on the ReliabilityFirstwebsite.

Version 2.0 - Released 7/11/08 Page 80f10


I. Section 6.2 ofthe CMEp l sets forth the information that must be included in a Mitigation Plan. The Mitigation Plan must include:

(1) The Registered Entity's point of contact for the Mitigation Plan, who shall be a person (i) responsible for filing the Mitigation Plan, (ii) technically knowledgeable regarding the Mitigation Plan, and (iii) authorized and competent to respond to questions regarding the status of the Mitigation Plan.

(2) The Alleged or Confirmed Violation(s) of Reliability Standard(s) the Mitigation Plan will correct.

(3) The cause ofthe Alleged or Confirmed Violation(s).

(4) The Registered Entity's action plan to correct the Alleged or Confirmed Violation(s).

(5) The Registered Entity's action plan to prevent recurrence of the Alleged or Confmned violation(s).

(6) The anticipated impact of the Mitigation Plan on the bulk power system reliability and an action plan to mitigate any increased risk to the reliability of the bulk power-system while the Mitigation Plan is being implemented.

(7) A timetable for completion of the Mitigation Plan including the completion date by which the Mitigation Plan will be fully implemented and the Alleged or Confirmed Violation(s) corrected.

(8) Key implementation milestones no more than three (3) months apart for Mitigation Plans with expected completion dates more than three (3) months from the date of submission. Additional violations could be determined for not completing work associated with accepted milestones.


(10) The Mitigation Plan shall be signed by an officer, employee, attorney or other authorized representative of the Registered Entity, which if applicable, shall be the person that signed the Self-Certification or Self Reporting submittals.

II. This submittal form must be used to provide a required Mitigation Plan for review and acceptance by ReliabilityFirst and approval by NERC.

III. This Mitigation Plan is submitted to ReliabilityFirst and NERC as confidential information in accordance with Section 1500 of the NERC Rules of Procedure.

N. This Mitigation Plan Submittal Form may be used to address one or more related Alleged or Confirmed violations of one Reliability Standard. A separate

I "Compliance Monitoring and Enforcement Program" of the ReliabilityFirst Corporation;" a copy of the current version approved by the Federal Energy Regulatory Commission is posted on the ReliabilityFirst website.

Version 2.0 - Released 7/11108 Page 80f10


mitigation plan is required to address Alleged or Confirmed violations withrespect to each additional Reliability Standard, as applicable.

V. If the Mitigation Plan is accepted by ReliabilityFirst and approved by NERC, acopy of this Mitigation Plan will be provided to the Federal Energy RegulatoryCommission in accordance with applicable Commission rules, regulations andorders.

VI. ReliabilityFirst or NERC may reject Mitigation Plans that they determine to beincomplete or inadequate.

VII. Remedial action directives also may be issued as necessary to ensure reliability ofthe BPS.


Attachment D


V. Ifthe Mitigation Plan is accepted by ReliabilityFirst and approved by NERC, acopy ofthis Mitigation Plan will be provided to the Federal Energy RegulatoryCommission in accordance with applicable Commission rules, regulations andorders.




mitigation plan is required to address Alleged or Confirmed violations with respect to each additional Reliability Standard, as applicable.

V. Ifthe Mitigation Plan is accepted by ReliabilityFirst and approved by NERC, a copy ofthis Mitigation Plan will be provided to the Federal Energy Regulatory Commission in accordance with applicable Commission rules, regulations and orders.

VI. ReliabilityFirst or NERC may reject Mitigation Plans that they determine to be incomplete or inadequate.

VII. Remedial action directives also may be issued as necessary to ensure reliability of the BPS.

Version 2.0 - Released 7/11/08 Page 9 ofl0


DOCUMENT CONTROL

Title: Mitigation Plan Submittal Form

Issue: Version 2.0

Date: II July 2008

Distribution: Public

Filename: ReliabilityFirst Mitigation Plan Submittal Form - Ver 2.DOC

Control: Reissue as complete document only

DOCUMENT APPROVAL

Prepared By Approved By Approval Signature Date

Robert K. Wargo Raymond J. Palmieri

SeniorConsultant VicePresident and~l~ 1/2/08

Compliance Director

Compliance

DOCUMENT CHANGEIREVISION mSTORY

Version Prepared By Summary of Changes Date

1.0 Robert K. WargoOriginal Issue - Replaces "Proposed

1/2/08Mitigation Plan" Form

Revised email address fromcompliance®rfirst.org to

2.0 TonyPurgar [email protected] 7/11/08


Attachment D

DOCUMENT CONTROL


Issue: Version 2.0

Date: 11 July 2008




DOCUMENT APPROVAL



Senior Consultant Vice President and~rJ'~ 1/2/08

Compliance Director

Compliance





Revised email address [email protected] to



DOCUMENT CONTROL


Issue: Version 2.0

Date: 11 July 2008




DOCUMENT APPROVAL



Senior Consultant Vice President and ~rJ·~ 112/08

Compliance Director

Compliance



1.0 Robert K. Wargo Original Issue - Replaces "Proposed

112/08 Mitigation Plan" Form

Revised email address from [email protected] to

2.0 TonyPurgar mitigation:[email protected] 7/11108



Attachment E


Date this Mitigation Plan is being submitted: 1111912010


A.l Notices and requirements applicable to Mitigation Plans and this SubmittalForm are set forth in "Attachment A - Compliance Notices & Mitigation PlanRequirements."


A.3 [g] I have reviewed Attachment A and understand that this Mitigation PlanSubmittal Form will not be accepted unless this box is checked.


B.1 Identify your organization.

Company Name:





NCR00683


Name:

Title:Compliance

Email:

Phone:


Kevin Koloini


[email protected]

1-614-540-1111

Page 1 of9

RFC201000651

Attachment E




A.1 Notices and requirements applicable to Mitigation Plans and this SubmittalFonn are set forth in "Attachment A - Compliance Notices & Mitigation PlanRequirements."

A.2 This fonn must be used to submit required Mitigation Plans for review andacceptance by ReliabilityFirst and approval by NERC.

A.3 [g] I have reviewed Attachment A and understand that this Mitigation PlanSubmittal Form will not be accepted unless this box is checked.



Company Name:





NCR00683


Name:

Title:Compliance

Email:

Phone:


Kevin Koloini


[email protected]

1-614-540-1111

Page 1 of9


Date this Mitigation Plan is being submitted: 1111912010


A.l Notices and requirements applicable to Mitigation Plans and this Submittal Fonn are set forth in "Attachment A - Compliance Notices & Mitigation Plan Requirements."

A.2 This fonn must be used to submit required Mitigation Plans for review and acceptance by ReliabilityFirst and approval by NERC.

A.3 [g] I have reviewed Attachment A and understand that this Mitigation Plan Submittal Form will not be accepted unless this box is checked.


B.l Identify your organization.



NERC Compliance Registry ill: NCR00683


Name: Kevin Koloini



Phone: 1-614-540-1111

Version 2.0 - Released 7111108 Page 1 of9


lElliA


C.l This Mitigation Plan is associated with the following Alleged or Confirmedviolation(s) of the reliability standard listed below.

NERC Reliability Requirement Violation Alleged or Method ofViolation ill # Standard Number Risk Confirmed Detection (e.g.,

Factor Violation Audit, Self-report,Date(') Investigation)

RFC201000651 FAC-008 R1(R1.2) Lower 10/1/10 (Date AuditofAuditExit

Briefing)

(*) Note: TheAlleged or Confirmed Violation Dateshallbe expressly specified by theRegistered Entity,andsubject to modification by ReliabilityFirst, as: (i) the datetheAlleged or Confirmed violation occurred;(ii) thedatethat theAlleged or Confirmed violation wasself-reported; or (iii) thedatethat theAlleged orConfrrmed violation hasbeendeemed to haveoccurred onby ReliabilityFirst. Questions regarding thedateto useshould be directed to the ReliabilityFirst contact identified in Section G of this form.


During an offsite compliance audit ofAmerican Municipal Power, Inc.("AMP") conducted by ReliabilityFirst Corporation ("RFC") from September10,2010 through September 30,2010, the RFC auditors identified a PossibleViolation ofReliability Standard FAC-008-l, Requirement Rl (sub-requirementR1.2). According to the information provided in the auditors' exit briefing,''[AMP's] rating methodology does not define methods for [rating] transmissionconductors, transformers, relay protective devices, and terminal equipment."

AMP described its methodology for rating transmission conductors,transformers, relay protective devices, and terminal equipment in itsdocumentation for Reliability Standard FAC-008-l. The ratings methodologies

Version2.0-Released 7/11/08 Page 2 of9

Attachment E

.ElIABIILIT


C.1 This Mitigation Plan is associated with the following Alleged or Confinnedviolation(s) of the reliability standard listed below.

NERC Reliability Requirement Violation Alleged or Method ofViolation ill # Standard Number Risk Confinned Detection (e.g.,

Factor Violation Audit, Self-report,Date(*) fuvestigation)

RFC201000651 FAC-008 Rl(Rl.2) Lower 10/1/10 (Date Auditof Audit Exit

Briefing)

(*) Note: The Alleged or Confirmed VIolation Date shall be expressly speCIfied by the RegIstered Entity,and subject to modification by ReliabilityFirst, as: (i) the date the Alleged or ConfIrmed violation occurred;(ii) the date that the Alleged or Conflfl1led violation was self-reported; or (iii) the date that the Alleged orConflfl1led violation has been deemed to have occurred on by ReliabilityFirst. Questions regarding thedate to use should be directed to the ReliabilityFirst contact identified in Section G ofthis form.

Co2 Identify the cause of the Alleged or Confinned violation(s) identified above.Additional detailed infonnation may be provided as an attachment.

During an offsite compliance audit ofAmerican Municipal Power, Inc.("AMP") conducted by ReliabilityFirst Corporation ("RFC") from September10,2010 through September 30,2010, the RFC auditors identified a PossibleViolation ofReliability Standard FAC-008-1, Requirement R1 (sub-requirementR1.2). According to the infonnation provided in the auditors' exit briefing,''[AMP's] rating methodology does not define methods for [rating] transmissionconductors, transfonners, relay protective devices, and tenninal equipment."

AMP described its methodology for rating transmission conductors,transfonners, relay protective devices, and tenninal equipment in itsdocumentation for Reliability Standard FAC-008-1. The ratings methodologies



C.l This Mitigation Plan is associated with the following Alleged or Confinned violation(s) of the reliability standard listed below.

NERC Reliability Requirement Violation Alleged or Method of Violation ill # Standard Number Risk Confinned Detection (e.g.,

Factor Violation Audit, Self-report, Date(*) fuvestigation)

RFC20 1 000651 FAC-008 Rl(Rl.2) Lower 10/1/10 (Date Audit of Audit Exit

Briefing)

(*) Note: The Alleged or Confirmed VIolation Date shall be expressly speCIfied by the RegIstered Entity, and subject to modification by ReliabilityFirst, as: (i) the date the Alleged or ConfIrmed violation occurred; (ii) the date that the Alleged or Confrrmed violation was self-reported; or (iii) the date that the Alleged or Confrrmed violation has been deemed to have occurred on by ReliabilityFirst. Questions regarding the date to use should be directed to the ReliabilityFirst contact identified in Section G of this form.

C.2 Identify the cause of the Alleged or Confinned violation(s) identified above. Additional detailed infonnation may be provided as an attachment.

During an off site compliance audit of American Municipal Power, Inc. ("AMP") conducted by ReliabilityFirst Corporation ("RFC") from September 10,2010 through September 30,2010, the RFC auditors identified a Possible Violation of Reliability Standard FAC-008-1, Requirement Rl (sub-requirement R1.2). According to the infonnation provided in the auditors' exit briefing, ''[AMP's] rating methodology does not define methods for [rating] transmission conductors, transfonners, relay protective devices, and tenninal equipment."

AMP described its methodology for rating transmission conductors, transfonners, relay protective devices, and tenninal equipment in its documentation for Reliability Standard F AC-008-1. The ratings methodologies



are set forth in Appendix A: AMP's Facility Ratings Methodology. AMPFacilities and Equipment are rated based upon Design, Nameplate, orDemonstrated Rating methodologies and the associated definitions specified inthe Facility Ratings Methodology. "Facilities" are defined as a "set of electricalequipment that operates as a single Bulk Electric System" element, while"Equipment" is defined in AMP's Facility Ratings Methodology as "generators,transmission conductors, transformers, relay protective devices, terminalequipment, and series and shunt compensation devices."

While AMP does not agree with the conclusion that its existing facilityratings methodology does not satisfy the requirements set forth in ReliabilityStandard FAC-008-l, AMP nonetheless agrees to modify its methodology tomore clearly document how AMP establishes ratings for transmissionconductors, transformers, relay protective devices, and terminal equipment.

Note: If a formal root cause analysis evaluation was performed, submit a copyofthe summary report.




D.l Identify and describe the action plan, including specific tasks and actions thatyour organization is proposing to undertake, or which it undertook if thisMitigation Plan has been completed, to correct the Alleged or Confirmedviolations identified above in Part C.l of this form. Additional detailedinformation may be provided as an attachment.

To mitigate the alleged Possible Violation, AMP will modify its existingfacility ratings methodology to address the alleged deficiencies identified duringAMP's audit, including to clearly correlate AMP's ratings methodology withthe specific devices included in the ratings.


Attachment E

REllABllITare set forth in Appendix A: AMP's Facility Ratings Methodology. AMPFacilities and Equipment are rated based upon Design, Nameplate, orDemonstrated Rating methodologies and the associated definitions specified inthe Facility Ratings Methodology. "Facilities" are defined as a "set of electricalequipment that operates as a single Bulk Electric System" element, while"Equipment" is defined in AMP's Facility Ratings Methodology as "generators,transmission conductors, transformers, relay protective devices, terminalequipment, and series and shunt compensation devices."

While AMP does not agree with the conclusion that its existing facilityratings methodology does not satisfy the requirements set forth in ReliabilityStandard FAC-008-1, AMP nonetheless agrees to modify its methodology tomore clearly document how AMP establishes ratings for transmissionconductors, transformers, relay protective devices, and terminal equipment.

Note: If a formal root cause analysis evaluation was performed, submit a copyofthe summary report.




D.1 Identify and describe the action plan, including specific tasks and actions thatyour organization is proposing to undertake, or which it undertook if thisMitigation Plan has been completed, to correct the Alleged or Confirmedviolations identified above in Part C.l of this form. Additional detailedinformation may be provided as an attachment.

To mitigate the alleged Possible Violation, AMP will modify its existingfacility ratings methodology to address the alleged deficiencies identified duringAMP's audit, including to clearly correlate AMP's ratings methodology withthe specific devices included in the ratings.


are set forth in Appendix A: AMP's Facility Ratings Methodology. AMP Facilities and Equipment are rated based upon Design, Nameplate, or Demonstrated Rating methodologies and the associated definitions specified in the Facility Ratings Methodology. "Facilities" are defined as a "set of electrical equipment that operates as a single Bulk Electric System" element, while "Equipment" is defined in AMP's Facility Ratings Methodology as "generators, transmission conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices."

While AMP does not agree with the conclusion that its existing facility ratings methodology does not satisfy the requirements set forth in Reliability Standard FAC-008-1, AMP nonetheless agrees to modify its methodology to more clearly document how AMP establishes ratings for transmission conductors, transformers, relay protective devices, and terminal equipment.

Note: If a formal root cause analysis evaluation was performed, submit a copy of the summary report.




D.1 Identify and describe the action plan, including specific tasks and actions that your organization is proposing to undertake, or which it undertook if this Mitigation Plan has been completed, to correct the Alleged or Confirmed violations identified above in Part C.l of this form. Additional detailed information may be provided as an attachment.

To mitigate the alleged Possible Violation, AMP will modify its existing facility ratings methodology to address the alleged deficiencies identified during AMP's audit, including to clearly correlate AMP's ratings methodology with the specific devices included in the ratings.





AMP will have fully mitigated the Possible Violation on or before 2/19120 II.


Key Milestone Activity Proposed/Actual Completion Date*(shall not be more than 3 months anart)

Modify facility ratings methodology 2/1912011Provide evidence ofmitigation plan 2/19/2011

completion to RFC


Version 2.0 - Released 7/1l/08 Page 4 of9

Attachment E

RIEILI~Bll.


D.2 Provide the date by which full implementation of the Mitigation Plan will be, orhas been, completed with respect to the Alleged or Confinned violationsidentified above. State whether the Mitigation Plan has been fully implemented,and/or whether the actions necessary to assure the entity has returned to fullcompliance have been completed.

AMP will have fully mitigated the Possible Violation on or before 2/1912011.

D.3 Enter Key Milestone Activities (with due dates) that can be used to track andindicate progress towards timely and successful completion ofthis MitigationPlan.

Key Milestone Activity Proposed!Actual Completion Date*(shall not be more than 3 months apart)

Modify facility ratings methodology 2/19/2011Provide evidence ofmitigation plan 2/19/2011

completion to RFC


Version 2.0 - Released 7/1l/08 Page 4 of9


D.2 Provide the date by which full implementation of the Mitigation Plan will be, or has been, completed with respect to the Alleged or Confinned violations identified above. State whether the Mitigation Plan has been fully implemented, and!or whether the actions necessary to assure the entity has returned to full compliance have been completed.

AMP will have fully mitigated the Possible Violation on or before 2/1912011.

D.3 Enter Key Milestone Activities (with due dates) that can be used to track and indicate progress towards timely and successful completion ofthis Mitigation Plan.

Key Milestone Activity Proposed! Actual Completion Date* (shall not be more than 3 months apart)

Modify facility ratings methodology 211912011 Provide evidence of mitigation plan 2/1912011

completion to RFC






E.I While your organization is implementing this Mitigation Plan the reliability ofthe Bulk Power System (BPS) may remain at higher risk or be otherwisenegatively impacted until the plan is successfully completed. To the extent theyare, or may be, known or anticipated: (i) identify any such risks or impacts; and(ii) discuss any actions that your organization is planning to take to mitigate thisincreased risk to the reliability ofthe BPS. Additional detailed informationmay be provided as an attachment.

AMP has not identified any material risks to the reliability of the BulkElectric System arising from this Possible Violation. The scope ofAMP'sfacility ratings methodology addressed generators, transmission conductors,transformers, relay protective devices, and terminal equipment (AMP does notown series and shunt compensation devices).


E.2 Describe how successful completion ofthis Mitigation Plan by yourorganization will prevent or minimize the probability that the reliability of theBPS incurs further risk of similar violations in the future. Additional detailedinformation may be provided as an attachment.

Upon completion ofthis mitigation plan, AMP will have in place adocumented facility ratings methodology that clearly correlates rated facilitiesand equipment with the methodology utilized to develop such ratings. Thesuccessful completion of this mitigation plan will continue to promote a cultureof compliance and reinforce reliability excellence at AMP. AMP's ultimategoal is to prevent recurrence ofallegations ofPossible Violations associatedwith the Facility Ratings Methodology Standard (FAC-008-1).


Attachment E



E.l While your organization is implementing this Mitigation Plan the reliability ofthe Bulk Power System (BPS) may remain at higher risk or be otherwisenegatively impacted until the plan is successfully completed. To the extent theyare, or may be, known or anticipated: (i) identify any such risks or impacts; and(ii) discuss any actions that your organization is planning to take to mitigate thisincreased risk to the reliability of the BPS. Additional detailed infonnationmay be provided as an attachment.

AMP has not identified any material risks to the reliability ofthe BulkElectric System arising from this Possible Violation. The scope ofAMP'sfacility ratings methodology addressed generators, transmission conductors,transfonners, relay protective devices, and tenninal equipment (AMP does notown series and shunt compensation devices).


E.2 Describe how successful completion ofthis Mitigation Plan by yourorganization will prevent or minimize the probability that the reliability oftheBPS incurs further risk of similar violations in the future. Additional detailedinfonnation may be provided as an attachment.

Upon completion of this mitigation plan, AMP will have in place adocumented facility ratings methodology that clearly correlates rated facilitiesand equipment with the methodology utilized to develop such ratings. Thesuccessful completion of this mitigation plan will continue to promote a cultureof compliance and reinforce reliability excellence at AMP. AMP's ultimategoal is to prevent recurrence ofallegations ofPossible Violations associatedwith the Facility Ratings Methodology Standard (FAC-008-l).




E.l While your organization is implementing this Mitigation Plan the reliability of the Bulk Power System (BPS) may remain at higher risk or be otherwise negatively impacted until the plan is successfully completed. To the extent they are, or may be, known or anticipated: (i) identify any such risks or impacts; and (ii) discuss any actions that your organization is planning to take to mitigate this increased risk to the reliability of the BPS. Additional detailed infonnation may be provided as an attachment.

AMP has not identified any material risks to the reliability ofthe Bulk Electric System arising from this Possible Violation. The scope of AMP's facility ratings methodology addressed generators, transmission conductors, transfonners, relay protective devices, and tenninal equipment (AMP does not own series and shunt compensation devices).


E.2 Describe how successful completion of this Mitigation Plan by your organization will prevent or minimize the probability that the reliability ofthe BPS incurs further risk of similar violations in the future. Additional detailed infonnation may be provided as an attachment.

Upon completion of this mitigation plan, AMP will have in place a documented facility ratings methodology that clearly correlates rated facilities and equipment with the methodology utilized to develop such ratings. The successful completion of this mitigation plan will continue to promote a culture of compliance and reinforce reliability excellence at AMP. AMP's ultimate goal is to prevent recurrence of allegations of Possible Violations associated with the Facility Ratings Methodology Standard (FAC-008-l).



RlEllABllll

Section F: Authorization

An authorized individual must sign and date this Mitigation Plan Submittal Form. Bydoing so, this individual, on behalfof your organization:



c) Acknowledges:

1. I am Vice President ofRisk Control ofAmerican Municipal Power, Inc.

2. I am qualified to sign this Mitigation Plan on behalf of AmericanMunicipal Power, Inc.


4. American Municipal Power, Inc. agrees to comply with, this MitigationPlan, including the timetable completion date, as accepted byReliabilityFirst and approved by NERC.

Authorized Individual Signature~~Name (print): Terry Leach

Title:

Date:


11/19/2010


Please direct completed forms or any questions regarding completion of this formto the ReliabilityFirst Compliance e-mail address [email protected] indicate the company name and reference the NERC Violation ill # (ifknown) in the subject line of the e-mail. Additionally, any ReliabilityFirstCompliance Staffmember is available for questions regarding the use of thisform. Please see the contact list posted on the ReliabilityFirst Compliance webpage.


Attachment E

Section F: AuthorizationAn authorized individual must sign and date this Mitigation Plan Submittal Form. Bydoing so, this individual, on behalf of your organization:


b) Ifapplicable, certifies that this Mitigation Plan was completed on or before thedate provided as the 'Date of Completion of the Mitigation Plan' on this form,and

c) Acknowledges:

1. I am Vice President ofRisk Control ofAmerican Municipal Power, Inc.

2. I am qualified to sign this Mitigation Plan on behalfofAmericanMunicipal Power, Inc.


4. American Municipal Power, Inc. agrees to comply with, this MitigationPlan, including the timetable completion date, as accepted byReliabilityFirst and approved by NERC.

Authorized Individual Signature~~Name (print): Terry Leach

Title:

Date:


11/19/2010

Section G: Regional Entity ContactPlease direct completed forms or any questions regarding completion of this formto the ReliabilityFirst Compliance e-mail address [email protected] indicate the company name and reference the NERC Violation ill # (ifknown) in the subject line of the e-mail. Additionally, any ReliabilityFirstCompliance Staffmember is available for questions regarding the use ofthisform. Please see the contact list posted on the ReliabilityFirst Compliance webpage.



a) Submits this Mitigation Plan for acceptance by ReliabilityFirst and approval by NERC, and

b) If applicable, certifies that this Mitigation Plan was completed on or before the date provided as the 'Date of Completion of the Mitigation Plan' on this form, and

c) Acknowledges:




4. American Municipal Power, Inc. agrees to comply with, this Mitigation Plan, including the timetable completion date, as accepted by ReliabilityFirst and approved by NERC.

Authorized Individual Signature ~ ~ Name (print): Terry Leach


Date: 11119/2010

Section G: Regional Entity Contact Please direct completed forms or any questions regarding completion of this form to the ReliabilityFirst Compliance e-mail address [email protected]. Please indicate the company name and reference the NERC Violation ID # (if known) in the subject line of the e-mail. Additionally, any ReliabilityFirst Compliance Staffmember is available for questions regarding the use of this form. Please see the contact list posted on the ReliabilityFirst Compliance web page.




I. Section 6.2 ofthe CMEp1 sets forth the information that must be included in aMitigation Plan. The Mitigation Plan must include:





(5) The Registered Entity's action plan to prevent recurrence of the Alleged orConfirmed violation(s).








IV. This Mitigation Plan Submittal Form maybe used to address one or more relatedAlleged or Confirmed violations of one Reliability Standard. A separate

I "Compliance Monitoring and Enforcement Program" ofthe ReliabilityFirst Corporation;" a copy of thecurrent version approved by the Federal Energy Regulatory Commission is postedontheReliabilityFirstwebsite.


Attachment E


I. Section 6.2 ofthe CMEp1 sets forth the infonnation that must be included in aMitigation Plan. The Mitigation Plan must include:


(2) The Alleged or Confrrmed Violation(s) ofReliability Standard(s) the MitigationPlan will correct.



(5) The Registered Entity's action plan to prevent recurrence of the Alleged orConfmned violation(s).


(7) A timetable for completion ofthe Mitigation Plan including the completion dateby which the Mitigation Plan will be fully implemented and the Alleged orConfirmed Violation(s) corrected.




II. This submittal fonn must be used to provide a required Mitigation Plan for reviewand acceptance by ReliabilityFirst and approval by NERC.

III. This Mitigation Plan is submitted to ReliabilityFirst and NERC as confidentialinfonnation in accordance with Section 1500 ofthe NERC Rules ofProcedure.

IV. This Mitigation Plan Submittal Ponn maybe used to address one or more relatedAlleged or Confinned violations of one Reliability Standard. A separate




I. Section 6.2 ofthe CMEp1 sets forth the infonnation that must be included in a Mitigation Plan. The Mitigation Plan must include:

(1) The Registered Entity's point of contact for the Mitigation Plan, who shall be a person (i) responsible for filing the Mitigation Plan, (ii) technically knowledgeable regarding the Mitigation Plan, and (iii) authorized and competent to respond to questions regarding the status of the Mitigation Plan.

(2) The Alleged or Confrrmed Violation(s) ofReIiabiIity Standard(s) the Mitigation Plan will correct.

(3) The cause of the Alleged or Confirmed Violation( s).


(5) The Registered Entity's action plan to prevent recurrence of the Alleged or Confmned violation(s).

(6) The anticipated impact of the Mitigation Plan on the bulk power system reliability and an action plan to mitigate any increased risk to the reliability of the bulk power-system while the Mitigation Plan is being implemented.

(7) A timetable for completion ofthe Mitigation Plan including the completion date by which the Mitigation Plan will be fully implemented and the Alleged or Confirmed Violation(s) corrected.




II. This submittal fonn must be used to provide a required Mitigation Plan for review and acceptance by ReliabilityFirst and approval by NERC.

III. This Mitigation Plan is submitted to ReliabilityFirst and NERC as confidential infonnation in accordance with Section 1500 ofthe NERC Rules of Procedure.

IV. This Mitigation Plan Submittal Ponn maybe used to address one or more related Alleged or Confinned violations of one Reliability Standard. A separate





V. If the Mitigation Plan is accepted by ReliabilityFirst and approved by NERC, acopy ofthis Mitigation Plan will be provided to the Federal Energy RegulatoryCommission in accordance with applicable Commission rules, regulations andorders.



Version2.0-Released 7/11/08 Page 8 of9

Attachment E


V. If the Mitigation Plan is accepted by ReliabilityFirst and approved by NERC, acopy ofthis Mitigation Plan will be provided to the Federal Energy RegulatoryCommission in accordance with applicable Commission rules, regulations andorders.




mitigation plan is required to address Alleged or Confirmed violations with respect to each additional Reliability Standard, as applicable.

V. If the Mitigation Plan is accepted by ReliabilityFirst and approved by NERC, a copy of this Mitigation Plan will be provided to the Federal Energy Regulatory Commission in accordance with applicable Commission rules, regulations and orders.

VI. ReliabilityFirst or NERC may reject Mitigation Plans that they determine to be incomplete or inadequate.

VII. Remedial action directives also may be issued as necessary to ensure reliability of the BPS.



DOCUMENT CONTROL


Issne: Version 2.0

Date: 11 July 2008

Distribntion: Public



DOCUMENT APPROVAL

Prepared By Approved By Approval Signatnre Date


SeniorConsultant VicePresident and~l~ 1/2/08

Compliance Director

Compliance

DOCUMENT CHANGEIREVISION HISTORY

Version Prepared By Snmmary of Changes Date






Attachment E

DOCUMENT CONTROLTitle: Mitigation Plan Submittal Form

Issue: Version 2.0

Date: 11 July 2008


Filename: ReliabilityFirst Mitigation Plan Submittal Form - Ver 2.DGe


DOCUMENT APPROVAL



Senior Consultant Vice President and~rJ·~ 1/2/08

ComplianceDirector

Compliance








DOCUMENT CONTROL Title: Mitigation Plan Submittal Form

Issue: Version 2.0

Date: 11 July 2008


Filename: ReliabilityFirst Mitigation Plan Submittal Form - Ver 2.DOe


DOCUMENT APPROVAL



Senior Consultant Vice President and ~rJ·~ 112/08

Compliance Director

Compliance




112/08 Mitigation Plan" Form


2.0 TonyPurgar [email protected] 7111/08



Attachment F




A.I Notices and requirements applicable to Mitigation Plans and this SubmittalFOnTI are set forth in "Attachment A - Compliance Notices & Mitigation PlanRequirements."

A.2 This fOnTI must be used to submit required Mitigation Plans for review andacceptance by ReliabilityFirst and approval by NERC.

A.3 [g] I have reviewed Attachment A and understand that this Mitigation PlanSubmittal FOnTI will not be accepted unless this box is checked.


B.I Identify your organization.

Company Name:





NCR00683


Name:

Title:Compliance

Email:

Phone:

Version 2.0 - Released 7/11108

Kevin Koloini


[email protected]

1-614-540-1111

Page I of9

RFC201000652

Attachment F

REtl




A.I Notices and requirements applicable to Mitigation Plans and this SubmittalForm are set forth in "Attachment A - Compliance Notices & Mitigation PlanRequirements...


A.3 C8J I have reviewed Attachment A and understand that this Mitigation PlanSubmittal Form will not be accepted unless this box is checked.



Company Name:





NCR00683


Name:

Title:Compliance

Email:

Phone:


Kevin Koloini


[email protected]

1-614-540-1111

Page 1 of9




A.l Notices and requirements applicable to Mitigation Plans and this Submittal Form are set forth in "Attachment A - Compliance Notices & Mitigation Plan Requirements ...

A.2 This form must be used to submit required Mitigation Plans for review and acceptance by ReliabilityFirst and approval by NERC.

A.3 C8J I have reviewed Attachment A and understand that this Mitigation Plan Submittal Form will not be accepted unless this box is checked.





NERC Compliance Registry ill: NCR00683


Name: Kevin Koloini



Phone: 1-614-540-1111



R


C.1 This Mitigation Plan is associated with the following Alleged or Confirmedviolation(s) of the reliability standard listed below.

NERC Reliability Requirement Violation Alleged or Method ofViolation ID # Standard Number Risk Confirmed Detection (e.g.,

Factor Violation Audit, Self-report,Date'? Investigation)

RFC20I000652 FAC-009 RI Medium 10/1/10 (Date Auditof Audit Exit

Briefing)

(*) Note: TheAlleged or Confmned VIOlatIOn Dateshallbe expressly specified by theRegistered Entity,andsubject to modification by ReliabilityFirst, as: (i) thedate theAlleged or Confmned violation occurred;(ii) thedatethat the Alleged or Confmned violation wasself-reported; or (iii)thedate that theAlleged orConfirmed violation hasbeen deemed to haveoccurred onby ReliabilityFirst. Questions regarding thedateto use should be directed to theReliabilityFirst contact identified in Section G of this form.


During an offsite compliance audit ofAmerican Municipal Power, Inc.("AMP") conducted by ReliabilityFirst Corporation ("RFC") from September10,2010 through September 30,2010, the RFC auditors identified a PossibleViolation ofReliability Standard FAC-009-1, Requirement RI. According tothe information provided in the auditors' exit briefing, "[r]ating values were notprovided for relay protective devices (relays and voltage and current sensingdevices) and terminal equipment" and AMP "did not identify the most limitingelement."

AMP's documentation for FAC-009-1 addresses relay protective devicesand terminal equipment. Specifically, AMP's Facility Equipment Ratings state


Attachment F

R

Section C: Identification of Alleged or Confirmed Violation(~

Associated with this Mitigation Plan

C.1 This Mitigation Plan is associated with the following Alleged or Confimledviolation(s) ofthe reliability standard listed below.

NERC Reliability Requirement Violation Alleged or Method ofViolation ill # Standard Number Risk Confirmed Detection (e.g.,

Factor Violation Audit, Self-report,Date(O) Investigation)

RFC201000652 FAC-009 Rl Medium 10/1/1 0 (Date Auditof Audit Exit

Briefmg)

(*) Note: The Alleged or Confmned VIOlatIOn Date shall be expressly specIfied by the RegIstered Entity,and subject to modification by ReliabilityFirst, as: (i) the date the Alleged or Confmned violation occurred;(ii) the date that the Alleged or Confmned violation was self-reported; or (iii) the date that the Alleged orConfirmed violation has been deemed to have occurred on by ReliabilityFirst. Questions regarding thedate to use should be directed to the ReliabilityFirst contact identified in Section G of this form.

C.2 Identify the cause of the Alleged or Confimled violation(s) identified above.Additional detailed infomlation may be provided as an attachment.

During an offsite compliance audit ofAmerican Municipal Power, Inc.("AMP") conducted by ReliabilityFirst Corporation ("RFC") from September10,2010 through September 30,2010, the RFC auditors identified a PossibleViolation ofReliability Standard FAC-009-1, Requirement Rl. According tothe information provided in the auditors' exit briefing, "[r]ating values were notprovided for relay protective devices (relays and voltage and current sensingdevices) and tenninal equipment" and AMP "did not identify the most limitingelement:'

AMP's documentation for FAC-009-1 addresses relay protective devicesand terminal equipment. Specifically, AMP's Facility Equipment Ratings state



C.l This Mitigation Plan is associated with the following Alleged or Confimled violation(s) ofthe reliability standard listed below.

NERC Reliability Requirement Violation Alleged or Method of Violation ID # Standard Number Risk Confirmed Detection (e.g.,

Factor Violation Audit, Self-report, Date(O) Investigation)

RFC201000652 FAC-009 Rl Medium 10/111 0 (Date Audit of Audit Exit

Briefmg)

(*) Note: The Alleged or Confmned VIOlatIOn Date shall be expressly specIfied by the RegIstered Entity, and subject to modification by ReliabilityFirst, as: (i) the date the Alleged or Confmned violation occurred; (ii) the date that the Alleged or Confmned violation was self-reported; or (iii) the date that the Alleged or Confirmed violation has been deemed to have occurred on by ReliabilityFirst. Questions regarding the date to use should be directed to the ReliabilityFirst contact identified in Section G of this form.

C.2 Identify the cause of the Alleged or Confimled violation(s) identified above. Additional detailed infomlation may be provided as an attachment.

During an offsite compliance audit of American Municipal Power, Inc. ("AMP") conducted by ReliabilityFirst Corporation ("RFC") from September 10,2010 through September 30,2010, the RFC auditors identified a Possible Violation of Reliability Standard FAC-009-1, Requirement Rl. According to the information provided in the auditors' exit briefing, "[rJating values were not provided for relay protective devices (relays and voltage and current sensing devices) and tenninal equipment" and AMP "did not identify the most limiting element."

AMP's documentation for FAC-009-1 addresses relay protective devices and terminal equipment. Specifically, AMP's Facility Equipment Ratings state



that "[r]elay protective devices and Terminal Equipment are designed to meetthe maximum voltage and current Facility Ratings, and are not limiting factors."See App. B, C, and D to AMP NERC Reliability Standard Procedure for FAC008-1 and FAC-009-1. With respect to limiting elements, AMP's facilityratings methodology states that "[e]ach Facility Rating is equal to the mostlimiting applicable Equipment Rating of the individual equipment thatcomprises the Facility." Thus, AMP's facility ratings inherently reflect the mostlimiting element.

While AMP does not agree with the conclusion that its existing facilityratings do not satisfy the requirements set forth in Reliability Standard FAC009-1, AMP nonetheless agrees to modify the documentation of its ratings tomore clearly document AMP's ratings for relay protective devices and terminalequipment and to explicitly identify the most limiting applicable rating of theindividual equipment that comprises a facility.



Section D: Details of Proposed Mitigation PlanMitigation Plan Contents

D.I Identify and describe the action plan, including specific tasks and actions thatyour organization is proposing to undertake, or which it undertook if thisMitigation Plan has been completed, to correct the Alleged or Confirmedviolations identified above in Part C.I of this form. Additional detailedinformation may be provided as an attachment.

To mitigate the alleged Possible Violation, AMP will modify thedocumentation of its facility ratings to address the alleged deficienciesidentified during AMP's audit, including to more clearly document its ratingsfor relay protective devices and terminal equipment and to specify the most


Attachment F

RlEll

that "[rJelay protective devices and Terminal Equipment are designed to meetthe maximum voltage and current Facility Ratings, and are not limiting factors."See App. B, C, and D to AMP NERC Reliability Standard Procedure for FAC008-1 and FAC-009-1. With respect to limiting elements, AMP's facilityratings methodology states that "[e]ach Facility Rating is equal to the mostlimiting applicable Equipment Rating ofthe individual equipment thatcomprises the Facility." Thus, AMP's facility ratings inherently reflect the mostlimiting element.

While AMP does not agree with the conclusion that its existing facilityratings do not satisfy the requirements set forth in Reliability Standard FAC009-1, AMP nonetheless agrees to modify the documentation of its ratings tomore clearly document AMP's ratings for relay protective devices and terminalequipment and to explicitly identify the most limiting applicable rating of theindividual equipment that comprises a facility.

Note: Ifa formal root cause analysis evaluation was performed, submit a copyof the summary report.




D.1 Identify and describe the action plan, including specific tasks and actions thatyour organization is proposing to undertake, or which it undertook if thisMitigation Plan has been completed, to correct the Alleged or Confirmedviolations identified above in Part C.1 of this form. Additional detailedinformation may be provided as an attachment.

To mitigate the alleged Possible Violation, AMP will modify thedocumentation of its facility ratings to address the alleged deficienciesidentified during AMP's audit, including to more clearly document its ratingsfor relay protective devices and terminal equipment and to specify the most


that "[rJelay protective devices and Terminal Equipment are designed to meet the maximum voltage and current Facility Ratings, and are not limiting factors." See App. B, C, and D to AMP NERC Reliability Standard Procedure for F AC-008-1 and FAC-009-1. With respect to limiting elements, AMP's facility ratings methodology states that "[ e ]ach Facility Rating is equal to the most limiting applicable Equipment Rating ofthe individual equipment that comprises the Facility." Thus, AMP's facility ratings inherently reflect the most limiting element.

While AMP does not agree with the conclusion that its existing facility ratings do not satisfy the requirements set forth in Reliability Standard F AC-009-1, AMP nonetheless agrees to modify the documentation of its ratings to more clearly document AMP's ratings for relay protective devices and terminal equipment and to explicitly identify the most limiting applicable rating of the individual equipment that comprises a facility.

Note: Ifa formal root cause analysis evaluation was performed, submit a copy of the summary report.




D.1 Identify and describe the action plan, including specific tasks and actions that your organization is proposing to undertake, or which it undertook if this Mitigation Plan has been completed, to correct the Alleged or Confirmed violations identified above in Part C.1 of this form. Additional detailed information may be provided as an attachment.

To mitigate the alleged Possible Violation, AMP will modify the documentation of its facility ratings to address the alleged deficiencies identified during AMP's audit, including to more clearly document its ratings for relay protective devices and terminal equipment and to specify the most



limiting applicable rating ofthe individual equipment that comprises a facility.


D.2 Provide the date by which full implementation of the Mitigation Plan will be, orhas been, completed with respect to the Alleged or Confirmed violationsidentified above. State whether the Mitigation Plan has been fully implemented,and!or whether the actions necessary to assure the entity has returned to fullcompliance have been completed.

AMP will have fully mitigated the Possible Violation on or before 3/1912011



Complete (FAC-008) mitigation plan 2/1912011milestones

Modify ratings to address relay protective 3/19/2011devices and terminal equipment and to

identify limiting elementsProvide evidence ofmitigation plan 3/19/2011

completion to RFC


Version 2.0 - Released 7/11/08 Page40f9

Attachment F



D.2 Provide the date by which full implementation of the Mitigation Plan will be, orhas been, completed with respect to the Alleged or Confmned violationsidentified above. State whether the Mitigation Plan has been fully implemented,and/or whether the actions necessary to assure the entity has returned to fullcompliance have been completed.




Complete (FAC-008) mitigation plan 211912011milestones

Modify ratings to address relay protective 3/1912011devices and terminal equipment and to

identify limiting elementsProvide evidence ofmitigation plan 3/1912011

completion to RFC





D.2 Provide the date by which full implementation of the Mitigation Plan will be, or has been, completed with respect to the Alleged or Confmned violations identified above. State whether the Mitigation Plan has been fully implemented, and/or whether the actions necessary to assure the entity has returned to full compliance have been completed.


D.3 Enter Key Milestone Activities (with due dates) that can be used to track and indicate progress towards timely and successful completion of this Mitigation Plan.

Key Milestone Activity Proposed! Actual Completion Date* (shall not be more than 3 months apart)

Complete (F AC-008) mitigation plan 211912011 milestones

Modify ratings to address relay protective 3/1912011 devices and terminal equipment and to

identify limiting elements Provide evidence of mitigation plan 3/1912011

completion to RFC


Version 2.0 - Released 7111108 Page 40f9





AMP has not identified any material risks to the reliability of the BulkElectric System arising from this Possible Violation. As discussed above,AMP's documentation of its facility ratings addressed relay protective devicesand terminal equipment and stated that such devices would not serve as limitingelements. As is also discussed above, AMP's facility ratings inherentlyconsider the most limiting equipment elements.



Upon completion of this mitigation plan, AMP will have in placedocumented facility ratings that clearly (i) demonstrate that relay protectivedevices and terminal equipment are rated and (ii) identify the most limitingapplicable rating for equipment that comprises a facility. The successfulcompletion ofthis mitigation plan will continue to promote a culture ofcompliance and reinforce reliability excellence at AMP. AMP's ultimate goal isto prevent recurrence of Possible Violations associated with the Facility RatingsStandard (FAC-009-l).


Attachment F



E.! While your organization is implementing this Mitigation Plan the reliability ofthe Bulk Power System (BPS) may remain at higher risk or be otherwisenegatively impacted until the plan is successfully completed. To the extent theyare, or may be, known or anticipated: (i) identify any such risks or impacts; and(ii) discuss any actions that your organization is planning to take to mitigate thisincreased risk to the reliability ofthe BPS. Additional detailed informationmay be provided as an attachment.

AMP has not identified any material risks to the reliability ofthe BulkElectric System arising from this Possible Violation. As discussed above,AMP's documentation of its facility ratings addressed relay protective devicesand terminal equipment and stated that such devices would not serve as limitingelements. As is also discussed above, AMP's facility ratings inherentlyconsider the most limiting equipment elements.



Upon completion of this mitigation plan, AMP will have in placedocumented facility ratings that clearly (i) demonstrate that relay protectivedevices and terminal equipment are rated and (ii) identify the most limitingapplicable rating for equipment that comprises a facility. The successfulcompletion ofthis mitigation plan will continue to promote a culture ofcompliance and reinforce reliability excellence at AMP. AMP's ultimate goal isto prevent recurrence ofPossible Violations associated with the Facility RatingsStandard (FAC-009-1).




E.l While your organization is implementing this Mitigation Plan the reliability of the Bulk Power System (BPS) may remain at higher risk or be otherwise negatively impacted until the plan is successfully completed. To the extent they are, or may be, known or anticipated: (i) identify any such risks or impacts; and (ii) discuss any actions that your organization is planning to take to mitigate this increased risk to the reliability ofthe BPS. Additional detailed information may be provided as an attachment.

AMP has not identified any material risks to the reliability ofthe Bulk Electric System arising from this Possible Violation. As discussed above, AMP's documentation of its facility ratings addressed relay protective devices and terminal equipment and stated that such devices would not serve as limiting elements. As is also discussed above, AMP's facility ratings inherently consider the most limiting equipment elements.


E.2 Describe how successful completion of this Mitigation Plan by your organization will prevent or minimize the probability that the reliability of the BPS incurs further risk of similar violations in the future. Additional detailed information may be provided as an attachment.

Upon completion of this mitigation plan, AMP will have in place documented facility ratings that clearly (i) demonstrate that relay protective devices and terminal equipment are rated and (ii) identify the most limiting applicable rating for equipment that comprises a facility. The successful completion of this mitigation plan will continue to promote a culture of compliance and reinforce reliability excellence at AMP. AMP's ultimate goal is to prevent recurrence of Possible Violations associated with the Facility Ratings Standard (F AC-009-1).



Section F: AuthorizationAn authorized individual must sign and date this Mitigation Plan Submittal Form. Bydoing so, this individual, on behalfof your organization:



c) Acknowledges:


2. I am qualified to sign this Mitigation Plan on behalfofAmericanMunicipal Power, Inc.


4. American Municipal Power, Inc. agrees to comply with, this MitigationPlan, including the timetable completion date, as accepted byReliabilityFirst and approved by~~ J

Authorized Individual Signature ~A{~Name (print): Terry Leach

Title:

Date:


11/19/2010


Please direct completed forms or any questions regarding completion of this formto the ReliabilityFirst Compliance e-mail address [email protected] indicate the company name and reference the NERC Violation ill # (ifknown) in the subject line of the e-mail. Additionally, any ReliabilityFirstCompliance Staffmember is available for questions regarding the use of thisform. Please see the contact list posted on the ReliabilityFirst Compliance webpage.


Attachment F

.B;·.. ;I?···lLi 1·.'1······;f' : i f ~ :~) ~ -:- ~

Section F: AuthorizationAn authorized individual must sign and date this Mitigation Plan Submittal Form. Bydoing so, this individual, on behalfofyour organization:


b) Ifapplicable, certifies that this Mitigation Plan was completed on or before thedate provided as the 'Date ofCompletion of the Mitigation Plan' on this fonn,and

c) Acknowledges:

1. I am Vice President of Risk Control ofAmerican Municipal Power, Inc.



4. American Municipal Power, Inc. agrees to comply with, this MitigationPlan, including the timetable completion date, as accepted byReliabilityFirst and approved by~Rj? J

Authorized Iudividual Signature ~'U7~Name (print): Terry Leach

Title:

Date:


1111912010

Section G: Regional Entity ContactPlease direct completed forms or any questions regarding completion ofthis formto the ReliabilityFirst Compliance e-mail address [email protected] indicate the company name and reference the NERC Violation ill # (ifknown) in the subject line of the e-mail. Additionally, any ReliabilityFirstCompliance Staffmember is available for questions regarding the use of thisform. Please see the contact list posted on the ReliabilityFirst Compliance webpage.



a) Submits this Mitigation Plan for acceptance by ReliabilityFirst and approval by NERC, and

b) If applicable, certifies that this Mitigation Plan was completed on or before the date provided as the 'Date of Completion of the Mitigation Plan' on this fonn, and

c) Acknowledges:




4. American Municipal Power, Inc. agrees to comply with, this Mitigation Plan, including the timetable completion date, as accepted by ReliabilityFirst and approved by ~~ J

Authorized Individual Signature ~'U7~ Name (print): Terry Leach


Date: 1111912010

Section G: Regional Entity Contact Please direct completed forms or any questions regarding completion ofthis form to the ReliabilityFirst Compliance e-mail address [email protected]. Please indicate the company name and reference the NERC Violation ID # (if known) in the subject line of the e-mail. Additionally, any ReliabilityFirst Compliance Staff member is available for questions regarding the use of this form. Please see the contact list posted on the ReliabilityFirst Compliance web page.




I. Section 6.2 of the CMEp1 sets forth the information that must be included in aMitigation Plan. The Mitigation Plan must include:

(I) The Registered Entity's point ofcontact for the Mitigation Plan, who shall be aperson (i) responsible for filing the Mitigation Plan, (ii) technicallyknowledgeable regarding the Mitigation Plan, and (iii) authorized and competentto respond to questions regarding the status of the Mitigation Plan.




(5) The Registered Entity's action plan to prevent recurrence ofthe Alleged orConfirmed violation(s).

(6) The anticipated impact of the Mitigation Plan on the bulk power systemreliability and an action plan to mitigate any increased risk to the reliability of thebulk power-system while the Mitigation Plan is being impl~mented.




(10) The Mitigation Plan shall be signed by an officer, employee, attorney or otherauthorized representative of the Registered Entity, which if applicable, shall bethe person that signed the Self-Certification or Self Reporting submittals.



N. This Mitigation Plan Submittal Form may be used to address one or more relatedAlleged or Confirmed violations of one Reliability Standard. A separate

I "Compliance Monitoring and Enforcement Program" ofthe ReliabilityFirst Corporation;" a copy ofIhecurrent version approved by Ihe Federal Energy Regulatory Commission is posted on Ihe ReliabilityFirstwebsite.


Attachment F

ElJABlllT


I. Section 6.2 of the CMEp l sets forth the information that must be included in aMitigation Plan. The Mitigation Plan must include:

(1) The Registered Entity's point ofcontact for the Mitigation Plan, who shall be aperson (i) responsible for filing the Mitigation Plan, (ii) technicallyImowledgeable regarding the Mitigation Plan, and (iii) authorized and competentto respond to questions regarding the status of the Mitigation Plan.

(2) The Alleged or Confmned Violation(s) ofReliability Standard(s) the MitigationPlan will correct.



(5) The Registered Entity's action plan to prevent recurrence ofthe Alleged orConfirmed violation(s).

(6) The anticipated impact of the Mitigation Plan on the bulk power systemreliability and an action plan to mitigate any increased risk to the reliability of thebulk power-system while the Mitigation Plan is being impl~mented.




(10) The Mitigation Plan shall be signed by an officer, employee, attorney or otherauthorized representative of the Registered Entity, which if applicable, shall bethe person that signed the Self-Certification or Self Reporting submittals.


III. This Mitigation Plan is submitted to ReliabilityFirst and NERC as confidentialinformation in accordance with Section 1500 ofthe NERC Rules ofProcedure.

N. This Mitigation Plan Submittal Form may be used to address one or more relatedAlleged or Confirmed violations ofone Reliability Standard. A separate




I. Section 6.2 of the CMEp l sets forth the information that must be included in a Mitigation Plan. The Mitigation Plan must include:

(1) The Registered Entity's point of contact for the Mitigation Plan, who shall be a person (i) responsible for filing the Mitigation Plan, (ii) technically lmowledgeable regarding the Mitigation Plan, and (iii) authorized and competent to respond to questions regarding the status of the Mitigation Plan.

(2) The Alleged or Confmned Violation(s) of Reliability Standard(s) the Mitigation Plan will correct.



(5) The Registered Entity's action plan to prevent recurrence ofthe Alleged or Confirmed violation(s).

(6) The anticipated impact of the Mitigation Plan on the bulk power system reliability and an action plan to mitigate any increased risk to the reliability of the bulk power-system while the Mitigation Plan is being impl~mented.

(7) A timetable for completion of the Mitigation Plan including the completion date by which the Mitigation Plan will be fully implemented and the Alleged or Confirmed Violation(s) corrected.




II. This submittal form must be used to provide a required Mitigation Plan for review and acceptance by ReliabilityFirst and approval by NERC.

III. This Mitigation Plan is submitted to ReliabilityFirst and NERC as confidential information in accordance with Section 1500 of the NERC Rules of Procedure.

N. This Mitigation Plan Submittal Form may be used to address one or more related Alleged or Confirmed violations of one Reliability Standard. A separate




DOCUMENT CONTROL


Issue: Version 2.0

Date: 11 July 2008




DOCUMENT APPROVAL



SeniorConsultant VicePresident and~r/~ 112/08

Compliance Director

Compliance




112/08Mitigation Plan" Form


2.0 TonyPurgar [email protected] 7111108


Attachment F

REllABll

DOCUMENT CONTROL


Issue: Version 2.0

Date: 11 July 2008




DOCUMENT APPROVAL



Senior Consultant Vice President and~rJ'~ 112/08

Compliance Director

Compliance




112/08Mitigation Plan" Form


2.0 TonyPurgar [email protected] 7111108


DOCUMENT CONTROL Title: Mitigation Plan Submittal Form

Issue: Version 2.0

Date: 11 July 2008




DOCUMENT APPROVAL



Senior Consultant Vice President and ~rJ'~ 1/2/08

Compliance Director

Compliance




1/2/08 Mitigation Plan" Form


2.0 TonyPurgar [email protected] 7111/08



Attachment b

AMP’s Certification of Mitigation Plan Completion for PRC-005-1 R2 dated March 31,

2011

Attachment c

AMP’s Certification of Mitigation Plan Completion for FAC-008-1 R1 dated February 24,

2011

Attachment d

AMP’s Certification of Mitigation Plan Completion for FAC-009-1 R1 dated March 18,

2011

Attachment e

ReliabilityFirst’s Verification of Mitigation Plan Completion for PRC-005-1 R2 dated April 20,

2011

In re: AMERICAN MUNICIPAL ) Docket No. RFC201000238 POWER ) ) ) ) NERC Registry ID No. NCR00683 ) NERC Reliability Standard: ) PRC-005-1, Requirement 2 ) )

VERIFICATION OF MITIGATION PLAN COMPLETION FOR MIT-07-3111

I. RELEVANT BACKGROUND American Municipal Power (“AMP”) submitted a Self Report of a possible violation of PRC-005-1, Requirement 2 on January 18, 2010. AMP developed a new formal policy in 2007 that specified an interval periodicity and procedures for generation protection systems, but did not clearly articulate the policy to plant personnel and contractors in charge of performing maintenance and testing. Before the NERC standards became enforceable, on June 18, 2007, generation protection devices were tested on a five year rotation. Due to a lack of clarity in the new policy’s interval periodicity, AMP tested its plant’s generation protection systems on a three year visual, mechanical, and electrical cycle. The intervals specified in the formal policy required maintenance testing on a one year cycle, but AMP failed to meet those intervals. AMP submitted a proposed mitigation plan to ReliabilityFirst on November 19, 2010, whereby stating AMP would complete all mitigating actions on March 31, 2011. This mitigation plan, designated MIT-07-3111, was accepted by ReliabilityFirst on December 1, 2010, and approved by NERC on December 13, 2010.

II. MITIGATION PLAN COMPLETION REVIEW PROCESS On March 31, 2011, AMP certified that the mitigation plan for PRC-005-1, Requirement 2 was completed as of March 31, 2011. ReliabilityFirst requested and received evidence of completion for actions taken by AMP as specified in the mitigation plan. ReliabilityFirst performed an in-depth review of the information provided to verify that all actions specified in the mitigation plan were successfully completed.

MIT-07-3111 for Docket Number RFC201000238

A. Evidence Reviewed per Standard and Requirement.

Evidence Reviewed

Applicable Standard

and Requirement

1.

AMP Public Power Partners Memorandum from Director of Reliability Standards Compliance, dated March 25, 2011.

PRC-005-1, R2

2. American Municipal Power Protection System Maintenance and Testing Program for Protection Systems that Affect the Reliability of the Bulk Electric System (Generator Facilities) Version 2, dated November 15, 2010.

PRC-005-1, R2

3. AMP Public Power Partners Memorandum from RHGS Plant Manager to the Director of Reliability Standards Compliance, dated September 22, 2010.

PRC-001-1, R1

4. AMP Public Power Partners Memorandum from Hamilton Operations Manager to the Director of Reliability Standards Compliance, dated September 10, 2010.

PRC-001-1, R1

5. AMP Public Power Partners Memorandum from Belleville Operations and Maintenance Supervisor to the Director of Reliability Standards Compliance, dated September 10, 2010.

PRC-001-1, R1

6. Email from the Director, Reliability Standards Compliance, dated January 31, 2011.

PRC-005-1, R2

7. AMP PRC-005 Maintenance Testing Records for Hamilton during April 13 – 16, 2011 and Belleville facilties during January 24 – 27, 2011.

PRC-005-1, R2

8. Belleville Maintenance Activities on March 2, 2011. Computer/Electronics Unlimited, Industrial Electronics Sales & Service, Service Report on April 21, 2010.

PRC-005-1, R2

9. Gexpro Invoice, dated April 29, 2010. PRC-005-1, R2

10. Emerson Network Power Current Transformer Ratio Saturation Test, dated April 14, 2010.

PRC-005-1, R2

11. AMP Generation Protection System Device to Basis Table, April 8, 2011.

PRC-001-1, R1


B. Verification of Mitigation Plan Completion.

1. PRC-005-1, Requirement 2 PRC-005-1, Requirement 2 states:

R2. Each Transmission Owner and any Distribution Provider that owns a transmission Protection System and each Generator Owner that owns a generation Protection System shall provide documentation of its Protection System maintenance and testing program and the implementation of that program to its Regional Reliability Organization on request (within 30 calendar days). The documentation of the program implementation shall include:

R2.1. Evidence Protection System devices were maintained and

tested within the defined intervals. R2.2. Date each Protection System device was last

tested/maintained.

• American Municipal Power Protection System Maintenance and Testing Program for Protection Systems that Affect the Reliability of the Bulk Electric System (Generator Facilities), November 15, 2010 – Confirms that AMP modified its program to match new intervals and basis and implemented these procedural changes as needed. On April 8, 2011, AMP submitted a Generation Protection System Device to Basis Table, which specifies the basis documents related to each Protection System component.

• AMP Public Power Partners Memorandum from RHGS Plant Manager related to Relay Training and Awareness, September 10, 2010 – Provides a list of operators who reviewed all the NERC webinars related to protection and relaying found on the NERC website.

• AMP Public Power Partners Memorandum from Hamilton Operations Manager related to Relay Training and Awareness, September 10, 2010 – Attests that the operation manager has reviewed the series of video recordings that NERC posted related to relaying.

• AMP Public Power Partners Memorandum from Belleville Operations and Maintenance Supervisor related to Relay Training and Awareness, September 22, 2010 – Provides a list of operators who reviewed all the NERC webinars related to protection and relaying found on the NERC website.

• Email from the Director, Reliability Standards Compliance, January 31, 2011 – States that the NERC training was completed for the PRC-005-1 Mitigation Plan and listed the training dates, topics, and attendees.

• AMP PRC-005 Maintenance Testing Records – Lists types of device, device and work dates for Hamilton during April 13 – 16, 2011 and Belleville facilities during January 24 – 27, 2011.


• Belleville Maintenance Activities – Summarizes the maintenance and testing that was conducted on station batteries.

• Computer/Electronics Unlimited, Industrial Electronics Service Report – Provides the test record for ABB type 46Q Relay on April 21, 2010. This document, in conjunction with AMP PRC-005 Maintenance Testing Records and Belleville Maintenance Activities above, demonstrates that AMP has implemented its Protection System maintenance and testing program.

• Gexpro Invoice for Hamilton JV2 – Demonstrates that a new CT was ordered and an additional CT was added to the order due to lack of spares. Per email explanation on April 8, 2011, the Hamilton unit testing revealed a CT that was out of tolerance, but not far enough out of tolerance to cause relays to trip. Upon learning the test results, AMP performed maintenance to address the device.

• Emerson Network Power Current Transformer Ratio Saturation Test, April 29, 2010 – Demonstrates that maintenance was performed on this device at the Hamilton JV2 generation site.

III. CONCLUSION

ReliabilityFirst Corporation reviewed the evidence AMP submitted in support of its Certification of Completion. This evidence demonstrates successful completion of the mitigating activities in mitigation plan MIT-07-3111 associated with PRC-005-1, Requirement 2. ReliabilityFirst hereby verifies that the mitigation plan associated with the alleged violation of the aforementioned NERC Reliability Standard is completed in accordance with its terms and conditions. Accepted:

David J. Coyle Date: April 9, 2011 Compliance Specialist ReliabilityFirst Corporation


Approved:

Robert K. Wargo Date: April 20, 2011 Director, Enforcement & Regulatory Affairs ReliabilityFirst Corporation

Attachment f

ReliabilityFirst’s Verification of Mitigation Plan Completion for FAC-008-1 R1 dated March 7,

2011

In re: AMERICAN MUNICIPAL ) Docket No. RFC201000651 POWER, INC ) ) ) ) NERC Registry ID No. NCR00683 ) NERC Reliability Standard: ) FAC-008-1, Requirement 1 )

VERIFICATION OF MITIGATION PLAN COMPLETION

FOR MIT-07-3113

I. RELEVANT BACKGROUND American Municipal Power, Inc. (“AMP”) was subject to a compliance audit on September 13, 2010 to October 1, 2010. The Audit Team identified a possible violation with NERC Reliability Standard FAC-008-1, Requirement 1. AMP’s rating methodology did not define methods for transmission conductors, transformers, relay protective devices, and terminal equipment. AMP submitted a proposed mitigation plan to ReliabilityFirst on November 19, 2010, whereby stating AMP would complete all mitigating actions on February 19, 2011. This mitigation plan, designated MIT-07-3113, was accepted by ReliabilityFirst on December 1, 2010, and approved by NERC on December 13, 2010.

II. MITIGATION PLAN COMPLETION REVIEW PROCESS On February 24, 2011, AMP certified that the mitigation plan for FAC-008-1, Requirement 1 was completed as of February 18, 2011. ReliabilityFirst requested and received evidence of completion for actions taken by AMP as specified in the mitigation plan. ReliabilityFirst performed an in depth review of the information provided to verify that all actions specified in the mitigation plan were successfully completed. A. Evidence Reviewed per Standard and Requirement.

Evidence Reviewed

Applicable Standard

and Requirement

1. FAC-008 Documenting and Communicating Facility Rating

Methodology, Version 2 dated February 18, 2011. FAC-008-1,

R1.2


B. Verification of Mitigation Plan Completion. FAC-008-1, Requirement 1 FAC-008-1, Requirement 1 states, in pertinent part:

R1. The Transmission Owner and Generator Owner shall each document its current methodology used for developing Facility Ratings (Facility Ratings Methodology) of its solely and jointly owned Facilities. The methodology shall include all of the following:

R1.1. A statement that a Facility Rating shall equal the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility. R1.2. The method by which the Rating (of major BES equipment that comprises a Facility) is determined.

R1.2.1. The scope of equipment addressed shall include, but not be limited to, generators, transmission conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices.

*** FAC-008 Documenting and Communicating Facility Rating Methodology; Version 2, February 18, 2011 – Pages 5 through 7 list and describe AMP’s methods for rating transmission conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices. The methods include identifying ratings provided by manufacturer(s) and adjusting according to design ratings, ambient conditions, and/or operating limitations.

III. CONCLUSION

ReliabilityFirst Corporation reviewed the evidence AMP submitted in support of its Certification of Completion. This evidence demonstrates successful completion of the mitigating activities in mitigation plan MIT-07-3113 associated with FAC-008-1, Requirement 1. ReliabilityFirst hereby verifies that the mitigation plan associated with the alleged violation of the aforementioned NERC Reliability Standard is completed in accordance with its terms and conditions.


Accepted:

David J. Coyle Date: March 3, 2011 Compliance Specialist ReliabilityFirst Corporation Approved:

Robert K. Wargo Date: March 7, 2011 Director, Enforcement & Regulatory Affairs ReliabilityFirst Corporation

Attachment g

ReliabilityFirst’s Verification of Mitigation Plan Completion for FAC-009-1 R1 dated April 5, 2011

In re: AMERICAN MUNICIPAL ) Docket No. RFC201000652 POWER – OHIO, INC ) ) ) ) NERC Registry ID No. NCR00683 ) NERC Reliability Standard: ) FAC-009-1, Requirement 1 ) )

VERIFICATION OF MITIGATION PLAN COMPLETION FOR MIT-07-3114

I. RELEVANT BACKGROUND American Municipal Power, Inc (“AMP”) was subject to a compliance audit on September 13, 2010 to October 1, 2010. The ReliabilityFirst audit team identified a possible violation of FAC-009-1, Requirement 1. AMP did not provide ratings values for relay protective devices (relays and voltage and current sensing devices) and terminal equipment, or identify the most limiting element. AMP submitted a proposed mitigation plan to ReliabilityFirst on November 19, 2010, whereby stating AMP would complete all mitigating actions on March 19, 2011. This mitigation plan, designated MIT-07-3114, was accepted by ReliabilityFirst on December 1, 2010, and approved by NERC on December 13, 2010.

II. MITIGATION PLAN COMPLETION REVIEW PROCESS On March 18, 2011, AMP certified that the mitigation plan for FAC-009-1, Requirement 1, was completed as of March 18, 2011. ReliabilityFirst requested and received evidence of completion for actions taken by AMP as specified in the mitigation plan. ReliabilityFirst performed an in-depth review of the information provided to verify that all actions specified in the mitigation plan were successfully completed.


A. Evidence Reviewed per Standard and Requirement.

Evidence Reviewed

Applicable Standard

and Requirement

1.

Hamilton Facility Ratings Summary Sheet (MVA), dated March 18, 2011.

FAC-009-1, R1

2. Belleville Facility Ratings Summary Sheet (MVA), dated March 18, 2011.

FAC-009-1, R1

3. AMP Detailed Rating Sheet Per FAC-008 Rating Methodology, no date.

FAC-009-1, R1

B. Verification of Mitigation Plan Completion.

1. FAC-009-1, Requirement 1 FAC-009-1, Requirement 1 states:

R1. The Transmission Owner and Generator Owner shall each establish Facility Ratings for its solely and jointly owned Facilities that are consistent with the associated Facility Ratings Methodology.

• Hamilton Facility Ratings Summary Sheet (MVA), dated March 18, 2011 -

Illustrates MVA ratings for terminal equipment, relay protective devices, transformers, substation bus, transmission conductors, generator, and facility rating (limiting element).

• Belleville Facility Ratings Summary Sheet (MVA), dated March 18, 2011 - Illustrates MVA ratings for terminal equipment, relay protective devices, transformers, substation bus, transmission conductors, generator, and facility rating (limiting element).

• AMP Detailed Rating Sheet Per FAC-008 Rating Methodology, no date – Lists summer and winter ratings for the scope of equipment described in R1.2.1 for Hamilton and Belleville units. Ratings include the considerations described in R1.3. The limiting elements and ratings are also shown on this rating sheet.


III. CONCLUSION

ReliabilityFirst Corporation reviewed the evidence AMP submitted in support of its Certification of Completion. This evidence demonstrates successful completion of the mitigating activities in mitigation plan MIT-07-3114 associated with FAC-009-1, Requirement 1. ReliabilityFirst hereby verifies that the mitigation plan associated with the alleged violation of the aforementioned NERC Reliability Standard is completed in accordance with its terms and conditions. Accepted:

David J. Coyle Date: March 25, 2011 Compliance Specialist ReliabilityFirst Corporation Approved:

Robert K. Wargo Date: April 5, 2011 Director, Enforcement & Regulatory Affairs ReliabilityFirst Corporation

Attachment h

Common Disposition Document

Attachment h

American Municipal Power Inc. Page 1 of 5

DISPOSITION OF VIOLATION1

INFORMATION COMMON TO INSTANT VIOLATIONS

Dated March 11, 2011

REGISTERED ENTITY NERC REGISTRY ID NOC# American Municipal Power Inc. (AMP)

NCR006832 NOC-760

REGIONAL ENTITY ReliabilityFirst Corporation (ReliabilityFirst)

I. REGISTRATION INFORMATION

ENTITY IS REGISTERED FOR THE FOLLOWING FUNCTIONS (BOTTOM ROW INDICATES REGISTRATION DATE):

BA DP GO GOP IA LSE PA PSE RC RP RSG TO TOP TP TSP X X X X X

5/30

/07

5/30

/07

5/30

/07

5/30

/07

5/30

/07

DESCRIPTION OF THE REGISTERED ENTITY AMP is a nonprofit Ohio corporation organized in 1971. The members of AMP are all municipalities that own and operate electric utility systems. AMP is either a full or partial requirements supplier of electric energy for certain of its members. AMP's primary purpose is to assist its member communities in meeting their electric and energy needs. This purpose is served in a number of ways, including through the ownership of electric generating facilities, scheduling and dispatch of member-owned generation, and through power supply and transmission arrangements with third parties. AMP serves 128 public power member communities: 82 in Ohio, 30 in Pennsylvania, six in Michigan, five in Virginia, three in Kentucky, and two in West Virginia. These member communities serve more than 570,000 customers.

IS THERE A SETTLEMENT AGREEMENT YES NO

1 For purposes of this document and attachments hereto, each violation at issue is described as a “violation,” regardless of its procedural posture and whether it was a possible, alleged or confirmed violation. 2 In the SERC Reliability Corporation region, AMP is also included on the NERC Compliance Registry (NCR) List for the LSE function as of February 16, 2010, under the same NCR ID NCR00683. In addition, AMP is included on the Coordinated Functional Registration (CFR) List for this function as of August 27, 2010 under CFR ID# JRO00084.

Attachment h


WITH RESPECT TO THE VIOLATION(S), REGISTERED ENTITY

NEITHER ADMITS NOR DENIES IT (SETTLEMENT ONLY) YES ADMITS TO IT YES DOES NOT CONTEST IT (INCLUDING WITHIN 30 DAYS) YES WITH RESPECT TO THE ASSESSED PENALTY OR SANCTION, REGISTERED ENTITY ACCEPTS IT/ DOES NOT CONTEST IT YES

II. PENALTY INFORMATION

TOTAL ASSESSED PENALTY OR SANCTION OF $25,000 FOR THREE VIOLATIONS OF RELIABILITY STANDARDS. (1) REGISTERED ENTITY’S COMPLIANCE HISTORY

PREVIOUSLY FILED VIOLATIONS OF ANY OF THE INSTANT RELIABILITY STANDARD(S) OR REQUIREMENT(S) THEREUNDER YES NO LIST VIOLATIONS AND STATUS

ADDITIONAL COMMENTS

PREVIOUSLY FILED VIOLATIONS OF OTHER RELIABILITY STANDARD(S) OR REQUIREMENTS THEREUNDER YES NO

LIST VIOLATIONS AND STATUS

ADDITIONAL COMMENTS

(2) THE DEGREE AND QUALITY OF COOPERATION BY THE REGISTERED ENTITY (IF THE RESPONSE TO FULL COOPERATION IS “NO,” THE ABBREVIATED NOP FORM MAY NOT BE USED.) FULL COOPERATION YES NO

IF NO, EXPLAIN

Attachment h


(3) THE PRESENCE AND QUALITY OF THE REGISTERED ENTITY’S COMPLIANCE PROGRAM IS THERE A DOCUMENTED COMPLIANCE PROGRAM

YES NO UNDETERMINED EXPLAIN

During an off-site audit concluding September 30 2010, ReliabilityFirst reviewed AMP’s internal compliance program (ICP), in effect at the time of the violations. ReliabilityFirst considered certain aspects of AMP’s ICP as mitigating factors, as discussed below including the role that AMP’s senior management plays in its compliance program, the independence of AMP’s compliance department, and the preventative nature of AMP’s ICP. AMP's ICP contains measures to detect and prevent compliance issues, including violations of Reliability Standards. Examples of these measures include performance of an annual internal compliance review, employee training in areas covered by the Reliability Standards, and the dedication of one full-time employee to the administration of AMP's Reliability Standards compliance activities. AMP operations personnel and supervisors responsible for substantive compliance with the Reliability Standards are also actively involved in developing policies and procedures to document compliance with applicable Reliability Standards.

EXPLAIN SENIOR MANAGEMENT’S ROLE AND INVOLVEMENT WITH RESPECT TO THE REGISTERED ENTITY’S COMPLIANCE PROGRAM, INCLUDING WHETHER SENIOR MANAGEMENT TAKES ACTIONS THAT SUPPORT THE COMPLIANCE PROGRAM, SUCH AS TRAINING, COMPLIANCE AS A FACTOR IN EMPLOYEE EVALUATIONS, OR OTHERWISE. AMP senior management is actively involved in AMP's compliance activities. Specifically, the individuals responsible for day-to-day oversight of compliance activities at AMP include the Vice President of Risk Control and the Director of Reliability Standards Compliance, who regularly brief AMP's Chief Executive Officer and Board of Trustees regarding compliance matters. AMP's Vice President of Risk Control has direct access and regularly reports to AMP's Chief Executive Officer and Board of Trustees, and AMP's Director of Reliability Standards Compliance has access to AMP's Board of Trustees.

AMP's ICP is managed independently from departments within AMP that are assigned responsibility for substantive compliance with Reliability Standards. AMP's Director of Reliability Standards

Attachment h


Compliance has no involvement with AMP's generation, marketing, operations, planning, and/or regulatory departments from a compliance perspective except for activities related to administration of AMP's ICP. AMP's Director of Reliability Standards Compliance reports directly to AMP's Vice President of Risk Control who, as discussed above, has direct access and reports to AMP's Chief Executive Officer and Board of Trustees.

(4) ANY ATTEMPT BY THE REGISTERED ENTITY TO CONCEAL THE VIOLATION(S) OR INFORMATION NEEDED TO REVIEW, EVALUATE OR INVESTIGATE THE VIOLATION.

YES NO IF YES, EXPLAIN (5) ANY EVIDENCE THE VIOLATION(S) WERE INTENTIONAL (IF THE RESPONSE IS “YES,” THE ABBREVIATED NOP FORM MAY NOT BE USED.)

YES NO IF YES, EXPLAIN (6) ANY OTHER MITIGATING FACTORS FOR CONSIDERATION

YES NO IF YES, EXPLAIN

(7) ANY OTHER AGGRAVATING FACTORS FOR CONSIDERATION

YES NO IF YES, EXPLAIN (8) ANY OTHER EXTENUATING CIRCUMSTANCES

YES NO IF YES, EXPLAIN

Attachment h


OTHER RELEVANT INFORMATION: NOTICE OF ALLEGED VIOLATION AND PROPOSED PENALTY OR SANCTION ISSUED DATE: OR N/A SETTLEMENT DISCUSSIONS COMMENCED DATE: 11/30/10 OR N/A NOTICE OF CONFIRMED VIOLATION ISSUED DATE: OR N/A SUPPLEMENTAL RECORD INFORMATION DATE(S) OR N/A REGISTERED ENTITY RESPONSE CONTESTED FINDINGS PENALTY BOTH DID NOT CONTEST HEARING REQUESTED YES NO DATE OUTCOME APPEAL REQUESTED

Disposition Document for PRC-005-1 R2

Attachment h-1


DISPOSITION OF VIOLATION Dated March 11, 2011

NERC TRACKING NO.

REGIONAL ENTITY TRACKING NO.

RFC201000238 RFC201000238

I. VIOLATION INFORMATION RELIABILITY STANDARD

REQUIREMENT(S) SUB-REQUIREMENT(S)

VRF(S) VSL(S)

PRC-005-1 2 High1 Severe 2

VIOLATION APPLIES TO THE FOLLOWING FUNCTIONS: BA DP GO GOP IA LSE PA PSE RC RP RSG TO TOP TP TSP

X PURPOSE OF THE RELIABILITY STANDARD AND TEXT OF RELIABILITY STANDARD AND REQUIREMENT(S)/SUB-REQUIREMENT(S) The purpose statement of PRC-005-1 provides: “To ensure all transmission and generation Protection Systems[3

] affecting the reliability of the Bulk Electric System (BES) are maintained and tested.”

PRC-005-1 R2 provides:

R2. Each Transmission Owner and any Distribution Provider that owns a transmission Protection System and each Generator Owner that owns a generation Protection System shall provide documentation of its Protection System maintenance and testing program and the implementation of that program to its Regional Reliability Organization[4

1 PRC-005-1 R2 has a “Lower” Violation Risk Factor (VRF); R2.1 and R2.2 each have a “High” VRF. During a final review of the standards subsequent to the March 23, 2007 filing of the Version 1 VRFs, NERC identified that some standards requirements were missing VRFs; one of these include PRC-005-1 R2.1. On May 4, 2007, NERC assigned PRC-005 R2.1 a “High” VRF. In the Commission’s June 26, 2007 Order on Violation Risk Factors, the Commission approved the PRC-005-1 R2.1 “High” VRF as filed. Therefore, the “High” VRF was in effect from June 26, 2007. In the context of this case, ReliabilityFirst determined that the violation related to both R2.1 and R2.2, and therefore a “High” VRF is appropriate.

] on request (within 30 calendar days). The documentation of the program implementation shall include:

2 The Self-Report states that the violation has a “Lower” Violation Severity Level. 3 The NERC Glossary of Terms Used in Reliability Standards defines Protection System as “Protective relays, associated communication systems, voltage and current sensing devices, station batteries and DC control circuitry.” 4 Consistent with applicable FERC precedent, the term ‘Regional Reliability Organization’ in this context refers to ReliabilityFirst.

Attachment h-1


R2.1. Evidence Protection System devices were maintained and tested within the defined intervals.

R2.2. Date each Protection System device was last tested/maintained.

(Footnotes added.) VIOLATION DESCRIPTION On January 18, 2010, AMP submitted a Self-Report to ReliabilityFirst concerning a violation of PRC-005-1 R2 because it determined that, although AMP was testing and maintaining its generator Protection Systems, it was not performing such testing and maintenance in accordance with the intervals specified in its Protection System maintenance and testing program. AMP's compliance program incorporates by reference the testing and maintenance intervals and procedures in the American National Standard Institute, International Electrical Testing Association Standard for Maintenance Testing Specifications for Electrical Power Distribution Equipment and Systems (the NETA Manual). The NETA Manual establishes varying testing and maintenance intervals for different testing and maintenance activities depending upon the type of Protection System equipment being tested and/or maintained. The NETA Manual specified visual inspections as often as once per month. Although AMP performed visual inspections in connection with its testing and maintenance activities and during rounds, such inspections were not documented according to the intervals specified in the AMP Program. ReliabilityFirst determined that AMP lacked maintenance and testing records for 15 out of its estimated 175 (8.6%) Protection System devices. AMP did not maintain documentation establishing that these 15 devices were maintained and tested within their defined intervals and did not maintain documentation establishing the date that these 15 devices were last tested and maintained. AMP did test and maintain 160 of its estimated 175 Protection System devices (91.4% of the total devices) within the past four years and provided documentation of those testing and maintenance activities and the dates that the devices were last tested and maintained. Nevertheless, the testing and maintenance intervals reflected in AMP's documentation did not conform to the testing and maintenance intervals specified in the NETA Manual. In addition, AMP did not document that it performed visual inspections of these devices, despite its claim that these inspections were performed. RELIABILITY IMPACT STATEMENT- POTENTIAL AND ACTUAL ReliabilityFirst determined that the violation posed a minimal risk and did not pose a serious or substantial risk to the reliability of the bulk power system (BPS)

Attachment h-1


because only 15 (8.6%) out of AMP’s estimated 175 Protection System devices, including relays, station batteries, CTs and PTs, and DC control circuitry at three of AMP’s facilities, were not tested or maintained within the past four years. Although AMP did not strictly comport with the intervals specified in its testing and maintenance program, AMP was performing Protection System testing and maintenance activities at intervals that are consistent with typical industry practice. For example, the NETA Manual specifies a one-year testing interval for mechanical and electrical testing compared to the industry standard range of three-year to six-year intervals. AMP provided documentation demonstrating that testing and maintenance was performed, both before and during the violation, on all Protection System devices, and that all Protection Systems devices were functioning properly. Additionally, AMP asserted that it also performed visual inspections on the 15 Protection Systems devices that were not tested or maintained. During these visual inspections, AMP identified no issues or problems with the devices.

II. DISCOVERY INFORMATION METHOD OF DISCOVERY

SELF-REPORT SELF-CERTIFICATION COMPLIANCE AUDIT COMPLIANCE VIOLATION INVESTIGATION SPOT CHECK COMPLAINT PERIODIC DATA SUBMITTAL EXCEPTION REPORTING

DURATION DATE(S) 6/18/07 (when the Standard became mandatory and enforceable) through 3/31/11 (Mitigation Plan completion) DATE DISCOVERED BY OR REPORTED TO REGIONAL ENTITY 1/18/10 IS THE VIOLATION STILL OCCURRING YES NO IF YES, EXPLAIN

REMEDIAL ACTION DIRECTIVE ISSUED YES NO PRE TO POST JUNE 18, 2007 VIOLATION YES NO

Attachment h-1


III. MITIGATION INFORMATION FOR FINAL ACCEPTED MITIGATION PLAN:

MITIGATION PLAN NO. MIT-07-3111 DATE SUBMITTED TO REGIONAL ENTITY 11/19/10 DATE ACCEPTED BY REGIONAL ENTITY 12/1/105

DATE APPROVED BY NERC 12/13/10

DATE PROVIDED TO FERC 12/14/10 IDENTIFY AND EXPLAIN ALL PRIOR VERSIONS THAT WERE ACCEPTED OR REJECTED, IF APPLICABLE N/A MITIGATION PLAN COMPLETED YES NO

EXPECTED COMPLETION DATE 3/31/11 EXTENSIONS GRANTED N/A

ACTUAL COMPLETION DATE 3/31/11

DATE OF CERTIFICATION LETTER 3/31/11 CERTIFIED COMPLETE BY REGISTERED ENTITY AS OF 3/31/11

DATE OF VERIFICATION LETTER 4/20/11

VERIFIED COMPLETE BY REGIONAL ENTITY AS OF 3/31/11

ACTIONS TAKEN TO MITIGATE THE ISSUE AND PREVENT RECURRENCE • AMP will verify documentation of prior testing and maintenance

activities. This action was completed on April 2, 2010.

• AMP will evaluate testing and maintenance intervals and procedures, and develop basis for new intervals. This action was completed on September 13, 2010.

• AMP will revise its Protection System maintenance and testing program

to match new maintenance and testing intervals, as well as their basis, and will implement related procedural revisions as needed. This action was completed on December 1, 2010.

• AMP will verify that Protection System equipment has been tested and

maintained. This action was completed on April 2, 2010.

5 The Settlement Agreement incorrectly states that ReliabilityFirst accepted AMP’s Mitigation Plan on December 3, 2010; the correct date was December 1, 2010.

Attachment h-1


• AMP will perform additional testing/maintenance as needed. This action is estimated to be completed on February 19, 2011.

• AMP will provide personnel with additional training on AMP’s revised

Protection Systems maintenance and testing program. This action was completed on February 1, 2011.

LIST OF EVIDENCE REVIEWED BY REGIONAL ENTITY TO EVALUATE COMPLETION OF MITIGATION PLAN OR MILESTONES (FOR CASES IN WHICH MITIGATION IS NOT YET COMPLETED, LIST EVIDENCE REVIEWED FOR COMPLETED MILESTONES)

• American Municipal Power Protection System Maintenance and Testing Program for Protection Systems that Affect the Reliability of the Bulk Electric System (Generator Facilities), November 15, 2010 – Confirms that AMP modified its program to match new intervals and basis and implemented these procedural changes as needed.

• Generation Protection System Device to Basis Table, which specifies the basis documents related to each Protection System component.

• AMP Public Power Partners Memorandum from RHGS Plant Manager related to Relay Training and Awareness, September 10, 2010 – Provides a list of operators who reviewed all the NERC webinars related to protection and relaying found on the NERC website.

• AMP Public Power Partners Memorandum from Hamilton Operations Manager related to Relay Training and Awareness, September 10, 2010 – Attests that the operation manager has reviewed the series of video recordings that NERC posted related to relaying.

• AMP Public Power Partners Memorandum from Belleville Operations and Maintenance Supervisor related to Relay Training and Awareness, September 22, 2010 – Provides a list of operators who reviewed all the NERC webinars related to protection and relaying found on the NERC website.

• Email from the Director, Reliability Standards Compliance, January 31, 2011 –States that the NERC training was completed for the PRC-005-1 Mitigation Plan and listed the training dates, topics, and attendees.

• AMP PRC-005 Maintenance Testing Records – Lists types of device, device and work dates for Hamilton during April 13, 2011 through April 16, 2011 and Belleville facilities during January 24, 2011 through January 27, 2011.

• Belleville Maintenance Activities – Summarizes the maintenance and testing that was conducted on station batteries.

• Computer/Electronics Unlimited, Industrial Electronics Service Report – Provides the test record for ABB type 46Q Relay on April 21, 2010. This document, in conjunction with AMP PRC-005 Maintenance Testing Records and Belleville Maintenance Activities above, demonstrates that AMP has implemented its Protection System maintenance and testing program.

• Gexpro Invoice for Hamilton JV2 – Demonstrates that a new CT was ordered and an additional CT was added to the order due to lack of spares. Per e-mail explanation on April 8, 2011, the Hamilton unit testing revealed a CT

Attachment h-1


that was out of tolerance, but not far enough out of tolerance to cause relays to trip. Upon learning the test results, AMP performed maintenance to address the device.

• Emerson Network Power Current Transformer Ratio Saturation Test, April 29, 2010 – Demonstrates that maintenance was performed on this device at the Hamilton JV2 generation site.

EXHIBITS:

SOURCE DOCUMENT AMP’s Self-Report for PRC-005-1 R2 submitted January 18, 2010 MITIGATION PLAN AMP’s Mitigation Plan MIT-07-3111 submitted November 19, 2010 CERTIFICATION BY REGISTERED ENTITY

AMP’s Certification of Mitigation Plan Completion dated March 31, 2011

VERIFICATION BY REGIONAL ENTITY ReliabilityFirst’s Verification of Mitigation Plan Completion dated April 20, 2011

Disposition Document for FAC-008-1 R1 and FAC-009-1 R1

Attachment h-2


DISPOSITION OF VIOLATION Dated March 11, 2011

NERC TRACKING NO.

REGIONAL ENTITY TRACKING NO.

RFC201000651 RFC201000652

RFC201000651 RFC201000652

I. VIOLATION INFORMATION

RELIABILITY STANDARD

REQUIREMENT(S) SUB-REQUIREMENT(S)

VRF(S) VSL(S)

FAC-008-1 1 1.2, 1.2.1 Medium1 Severe FAC-009-1 1 Medium High

VIOLATION APPLIES TO THE FOLLOWING FUNCTIONS: BA DP GO GOP IA LSE PA PSE RC RP RSG TO TOP TP TSP

X PURPOSE OF THE RELIABILITY STANDARD AND TEXT OF RELIABILITY STANDARD AND REQUIREMENT(S)/SUB-REQUIREMENT(S) The purpose statement of FAC-008-1 and FAC-009-1 provides: “To ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on an established methodology or methodologies.” FAC-008-1 R1 provides in pertinent part:

R1. The Transmission Owner and Generator Owner shall each document its current methodology used for developing Facility Ratings (Facility Ratings Methodology) of its solely and jointly owned Facilities. The methodology shall include all of the following:

R1.2. The method by which the Rating (of major BES equipment

that comprises a Facility) is determined.

R1.2.1. The scope of equipment addressed shall include, but not be limited to, generators, transmission

1 FAC-008-1 R1, R1.3 and R1.3.5 each have a “Lower” VRF; R1.1, R1.2, R1.2.1, R1.2.2, R1.3.1-4 each have a “Medium” VRF. When NERC filed VRFs it originally assigned FAC-008-1 R1.1, R1.2, R1.2.1 and R1.2.2 “Lower” VRFs. The Commission approved the VRFs as filed; however, it directed NERC to submit modifications. NERC submitted the modified “Medium” VRFs and on February 6, 2008, the Commission approved the modified “Medium” VRFs. Therefore, the “Lower” VRFs for FAC-008-1 R1.1, R1.2, R1.2.1 and R1.2.2 were in effect from June 18, 2007 until February 6, 2008 when the “Medium” VRFs became effective.

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conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices.

FAC-009-1 R1 provides: “The Transmission Owner and Generator Owner shall each establish Facility Ratings for its solely and jointly owned Facilities that are consistent with the associated Facility Ratings Methodology.” VIOLATION DESCRIPTION FAC-008-1 R1/1.2.1 (RFC201000651) During a compliance audit conducted by ReliabilityFirst from September 10, 2010 through September 30, 2010 (Audit), ReliabilityFirst determined that, although the scope of AMP's Facility Ratings Methodology was defined to include generators, transmission conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices, the documentation did not specify which rating method (name plate, manufacturer’s rating, etc.) would apply to define the actual rating of each of the transmission conductors, transformers, relay protective devices and terminal equipment. FAC-009-1 R1 (RFC201000652) During the Audit, AMP provided ReliabilityFirst with three tables of data intended to serve as the requisite Facility Ratings documentation. ReliabilityFirst determined that the tables did not identify the basis of the ratings for AMP’s solely and jointly owned terminal equipment and relay protective devices (including relays and voltage and current sensing devices) and did not identify the most limiting element. RELIABILITY IMPACT STATEMENT- POTENTIAL AND ACTUAL ReliabilityFirst determined that the violations posed a minimal risk and did not pose a serious or substantial risk to the reliability of the bulk power system (BPS) because:

a. FAC-008-1 R1 (RFC201000651): AMP facilities were operating with partially-established Facility Ratings, and AMP also identified the most limiting element in its methodology as the most limiting applicable Equipment Rating of the individual equipment that comprises the Facility. Additionally, once AMP completes its Mitigation Plan and adequately documents its methodology, the equipment that constitutes thes most limiting element will not change.

b. FAC-009-1 R1 (RFC201000652): AMP did provide Ratings for generators, transformers, transmission conductors and substation buses, and AMP

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operated with the knowledge of the identity of the most limiting element as defined in its methodology.

II. DISCOVERY INFORMATION METHOD OF DISCOVERY

SELF-REPORT SELF-CERTIFICATION COMPLIANCE AUDIT COMPLIANCE VIOLATION INVESTIGATION SPOT CHECK COMPLAINT PERIODIC DATA SUBMITTAL EXCEPTION REPORTING

DURATION DATE(S)2

FAC-008-1 R1 (RFC201000651): 6/18/07 (when the Standard became mandatory and enforceable) through 2/18/11 (estimated Mitigation Plan completion)

FAC-009-1 R1 (RFC201000652): 6/18/07 (when the Standard became mandatory and enforceable) through 3/18/11 (estimated Mitigation Plan completion) DATE DISCOVERED BY OR REPORTED TO REGIONAL ENTITY 10/1/10 IS THE VIOLATION STILL OCCURRING YES NO IF YES, EXPLAIN

REMEDIAL ACTION DIRECTIVE ISSUED YES NO PRE TO POST JUNE 18, 2007 VIOLATION YES NO

III. MITIGATION INFORMATION FOR FINAL ACCEPTED MITIGATION PLAN:

MITIGATION PLAN NO. FAC-008-1 R1 (RFC201000651): MIT-07-3113 FAC-009-1 R1 (RFC201000652): MIT-07-3114 DATE SUBMITTED TO REGIONAL ENTITY 11/19/10 DATE ACCEPTED BY REGIONAL ENTITY 12/1/103

DATE APPROVED BY NERC 12/13/10

DATE PROVIDED TO FERC 12/14/10

2 The Summary for Possible Violation document for both the FAC-008-1 R1 and FAC-000-1 R1 violations state that the violation began on June 17, 2007. 3 The Settlement Agreement incorrectly states that ReliabilityFirst accepted AMP’s Mitigation Plan on December 3, 2010; the correct date was December 1, 2010.

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IDENTIFY AND EXPLAIN ALL PRIOR VERSIONS THAT WERE ACCEPTED OR REJECTED, IF APPLICABLE N/A MITIGATION PLAN COMPLETED YES NO

EXPECTED COMPLETION DATE FAC-008-1 R1 (RFC201000651): 2/19/11 FAC-009-1 R1 (RFC201000652): 3/19/11

R1 EXTENSIONS GRANTED N/A ACTUAL COMPLETION DATE 2/18/11 R2 EXTENSIONS GRANTED N/A ACTUAL COMPLETION DATE 3/18/11

R1 DATE OF CERTIFICATION LETTER 2/24/11 CERTIFIED COMPLETE BY REGISTERED ENTITY AS OF 2/18/11 R2 DATE OF CERTIFICATION LETTER 3/18/11 CERTIFIED COMPLETE BY REGISTERED ENTITY AS OF 3/18/11

R1 DATE OF VERIFICATION LETTER 3/7/11 (R1)

VERIFIED COMPLETE BY REGIONAL ENTITY AS OF 2/18/11 (R1)

R2 DATE OF VERIFICATION LETTER 4/5/11 (R2)

VERIFIED COMPLETE BY REGIONAL ENTITY AS OF 3/18/11 (R2) ACTIONS TAKEN TO MITIGATE THE ISSUE AND PREVENT RECURRENCE FAC-008-1 R1 (RFC201000651)

• AMP will modify its existing Facility Ratings Methodology to address the deficiencies identified during the Audit, including to clearly correlate AMP's methodology with the specific devices included in the Ratings. Specifically, AMP will modify its methodology to more clearly document how AMP establishes Ratings for transmission conductors, transformers, relay protective devices and terminal equipment.

• FAC-009-1 R1 (RFC201000652)

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• AMP will modify the documentation of its Facility Ratings to address the deficiencies identified during the Audit, including clearly documenting its Ratings for relay protective devices and terminal equipment and specifying the most limiting applicable rating of the individual equipment that comprises a Facility.

LIST OF EVIDENCE REVIEWED BY REGIONAL ENTITY TO EVALUATE COMPLETION OF MITIGATION PLAN OR MILESTONES (FOR CASES IN WHICH MITIGATION IS NOT YET COMPLETED, LIST EVIDENCE REVIEWED FOR COMPLETED MILESTONES) FAC-008-1 R1:

• FAC-008 Documenting and Communicating Facility Rating Methodology; Version 2, February 18, 2011 – Pages 5 through 7 list and describe AMP’s methods for rating transmission conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices. The methods include identifying ratings provided by manufacturer(s) and adjusting according to design ratings, ambient conditions, and/or operating limitations. FAC-009-1 R1:

• Hamilton Facility Ratings Summary Sheet (MVA), dated March 18, 2011 -Illustrates MVA ratings for terminal equipment, relay protective devices, transformers, substation bus, transmission conductors, generator, and facility rating (limiting element).

• Belleville Facility Ratings Summary Sheet (MVA), dated March 18, 2011 - Illustrates MVA ratings for terminal equipment, relay protective devices, transformers, substation bus, transmission conductors, generator, and facility rating (limiting element).

• AMP Detailed Rating Sheet Per FAC-008 Rating Methodology, no date – Lists summer and winter ratings for the scope of equipment described in R1.2.1 for Hamilton and Belleville units. Ratings include the considerations described in R1.3. The limiting elements and ratings are also shown on this rating sheet.

EXHIBITS:

SOURCE DOCUMENT ReliabilityFirst’s Summary for Possible Violation for FAC-008-1 R1 dated October 1, 2010 ReliabilityFirst’s Summary for Possible Violation for FAC-009-1 R1 dated October 1, 2010 MITIGATION PLAN AMP’s Mitigation Plan MIT-07-3113 for FAC-008-1 R1 submitted November 19, 2010

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AMP’s Mitigation Plan MIT-07-3114 for FAC-009-1 R1 submitted November 19, 2010 CERTIFICATION BY REGISTERED ENTITY AMP’s Certification of Mitigation Plan Completion for FAC-008-1 dated February 24, 2011 AMP’s Certification of Mitigation Plan Completion for FAC-009-1 dated March 18, 2011

VERIFICATION BY REGIONAL ENTITY Reliability First’s Verification of Mitigation Plan Completion for FAC-008-1 dated March 7, 2011 Reliability First’s Verification of Mitigation Plan Completion for FAC-009-1 dated April 5, 2011

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Notice of Filing

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

American Municipal Power Inc. Docket No. NP11-___-000

NOTICE OF FILING April 29, 2011

Take notice that on April 29, 2011, the North American Electric Reliability

Corporation (NERC) filed a Notice of Penalty regarding American Municipal Power Inc. in the ReliabilityFirst Corporation region.

Any person desiring to intervene or to protest this filing must file in accordance with Rules 211 and 214 of the Commission’s Rules of Practice and Procedure (18 CFR 385.211, 385.214). Protests will be considered by the Commission in determining the appropriate action to be taken, but will not serve to make protestants parties to the proceeding. Any person wishing to become a party must file a notice of intervention or motion to intervene, as appropriate. Such notices, motions, or protests must be filed on or before the comment date. On or before the comment date, it is not necessary to serve motions to intervene or protests on persons other than the Applicant.

The Commission encourages electronic submission of protests and interventions

in lieu of paper using the “eFiling” link at http://www.ferc.gov. Persons unable to file electronically should submit an original and 14 copies of the protest or intervention to the Federal Energy Regulatory Commission, 888 First Street, N.E., Washington, D.C. 20426.

This filing is accessible on-line at http://www.ferc.gov, using the “eLibrary” link and is available for review in the Commission’s Public Reference Room in Washington, D.C. There is an “eSubscription” link on the web site that enables subscribers to receive email notification when a document is added to a subscribed docket(s). For assistance with any FERC Online service, please email [email protected], or call (866) 208-3676 (toll free). For TTY, call (202) 502-8659. Comment Date: [BLANK]

Kimberly D. Bose, Secretary