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November 5, 2010 Ms. Kimberly Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re: NERC Notice of Penalty regarding Georgia Power Company

FERC Docket No. NP11-_-000 Dear Ms. Bose: The North American Electric Reliability Corporation (NERC) hereby provides this Notice of Penalty1

regarding Georgia Power Company (Georgia Power),2 NERC Registry ID# NCR01247,3

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)).4

On November 7, 2008, Georgia Power submitted a response to a SERC Reliability Corporation (SERC) spot check in which it reported a violation5

1 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).

of PRC-005-1 Requirement (R) 2 for its failure to have documentation of testing for several of its batteries at 31 of its generating facilities. On December 2, 2008, Georgia Power self-reported another violation of PRC-005-1 R2 to SERC for Georgia Power’s failure to test a newly installed Current Transformer (CT)

2 On September 25, 2009, NERC filed a Notice of Penalty at FERC regarding Georgia Power Company’s violation of FAC-003-1 R2, which was designated as Docket No. NP09-40-000. FERC issued a Notice stating it would not further review that Notice of Penalty on October 23, 2009. 3 SERC Reliability Corporation confirmed that Georgia Power was included on the NERC Compliance Registry as a Distribution Provider, Generator Owner, Load Serving Entity and Transmission Owner on May 31, 2007. As a Distribution Provider, Generator Owner and Transmission Owner, Georgia Power is subject to the requirements of NERC Reliability Standard PRC-005-1. The violations herein pertain to Georgia Power’s registration as a Generator Owner. Subsequent to the identification of the issues of Georgia Power Company, its affiliates also identified possible violations. Those were previously filed in Docket Nos. NP10-35-000 (Southern Power Company), NP10-34-000 (Alabama Power Company), NP10-33-000 (Mississippi Power Company) and NP10-32-00 (Gulf Power Company). The issues discussed in this Notice of Penalty preceded those discussed in the other Notices of Penalty and initiated the review at the affiliates’ facilities. 4 See 18 C.F.R § 39.7(c)(2). 5 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.

NERC Notice of Penalty Georgia Power Company November 5, 2010

during initial start-up of a newly installed Generator Step-Up (GSU) transformer at its Hatch Nuclear Power Station in accordance with its maintenance and testing program. On April 14, 2009, Georgia Power self-reported another violation of PRC-005-1 R2 to SERC for Georgia Power’s failure to perform required functional testing upon installation of new CTs at its Vogtle Nuclear Power Station in accordance with the maintenance and testing program.6

This Notice of Penalty is being filed with the Commission because SERC and Georgia Power have entered into a Settlement Agreement to resolve all outstanding issues arising from a preliminary and non-public assessment resulting in SERC’s determination and findings of the enforceable violations of PRC-005-1 R2. According to the Settlement Agreement, Georgia Power neither admits nor denies the violations, but has agreed to the proposed penalty of thirty thousand dollars ($30,000) to be assessed to Georgia Power, 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 Identification Numbers SERC200800245, SERC200800240 and SERC200900259 are being filed in accordance with the NERC Rules of Procedure and the CMEP.

Statement of Findings Underlying the Violations This Notice of Penalty incorporates the findings and justifications set forth in the Settlement Agreement executed on October 27, 2009, by and between SERC and Georgia Power, which is included as Attachment d. The details of the findings and basis for the penalty are set forth in the Settlement Agreement and herein. This Notice of Penalty 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 (2007), NERC provides the following summary table identifying each violation of a Reliability Standard resolved by the Settlement Agreement, as discussed in greater detail below.

Region Registered

Entity NOC ID NERC Violation

ID Reliability

Std. Req. (R) VRF

Total Penalty

($)

SERC Georgia Power NOC-410 SERC200800245 PRC-005-1 2 High7

30,000

SERC200800240 PRC-005-1 2 High8

6 The Settlement Agreement, paragraphs 5 and 6, discusses three pre-June 18, 2007 violations of PRC-005-1 R2. These violations are informational regarding the history of Georgia Power’s compliance with PRC-005-1, but were prior to the date the Reliability Standards became enforceable, so were not considered as prior violations for the purpose of this Notice of Penalty.

7 During a final review of the standards subsequent to the March 23, 2007 filing of the Version 1 Violation Risk Factors (VRFs), NERC identified that some standards requirements were missing VRFs. One of these was PRC-005-1 R2.1. On May 4, 2007, NERC assigned PRC-005-1 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. PRC-005-1 R2 has a “Lower” VRF and its sub-requirements have “High” VRFs. According to the Settlement Agreement, SERC determined that the VRF for each of the instant violations was “High.” 8 Id.


SERC200900259 PRC-005-1 2 High9

PRC-005-1 The purpose of Reliability Standard PRC-005-1 is to ensure all transmission and generation Protection Systems10

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

PRC-005-1 R2 requires “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 and (R2.2) the date each Protection System device was last tested/maintained. PRC-005-1 R2 has a “Lower” Violation Risk Factor (VRF) and its sub-requirements each have a “High” VRF.

First Violation On October 8, 2008, SERC provided notice that it would be conducting a spot check of Georgia Power’s compliance with PRC-005-1. On November 7, 2008,11 Georgia Power submitted its response to the SERC spot check and reported that it discovered a lack of documentation for the monthly inspection of batteries that had been conducted. Georgia Power’s Protection System maintenance and testing program12

9 Id.

for its Protection System devices requires that station batteries be inspected on a monthly basis. For the seventeen-month period covered by the spot check (June 2007 through October 2008), records were missing for 373 of the 1,386 monthly intervals affecting 48 of the 82 batteries at 31 of Georgia Power’s generating facilities. Thirty four (34) batteries at the affected plants had documentation for all intervals and all batteries at Georgia Power’s other six generating facilities had documentation for all intervals. Due to this lack of documentation, Georgia Power could not confirm whether the station batteries at these plants were inspected within the time intervals established by Georgia Power pursuant to NERC Reliability Standard PRC-005-1 R1. Following the discovery of this lack of evidence, Georgia Power immediately began an investigation into the lack of documentation for these battery inspection activities.

10 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.” 11 SERC provided a Spot Check Screening Worksheet dated December 31, 2008 as the source document, which is when the alleged violation was entered into SERC’s database. 12 Georgia Power uses Southern Company’s program as its maintenance and testing program. The program includes the intervals and basis for monthly battery maintenance. SERC reviewed several revisions of this program including version 4, in effect from June 18, 2007 to May 16, 2008; version 7, in effect from August 26, 2008 to February 3, 2009 (during the spot check), and version 11, effective from June 15, 2009 to present. All versions reviewed state that the battery maintenance interval is monthly. The basis for that interval was in another document for version 4 and version 7, but is included in the most recent version.


Second Violation On December 2, 2008, Georgia Power self-reported13

to SERC a violation of PRC-005-1 R2. In its Self-Report, Georgia Power stated that it had installed a new GSU transformer at its Hatch Nuclear Power Station in March 2008. Along with the GSU transformer, Georgia Power also installed a new neutral CT. The newly installed CT is an input to the existing protective relaying that is within the scope of the Protection System maintenance and testing program. The subject neutral CT was not tested during initial start-up of the GSU transformer in accordance with the Plant Hatch maintenance and testing program developed pursuant to NERC Reliability Standard PRC-005-1 R1.

Third Violation On April 14, 2009, Georgia Power self-reported to SERC a violation of PRC-005-1 R2 related to the testing of CTs at its Vogtle Nuclear Power Station. As reported by Georgia Power, during April 2008 and October 2008, at Vogtle Unit 1 and Vogtle Unit 2, respectively, the existing Main Generator Exciter control systems were upgraded to GE EX2100 control systems. This upgrade included the installation of new CTs and the replacement of existing CTs and involved 19 CTs per unit. These CTs are utilized to provide a signal to Generator Protection relaying within the scope of the Protection System maintenance and testing program. The newly installed CTs were subjected to various functional tests to ensure the integrity and reliability of the equipment. The Plant Vogtle maintenance and testing program requires, among other things, that a Secondary Resistance (Burden) Test, a Saturation Test and a Ratio Test, be performed on all newly installed CTs. As part of an internal review of Plant Vogtle’s compliance with NERC Reliability Standard PRC-005-1, it was discovered on March 27, 2009, that the newly installed CTs were not tested in accordance with the procedures required under the Plant Vogtle maintenance and testing program. Specifically, a Secondary Resistance Test was not performed on any of the newly installed CTs at Vogtle Units 1 and 2. These tests were not performed due to a failure to clearly communicate to plant personnel the expectations that this test should be included in the work order planning process. This responsibility rests with SCS Technical Services as a whole as well as the operating companies who failed to implement the program as directed. In addition, it cannot be confirmed that a Saturation Test and/or a Ratio Test had been performed for five of the newly installed CTs. Upon subsequent review of the work order package for these five CTs, it was discovered that the work orders did not include evidence of these specific tests. After discovering that these CTs had not been tested, Georgia Power began an investigation into the matter. SERC determined that Georgia Power had three violations of PRC-005-1 R2 because Georgia Power did not perform the required functional testing upon installation of new CTs at its Hatch and Vogtle Nuclear Power Stations in accordance with the maintenance and testing program and due to a lack of documentation, and Georgia Power could not provide SERC with evidence that a

13 Georgia Power made SERC aware of this possible violation on November 18, 2008 and stated that it would be performing an investigation.


number of station batteries at several of its plants were maintained and tested within the time intervals defined in its Protection System maintenance and testing program. SERC determined that the duration of the violation discovered during the 2008 spot check was from June 18, 2007, the date the Standard became enforceable, through February 28, 2009, when Georgia Power completed the related Mitigation Plan. SERC determined that the duration of the violation associated with the December 2, 2008 Self-Report was from March 20, 2008, the on-line date for the new GSU transformer at its Hatch Nuclear Power Station and the last date the newly installed CT for such unit should have been tested, through September 1, 2009, when Georgia Power completed the related Mitigation Plan. SERC determined that the duration of the violation associated with the April 14, 2009 Self-Report was from April 24, 2008, the date the newly installed CTs at Vogtle Unit 1 should have been tested, until Georgia Power completed the related Mitigation Plan which had an approved completion date of June 30, 2010. Therefore, SERC determined that beginning on June 18, 2007 and continuing until Georgia Power completed its Mitigation Plan for its violation self-reported on April 14, 2009, on June 28, 2010, Georgia Power was not compliant with PRC-005-1 R2. Regional Entity’s Basis for Penalty

According to the Settlement Agreement, SERC has assessed a penalty of thirty thousand dollars ($30,000) for the referenced violations. In reaching this determination, SERC considered the following factors: (1) Georgia Power self-reported two of the violations; (2) Georgia Power was cooperative throughout the enforcement process; (3) Georgia Power agreed to resolve this issue via settlement before receiving a Notice of Alleged Violation and Proposed Penalty or Sanction; (4) there was no evidence of any attempt to conceal a violation nor evidence of intent to do so; and (5) Georgia Power had three violations of PRC-005-1 R2. Additionally, SERC determined that the violations did not pose a serious or substantial risk to the BPS because: (a) the testing and maintenance required by PRC-005-1 R2.1 was being performed for most batteries; (b) no batteries were missing documentation of testing and maintenance for all intervals; (c) all batteries at six of Georgia Power’s generating facilities had documentation for all monthly intervals and 34 of the 82 batteries at the other plants had documentation for all intervals; (d) the gaps in documentation for the relays involved indicated there was no systematic program deficiency; and (e) functional tests were performed on the CTs by a vendor prior to delivery to Plant Hatch and Plant Vogtle, which provided assurance that they would operate reliably. After consideration of the above factors, SERC determined that, in this instance, the penalty amount of thirty thousand dollars ($30,000) is appropriate and bears a reasonable relation to the seriousness and duration of the violations. This instant spot check of Georgia Power prompted the self-reported violations of other Southern Company operating companies14

14 Southern Company is a holding company under the Public Utility Holding Company Act of 2005, as amended (“PUHCA”). Southern Company does not produce goods or services itself, but owns all of the common stock of five operating public utility companies whose primary business is the sale of electricity. The four retail operating companies – Alabama Power, Georgia Power Company (“Georgia Power”), Gulf Power and Mississippi Power –

which were filed on December 30, 2009, in FERC Docket Nos.


NP10-32 through NP10-35. The Commission issued an order stating it would not engage in further review of those Notices of Penalty. NERC incorporates by reference in this docket the response to FERC’s Request for Information dated January 29, 2010 in the referenced dockets regarding how the violations and related factors were considered. In NERC’s response to FERC’s Request for Information in Docket Nos. NP10-32-000 through NP10-35-000 NERC addressed FERC’s questions about the potential relationship between the violations of affiliates of Southern Company, including Georgia Power. Because Georgia Power and its affiliates share elements of the same Protection System maintenance and testing program, after SERC’s spot check of Georgia Power initiated in October 2008, all Southern Company’s affiliates proactively initiated their own internal investigation of compliance with PRC-005-1. Although Southern Company’s affiliates operate under the same Protection System maintenance and testing program, it is implemented independently at each plant within each Southern Company operating company and each company’s compliance officer is responsible for determining how compliance programs and procedures are to be implemented.

SERC did not consider Georgia Power’s violations within the Notice of Penalty to be “repeat” violations that aggravated the penalty because these violations were settled prior to the violations in Docket Nos. NP10-32-000 through NP10-35-000. Within this NOP, the multiple violations were considered repeat violations and that was taken into account when determining the appropriate penalty. Status of Mitigation Plan15

First Violation Georgia Power’s Mitigation Plan to address its first violation of PRC-005-1 R2 discovered during the 2008 spot check was signed on December 18, 2008 and submitted to SERC on December 19, 2008 with a proposed completion date of February 28, 2009. The Mitigation Plan was accepted by SERC on January 15, 2009 and approved by NERC on February 17, 2009. The Mitigation Plan for this violation is designated as MIT-07-1375 and was submitted as non-public information to FERC on February 24, 2009 in accordance with FERC orders.

each provide retail electric service to customers in four Southeastern states. The fifth operating company -- Southern Power -- constructs, acquires, owns, and manages generation assets and sells electricity at market-based rates in the wholesale market. Each of these operating companies has its own management council and board of directors. In addition, each operating company has its own compliance officer who oversees, among other things, compliance with NERC Registered Entity functions and reports directly to its board of directors. Each company’s compliance officer is responsible for determining how compliance programs and procedures are to be implemented. In addition, each operating company is responsible for any sanctions associated with NERC Reliability Standards. Southern Company Services (“SCS”) is a service company under PUHCA and provides, at cost, specified services to Southern Company and its subsidiaries, including the four retail operating companies (Alabama Power, Georgia Power, Gulf Power, and Mississippi Power) and Southern Power. The services provided by SCS include general and design engineering, purchasing, accounting and statistical analysis, finance and treasury, tax, information resources, marketing, auditing, insurance and pension administration, human resources, systems and procedures, digital wireless communications, and other services with respect to business and operations, including power pool transactions. 15 See 18 C.F.R § 39.7(d)(7).


Georgia Power’s Mitigation Plan required Georgia Power to complete the following actions: • Where inspection documentation was not available, batteries were inspected with

confirmation that they are in good working condition and documentation was retained – completed November 30, 2008;

• Review by technical experts, who are independent of plant management, to confirm the integrity of all batteries by January 30, 2009;

• Require plant managers to confirm in writing that they understand the required monthly inspection and documentation associated with station batteries and that they will communicate the requirements to appropriate plant maintenance personnel by January 30, 2009; and

• Establish revised procedures for the centralized retention and real-time sharing of documentation associated with battery inspection and maintenance by February 28, 2009.

To prevent recurrence of a similar violation, the Mitigation Plan also stated that Georgia Power would review inspection documentation on a monthly basis to ensure that the required maintenance is performed, and that it would establish a formal Plant Goal 2009 associated with compliance with PRC-005-1 pursuant to which a failure to comply would be considered in personnel evaluations and could affect overall compensation. Georgia Power certified on March 12, 200916

• A spreadsheet documenting dates of battery inspections for each applicable plant battery;

that the above actions required by its Mitigation Plan were completed on February 28, 2009. As evidence of completion of its Mitigation Plan, Georgia Power submitted the following:

• Sample battery inspection sheets documenting the inspections for selected plants where battery information was missing;

• An affidavit from the Senior Plant Services Specialist documenting expert review independent of plant management confirming the integrity of the batteries that were not inspected according to the Preventative Maintenance Procedure;

• E-mails from the Plant Manager of each plant documenting his or her understanding of the Preventative Maintenance Procedure and communication of the procedure to appropriate plant personnel; and

• The procedure developed to allow plant personnel to download battery inspection sheets to a central database for retention and real-time sharing of documentation.

On March 27, 2009, after reviewing Georgia Power’s submitted evidence, SERC verified that Georgia Power’s Mitigation Plan was completed on February 28, 2009. Second Violation Georgia Power’s proposed Mitigation Plan to address its second violation of PRC-005-1 R2 associated with its December 2, 2008 Self-Report was submitted to SERC on February 3, 2009. A revised Mitigation Plan was submitted to SERC on February 12, 200917

16 Georgia Power’s Certification of Completion was signed on March 11, 2009.

with a proposed

17 SERC’s Verification of Completion states that the Mitigation Plan was submitted on February 3, 2009. This was the date the initially proposed Mitigation Plan was submitted. A revised Mitigation Plan was submitted on February 12, 2009 which was the Mitigation Plan that was approved by SERC.


completion date of June 30, 2010. The Mitigation Plan was accepted by SERC on February 19, 2009 and approved by NERC on March 9, 2009. The Mitigation Plan for this violation is designated as MIT-08-1445 and was submitted as non-public information to FERC on March 10, 2009 in accordance with FERC orders. Georgia Power’s Mitigation Plan required Georgia Power to complete the following actions:

• Revise plant procedures to ensure CTs are tested per the maintenance program summary document by March 31, 2009; and

• Perform testing of the Unit 1 GSU CT at issue per the maintenance program summary document by May 30, 2010.

Georgia Power certified on October 13, 200918

• Procedure 95IT-OTM-001-0, Version 5.3 “Maintenance Work Order Functional Test Guideline,” effective date March 17, 2009 which described the tests to be performed as parts of the Functional Test;

that the above actions required by its Mitigation Plan were completed on September 1, 2009. As evidence of completion of its Mitigation Plan, Georgia Power submitted the following:

• Procedure 425P-03-27-09-PT-1-1, Version 1.1 “Neutral Bushing CT Testing on Main Transformer 1511-5001,” effective date April 17, 2009 in which the objective is to functionally test the neutral bushing CT on the Main Power Transformer; and

• Maintenance Work Order (MWO) 1082159901 – performed on May 4, 2009, amended September 1, 2009.

On October 20, 2009, after reviewing Georgia Power’s submitted evidence, SERC verified that Georgia Power’s Mitigation Plan was completed on September 1, 2009. Third Violation Georgia Power’s Mitigation Plan to address its third violation of PRC-005-1 R2 associated with its April 14, 2009 Self-Report was submitted to SERC on April 22, 2009 with a proposed completion date of June 30, 2010. The Mitigation Plan was accepted by SERC on May 21, 2009 and approved by NERC on June 8, 2009. The Mitigation Plan for this violation is designated as MIT-08-1735 and was submitted as non-public information to FERC on June 8, 2009 in accordance with FERC orders. Georgia Power’s Mitigation Plan required Georgia Power to complete the following actions:

• Review and revise site testing procedures/programs as required to ensure that testing of CTs is performed as required by the Plant Vogtle testing program – to be completed by July 1, 2009;

• Review and revise site procedures/programs as required to ensure that all CTs that fall within the scope of PRC-005-1, including CTs that are added or CTs that are replaced,

18 Georgia Power’s Certification incorrectly identifies the violation ID as SERC200800234 instead of SERC200800240.


receive the required testing as prescribed in the Plant Vogtle testing program – to be completed by October 1, 2009;

• For the identified CTs, perform Secondary Resistance Tests, Saturation Tests and Ratio Tests where documentation of testing cannot be obtained, or provide documented justification for not performing testing of the Unit 1 CTs – to be completed by December 1, 2009; and

• For the identified CTs, perform Secondary Resistance Tests, Saturation Tests and Ratio Tests where documentation of testing cannot be obtained, or provide documented justification for not performing testing of the Unit 2 CTs – to be completed by May 30, 2010.

Georgia Power certified on June 28, 2010 that the above actions required by its Mitigation Plan were completed on June 28, 2010. As evidence of completion of its Mitigation Plan, Georgia Power submitted the following:

• Current Transformer Testing 25086-C Rev 1 dated June 26, 2009 – A PDF file of a new procedure developed to provide instruction on how to perform required testing on new CTs or CTs that are installed as replacements for existing CTs.

• Work Order Functional Tests 29401-C Rev 28 dated June 25, 2009 – A PDF file of a revised procedure that establishes guidelines/requirements for assignment of functional tests on Work Orders.

• Southern Nuclear Company Guideline NMP-ES-038-GL01 – General Engineering Guidance Version 4 dated October 2009 – A PDF file of a procedure providing guidance for all engineering activities revised to include a review of such activities required by NERC Reliability Standards.

• Testing Cross Reference Vogtle Unit 1 (2) - An undated spreadsheet Georgia Power developed to aid SERC in identifying the location of the data related to the tests performed for each CT.

• Maintenance Work Order (MWO) 1049001580 and MWO 2049001681 – PDF files of MWOs originated May 22, 2009 for Unit 1 and October 17, 2008 for Unit 2 respectively, which state that the purpose of the MWOs is to test newly installed CTs. These documents also contain logs of data for the tests performed including secondary resistance test and the manufacturers’ saturation test results.

• SERC 09-014 Attestation for CT Testing.pdf – An attestation dated July 29, 2010 signed

by Georgia Power’s Fleet design director stating “Prior to beginning the refueling outages the necessary test data to satisfy the mitigation plan was obtained for the secondary resistance tests and the saturation and ratio test. In some cases the test information was factory tests. In lieu of performing the tests the factory test data was reviewed and accepted…”


• An August 27, 2010 e-mail from Georgia Power to SERC that includes the rationale for accepting the resistance tests that had been performed during installation and which eliminated the need for a “burden” test. The e-mail also includes a statement that the manufacturers saturation testing results were included as an amendment to the completed work order.

• System Eng Email.pdf – an e-mail dated June 9, 2009 from a Georgia Power system engineer stating that the resistance tests had been performed on all the CTs.

On August 27, 2010, after reviewing Georgia Power’s submitted evidence, SERC verified that Georgia Power’s Mitigation Plan was completed on June 28, 2010. According to the Settlement Agreement, Georgia Power will complete the following actions to prevent recurrence of a similar violation:

• Dedication of engineering subject matter expert to provide technical leadership and guidance – completed on January 1, 2009;

• Establishment of formal compliance goal for all plants in 2009 – completed on January 1, 2009;

• Hire a full-time Compliance Coordinator to monitor compliance with generation-related NERC Reliability Standards – completed on January 5, 2009;

• Implementation of Weekly Compliance Meetings – completed on January 7, 2009;

• Development of Interactive Web-based Application for Generation-Related ERO Compliance Activities – completed on January 9, 2009;

• Implementation of New Training on NERC Reliability Standards – to be completed on January 20, 2009;

• Implementation of quarterly certification requirement to confirm plant compliance with NERC Reliability Standard PRC-005-1 – to be completed on April 30, 2009; and

• Development of new Protection System maintenance and testing procedures for nuclear plants – to be completed on September 30, 2009.

According to the Settlement Agreement, Georgia Power submitted the following as evidence of its completion of the above actions to prevent a similar violation:

1. Screenshots showing the ERO Compliance website;

2. a charter formalizing the weekly Compliance Committee meetings;

3. a screenshot of the meeting notice sent to training participants initiating the first training session;

4. a personnel report documenting the Compliance Coordinator’s hire date;

5. a memo from the Electrical Systems and Field Support Manager detailing organizational changes resulting in a full time technical support position;


6. a description of the current plant goal regarding NERC Reliability Standards compliance; and

7. the Certification Form template. SERC reviewed Georgia Power’s submitted evidence and determined that Georgia Power had completed the additional actions to prevent recurrence of a similar violation. The estimated costs to Georgia Power to implement the actions described the above actions are approximately $43,000 initially with costs of $167,000 that Georgia Power will incur on an annual basis. SERC may audit and inspect financial records to validate actual expenditures with estimates in the Settlement Agreement. Statement Describing the Proposed Penalty, Sanction or Enforcement Action Imposed19

Basis for Determination Taking into consideration the Commission’s direction in Order No. 693, the NERC Sanction Guidelines and the Commission’s July 3, 2008 and October 26, 2009 Guidance Order,20

the NERC BOTCC reviewed the Settlement Agreement and supporting documentation on February 10, 2010. The NERC BOTCC approved the Settlement Agreement, including SERC’s imposition of a financial penalty, assessing a penalty of thirty thousand dollars ($30,000) against Georgia Power and other actions to facilitate future compliance required under the terms and conditions of the Settlement Agreement. SERC staff considered the individual merits of each of the alleged violations as well as each of the factors included in the penalty and sanction guidelines. 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) Georgia Power self-reported two of the violations;

(2) Georgia Power had three violations of PRC-005-1 R2;

(3) SERC reported Georgia Power was cooperative throughout the enforcement process;

(4) there was no evidence of any attempt to conceal a violation nor evidence of intent to do so;

(5) SERC found no evidence that there was a deliberate intent to avoid costs by its failure to inspect or test all components within the defined intervals; and

(6) SERC determined that the violations did not pose a serious or substantial risk to the BPS, as discussed above.

19 See 18 C.F.R § 39.7(d)(4). 20 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). See also North American Electric Reliability Corporation, “Notice of No Further Review and Guidance Order,” 132 FERC ¶ 61,182 (2010).


For the foregoing reasons, the NERC BOTCC approves the Settlement Agreement and believes that the proposed penalty of thirty thousand dollars ($30,000) is appropriate for the violations and circumstances at issue, and is consistent with NERC’s goal to promote and ensure reliability of the bulk power system. Pursuant to Order No. 693, the penalty will be effective upon expiration of the 30 day period following the filing of this Notice of Penalty 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 Notice of Penalty are the following documents and material:

a) SERC’s Spot Check Screening Worksheet for PRC-005-1 R2 SERC200800245 dated December 31, 2008, included as Attachment a;

b) Georgia Power’s Self-Report for PRC-005-1 R2 SERC200800240 dated December 2, 2008, included as Attachment b;

c) Georgia Power’s Self-Report for PRC-005-1 R2 SERC200900259 dated April 14, 2009, included as Attachment c;

d) Settlement Agreement by and between SERC and Georgia Power executed October 27, 2009, included as Attachment d;

i. Georgia Power’s Mitigation Plan designated as MIT-08-1445 for the December 2, 2008 self-reported violation SERC200800240 submitted February 12, 2009, included in the Settlement Agreement as Appendix A-1;

ii. Georgia Power’s Certification of Completion of the Mitigation Plan for the December 2, 2008 self-reported violation SERC200800240 dated October 13, 2009, included in the Settlement Agreement as Appendix A-2;

iii. SERC’s Verification of Completion of the Mitigation Plan for the December 2, 2008 self-reported violation SERC200800240 dated October 20, 2009, included in the Settlement Agreement as Appendix A-3;

iv. Georgia Power’s Mitigation Plan designated as MIT-07-1375 for the violation SERC200800245 discovered during the 2008 Spot Check submitted December 19, 2008, included in the Settlement Agreement as Appendix A-4;

v. Georgia Power’s Certification of Completion of the Mitigation Plan for the violation SERC200800245 discovered during the 2008 Spot Check dated March 12, 2009, included in the Settlement Agreement as Appendix A-5;

vi. SERC’s Verification of Completion of the Mitigation Plan for the violation SERC200800245 discovered during the 2008 Spot Check dated March 27, 2009, included in the Settlement Agreement as Appendix A-6; and

vii. Georgia Power’s Mitigation Plan designated as MIT-08-1735 for the April 14, 2009 self-reported violation SERC200900259 submitted April 22, 2009, included in the Settlement Agreement as Appendix A-7.

e) Georgia Power’s Certification of Completion of the Mitigation Plan for the April 14, 2009 self-reported violation SERC200800259 dated June 28, 2010, included in Attachment e;

f) SERC’s Verification of Completion of the Mitigation Plan for the April 14, 2009 self-reported violation SERC200800259 dated August 27, 2010, included in Attachment f.

g) A Form of Notice Suitable for Publication21

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

21 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* Senior Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, N.J. 08540-5721 (609) 452-8060 (609) 452-9550 – facsimile [email protected] [email protected] Helen R. Nalley* SCG Compliance Director Southern Company Services 600 North 18th Street Birmingham, AL 35203 (205) 257-2055 (205) 257-2511 - facsimile [email protected] Tom Bishop* SVP Chief Compliance Officer & General Counsel Georgia Power Company 241 Ralph McGill Blvd Atlanta, GA 30308 (404) 506-2700 (404) 506-2725 - facsimile [email protected] Wayne Moore* SCG Compliance Officer Southern Company Services 600 North 18th Street Birmingham, AL 35203 (205) 257-6208 (205) 257-5858 – facsimile [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.

Rebecca J. Michael* Assistant General Counsel North American Electric Reliability Corporation 1120 G Street, N.W. Suite 990 Washington, D.C. 20005-3801 (202) 393-3998 (202) 393-3955 – facsimile [email protected] R. Scott Henry President and CEO SERC Reliability Corporation 2815 Coliseum Centre Drive Charlotte, NC 28217 (704) 940-8202 (704) 357-7914 – facsimile [email protected] Marisa A. Sifontes* General Counsel Jacqueline E. Carmody* Legal Counsel SERC Reliability Corporation 2815 Coliseum Centre Drive, Suite 500 Charlotte, NC 28217 (704) 494-7775 (704) 357-7914 – facsimile [email protected] [email protected] Kenneth B. Keels, Jr.* Compliance Director Andrea Koch* Manager of Compliance Enforcement and Mitigation SERC Reliability Corporation 2815 Coliseum Centre Drive Charlotte, NC 28217 (704) 940-8214 (704) 357-7914 – facsimile [email protected] [email protected]


Conclusion NERC respectfully requests that the Commission accept this Notice of Penalty 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 Senior Vice President and General Counsel North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, N.J. 08540-5721 (609) 452-8060 (609) 452-9550 – facsimile [email protected] [email protected]

Rebecca J. Michael Assistant General Counsel North American Electric Reliability

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

cc: Georgia Power Company SERC Reliability Corporation Attachments

Attachment a

SERC’s Spot Check Screening Worksheet for PRC-005-1 R2 SERC200800245 dated December

31, 2008

Screening Worksheet

Tracking Number 08-169

Entity Name Is Entity Registered?

Georgia Power Company NCR01247 Yes Unregistered Entity

Entity Contact Entity Telephone Number Steve Bennett ([email protected]) 404.506.2958

Enter Unlisted Contact Name Here Enter Unlisted Contact E-Mail and/or Telephone Here

Standard Requirement Is Issue Still Occurring? Remedial Action Directive?

PRC-005-1 R2 No No

Date Issue Occurred Date Issue/Event Reported Method of Discovery 12/30/08 12/30/08 Spot Check

NERC 48-Hour Reportable? Threat to BES?

No No

Alleged Violation Applies to: BA DP GO GOP LSE PA PSE RC RP RSG TO TOP TP TSP Yes Yes

Brief Description

Entity did not have complete battery maintenance records for all Fossil/Hydro Generating plants.

Detailed Description

A possible violation of Requirement 2.1 is identified for the following reason: Complete and Continuous Monthly Battery testing Data was missing for a substantial number of fossil/hydro generating stations in the printout provided. GPC has indicated that the verification of this monthly testing is unavailable. A mitigation plan is being developed to address this gap in records and all the batteries have been subsequently tested and found to be in acceptable condition according to Evidence Issues Identified Response dated 12/12/08 by Steve Bennett.

Prepared By Date Sam Stryker 12/31/08

Attachment b

Georgia Power’s Self-Report for PRC-005-1 R2 SERC200800240 dated December 2, 2008

SERC Reliability Corporation Self-Reporting / Complaint Form Template

Revision 1 (10-25-07) Report Type (please check): _X_ Self-Report ____ Complaint Date of Report: _____________

NAME OF PERSON REPORTING POSSIBLE STANDARD VIOLATION(S)

CONTACT NAME CONTACT TELEPHONE

NUMBER David L. Gambrell 205-992-6480

CONTACT E-MAIL CONTACT FAX

[email protected] 205-992-5465

REPORTING COMPANY NAME ANONYMOUS? (Y/N) Georgia Power Company N

NERC OR REGIONAL STANDARD(S) AND SPECIFIC REQUIREMENT(S) POSSIBLY

VIOLATED

NAME OF COMPANY POSSIBLY VIOLATING STANDARD(S) ENTITY FUNCTION TYPE(S) Southern Nuclear Operating Company as agent for Georgia

Power Company GO

STANDARD # AND VERSION MEASURE / REQUIREMENT DATE OF POSSIBLE

VIOLATION(S) PRC-005-1 R2/M2 11/18/08

POSSIBLE VIOLATION DESCRIPTION, REASON FOR COMPLAINT, OR QUESTION

In March 2008, Edwin I. Hatch Nuclear Plant, Unit 1, installed a new Generator Step Up (GSU) transformer. Along with the transformer, a new neutral Current Transformer (CT) was installed; the new neutral CT is an input to the existing protective relaying that is within the scope of PRC-005-1. The subject neutral CT was not tested during initial start-up of the GSU, in accordance with the Plant Hatch maintenance program summary document developed to satisfy PRC-005-1.

RELIABILITY IMPACT (IF KNOWN) No impact is expected for the reliability of this CT or the associated relays. This CT is also connected to a fault recorder. The readings from this fault recorder indicate that the CT is properly installed and configured. Additionally, various testing was performed on the CT by the vendor, prior to delivery, providing additional assurance of reliability.

SERC Staff will contact the person providing the report as soon as possible. If you do not receive a response from SERC Staff within 2 business days please contact the SERC office (704-357-7372). Please complete the form as completely as possible and email to [email protected].

mailto:[email protected]

Attachment c

Georgia Power’s Self-Report for PRC-005-1 R2 SERC200900259 dated April 14, 2009

SERC Reliability Corporation Self-Reporting / Complaint Form Template

Revision 1 (10-25-07) Report Type (please check): X Self-Report ____ Complaint Date of Report: April 14, 2009

NAME OF PERSON REPORTING POSSIBLE STANDARD VIOLATION(S)

CONTACT NAME CONTACT TELEPHONE

NUMBER Helen Nalley 205-257-2055

CONTACT E-MAIL CONTACT FAX

[email protected] 205-257-7605

REPORTING COMPANY NAME ANONYMOUS? (Y/N) Georgia Power Company N

NERC OR REGIONAL STANDARD(S) AND SPECIFIC REQUIREMENT(S) POSSIBLY

VIOLATED

NAME OF COMPANY POSSIBLY VIOLATING STANDARD(S) ENTITY FUNCTION TYPE(S) Georgia Power Company GO

STANDARD # AND VERSION MEASURE / REQUIREMENT DATE OF POSSIBLE

VIOLATION(S) PRC-005-1 M2 / R2 3/27/09

POSSIBLE VIOLATION DESCRIPTION, REASON FOR COMPLAINT, OR QUESTION

This self report describes a possible violation of Requirement R2 of PRC-005-1 associated with the testing of Pr otection S ystem Devices at Georgia Power’s Alvin Vogtle Nuclear Plant (“Vogtle”). More detailed information on this possible violation is below.

During April 2008 and October 2008, at Vogtle Un it 1 an d Vogtle Unit 2 respectively , the existing Main Generator Exciter co ntrol systems were upgraded to GE EX2100 contr ol systems. This upgrade included the installation of new Current Transforme rs (CTs) an d the replacement of existing CTs. This upgrade involved 19 CTs per unit.

These CTs are utilized to provide a signal to Genera tor Protection relay ing within the scope of PRC-005-1. The n ewly installed CTs were subjected to va rious functional tests to ensure the integrity and reliability of the equipment. The Vogtle tes ting program requires, am ong other things, that a Secondary Resistance (Burden) Test, a Saturation Test, and a Ratio Test, be performed on all newly installed CTs. As part of an internal review of Plant Vogtle’s compliance with PRC-005, it was discovered on March 27, 2009, that the newly installed CTs were not tested i n accordance with the procedures required under the Vogtle testing program. Specifically, a Secondary Resistance Test was not perform ed on any of the newly installed CTs a t Vogtle Units 1 and 2. These test s were not performed due to a failure to clearly communicate to plant personnel the expectations that this test should be included in t he work order planning process. In addition, it cannot be confirm ed that a Saturation Test and/or a R atio Test had been perfor med for three of t he newly installed CTs. Upon

subsequent review of the work order package fo r these three C Ts, it was di scovered that the work orders did not include evidence of these specific tests.

After discovering that these CTs had n ot been t ested, a non-conf ormance was initiated to docum ent and investigate this event in accordance with the plant site Corrective Action Program.

RELIABILITY IMPACT (IF KNOWN)

There was no impact to the reliability of the bulk electric system resulting from the failure to test these CTs. The CTs were functionally tested to verify the integrity and reliability of the CTs. Additionally, the CT loops were tested and verified to be complete and functional and were placed into service. The system has been successfully operating since the CTs were installed and commissioned.

SERC Staff will contact the person providing the report as soon as possible. If you do not receive a response from SERC Staff within 2 business days please contact the SERC office (704-357-7372). Please complete the form as completely as possible and email to [email protected].

Attachment d

Settlement Agreement by and between SERC and Georgia Power executed October 27, 2009

Settlement Agreement of Georgia Power Company and SERC Reliability Corporation

Page 1 of 18

SETTLEMENT AGREEMENT

OF

SERC RELIABILITY CORPORATION

AND

GEORGIA POWER COMPANY

I. INTRODUCTION

1. SERC R eliability C orporation ( “SERC”) and G eorgia P ower C ompany ( “Georgia Power”) enter in to th is Settlement Agreement (“Settlement Agreement”) to resolve all outstanding issues arising from a preliminary and non-public assessment resulting in S ERC’s de termination a nd f indings, pur suant t o t he N orth A merican E lectric Reliability Corporation (“NERC”) Rules of Procedure, of three alleged violations by Georgia P ower of NERC R eliability S tandard P RC-005-1 ( Transmission a nd Generation P rotection S ystem M aintenance an d T esting), Requirement 2 ( SERC Issue T racking Nos. 0 8-163, 08 -169, a nd 09 -014; N ERC Violation I D N os. SERC200800240, SERC200800245, and SERC200900259).

II. STIPULATION

2. The facts stipulated herein are stipulated solely for the purpose of resolving, between Georgia P ower a nd S ERC, t he m atters di scussed he rein a nd do not c onstitute stipulations or admissions for any other purpose. Georgia Power and SERC hereby stipulate and agree to the following:

Background

3. Georgia P ower i s a r egulated publ ic ut ility providing s ervice t o approximately 1.4 million electric customers in Georgia. In the SERC region, Georgia Power owns, or jointly ow ns, t hirty-seven g enerating f acilities w ith a to tal n ameplate c apacity o f 16,296 m egawatts. Georgia P ower i s r esponsible f or complying with t he N ERC Reliability S tandards applicable to Generator Owners for th irty-five facilities. T he other f acilities owned by G eorgia P ower are o perated b y an affiliate t hat i s responsible for compliance with NERC Reliability Standards for those facilities. Its corporate headquarters is located in Atlanta, Georgia.

4. Georgia P ower i s i ncluded on t he N ERC C ompliance R egistry as a T ransmission

Owner, D istribution P rovider, Load S erving E ntity, a nd G enerator O wner (NCR01247) a nd i s t herefore s ubject t o t he requirements of NERC R eliability Standard PRC-005-1.


Page 2 of 18

5. Prior to the mandatory reliability period, Georgia Power submitted three self-reports

to S ERC th at in volved c ompliance w ith N ERC R eliability S tandard P RC-005-1, Requirement 2. O n M ay 22, 2007, G eorgia P ower s ubmitted a s elf r eport, a s a Transmission O wner, r egarding t his r equirement a nd a l ack of c omplete ba ttery maintenance documentation involving eleven batteries at 9 of 254 substations. That same day, Georgia Power submitted a completed mitigation plan on this self-reported item which was certified to have been completed on April 24, 2007. On November 14, 2007, SERC s taff reviewed G eorgia P ower’s m aintenance r ecords f or t he involved substations and confirmed that the necessary records were being maintained such that Georgia Power had completed its mitigation plan.

6. On May 30, 2007, G eorgia Power, as a Generator Owner, submitted two other self-

reports r egarding N ERC R eliability S tandard P RC-005-1, R equirement 2. T hese self-reports were related to the functional testing of certain relays at its Vogtle and Hatch nuclear power stations in accordance with its maintenance and testing program intervals. T hat same day, Georgia Power submitted mitigation p lans for both self-reported i tems w hich provided t hat t he r equired f unctional t esting w ould b e performed during the next scheduled refueling outage or dur ing a forced outage of sufficient length. The Vogtle mitigation plan was to be completed by June 30, 2008. Georgia Power certified the mitigation plan as complete on J une 30, 20 08 with a ll mitigation actions having been completed by April 1, 2008. On July 31, 2008, SERC Staff c onfirmed th at G eorgia P ower h ad completed its mitig ation p lan f or V ogtle. The Hatch mitigation plan was to be completed by June 30, 2009. G eorgia Power certified this mitigation plan as complete on June 24, 2009 with all mitigation actions having be en c ompleted b y M arch 14, 2009. O n J uly 2, 2009, S ERC ve rified completion of the required mitigation actions.

Alleged Violations of NERC Reliability Standard PRC-005-1, Requirement 2

7. The pur pose of N ERC R eliability S tandard PRC-005-1 i s t o e nsure t hat al l

transmission and generation Protection Systems that affect the reliability of the Bulk Electric System are maintained and tested.

8. NERC Reliability Standard PRC-005-1, Requirement 2 requires that “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 t o i ts R egional R eliability O rganization on r equest ( within 3 0 c alendar days).” R equirement 2.1 r equires t hat t he doc umentation of t he pr ogram implementation pr ovided t o t he R egional R eliability O rganization pur suant t o Requirement 2 include “[e]vidence Protection System devices were maintained and tested within the defined intervals.”

9. On December 2, 2008, Georgia Power self-reported to SERC a possible violation of

NERC R eliability S tandard P RC-005-1, R equirement 2 r elated t o t he t esting of a newly installed Current Transformer (“CT”). As detailed in its December self-report,


Page 3 of 18

in M arch 2008, G eorgia P ower i nstalled a n ew G enerator S tep-Up ( “GSU”) transformer a t its H atch nuc lear pow er s tation. A long w ith t he G SU t ransformer, Georgia Power also installed a new neutral CT. The newly installed CT was an input to the existing protective relaying that is within the scope of the Protection System maintenance a nd t esting pr ogram. T he s ubject ne utral C T w as not t ested dur ing initial s tart-up o f the GSU t ransformer i n acco rdance w ith t he P lant H atch maintenance and testing program developed pursuant to NERC Reliability Standard PRC-005-1, Requirement 1.

10. In 2008, i n accordance with the Compliance Monitoring and Enforcement Program

(“CMEP”), S ERC s taff i nitiated a s pot ch eck au dit p rocess, t o r eview co mpliance status for certain entities. The selection of entities, functions, and NERC Reliability Standards to be included in the spot check process was based on t he existing audit schedule and compliance history. On October 8, 2008, SERC provided notice that it would be c onducting a s pot c heck of G eorgia P ower’s compliance w ith N ERC Reliability Standard PRC-005-1.1

Prior to issuing the spot check notice to Georgia Power, S ERC S taff co nfirmed G eorgia P ower’s N ERC R egistration S tatus as a Generator Owner and that Georgia Power was subject to Requirement 2.1 of NERC Reliability S tandard P RC-005-1. Georgia P ower w as s elected for a s pot ch eck because i t w as not on t he 2008 a udit c ycle a nd ha d not be en previously audited. NERC R eliability S tandard P RC-005-1 w as s elected f or t he s pot c heck due t o t he significant number of violations that had been reported across the U.S.

11. In preparation of its response to the SERC spot check, Georgia Power discovered a lack of doc umentation f or t he m onthly i nspection of ba tteries a t s everal of i ts generating p lants. G eorgia P ower’s P rotection S ystem m aintenance a nd t esting program for its Protection System devices requires that station batteries be inspected on a m onthly ba sis. F or t he s eventeen-month pe riod c overed b y t he spot ch eck (June 2007 t hrough O ctober 2008) , r ecords w ere m issing f or 373 of t he 1,386 monthly i ntervals a ffecting 48 of t he 82 ba tteries a t 31 of G eorgia P ower’s generating facilities. 3 4 b atteries at t he af fected p lants h ad d ocumentation f or all intervals a nd all b atteries a t G eorgia P ower’s other s ix g enerating facilities h ad documentation for all intervals. D ue to this lack of documentation, Georgia Power could not confirm whether the station batteries at these plants were inspected within the time in tervals e stablished b y Georgia P ower p ursuant to N ERC R eliability Standard P RC-005-1, R equirement 1. F ollowing t he di scovery of t his l ack of evidence, Georgia P ower immediately b egan an in vestigation in to th e la ck o f documentation for these battery inspection activities.

1 The spot-check notice provides 30 day notice to an entity that SERC is requesting documentation to show

that, in t he case o f NERC Reliability S tandard PRC-005-1, the entity has maintained and inspected its P rotection System devices within the defined intervals in its Protection System maintenance and testing program established pursuant to the Standard.


Page 4 of 18

12. On A pril 14, 2009, G eorgia P ower s elf-reported t o S ERC a pos sible vi olation of PRC-005-1, Requirement 2 related to the testing of CTs at its Vogtle nuclear power station. A s r eported b y G eorgia P ower, dur ing A pril 2008 and O ctober 2008, a t Vogtle Unit 1 and Vogtle Unit 2 respectively, the existing Main Generator Exciter control s ystems w ere u pgraded t o G E E X2100 c ontrol s ystems. T his upg rade included t he i nstallation of ne w C Ts a nd t he r eplacement of e xisting CTs. T his upgrade i nvolved 19 C Ts pe r uni t. T hese C Ts a re ut ilized t o pr ovide a s ignal t o Generator Protection relaying within the scope of the Protection System maintenance and testing program. T he newly installed CTs were subjected to various functional tests to e nsure th e in tegrity and r eliability o f the e quipment. T he P lant V ogtle maintenance and t esting program r equires, a mong ot her t hings, t hat a Secondary Resistance (Burden) Test, a S aturation Test, and a R atio Test, be performed on al l newly installed CTs. As part of an internal review of Plant Vogtle’s compliance with NERC Reliability S tandard PRC-005-1, i t was di scovered on M arch 27, 2009, that the newly installed CTs were not tested in accordance with the procedures required under the Plant Vogtle maintenance and testing program. S pecifically, a Secondary Resistance Test was not performed on any of the newly installed CTs at Vogtle Units 1 and 2. T hese tests were not performed due to a failure to clearly communicate to plant personnel the expectations that this test should be included in the work order planning process. In addition, it cannot be confirmed that a Saturation Test and/or a Ratio T est ha d be en p erformed f or t hree of the ne wly i nstalled C Ts. U pon subsequent review of the work order package for these three CTs, it was discovered that t he w ork or ders did not i nclude e vidence of t hese s pecific te sts. A fter discovering t hat t hese C Ts ha d not b een t ested, G eorgia P ower be gan an investigation into the matter.

13. Consistent with its corporate compliance program and normal operating procedures, Georgia Power’s operational and compliance managers were informed of the above described i nvestigations. G eorgia P ower’s S enior V ice P resident and C hief Compliance Officer, Senior Vice President and Senior Production Officer, and other compliance officials were immediately notified of the situations. In addition, senior executives, including the President of Georgia Power, were briefed on the matters.

14. After receiving Georgia Power’s s elf-reports and spot check r esponse, S ERC S taff commenced its detailed compliance assessments into the matters. On December 20, 2008, J anuary 6, 2009, and A pril 17, 2009, S ERC S taff i ssued t o G eorgia P ower Compliance Assessment Notices advising Georgia Power of the initiation of formal assessments to determine its compliance relative to NERC Reliability Standard PRC-005-1 and directing Georgia Power to preserve all relevant records and information. SERC S taff p romptly e stablished d irect contact w ith r epresentatives o f G eorgia Power t o be gin t he pr ocess of gathering i nformation a nd doc umentation f or t he detailed compliance assessments. SERC Staff also reported the possible violations to NERC w hich, i n t urn, r eported t he pos sible violations t o t he F ederal E nergy Regulatory C ommission ( the “ Commission”) i n accordance w ith t he C MEP of t he NERC Rules of Procedure. The investigations conducted by SERC Staff included a review of ba ttery m aintenance r ecords, di scussions w ith G eorgia P ower


Page 5 of 18

representatives, an d a review o f t he P rotection S ystem m aintenance and t esting program.

15. On February 3, 2009, Georgia Power representatives participated in a conference call with SERC Staff to discuss SERC Staff’s initial evaluation of the alleged violation self-reported on December 2, 2008, and the alleged violation related to the October 8, 2008 s pot-check. S ubsequently, on M arch 1 0, 2009, S ERC Staff co nvened a Webex-based me eting with G eorgia P ower’s r epresentatives. D uring th at me eting SERC S taff a dvised Georgia P ower of i ts f indings of a lleged v iolations of Requirement 2.1 of N ERC R eliability S tandard P RC-005-1, t he f actual ba sis upon which the determination was based, and the proposed daily penalty to which Georgia Power w as e xposed b y virtue of t he a lleged vi olations i ncluding t he f actors considered b y S ERC S taff i n de termining t he p roposed pe nalty. S ERC S taff also discussed with Georgia Power the next steps in the enforcement process. On April 8, 2009, S ERC S taff m et w ith G eorgia P ower r epresentatives t o di scuss pos sible settlement of the alleged violations. Subsequently, after Georgia Power self-reported a pos sible vi olation on A pril 14, 2009, S ERC c onducted a nother Webex-based meeting w ith G eorgia Power r epresentatives t o d iscuss th e additional a lleged violation of NERC Reliability Standard PRC-005-1, Requirement 2.

16. As a result o f its in vestigation, S ERC S taff c oncluded th at th e f acts a nd e vidence supported a finding that Georgia Power violated Requirement 2 of NERC Reliability Standard PRC-005-1 because evidence reviewed showed that: (1) Georgia Power did not perform the required functional testing upon installation of new CTs at its Hatch and V ogtle n uclear p ower s tations i n acco rdance w ith t he m aintenance and t esting program G eorgia P ower ha d established pur suant t o N ERC R eliability S tandard PRC-005-1, Requirement 1; and (2) due to a lack of documentation, Georgia Power could not provide SERC with evidence that a number of station batteries at several of its p lants w ere ma intained a nd te sted w ithin the time in tervals d efined in its Protection S ystem ma intenance a nd te sting p rogram. N ERC R eliability S tandard PRC-005-1, R equirement 2, ha s a “High” Violation R isk F actor ( “VRF”). S ERC Staff further concluded that the alleged violations did not put the bulk power system at a serious or substantial risk because: (1) the testing and maintenance required by NERC R eliability S tandard PRC-005-1, Requirement 2.1 w as be ing pe rformed f or most batteries, albeit less frequently than required under Georgia Power’s Protection System ma intenance a nd te sting p rogram; (2) n o b atteries w ere mis sing documentation of testing and maintenance for all intervals; (3) all batteries at six of Georgia P ower’s g enerating f acilities h ad d ocumentation f or a ll mo nthly in tervals and 34 of the 82 batteries at the other plants had documentation for all intervals; (4) the gaps in documentation for the relays involved indicated there was no systematic program de ficiency; a nd ( 5) f unctional t ests w ere pe rformed on t he C Ts b y t he vendor prior to delivery to Plant Hatch and Plant Vogtle, which provided assurance that they would operate reliably.


Page 6 of 18

III. PARTIES’ SEPARATE REPRESENTATIONS

Statement of SERC and Summary of Findings

17. SERC Staff finds that beginning on June 18, 2007 and continuing until completion of Georgia Power’s Mitigation Plan for its April 14, 2009 self-report, Georgia Power, as a G enerator O wner, d id n ot h ave ev idence th at it ma intained a nd in spected its Protection System devices in accordance with its Protection System maintenance and testing program.

18. Georgia P ower h as a documented P rotection S ystem m aintenance and t esting program f or i ts P rotection S ystem de vices as t he t erm i s d efined i n t he F ERC-approved NERC Glossary of Terms. P ursuant to this program, station batteries are scheduled to be inspected on a monthly basis to ensure the integrity of the batteries. Additionally, t he pr ogram r equires t hat a ll C Ts b e f unctionally t ested upon t heir installation. B ased upon i ts r eview of t he m aintenance a nd t esting pr ogram, t he battery t esting r ecords p rovided b y G eorgia P ower, a nd di scussions w ith G eorgia Power and i ts representatives, SERC S taff determined that the underlying cause o f the alleged violations was an error in the implementation of the program through the failure to clearly communicate to plant personnel that: (1) s tation batteries must be inspected m onthly as required b y t he P rotection S ystem m aintenance and t esting program; (2) station battery inspections must be properly documented; and (3) CTs must be f unctionally t ested upon i nstallation a s required b y t he P rotection S ystem maintenance and testing programs.

19. SERC Staff concluded that the alleged violations did not pose a serious or substantial risk to the bulk-power system, as discussed above.

20. SERC agrees that this Settlement Agreement is in the best interest of the parties and in the best interest of bulk-power system reliability.

Statement of Georgia Power

21. Georgia Power neither admits nor denies that the facts set forth and agreed to by the parties f or p urposes o f this S ettlement A greement c onstitute v iolations o f N ERC Reliability S tandard P RC-005-1, R equirement 2 .1. A lthough Georgia P ower doe s not admit to, nor does i t deny, the alleged violations, Georgia Power has agreed to enter in to th is S ettlement A greement w ith S ERC to a void extended litig ation w ith respect t o t he m atters de scribed or r eferred t o he rein, t o a void unc ertainty, a nd t o effectuate a complete a nd f inal r esolution of t he i ssues s et f orth he rein. G eorgia Power agrees that this Settlement Agreement is in the best interest of the parties and in the best interest of bulk-power system reliability.

22. Georgia Power has a strong compliance program that is centralized with substantial senior e xecutive s upport, c onsistent f unding, a nd hi ghly qu alified a nd e xperienced personnel. A s part of that compliance program, Georgia Power has implemented a


Page 7 of 18

sound Protection System maintenance and testing program that ensures all Protection System d evices are m aintained an d t ested as necessary t o ensure t he r eliable operation of t he bul k-power s ystem. T his pr ogram r equires t hat pl ant pe rsonnel inspect station batteries on a monthly basis and perform functional testing of all CTs upon installation. D espite Georgia Power’s confidence in this established program, the required inspection of station batteries and testing of new CTs prior to installation was not pr operly pe rformed or doc umented as r equired b y NERC R eliability Standard PRC-005-1, Requirement 2.1.

23. In f urtherance o f its c ommitment to b ulk-power s ystem r eliability, G eorgia P ower has taken steps to mitigate any potential violations and prevent recurrences. T hese mitigation actions and preventative measures include the following:

(i) Where ba ttery i nspection doc umentation w as no t a vailable, G eorgia P ower immediately to ok r esponsive a ction to e nsure t hat: ( a) a ll s tation b atteries were i nspected; ( b) t hat t hey w ere i n good w orking c ondition; a nd ( c) t hat documentation for each station battery was retained.

(ii) Technical ex perts f rom SCS T echnical S ervices, a s hared s upport s ervices organization t hat pr ovides t echnical s upport t o Georgia P ower’s generating facilities, c onfirmed th e in tegrity o f all s tation b atteries. S CS T echnical Services is not a part of the generating plant management reporting structure; therefore, due to their independence from plant management, their review of the station batteries provided an additional quality assurance measure.

(iii) Plant managers were required to confirm in writing that they understood the monthly inspection and documentation requirements associated with s tation batteries and that th ey would communicate the requirements to appropriate plant maintenance personnel.

(iv) Georgia Power implemented revised procedures for the centralized retention and r eal-time s haring o f d ocumentation a ssociated w ith b attery in spection and testing.

(v) An interactive web-based application was developed to assist Georgia Power in managing generation-related reliability compliance activities.

(vi) Georgia P ower i mplemented ne w c ompliance m onitoring pr ocedures t o review ba ttery i nspection doc umentation on a m onthly b asis t o e nsure t hat the required maintenance has been performed and properly documented.

(vii) Georgia Power established a formal compliance goal for a ll plants in 2009. Non-compliance with t his g oal w ill be a c onsideration i n pe rsonnel evaluation and could affect overall compensation for these personnel.

(viii) Georgia P ower es tablished a r equirement t hat p lant managers s ubmit a quarterly c ertification f orm c onfirming c ompliance w ith a ll g eneration-


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related N ERC R eliability S tandards, i ncluding c ompliance w ith N ERC Reliability Standard PRC-005-1.

(ix) SCS G eneration C ompliance, a s hared s upport s ervices or ganization o f Georgia Power, hired a full-time Compliance Coordinator whose primary job responsibility i s t o m onitor c ompliance, pr ovide g uidance, and i mprove quality as surance w ith regard to g eneration-related N ERC R eliability Standards.

(x) SCS T echnical S ervices, a s hared s upport s ervices or ganization of G eorgia Power, d edicated an en gineering s ubject m atter ex pert t o en sure t echnical leadership and direction, provide technical guidance, and improve technical program c onsistency with r egard ge neration-related N ERC R eliability Standards.

(xi) A n ew E RO g eneration co mpliance g overnance committee w as es tablished for Georgia Power and i ts affiliates that i s comprised of both technical and compliance pe rsonnel. T his c ommittee m eets onc e a w eek t o di scuss compliance activities t o e nsure t here i s c onsistent unde rstanding a nd application of procedures for generation-related NERC Reliability Standards compliance. T his co mmittee o versees t he m aintenance m ethodology document a nd i s r esponsible f or confirming a ny pr ocedural a nd/or documentation revisions.

(xii) Each Georgia Power nuclear facility created a procedure requiring each plant to develop and maintain a comprehensive database of all Protection System devices t hat ar e r equired t o b e t ested i n acco rdance w ith t he P rotection System maintenance testing program established at each facility. These plant procedures require the review of documentation for the most recent testing of Protective System devices performed to ensure that the work was completed satisfactorily an d m eets t he r equirements o f th e P rotection S ystem maintenance and testing program.

The wide range of measures being implemented by Georgia Power to protect against future v iolations o f th e same o r s imilar r equirements a re d escribed mo re f ully in Paragraph 29.

IV. MITIGATING ACTIONS, REMEDIES AND SANCTIONS

24. Georgia Power’s Mitigation Plan, MIT-08-1445, to address the alleged violation of NERC Reliability Standard PRC-005-1, associated with i ts December 2 , 2008 s elf-report related to CT testing at Plant Hatch, was submitted to SERC on February 12, 2009. T he M itigation P lan w as a ccepted b y SERC on F ebruary 19, 2009, a nd approved by NERC on March 9, 2009, and was submitted as non-public information to t he C ommission on M arch 10, 2009. Georgia P ower certified on October 13 , 2009, t hat t he M itigation P lan ha d be en c ompleted on S eptember 1, 20 09. S ERC


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verified completion of t he Mitigation P lan on O ctober 20 , 2009. Georgia Power’s Mitigation Plan MIT-08-1445 is attached hereto as Appendix A-1. Its Certification of M itigation P lan C ompletion i s a ttached he reto a s A ppendix A -2,2

25. Georgia Power’s Mitigation Plan, MIT-07-1375, to address the alleged violation of NERC R eliability S tandard PRC-005-1, a ssociated w ith t he spot-check, w as submitted t o SERC on December 19, 2008. T he Mitigation P lan was a ccepted b y SERC on January 15, 2009, and approved by NERC on February 17, 2009, and was submitted a s n on-public i nformation t o the C ommission on F ebruary 24, 2009. Georgia P ower certified o n M arch 1 2, 2009, t hat t he M itigation P lan ha d be en completed on F ebruary 28, 2009. S ERC verified completion of the Mitigation Plan on M arch 2 7, 2009 . Georgia P ower’s Mitigation P lan M IT-07-1375 i s a ttached hereto as Appendix A-4. Its Certification of Mitigation Plan Completion is attached hereto as Appendix A-5, and the Statement of SERC Staff Regarding Completion of Georgia Power’s Mitigation Plan MIT-07-1375 is attached hereto as Appendix A-6.

and t he Statement of SERC Staff Regarding Completion of Georgia Power’s Mitigation Plan MIT-08-1445 is attached hereto as Appendix A-3.

26. Georgia Power’s Mitigation Plan, MIT-08-1735, to address the alleged violation of NERC Reliability Standard PRC-005-1, associated with its April 14, 2009 self-report related to CT testing at Plant Vogtle, was submitted to SERC on April 22, 2009. The Mitigation Plan was accepted by SERC on May 21, 2009, and approved by NERC on June 8, 2009, a nd w as submitted a s non -public i nformation t o t he C ommission on June 8, 2009. T he execution of this mitigation plan is ongoing and scheduled to be completed at the time of the next plant refueling outage, by June 30, 2010. G eorgia Power’s Mitigation Plan MIT-08-1735 is attached hereto as Appendix A-7.

27. Georgia Power’s approved Mitigation Plans will correct the possible violations and will he lp t o pr event a r ecurrence of a ny s imilar vi olation. W here i nspection documentation was not available, responsive action was immediately taken to ensure the s tation ba tteries w ere i nspected t o c onfirm t hat t hey w ere i n good w orking condition. S ubsequently, t echnical experts f rom S CS T echnical S ervices al so checked and confirmed the integrity of all batteries with missing documentation. In addition, plant managers were required to confirm in writing that they understood the monthly inspection and documentation requirements associated with station batteries and t hat t hey would c ommunicate t hese r equirements t o a ll a ppropriate pl ant maintenance personnel. With regard to the newly installed CTs at the Vogtle nuclear power station, Georgia Power will perform the required functional testing of the CTs during the Plant’s next scheduled refueling outage.

2 Note: Appendix A-2 incorrectly lists the NERC Violation ID Number as 200800234, instead of

200800240.


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28. To confirm its completion of these actions, Georgia Power provided SERC with the following evidence: (1) spreadsheet documenting the dates of battery inspections for each plant battery; (2) sample battery inspection sheets documenting the inspections for selected plants where battery documentation was missing; (3) an affidavit of an SCS T echnical S ervices en gineer ex pert co nfirming t he i ntegrity o f t he i nspected batteries; ( 4) e mails f rom th e P lant M anager o f each p lant d ocumenting th eir understanding of t he P rotection S ystem m aintenance a nd t esting p rogram a nd communication of the program to appropriate plant personnel; and (5) documentation of t he pr ocedure de veloped f or t he c entralized r etention of a ll ba ttery inspection documentation. SERC has reviewed the evidence p rovided b y Georgia Power and determined that the actions set forth in the Mitigation Plan are effective for restoring compliance. Georgia Power and SERC have agreed that this agreement is contingent upon Georgia Power completing its Mitigation Plan for the t esting of CTs a t Plant Vogtle.

29. In a ddition to th e actions to r estore c ompliance s et forth in th e M itigation P lans, SERC and Georgia Power agree that Georgia Power has implemented the following measures to help prevent a recurrence of a similar violation:

(i) Development o f Interactive W eb-based A pplication f or E RO C ompliance Activities. A n i nteractive w eb-based application ha s be en d eveloped a nd implemented to a ssist G eorgia P ower a nd its a ffiliates in ma naging generation-related r eliability c ompliance a ctivities. T he a pplication is deployed through a centralized por tal t hat provides access t o r eference and training materials for compliance activities, as well as access to cen tralized databases for the retention of documentation associated with the maintenance and testing of Protection System devices. This new application allows plant and technical services personnel to upload battery inspection documentation to the database to be reviewed by the Compliance Coordinator. This process is designed to ensure that all Protection System devices have been tested and documented. In a ddition t o t he c entralized por tal t o t he da tabases, the application pr ovides e mployees w ith a ccess t o the f ollowing: ( 1) t raining slides and plant action slides for each NERC Reliability Standard applicable to plant personnel; (2) schedules for certain compliance activities (i.e., testing and m aintenance s chedules); ( 3) a d atabase t o upload t he ne wly required quarterly ma nagement c ertifications o f c ompliance w ith N ERC R eliability Standards; a nd ( 4) l inks t o w ebsites s uch a s t he N ERC a nd S ERC homepages. T he application a lso pr ovides a n i nteractive forum w hereby personnel can submit compliance related questions. T his forum i s actively monitored b y compliance pe rsonnel s o t hat a ny questions c an be pr omptly answered.

(ii) Implementation of W eekly C ompliance M eetings. A n ew E RO generation compliance governance committee was established that is comprised of both technical and compliance personnel. T his committee meets once a w eek to discuss s ystem-wide ( which i ncludes G eorgia P ower) co mpliance act ivities


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to ensure there is consistent understanding and application of procedures for generation-related NERC Reliability Standards compliance. This committee oversees t he m aintenance m ethodology do cument a nd i s r esponsible f or confirming any procedural and/or documentation revisions.

(iii) Implementation of New Training on NERC Reliability Standards. Technical experts w ith know ledge of N ERC R eliability Standard r equirements and compliance s taff c onducted t raining s essions w ith pl ant pe rsonnel t o reinforce t he ge neration-related N ERC R eliability S tandards r equirements applicable t o ea ch p lant. T he t raining was r equired f or pl ant m anagement and ot her i ndividuals r esponsible f or c arrying out da y-to-day E RO compliance activities. In addition, plant personnel may access these training presentations a t a ny tim e o n th e n ewly imp lemented in teractive w eb-based application di scussed a bove. T his t raining w ill also be come a pe rmanent aspect of Georgia Power’s training program for its plant personnel.

(iv) Hiring o f F ull-Time C ompliance C oordinator. A fu ll-time C ompliance Coordinator was hired whose primary job responsibilities include monitoring system-wide ( which i ncludes G eorgia P ower) generation-related r eliability compliance a ctivities, pr oviding guidance on r eliability c ompliance, and improving quality assurance with regard to the NERC Reliability Standards.

(v) Dedication of Full-Time Technical Engineer. An engineering subject matter expert now provides system-wide (which includes Georgia Power) technical leadership guidance to improve technical program consistency with regard to generation-related NERC Reliability Standards.

(vi) Establishment of New 2009 Plant Goal. Georgia Power established a formal goal f or ea ch p lant r elated t o N ERC R eliability S tandards co mpliance. Non-compliance w ith t his g oal w ill be a c onsideration i n pl ant pe rsonnel evaluation and could affect overall compensation for these personnel.

(vii) Quarterly C ertifications o f C ompliance w ith N ERC R eliability S tandards. Georgia P ower now r equires t hat pl ant m anagers s ubmit to t he G eneration Compliance Director a q uarterly c ertification form confirming c ompliance with g eneration-related NERC R eliability S tandards, in cluding c ompliance with NERC Reliability Standard PRC-005-1.

(viii) Development o f N ew P rocedures f or N uclear P lants. E ach G eorgia P ower nuclear facility created a p rocedure r equiring e ach pl ant t o de velop a nd maintain a comprehensive database of all Protection System devices that are required to be tested in accordance with the Protection System maintenance testing program established at each facility. T hese plant procedures require the review of documentation for the most recent testing of Protective System devices performed to ensure that the work was completed satisfactorily and


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meets t he r equirements of t he P rotection S ystem m aintenance an d t esting program.

30. As described in Paragraph 29, the following is a summary and schedule of measures that w ere co mpleted t o p revent an y future recurrence o f t he s ame, o r a s imilar, violation on the bulk power system:

Preventative Measures Completion Date

(i) Development of Interactive Web-based Application for Generation-Related ERO Compliance Activities. January 9, 2009

(ii) Implementation of Weekly Compliance Meetings. January 7, 2009

(iii) Implementation o f New Training on NERC Reliability Standards. January 20, 2009

(iv) Hire a full-time C ompliance C oordinator to m onitor compliance w ith g eneration-related N ERC R eliability Standards.

January 5, 2009

(v) Dedication o f e ngineering s ubject m atter e xpert to provide technical leadership and guidance. January 1, 2009

(vi) Establishment o f formal compliance goal for all plants in 2009. January 1, 2009

(vii) Implementation of quarterly certification requirement to confirm pl ant c ompliance w ith N ERC R eliability Standard PRC-005-1.

April 30, 2009

(viii) Development o f n ew P rotection S ystem maintenance and testing procedures for nuclear plants. September 30, 2009

31. SERC h as r eviewed ev idence o f t he completion o f t he p reventative m easures

described in Paragraph 29 and has determined that these measures will assist Georgia Power i n improving pr ospective co mpliance with t he r equirements of N ERC Reliability S tandard P RC-005-1 a nd w ill u ltimately enhance th e reliability o f th e bulk-power system within an appropriate time-frame. In order to facilitate SERC’s need t o communicate t he s tatus o f t hese p reventative m easures and t o pr ovide accountability to NERC, Georgia Power has provided SERC with documentation to confirm t he completion of t hese a ctivities. This doc umentation i ncluded t he following: ( 1) s creenshots s howing t he E RO C ompliance w ebsite, ( 2) a c harter formalizing th e w eekly Compliance C ommittee me etings, ( 3) a s creenshot o f th e meeting notice sent to training participants initiating the first training session, (4) a personnel report documenting the Compliance Coordinator’s hi re da te, (5) a memo


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from t he E lectrical S ystems a nd F ield S upport M anager de tailing or ganizational changes r esulting i n a f ull t ime t echnical s upport pos ition, ( 6) a de scription of t he current pl ant goal r egarding N ERC R eliability Standards c ompliance, and ( 7) t he Certification F orm T emplate. S ERC ha s r eviewed t his do cumentation a nd determined that it sufficiently supports a finding that Georgia Power has completed these additional p reventative measures. These and other documents r elated t o t his proceeding w ill b e ma intained b y S ERC i n a ccordance w ith t he c onfidentiality provisions of Section 1500 of the NERC Rules of Procedure.

32. SERC S taff al so co nsidered t he s pecific f acts an d ci rcumstances o f t he al leged violations a nd G eorgia Power’s a ctions i n r esponse t o t he alleged vi olations i n determining a pr oposed penalty t hat m eets t he r equirement i n S ection 215 of t he Federal P ower A ct t hat “[ a]ny p enalty i mposed u nder t his s ection s hall b ear a reasonable r elation t o t he s eriousness of t he vi olation a nd s hall t ake i nto consideration the efforts o f [ Georgia P ower] to r emedy th e v iolation in a time ly manner.”3

(i) Georgia Power has no pr ior violation of this standard or any closely-related standard during the mandatory reliability period.

The f actors considered b y S ERC S taff i n t he de termination of t he appropriate pe nalty for Georgia P ower’s a lleged vi olations of N ERC Reliability Standard PRC-005-1 pursuant to this Settlement Agreement included the following:

(ii) Georgia P ower s elf-reported t wo of t he a lleged vi olations. O nce G eorgia Power b ecame a ware of t he pos sible vi olations, a nd c onfirmed t he surrounding information, i t f iled self-reports with SERC. G eorgia Power’s diligence in in vestigating th e p ossible v iolations a nd in s elf-reporting t he events to SERC are commendable and a s ignificant factor in a reduction of the penalty.4

(iii) Georgia P ower co operated i n b oth a t imely and ex emplary m anner w ith SERC Staff dur ing t he i nvestigation.

5

3 16 U.S.C. § 824o(e)(6).

Georgia P ower pr ovided pr ompt responses to all of SERC Staff’s questions and satisfactorily cooperated with SERC S taff dur ing m eetings be tween t he p arties t o di scuss t hese e vents. Furthermore, G eorgia P ower p roactively i nitiated its o wn in ternal investigation and voluntarily provided supporting information to SERC Staff to a ssist in S ERC S taff’s r eview o f th e facts an d ci rcumstances. T his included bringing personnel from different areas of its operations to SERC’s office t o pr ovide d etailed i nformation on t he i nvestigation a nd t o comprehensively respond to SERC Staff questions. This enabled SERC Staff to conduct a thorough investigation in an efficient manner.

4 Policy Statement on Compliance, 125 FERC ¶ 61,058, P 19 (October 16, 2008). 5 Revised Policy Statement on Enforcement, 123 FERC ¶ 61,156, P 65 (May 15, 2008).


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(iv) Georgia Power agreed to expeditiously resolve this issue via settlement and promptly i nitiated va rious m itigation a nd pr eventative m easures be fore receiving a Notice of Alleged Violation from SERC.

(v) Georgia Power possessed a clear lack of intent to commit or to conceal the alleged vi olations. Georgia P ower di d not attempt t o c onceal t he alleged violations. F urthermore, G eorgia P ower di d not i ntend t o c ommit such violations, a s w as s upported b y t he e xistence of cer tain m aintenance and testing records for all of its station batteries.

(vi) Georgia P ower h as a q uality co mprehensive compliance p rogram t hat w as developed using Commission guidance.6

(vii) Georgia P ower is im plementing p reventative measures t hat i nclude the implementation of a formal compliance goal for all plants in 2009. Meeting this pl ant g oal w ill be a n i ntegral c omponent of pe rsonnel e valuation. Accordingly, a f ailure t o m aintain c ompliance c ould ha ve a corresponding affect on overall compensation.

Georgia Power has participated in voluntary compliance programs prior to the effective date of the mandatory and enforceable NERC Reliability Standards. T his comprehensive program includes substantial, high-level support and dedicated compliance personnel who are responsible for its implementation.

(viii) Georgia Power is implementing a wide range of additional measures set forth in P aragraph 29 t o pr otect a gainst f uture vi olations of t he s ame or s imilar requirements. A mong the m easures pr oposed by Georgia P ower, i s t he implementation of an internally developed interactive web-based application to a ssist G eorgia P ower in ma naging generation-related r eliability compliance activities. In addition, Georgia Power will now require that plant managers s ubmit to th e Compliance D irector a quarterly c ertification f orm confirming compliance with generation-related NERC Reliability Standards, including compliance with NERC Reliability Standard PRC-005-1.

33. Based on t he a bove f actors, a s w ell a s t he m itigation a ctions a nd preventative measures t aken, G eorgia P ower s hall pa y $30, 000 t o S ERC a s s et f orth i n t his Settlement Agreement. Georgia Power shall remit the payment to SERC via check, or b y w ire t ransfer t o an a ccount t o b e i dentified b y S ERC ( “SERC A ccount”), within tw enty da ys a fter S ERC pr ovides G eorgia P ower w ith a not ice of pe nalty payment due and invoice, to be issued by SERC after this Settlement Agreement is either a pproved b y t he C ommission or b y ope ration of l aw. S ERC s hall not ify NERC, a nd N ERC s hall not ify t he C ommission, if th e p ayment is not time ly received. If Georgia Power does not remit the payment by the required date, interest payable to SERC will begin to accrue pursuant to the Commission’s regulations at 18

6 Policy Statement on Compliance, 125 FERC ¶ 61,058, PP 6, 13-15 (October 16, 2008).


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C.F.R. §35.19a(a)(2)(iii) from the date that payment is due, and shall be payable in addition to the payment.

34. The e stimated c osts to G eorgia P ower to imp lement th e a greed to me asures in Paragraph 29 are approximately $43,000 initially with costs of $167,000 that Georgia Power will incur on an annual basis. SERC may audit and inspect financial records to validate actual expenditures with estimates in this Settlement Agreement.

35. Failure to make a timely penalty p ayment o r to comply with any o f the te rms and conditions a greed t o he rein, or a ny ot her conditions o f th is S ettlement Agreement shall be deemed to be either the same alleged violation that initiated this Settlement Agreement and/or additional violation(s) and may subject Georgia Power to new or additional e nforcement, penalty or s anction a ctions i n acco rdance w ith the N ERC Rules of P rocedure. Georgia P ower s hall r etain a ll r ights t o de fend against s uch additional enforcement actions in accordance with NERC Rules of Procedure.

V. ADDITIONAL TERMS

36. The signatories to the Settlement Agreement agree that they enter into the Settlement

Agreement voluntarily and that, other than the recitations set forth herein, no tender, offer o r promise of any kind b y any m ember, employee, o fficer, di rector, a gent or representative of SERC or Georgia Power has been made to induce the signatories or any o ther party to en ter into the Settlement Agreement. T he s ignatories agree that the te rms a nd c onditions o f th is S ettlement Agreement a re c onsistent w ith th e Commission’s regulations and orders, and NERC’s Rules of Procedure.

37. SERC s hall r eport th e t erms o f a ll s ettlements o f c ompliance ma tters t o N ERC. NERC will review the settlement for the purpose of evaluating its consistency with other s ettlements e ntered in to f or s imilar v iolations o r u nder o ther, s imilar circumstances. Based o n th is r eview, NERC w ill e ither approve th e s ettlement o r reject t he s ettlement a nd not ify S ERC a nd Georgia P ower of changes t o t he settlement that would result in approval. If NERC rejects the settlement, NERC will provide s pecific written r easons f or s uch r ejection a nd S ERC w ill attempt to negotiate a revised settlement agreement with Georgia Power including any changes to t he s ettlement s pecified b y N ERC. If a s ettlement can not b e reached, t he enforcement process shall continue to conclusion. If NERC approves the settlement, NERC w ill ( i) r eport th e a pproved s ettlement to th e Commission f or th e Commission’s r eview a nd a pproval b y or der or ope ration of l aw a nd ( ii) publ icly post this Settlement Agreement.

38. This Settlement Agreement shall become effective upon the Commission’s approval of th e S ettlement A greement b y o rder o r o peration o f law a s s ubmitted to it o r a s modified in a manner acceptable to the parties.


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39. Georgia Power agrees that this Settlement Agreement, when approved by NERC and the Commission, shall represent a final settlement of all matters set forth herein and Georgia Power waives its right to further hearings and appeal, unless and only to the extent th at Georgia Power c ontends t hat a ny N ERC or C ommission a ction on t he Settlement Agreement contains one or more material modifications to the Settlement Agreement. S ERC r eserves a ll r ights to in itiate e nforcement, p enalty o r s anction actions against Georgia Power in accordance with the NERC Rules of Procedure in the event t hat Georgia Power f ails to c omply with th e mitig ation plan a nd compliance program agreed to in this Settlement Agreement. In the event Georgia Power fails to comply with any of the stipulations, remedies, sanctions or additional terms, as s et f orth in th is S ettlement A greement, S ERC w ill initiate e nforcement, penalty, or sanction actions against Georgia Power to the maximum extent allowed by the NERC Rules of Procedure, up t o t he maximum s tatutorily a llowed penalty. Except as o therwise s pecified i n this S ettlement A greement, Georgia Power s hall retain a ll r ights t o de fend a gainst s uch e nforcement a ctions, a lso a ccording t o t he NERC Rules of Procedure.

40. Georgia P ower consents t o t he us e of S ERC’s de terminations, f indings, a nd conclusions s et f orth i n this A greement f or t he pur pose of a ssessing t he f actors, including t he f actor o f de termining t he c ompany’s hi story of vi olations, i n accordance with the NERC Sanction Guidelines and applicable Commission orders and pol icy s tatements. Such use may be in any enforcement act ion o r compliance proceeding und ertaken by N ERC a nd/or any R egional E ntity; pr ovided, how ever, that Georgia Power does not consent to the use of the specific acts set forth in this Agreement as t he s ole b asis f or any o ther a ction o r p roceeding brought b y N ERC and/or SERC, nor does Georgia Power consent to the use of this Agreement by any other party in any other action or proceeding.

41. Each of the undersigned warrants that he or she is an authorized representative of the entity d esignated, is authorized t o b ind s uch entity and a ccepts t he S ettlement Agreement on the entity’s behalf.

42. The unde rsigned r epresentative of e ach p arty a ffirms t hat he or s he ha s r ead t he Settlement Agreement, that all of the matters set forth in the Settlement Agreement are true and correct to the best of his or her knowledge, information and belief, and that he or s he unde rstands t hat t he S ettlement Agreement i s e ntered i nto b y s uch party i n express r eliance on t hose r epresentations, pr ovided, how ever, that s uch affirmation b y each p arty’s r epresentative s hall not a pply t o t he ot her p arty’s statements of position set forth in Section III of this Settlement Agreement.

43. The Settlement Agreement may be signed in counterparts.

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


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APPENDIX A TO

SETTLEMENT AGREEMENT OF

SERC RELIABILITY CORPORATION AND

GEORGIA POWER COMPANY

Mitigation Plan MIT-08-1445

(1) Georgia Power’s Mitigation Plan for its December 2, 2008 Self-Report

(2) Georgia Power’s Certification of Mitigation Plan Completion

(3) Statement of SERC Reliability Corporation Compliance Staff Regarding Completion of Georgia Power’s Mitigation Plan


(4) Georgia Power’s Mitigation Plan for the October 8, 2008 Spot-Check

(5) Georgia Power’s Certification of Mitigation Plan Completion

(6) Statement of SERC Reliability Corporation Compliance Staff Regarding Completion of Georgia Power’s Mitigation Plan


(7) Georgia Power’s Mitigation Plan for its April 14, 2009 Self-Report

Mitigation Plan Submittal Form Date this Mitigation Plan is being submitted: 2-12-09 * * - This is a revision to the plan submitted on 2-3-09. If this Mitigation Plan has already been completed:

• Check this box and • Provide the Date of Completion of the Mitigation Plan:

Section A: Compliance Notices1 • Section 6.2 of the CMEP2 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. This person may be the Registered Entity’s point of contact described in Section 2.0.

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

(3) The cause of the 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 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 implemented.

1 This document will become part of the public record to be included in the Notice of Penalty filing to be submitted to the Federal Energy Regulatory Commission (Commission) upon determination that a confirmed violation has occurred or in the event a settlement agreement is reached between the Registered Entity and the Regional Entity. The entire document will be submitted as part of the public record, unless the Registered Entity marks specific information as confidential Critical Energy Infrastructure Information or Privileged Information in accordance with the NERC Rules of Procedure Section 1500 and the Commission’s regulations, rules and orders. The Registered Entity must provide adequate justification supporting designation of information that is submitted to the Commission as Confidential Information. Until such time as this document is submitted to the Commission, it will remain confidential within NERC and the Regional Entity compliance organization pursuant to Section 1500 of the Rules of Procedure.

Derived from NERC Form Version 1.7 Form Rev. Date – 10/7/08

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2 “Uniform Compliance Monitoring and Enforcement Program of the North American Electric Reliability Corporation;” a copy of the current version approved by the Federal Energy Regulatory Commission is posted on NERC’s website.

Appendix A-1

For Public Release 10-26-09

l,,~ERCSERe RElIiitbltlt\j Corporation

(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) 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.

(9) Any other information deemed necessary or appropriate.

(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.

• This submittal form shall be used to provide a required Mitigation Plan for review and approval by SERC and NERC.

• The Mitigation Plan shall be submitted to SERC and NERC as confidential information in accordance with Section 1500 of the NERC Rules of Procedure.

• This Mitigation Plan form may be used to address one or more related violations of one Reliability Standard. A separate mitigation plan is required to address violations with respect to each additional Reliability Standard, as applicable.

• If the Mitigation Plan is approved by SERC and 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.

• SERC or NERC may reject Mitigation Plans that they determine to be incomplete or inadequate.

• Remedial action directives also may be issued as necessary to ensure reliability of the bulk power system.

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

Company Name: Georgia Power Company Company Address: 241 Ralph McGill Blvd. Atlanta, Georgia 30308 NERC Compliance Registry ID [if known]: NCR01247


Page 2 of 9

B.2 Identify the individual in your organization who will serve as the Contact to SERC regarding this Mitigation Plan. This person shall be technically knowledgeable regarding this Mitigation Plan and authorized to respond to SERC regarding this Mitigation Plan.

Name: David Gambrell

Appendix A-1



Title: Southern Nuclear Company - Chief Engineer Email: [email protected] Phone: 205-992-6480

Section C: Identity of Reliability Standard Violations

Associated with this Mitigation Plan This Mitigation Plan is associated with the following violation(s) of the reliability standard listed below:

C.1 Standard: PRC-005-1

[Identify by Standard Acronym (e.g. FAC-001-1)] C.2 Requirement(s) violated and violation dates:

[Enter information in the following Table]

(*) Note: The Violation Date shall be: (i) the date that the violation occurred; (ii) the date that the violation was self-reported; or (iii) the date that the violation has been deemed to have occurred on by SERC. Questions regarding the date to use should be directed to SERC. C.3 Identify the cause of the violation(s) identified above:

In March 2008, Edwin I. Hatch Nuclear Plant, Unit 1, installed a new Generator Step Up (GSU) transformer. Along with the transformer, a new neutral Current Transformer (CT) was installed; the new neutral CT is an input to the existing protective relaying that is within the scope of PRC-005-1. The subject neutral CT was not tested during initial start-up of the GSU, in accordance with the Plant Hatch maintenance program summary document developed to satisfy PRC-005-1.

C.4 [Optional] Provide any relevant additional information regarding the violations associated with this Mitigation Plan:

Upon identification of the potential non-compliance, a condition report was generated to investigate and determine the cause(s).


Page 3 of 9

NERC Violation ID # [if known]

SERC Violation ID

# [if known ]

Requirement Violated

(e.g. R3.2)

Violation Date(*)

SERCYYYYnnnnn 2008-163 R2 12/2/2008

Appendix A-1



Section D: Details of Proposed Mitigation Plan Mitigation Plan Contents 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 violations identified above in Part C.2 of this form:

This CT will be tested during the next scheduled Unit 1 refueling outage. This test will be completed as described in the milestone activity table. Additionally, plant procedures will be revised to further ensure CTs are tested as described in the maintenance program summary document.

Check this box and proceed to Section E of this form if this Mitigation Plan, as set forth in Part D.1, has already been completed; otherwise respond to Part D.2, D.3 and, optionally, Part D.4, below. Mitigation Plan Timeline and Milestones D.2 Provide the timetable for completion of the Mitigation Plan, including the

completion date by which the Mitigation Plan will be fully implemented and the violations associated with this Mitigation Plan are corrected: The procedure revision will be performed as described in the milestone activity table. This date will allow for the necessary review and approvals of the revision. The testing described above will be completed by 5/30/10. Therefore, to allow for review and approval of the documentation and submittal of the necessary SERC required documentation, a date of 6/30/10 would be required for completion of the Mitigation Plan.

D.3 Enter Milestone Activities, with completion dates, that your organization

is proposing for this Mitigation Plan:

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

Revise plant procedures to ensure CTs are tested per the maintenance program summary document

3/31/09

Perform testing of the U1 GSU CT per the maintenance program summary document

5/30/10


Page 4 of 9

Appendix A-1



(*) Note: 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.

Additional Relevant Information (Optional) D.4 If you have any relevant additional information that you wish to include

regarding the mitigation plan, milestones, milestones dates and completion date proposed above you may include it here: The requisite testing can only be performed during a unit outage that requires the plant to be placed into a “cold shutdown” condition of 4 days or more, to support the extensive clearance and tagging requirements to safely perform the test. Accordingly, this testing of the Unit 1 GSU CT is scheduled to be performed during the next scheduled refueling outage. The testing is also being added to the unit’s forced outage contingency plan. In the event such a shutdown occurs, the site will promptly evaluate conditions and, if prudent, make every reasonable effort to perform the requisite testing, barring unforeseen circumstances which may prohibit access or otherwise preclude our ability to perform the test. This contingency will be put in place to support inclusion of this work during an outage of such duration, if it were to occur after 4/30/09. A quarterly update will be provided to SERC regarding the status of the milestones identified in Section D.3, beginning 4/1/09 and each quarter thereafter until the Unit 1 GSU CT testing has been performed. This update also will report on any forced outages that occurred during the quarter. These quarterly reports are in lieu of additional interim milestones.

Section E: Interim and Future Reliability Risk Check this box and proceed and respond to Part E.2 and E.3, below, if this Mitigation Plan, as set forth in Part D.1, has already been completed. Abatement of Interim BPS Reliability Risk


Page 5 of 9

E.1 While your organization is implementing the Mitigation Plan proposed in Part D of this form, the reliability of the Bulk Power System 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 or is proposing as part of the Mitigation Plan to mitigate any increased risk to the reliability of the bulk power system while the Mitigation Plan is being implemented:

Appendix A-1



This testing issue is not expected to impact the reliability of the Bulk Power System, this CT or the associated relays. This CT as well as the GSU are new components that were installed as part of plant long range strategies to enhance reliability. Collectively, the installation of the new GSU and CT is considered more reliable than the previous configuration. Although the subject CT was not tested during installation, as described in the Hatch maintenance program summary document, factory testing was performed by the vendor prior to delivery to Plant Hatch. This CT is also connected to a fault recorder. The readings from this fault recorder indicate that the CT is properly installed and configured, providing additional assurance of reliability.

Prevention of Future BPS Reliability Risk E.2 Describe how successful completion of the Mitigation Plan as laid out in

Part D of this form will prevent or minimize the probability that your organization incurs further violations of the same or similar reliability standards requirements in the future:

The procedure revisions referenced above will be made in a manner that will ensure plant personnel are aware of the requirement to test CTs within the scope of PRC-005-1. This procedure revision will ensure the testing is performed per the program summary document.

E.3 Your organization may be taking or planning other action, beyond that

listed in the Mitigation Plan, as proposed in Part D.1, to prevent or minimize the probability of incurring further violations of the same or similar standards requirements listed in Part C.2, or of other reliability standards. If so, identify and describe any such action, including milestones and completion dates:

Continued on Next Page


Page 6 of 9

Appendix A-1



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 the Mitigation Plan, as laid out in Section D of this form, to SERC for acceptance by SERC and approval by NERC, and

b) If applicable, certifies that the Mitigation Plan, as laid out in Section D of this form, was completed (i) as laid out in Section D of this form and (ii) on or before the date provided as the ‘Date of Completion of the Mitigation Plan’ on this form, and

c) Acknowledges: 1. I am Sr. Vice President, Compliance Officer and General Counsel

of Georgia Power Company. 2. I am qualified to sign this Mitigation Plan on behalf of Georgia

Power Company. 3. I have read and understand Georgia Power Companies obligations

to comply with Mitigation Plan requirements and ERO remedial action directives as well as ERO documents, including, but not limited to, the NERC Rules of Procedure, including Appendix 4(C) (Compliance Monitoring and Enforcement Program of the North American Electric Reliability Corporation” (NERC CMEP)).

4. I have read and am familiar with the contents of the foregoing Mitigation Plan.

5. Georgia Power Company agrees to be bound by, and comply with, the Mitigation Plan, including the timetable completion date, as approved by SERC and approved by NERC.

Authorized Individual Signature ____________________________

(Electronic signatures are acceptable; see CMEP) Name (Print): Thomas P. Bishop

Title: Sr. Vice President, Compliance Officer and General Counsel


Page 7 of 9

Date: 2-12-09

Appendix A-1


'~ERCSERC Reliability Corporation


Page 8 of 9

Appendix A-1




Page 9 of 9

Section G: Comments and Additional Information You may use this area to provide comments or any additional relevant information not previously addressed in this form.

[Provide your response here; additional detailed information may be provided as an attachment as necessary]

Submittal Instructions: Please convert the completed and signed document to a text-searchable Adobe .pdf document using the following naming convention: [(MP Entity Name (STD-XXX) MM-DD-YY.pdf)] Email the pdf file to [email protected]. Please direct any questions regarding completion of this form to:

Ken Keels Manager, Compliance Enforcement SERC Reliability Corporation 704-357-7372 [email protected]

Appendix A-1





Thomas P. BishopSenior Vice PresidentCompliance Officer andGeneral Counsel

241 Ralph McGill Boulevard t\IEAtlanta, Georgia 30308-3374

T81404,506.2700Fax [email protected]

GEORGIAAPOWER

A SOUTHERN COMPANY

To Close Out a Completed Mitigation Plan, fill out this form, save itas a text searchable pdf file or MS Word file, and email it [email protected]. Note that electronic signatures are

acceptable.

All Mitigation Plan Completion Certification submittals shall include data orinformation sufficient for SERC to verify completion of the Mitigation Plan.SERC may request such additional data or information and conduct follow-upassessments, on-site or other Spot Checking, or Compliance Audits as itdeems necessary to verify that all required actions in the Mitigation Plan havebeen completed and the Registered Entity is in compliance with the subjectReliability Standard. (CMEP Section 6.6) Data or information submitted maybecome part of a public record upon final disposition of the possible violation,therefore any confidential information contained therein should be marked assuch in accordance with the provisions of Section 1500 of the NERC Rules ofProcedure.

Certification of a Completed Mitigation Plan

SERC Reliability CorporationViolation Mitigation Plan Closure Form

Name of Registered Entity submitting certification: Georgia Power Company

Date of Certification: 10/13/09

Name of Standard and the Requirement(s) of mitigated violation(s): PRC-005-1, R2Functional Testing/Calibration of identified CT not tested upon installation per Hatchmaintenance program summary document.

SERC Tracking Number (contact SERC if not known): 08-163

NERC Violation 10 Number (if assigned): SERC200800234

Date of completion of the Mitigation Plan: 9-1-2009

Summary of all actions described in Part 0 of the relevant mitigation plan:

Appendix A-2Thomas P. BishopSenior Vice PresidentCompliance Officer andGeneral Counsel

241 Ralph McGill Boulevard t\IEAtlanta, Georgia 30308-3374

T81404,506.2700Fax [email protected]

GEORGIAAPOWER

A SOUTHERN COMPANY

To Close Out a Completed Mitigation Plan, fill out this form, save itas a text searchable pdf file or MS Word file, and email it [email protected]. Note that electronic signatures are

acceptable.

All Mitigation Plan Completion Certification submittals shall include data orinformation sufficient for SERC to verify completion of the Mitigation Plan.SERC may request such additional data or information and conduct follow-upassessments, on-site or other Spot Checking, or Compliance Audits as itdeems necessary to verify that all required actions in the Mitigation Plan havebeen completed and the Registered Entity is in compliance with the subjectReliability Standard. (CMEP Section 6.6) Data or information submitted maybecome part of a public record upon final disposition of the possible violation,therefore any confidential information contained therein should be marked assuch in accordance with the provisions of Section 1500 of the NERC Rules ofProcedure.




Date of Certification: 10/13/09

Name of Standard and the Requirement(s) of mitigated violation(s): PRC-005-1, R2Functional Testing/Calibration of identified CT not tested upon installation per Hatchmaintenance program summary document.


NERC Violation 10 Number (if assigned): SERC200800234

Date of completion of the Mitigation Plan: 9-1-2009

Summary of all actions described in Part 0 of the relevant mitigation plan:

Milestone Activity Target Completion StatusCompletion

DateRevise plant procedures to ensure CTs March 31,2009 Functional testing procedure,are tested per the maintenance program 95IT-OTM-001-0, Version 5.3,summary document. "Maintenance Work Order

Functional Test Guideline",was revised with an effective dateof 3/17/2009.

Perform testing of the U1 GSU CT per May 30,2010 U1 GSU CT testing performed onthe maintenance program summary 5/4/2009 (amended on 9/1/2009)document. by Maintenance Work Order

(MWO) 1082159901 usingProcedure 42SP-03-27-09-PT-1-1,"1\Jeutral Bushing CT Testing onMain Transformer 1S11-S001".

Description of the information provided to SERC for their evaluation:

Evidence of Compliance - Closure Letters

June 18, 2009 5NC Mitigation Plan Closure Letter (LR-PM-001-0509)

Evidence of Compliance - Calibration and Functional Test Procedures

Procedure 95IT-OTM-001-0, Version 5.3 "Maintenance Work Order FunctionalTest Guideline", effective date 3/17/2009 (reference pages 27 and 52).

Procedure 425P-03-27-09-PT-1-1, Version 1.1 "Neutral Bushing CT Testing onMain Transformer 1511-5001", effective date 4/17/2009.

Evidence of Compliance - Work Orders, Calibration or Test Results

Maintenance Work Order (MWO) 1082159901 - performed on 5/4/2009,amended 9/1/2009.

I certify that the mitigation plan for the above-named violation has been completed onthe date shown above. In doing so, I certify that all required mitigation plan actionsdescribed in Part D of the relevant mitigation plan have been completed, compliancehas been restored, the above-named entity is currently compliant with all of therequirements of the referenced standard, and that all information submittedinformation is complete and correct to the best of my knowledge.

Appendix A-2

Milestone Activity Target Completion StatusCompletion

DateRevise plant procedures to ensure CTs March 31,2009 Functional testing procedure,are tested per the maintenance program 95IT-OTM-001-0, Version 5.3,summary document. "Maintenance Work Order

Functional Test Guideline",was revised with an effective dateof 3/17/2009.

Perform testing of the U1 GSU CT per May 30,2010 U1 GSU CT testing performed onthe maintenance program summary 5/4/2009 (amended on 9/1/2009)document. by Maintenance Work Order

(MWO) 1082159901 usingProcedure 42SP-03-27-09-PT-1-1,"1\Jeutral Bushing CT Testing onMain Transformer 1S11-S001".


Evidence of Compliance - Closure Letters

June 18, 2009 5NC Mitigation Plan Closure Letter (LR-PM-001-0509)

Evidence of Compliance - Calibration and Functional Test Procedures

Procedure 95IT-OTM-001-0, Version 5.3 "Maintenance Work Order FunctionalTest Guideline", effective date 3/17/2009 (reference pages 27 and 52).

Procedure 425P-03-27-09-PT-1-1, Version 1.1 "Neutral Bushing CT Testing onMain Transformer 1511-5001", effective date 4/17/2009.

Evidence of Compliance - Work Orders, Calibration or Test Results

Maintenance Work Order (MWO) 1082159901 - performed on 5/4/2009,amended 9/1/2009.

I certify that the mitigation plan for the above-named violation has been completed onthe date shown above. In doing so, I certify that all required mitigation plan actionsdescribed in Part D of the relevant mitigation plan have been completed, compliancehas been restored, the above-named entity is currently compliant with all of therequirements of the referenced standard, and that all information submittedinformation is complete and correct to the best of my knowledge.

Name: Thomas P. BishopTitle: SVP General Counsel and Chief Compliance OfficerEntity: Georgia Power CompanyEmail: [email protected]: 404-506-2700

Designated Signature~ ~~Date / v-IJ-~[NOTE - Closure Form should be signed by same individual that signed Mitigation Plan]

(Form Revised August 13, 2008)

Appendix A-2

Name: Thomas P. BishopTitle: SVP General Counsel and Chief Compliance OfficerEntity: Georgia Power CompanyEmail: [email protected]: 404-506-2700

Designated Signature~ ~~Date / v-IJ-~[NOTE - Closure Form should be signed by same individual that signed Mitigation Plan]

(Form Revised August 13, 2008)

Appendix Appendix A-3 1

Statement of SERC Reliability Corporation Compliance Staff Regarding Completion of Mitigation Plan

Registered Entity: Georgia Power Company SERC Tracking ID: 08-169 NERC Violation No: SERC200800245 NERC Mitigation Plan ID: MIT-07-1375 Standard: PRC-005-1 Requirement(s): 2.1 Violation Summary: Entity's Protection System maintenance and testing program requires battery maintenance to be performed on a monthly basis. Entity is able to produce evidence that the maintenance has occurred, but not at the defined interval. This is a violation of PRC-005-1 R2. A High VRF is assigned in accordance with the Complete Violation Risk Factor Matrix and a LOWER VSL is assigned in accordance with the revised VSL Matrix contained in NERC's compliance filing to the Commission on December 19, 2008. The violation has endured from June 18, 2007 until mitigated. The risk to the reliability of the bulk power system is minimal because testing and maintenance is being performed at regular intervals. Mitigation Plan Summary: Georgia Power Company’s Mitigation Plan to address the referenced violation was submitted on December 19, 2008 and was accepted by SERC on January 15, 2009 and approved by NERC on February 17, 2009. The Mitigation Plan is identified as MIT-07-1375 and was submitted as non-public information to FERC on February 24, 2009 in accordance with FERC orders. The approved mitigation plan was neither revised nor was the completion date extended. In summary, the Mitigation Plan included the following:

• Batteries were inspected with confirmation that they are in good working condition and documentation was retained;

• Technical experts confirmed the integrity of all batteries; • Plant managers confirmed in writing that they understand the required monthly

inspection and documentation associated with station batteries and that they will communicate the requirements to appropriate plant maintenance personnel;

Appendix A-3 22

• Procedures were established for the centralized retention and real-time sharing of documentation associated with battery inspection and maintenance.

• Mitigation Plan is scheduled for completion by February 28, 2009. SERC’s Monitoring of Registered Entity’s Mitigation Plan Progress: SERC Reliability Corporation Compliance Staff (“SERC Staff”) monitors the Registered Entity’s progress towards completion of its Mitigation Plans in accordance with Section 6.0 of the uniform Compliance Monitoring and Enforcement Program, (“CMEP”). Pursuant to the CMEP, Registered Entities are required to establish implementation milestones no more than three (3) months apart. SERC Staff solicits quarterly reports from all Registered Entities with open mitigation plans to monitor the progress on completion of milestones. SERC Staff also produces and reviews daily Mitigation Plan status reports highlighting Mitigation Plans that are nearing the scheduled completion date. If the Registered Entity fails to complete its Mitigation Plan according to schedule, appropriate additional enforcement action is initiated to assure compliance is attained. Mitigation Plan Completion Review Process: Georgia Power Company certified on March 12, 2009 that the subject Mitigation Plan was completed on February 28, 2009. A SERC compliance staff member reviewed the evidence submitted in a manner similar to a compliance audit. That action was followed by another compliance staff member’s peer review of the initial conclusion. Evidence Reviewed: Georgia Power Company submitted and SERC Staff reviewed the following evidence in support of its certification that its Mitigation Plan was completed in accordance with its terms: a. Spreadsheet documenting dates of battery inspections for each applicable plant battery. b. Sample battery inspections sheets power plants documenting the inspections for selected plants where battery information was missing. c. Affidavit from Sr. Plant Services Specialist documenting expert review confirming the integrity of the batteries that were not inspected according to the Preventive Maintenance Procedure. d. Emails from the Plant Manager of each plant documenting his or her understanding of the Preventive Maintenance Procedure and communication of the Procedure to appropriate Plant Personnel. e. Procedure developed to allow plant personnel to download battery inspection sheets to a central database for retention and real-time sharing of documentation. Conclusion:

Appendix A-3 3

On March 27, 2009 SERC Reliability Corporation Compliance Staff (“SERC Staff”) completed its review of the evidence submitted by Georgia Power Company in support of its Certification of Completion of the subject Mitigation Plan. Based on its review of the evidence submitted, SERC Staff verifies that, in its professional judgment, all required actions in the Mitigation Plan have been completed and Georgia Power Company is in compliance with the subject Reliability Standard Requirements. This Statement, along with the subject Mitigation Plan, may become part of a public record upon final disposition of the possible violation. Respectfully Submitted, John Wolfmeyer Sam Stryker


(8) 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.



This submittal form shall be used to provide a required Mitigation Plan for review and approval by SERC and NERC. The Mitigation Plan shall be submitted to SERC and NERC as confidential information in accordance with Section 1500 of the NERC Rules of Procedure. This Mitigation Plan form may be used to address one or more related violations of one Reliability Standard. A separate mitigation plan is required to address violations with respect to each additional Reliability Standard, as applicable. If the Mitigation Plan is approved by SERC and 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. SERC or NERC may reject Mitigation Plans that'they determine to be incomplete or inadequate. Remedial action directives also may be issued as necessary to ensure reliability of the bulk power system.

Section B: Registered Entity Information

B.l Identify your organization:

Company Name: Georgia Power Company Company Address: 241 Ralph McGill Boulevard NE, Atlanta; GA 30308 NERC Compliance Registry ID [if known$

B.2 identify the individual in your organization who will serve as the Contact to SERC regarding this Mitigation Plan. This person shall be technically knowledgeable regarding this Mitigation Plan and authorized to respond to SERC regarding this Mitigation Plan.

Derived from NERC Form Version 1.7 Form Rev. Date - 1 O m 8

Page 2 of 1 1

Appendix A-4


aERCSERC REliability Corporation

(7) A timetable for completion of the Mitigation Plan including the completion date bywhich the Mitigation Plan will be fully implemented and the Alleged or ConfirmedViolation(s) corrected.

(8) Implementation milestones no more than three (3) months apart for MitigationPlans with expected completion dates more than three (3) months from the dateof submission. Additional violations could be determined for not completing workassociated with accepted milestones.


(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.

• This submittal form shall be used to provide a required Mitigation Plan for review andapproval by SERC and NERC.

• The Mitigation Plan shall be submitted to SERC and NERC as confidentialinformation in accordance with Section 1500 of the NERC Rules of Procedure.

• This Mitigation Plan form may be used to address one or more related violations ofone Reliability Standard. A separate mitigation plan is required to address violationswith respect to each additional Reliability Standard, as applicable.

• If the Mitigation Plan is approved by SERC and NERC, a copy of this Mitigation Planwill be provided to the Federal Energy Regulatory Commission in accordance withapplicable Commission rules, regulations and orders.

• SERC or NERC may reject Mitigation Plans that 'they determine to be incomplete orinadequate.

• Remedial action directives also may be issued as necessary to ensure reliability ofthe bulk power system.

Section 8: Registered Entity Information

8.1 Identify your organization:

Company Name: Georgia Power CompanyCompany Address: 241 Ralph McGill Boulevard NE, Atlanta; GA30308NERC Compliance Registry ID [if known]:

8.2 Identify the individual in your organization who will serve as the Contactto SERC regarding this Mitigation Plan. This person shall be t~chnically

knOWledgeable regarding this Mitigation Plan and authorized to respondto SERG regarding this Mitigation Plan.

Derived from NERC Form Version 1.7

Page 2 of 11

Form Rev. Oate-1017/08

6 ~ E R C SERC Rcilabillty Corporation

Name: Helen Nalley Title: Compliance Director Email: hrnalley @ southemco.com Phone: 205-257-2055

Derived from NERC Form Version 1.7 Form Rev. Date - 10/7/08 Page 3 of 1 1

Appendix A-4


Name:Title:Email:Phone:

6~seRCSERC Reliability Corporation

Helen NalleyCompliance [email protected]


Page 3 of 11

Form Rev. Date -1017/08

Section C: Identity of Reliability Standard Violations Associated with this Mitigation Plan

This Mitigation Plan is associated with the following violation(s) of the reliability standard listed below:

C. 1 Standard: PRC-005-1 [ldentify by Standard Acronym (e. g. FA C-001- I)]

Requirement(s) violated and violation dates: [Enter information in the following Table]

NERC Violation ID # SERC Requirement Violation ate(? [if known] Violation ID Violated

# (e.g. R3.2)

(*) Note: The Violation Date shall be: (i) the date that the violation occurred; (ii) the date that the violation was self-reported; or (iii) the date that the violation has been deemed to have occurred on by SERC. Questions regarding the date to use should be directed to SERC.

Identify the cause of the violation(s) identified above:

NERC Reliability Standard PRC-005-1 requires that a Generator Owner define the intervals by which it maintains and inspects its Protection System devices. Consistent with this requirement, company procedures require that station batteries be inspected on a monthly basis. On November 7,2008, in response to a SERC spot check for compliance with PRC-005-1, Georgia Power reported to SERC that it had discovered inconsistent documentation for the monthly inspection of some of the batteries at several Georgia Power facilities. Due to this inconsistency in documentation, Georgia Power was unable to confirm whether the station batteries at these plants were inspected in all cases within the time interval established by current procedures.

Form Rev. Date - 10/7/08

Appendix A-4


Section C:

SERe Reliability Corporation

Identity of Reliability Standard ViolationsAssociated with this Mitigation Plan

This Mitigation Plan is associated with the following violation(s) of the reliabilitystandard listed below:

C.1 Standard: PRC-005-1[Identify by Standard Acronym (e.g. FAC-001-1)J

C.2 Requirement(s) violated and violation dates:[Enter information in the following Table]

NERC Violation ID # SERC Requirement Violation Daten[if known] Violation ID Violated

# (e.g. R3.2)[if known]

SERCVYVYnnnnn R.2.1 06/18/2007

(*) Note: The Violation Date shall be: (i) the date that the violation occurred; (ii) the date that theviolation was self-reported; or (iii) the date that the violation has been deemed to have occurredon by SERG. Questions regarding the date to use should be directed to SERG.

C.3 Identify the cause of the violation(s) identified above:

NERC Reliability Standard PRC-005-1 requires that a Generator Ownerdefine the intervals by which it maintains and inspects its ProtectionSystem devices. Consistent with this requirement, company proceduresrequire that station batteries be inspected on a monthly basis. OnNovember 7, 2008, in response to a SERC spot check for compliancewith PRC-005-1, Georgia Power reported to SERC that it had discoveredinconsistent documentation for the monthly inspection of some of thebatteries at several Georgia Power facilities. Due to this inconsistency indocumentation, Georgia Power was unable to confirm whether thestation batteries at these plants were inspected in all cases within thetime interval established by current procedures.


Page 4 of 11

Form Rev. Date -1017/08


C:4 [OptionalJ Provide any relevant additional information regarding the violations associated with this Mitigation Plan:

[Provide your response here; additional detailed information may be provided as an attachment as necessary] .

Derived from NERC Form Version 1 -7 Form Rev. Date - 1 0/7/08

Page 5 of 1 1

Appendix A-4


le~ERCseRe REliability Corporation

[Provide your response here; additional detailed information may be provided as anattachment as necessary]

CA [Optional] Provide any relevant additional information regarding theviolations associated with this Mitigation Plan:

[Provide your response here; additional detailed information may be provided as anattachment as necessary] .


Page 5 of 11

Form Rev. Date-10n/08

Sax SERC R~llablllty corporation

Section D: Details of Proposed Mitiaation Plan

Mitisation Plan Contents

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 violations identified above in Part C.2 of this form:

Georgia Power is taking the following actions to ensure that all battery inspection and maintenance at Georgia Power facilities will be completed within the time intervals established under the applicable maintenance plan.

o Where inspection documentation was not available, responsive action was taken to ensure the batteries were inspected with confirmation that they are in good working condition and documentation was retained;

o Technical experts, who are independent of plant management, are in the process of confirming the integrity of all batteries;

o Plant managers will confirm in writing that they understand the required monthly inspection and dociunentation associated with station batteries and that they will communicate the requirements to appropriate plant maintenance personnel; and

o Revised procedures are being established for the centralized retention and real-time shtuing of documentation associated with battery inspection and maintenance.


Check this box [Z1 and proceed to Section E of this form if this Mitigation Plan, as set forth in Part D.1, has already been completed; otherwise respond fo Part D.2, D.3 and, optionally, Part D.4, below.

Mitiaation Plan Timeline and Milestones

D.2 Provide the timetable for completion of the Mitigation Plan, including the completion date by which the Mitigation PIan will be fully implemented and the violations associated with this Mitigation PIan are corrected:

Derived from NERC Form Version 1.7 Form Rev. Date - '1 0/7/08

Page 6 of 1 1

Appendix A-4


Section D:

aeRCSERC REliability Corporation

Details of Proposed Mitigation Plan

Mitigation Plan Contents

0.1 Identify and describe the action plan, including specific tasks and actionsthat your organization is proposing to undertake, or which it undertook ifthis Mitigation Plan has been completed, to correct the violationsidentified above in Part C.2 of this form:

Georgia Power is taking the following actions to ensure that all batteryinspection and maintenance at Georgia Power facilities will be completedwithin the time intervals established under the applicable maintenance plan.

o Where inspection documentation was not available, responsive action wastaken to ensure the batteries were inspected with confirmation that they are ingood working condition and documentation was retained;

o Technical experts, who are independent of plant management, are in theprocess of confirming the integrity of all batteries;

o Plant managers will confirm in writing that they understand the requiredmonthly inspection and docUmentation associated with station batteries and thatthey will communicate the requirements to appropriate plant maintenancepersonnel; and

o Revised procedures are being established for the centralized retention andreal-time sharing of documentation associated with battery inspection andmaintenance.

[Provide your response here; additional detailed information may be proVided as anattachment as necessary]

Check this box 0 and proceed to Section E of this form if this MitigationPlan, as set forth in Part 0.1, has already been completed; othelWiserespond to Part 0.2, 0.3 and, optionally, Part DA, below.

Mitigation Plan Timeline and Milestones

0.2 Provide the timetable for completion of the Mitigation Plan, including thecompletion date by which the Mitigation Plan will be fully implementedand the violations associated with this Mitigation Plan are corrected:


Page 6 of 11

Form Rev. Date-1017/08

The Mitigation Plan actions discussed in Section D.l will be completed according to the following schedule: (1) Inspection of batteries to confirm they were in good working condition and documentation retained -- completed on November 30, 2008; (2) Review by technical experts to confirm integrity of batteries -- to be completed by January 30, 2009; (3) Receipt of written confirmation that plant managers understand battery inspection requirements and will communicate them to plant personnel -- to be completed by January 30, 2009; and (4) Establishment of procedures for centralized retention and real-time sharing of documentation associated with battery inspections -- to be completed by February 28,2009.

0.3 Enter Milestone Activities, with completion dates, that your organization is proposing for this Mitigation Plan:

Milestone Activity Proposed Completion Date*

(*) Note: 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.

[Note: Provide your response here; additional detailed information may be provided as an attachment as necessary]

Derived from NERC Form Version 1.7 Form Rev. Date - 10/7/08

Page 7 of 1 1

Appendix A-4


l.,~eRCSERe Reliability Corporation.

The Mitigation Plan actions discussed in Section 0.1 will be completedaccording to the following schedule: (1) Inspection of batteries toconfirm they were in good working condition and documentation retained-- completed on November 30, 2008; (2) Review by technical experts toconfirm integrity of batteries -- to be completed by January 30,2009; (3)Receipt of written confirmation that plant managers understand batteryinspection requirements and will communicate them to plant personnel -to be completed by January 30, 2009; and (4) Establishment ofprocedures for centralized retention and real-time sharing ofdocumentation associated with battery inspections -- to be completed byFebruary 28,2009.

0.3 Enter Milestone Activities, with completion dates, that your organizationis proposing for this Mitigation Plan:

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

(1) Battery Inspection Completed November 30, 2008(2) Technical Expert Review January 30, 2009

(3) Plant Manager Confirmation January 30,2009(4) Centralized Document Retention February 28,2009

(*) Note: Implementation milestones no more than three (3) months apart for Mitigation Plans withexpected completion dates more than three (3) months from the date of submission. Additionalviolations could be determined for not completing work associated with accepted milestones.

[Note: Provide your response here; additional detailed information may be provided as anattachment as necessary]


Page 7 of 11

Form Rev. Date - 1017/08

ERC SERC R~liablilty Corporation

Additional Relevant Information (O~tionall

D.4 If you have any relevant additional information that you wish to include regarding the mitigation plan, 'milestones, milestones dates and completion date proposed above you may include it here:


Section E: Interim and Future Reliabilitv Risk

Check this boxm and proceed and respond to Part E.2 and E.3, below, if this Mifigation Plan, as set forfh in Part D, I, has already been completed.

Abatement of Interim BPS Reliabilitv Risk

E.l While your organization is implementing the Mitigation Plan proposed in Part D of this form, the reliability of the Bulk Power System 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 or is proposing as part of the Mitigation Plan to mitigate any increased risk to the reliability of the bulk power system while the Mitigation Plan is being implemented:

Inspection of the batteries confirmed that they are in good working condition; therefore, there is no increased risk to the reliability of the bulk power systeni. As per the company procedure batteries will continue to be inspected on a monthly basis. [Provide your response here; additional detailed information may be provided as an attachment as necessary]

Prevention of Future BPS Reliabilitv Risk

E.2 Describe how successful completion of the Mitigation Plan as laid out in Part D of this form will prevent or minimize the probability that your organization incurs further violations of the same or similar reliability standards requirements in the future:

Derived from NERC Form Version 1.7 Form Rev. Date - 10/7/08

Page 8 of 1 1

Appendix A-4


I.~ERCSERe Reliability Corporation

Additional Relevant Information (Optional}

D.4 If you have any relevant additional information that you wish to includeregarding the mitigation plan, .milestones, milestones dates andcompletion date proposed above you may include it here:


Section E: Interim and Future Reliability Risk

Check this boxD and proceed and respond to Part £.2 and £.3, below, ifthis Mitigation Plan, as set forth in Part 0.1, has already been completed.

Abatement of Interim BPS Reliability Risk

E.1 While your organization is implementing the Mitigation Plan proposed inPart D of this form, the reliability of the Bulk Power System may remainat higher risk or be otherwise negatively impacted until the plan issuccessfully completed. To the extent they are, or may be, known oranticipated: (i) identify any such risks or impacts; and (ii) discuss anyactions that your organization is planning to take or is proposing as partof the Mitigation Plan to mitigate any increased risk to the reliability ofthe bulk power system while the Mitigation Plan is being implemented:

Inspection of the batteries confirmed that they are in good working condition;therefore, there is no increased risk to the reliability of the bulk power system.As per the company procedure batteries will continue to be inspected on amonthly basis.[Provide your response here; additional detailed information may be provided as anattachment as necessary]

Prevention of Future BPS Reliability Risk

E.2 Describe how successful completion of the Mitigation Plan as laid out inPart D of this form will prevent or minimize the probability that yourorganization incurs further violations of the same or similar reliabilitystandards requirements in the future:


Page 8 of 11

Form Rev. Date - 10/7/08

a e F ? c SERC Rciiablllty Corporation


E.3 Your organization may be taking or planning other action, beyond that listed in the Mitigation Plan, as proposed in Part D.1, to prevent or minimize the probability of incurring further violations of the same or similar standards requirements listed in Part C.2, or of other reliability standards. If so, identify and describe any such action, including milestones and completion dates:

Reliability has always been, and will continue to be, a top priority for Georgia Power. Georgia Power has consistently maintained a strong compliance program and is committed to training its plant management personnel to ensure that compliance is a top priority. As a result of this issue, the following measures are being implemented to provide additional assurance of compliance with battery inspection procedures at all plants:

1. Implementation of compliance monitoring procedures whereby inspection documentation will be reviewed on a monthly basis to ensure that the required maintenance has been performed.

2. Establishment of a fonnaI Plant Goal for 2009 associated with compliance with PRC-005-1 pursuant to which a failure to comply will be considered in personnel evaluation and could affect overall compensation.

[Provide your response here; additional detailed information may be provided as an attachment as necessaw]

Continued on Next Paqe

Derived from NERC Form Version 1.7 Form Rev. Date .- 1 0/7/08

Page 9 of 1 1

Appendix A-4


~~RCSERe REliability Corporation


E.3 Your organization may be taking or planning other action, beyond thatlisted in the Mitigation Plan, as proposed in Part D.1, to prevent orminimize the probability of incurring further violations of the same orsimilar standards requirements listed in Part C.2, or of other reliabilitystandards. If so, identify and describe any such action, includingmilestones and completion dates:

Reliability has always been, and will continue to be, a top priority for GeorgiaPower. Georgia Power has consistently maintained a strong complianceprogram and is committed to training its plant management personnel to ensurethat compliance is a top priority. As a result of this issue, the followingmeasures are being implemented to provide additional assurance of compliancewith battery inspection procedures at all plants:

1. Implementation of compliance monitoring procedures whereby inspectiondocumentation will be reviewed on a monthly basis to ensure that the requiredmaintenance has been performed.

2. Establishment of a formal Plant Goal for 2009 associated with compliancewith PRC-005-1 pursuant to which a failure to comply will be considered inpersonnel evaluation and could affect overall compensation.

[Provide your response here; additional detailed information may be provided as an .attachment as necessary]



Page 9 of 11

Form Rev. Date- 1017/08

SERC Rrllability Corporation

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:


b) If applicable, certifies that the Mitigation Plan, as laid out in Section D of this form, was completed (i) as laid out in Section D of this fonn and (ii) on or before the date provided as the 'Date of Completion of the Mitigation Plan' on this fonn, and

c) Acknowledges:

I am Senior Vice Presidentl of Georgia Power Company.

I am qualified to sign this Mitigation Plan on behalf of Georgia Power Company.

I have read and understand Georgia Power Company's obligations to comply with Mitigation Plan requirements and ERO remedial action directives as well as ERO documents, including, but not limited to, the NERC Rules of Procedure, including Appendix 4(C) (Compliance Monitoring and Enforcement Program of the North American Electric Reliability Corporation" (NERC CMEP)).

1 have read and am familiar with the contents of the foregoing Mitigation Plan.

Georgia Power Company agrees to be bound by, and comply with, the Mitigation Plan, including the timetable completion date, as approved by SERC and approved by NERC.

Authorized Individual Signat

Name (Print): Douglas E. Jones Title: Senior Vice Presidentl Date: December 18,2008

Derived from NERC Form Version 1.7 Form Rev. Date - 1 0/7/08

Page 10 of 11

Appendix A-4


\"~RCSeRC REliability Corporation


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

a) Submits the Mitigation Plan, as laid out in Section D of this form, toSERC for acceptance by SERC and approval by NERC, and

b) If applicable, certifies that the Mitigation Plan, as laid out in Section D ofthis form, was completed (i) as laid out in Section Dof this form and (ii)on or before the date provided as the 'Date of Completion of theMitigation Plan' on this form, and

c) Acknowledges:

1. I am Senior Vice Presidentl of Georgia Power Company.

2. I am qualified to sign this Mitigation Plan on behalf of GeorgiaPower Company.

3. I have read and understand Georgia Power Company's obligationsto comply with Mitigation Plan requirements and ERO remedialaction directives as well as ERO documents, including, but notlimited to, the NERC Rules of Procedure, including Appendix 4(C}(Compliance Monitoring and Enforcement Program of the NorthAmerican Electric Reliability Corporation" (NERC CMEP».

4. I have read and am familiar with the contents of the foregoingMitigation Plan.

5. Georgia Power Company agrees to be bound by, and comply with,the Mitigation Plan, including the timetable completion date, asapproved by SERC and approved by NERC.

Authorized Individual Signatu.go.--==--=--=~--=:,-,,-~r--~~:'S:s=--(Electronic signatures a

Name (Print): Douglas E. JonesTitle: Senior Vice PresidentlDate: December 18, 2008


Page 10 of 11

Form Rev. Date-1017/0B

Section G: Comments and Additional Information

You may use this area to provide comments or any additional relevant information not previously addressed in this form.


Submittal Instructions:

Piease convert the completed and signed document to a text-searchable Adobe .pdf document using the following naming convention:

Emaii the pdf file to serccom~lv@sercl .orq.

Please direct any questions regarding completion of this form to:

Ken Keels Manager, Compliance Enforcement SERC Reliability Corporation 704-357-7372 kkeels@sercl .erg

Derived from NERC Form Version 1.7 Form Rev. Date - 10/7108

Page 11 of 11

Appendix A-4


Section G:

aeRCSEAe REliability Corpo~atlon

Comments and Additional Information

You may use this area to provide comments or any additional relevantinformation not preViously addressed in this form.



Please convert the completed and signed document to a text-searchableAdobe .pdf document using the following naming convention:

Email the pdf file to [email protected].


Ken KeelsManager, Compliance EnforcementSERC Reliability [email protected]


Page 11 of 11

Form Rev. Date - 1017/08

Appendix A-5Douglas E. JonesSenior Vice PresidentSenior Production Officer

Southern Company GenerationBin 10240241 Ralph McGill Boulevard NEAtlanta, Georgia 30308-3374

Tel 404.506.7328Fax [email protected]

GEORGIAAPOWER

A SOUTHERN COMPANY

To Close Out a Completed Mitigation Plan, fill out this form, save it asa text searchable pdf file or MS Word file, and email it to

[email protected]. Note that electronic signatures areacceptable.

All Mitigation Plan Completion Certification submittals shall include data orinformation sufficient for SERC to verify completion of the Mitigation Plan. SERCmay request such additional data or information and conduct follow-upassessments, on-site or other Spot Checking, or Compliance Audits as it deemsnecessary to verify that all required actions in the Mitigation Plan have beencompleted and the Registered Entity is in compliance with the subject ReliabilityStandard. (CMEP Section 6.6) Data or information submitted may become part ofa public record upon final disposition of the possible violation, therefore anyconfidential information contained therein should be marked as such inaccordance with the provisions of Section 1500 of the NERC Rules of Procedure.




Date of Certification: March 12, 2009

Name of Standard and the Requirement(s) of mitigated violation(s): PRC-005-1, R2.1


NERC Violation ID Number (if assigned):

Date of completion of the Mitigation Plan: February 28, 2009

Summary of all actions described in Part D of the relevant mitigation plan:

(Milestone 1) Inspection of batteries to confirm they were in good working conditionand documentation retained-- completed on November 30,2008;

Appendix A-5

(Milestone 2) Review by technical experts to confirm integrity of batteries -completed by January 30, 2009;(Milestone 3) Receipt of written confirmation that plant managers understand batteryinspection requirements and will communicate them to plant personnel -- completedby January 30, 2009; and(Milestone 4) Establishment of procedures for centralized retention and real-timesharing of documentation associated with battery inspections -- completed byFebruary 28, 2009.


(Milestone 1)a. Spreadsheet documenting dates of battery inspections for each applicable

plant battery.b. Sample battery inspections sheets documenting the inspections for selected

plants where battery information was missing.

(Milestone 2)a. Affidavit from Sr Plant Services Specialist, documenting

expert review confirming the integrity of the batteries that were not inspectedaccording to the Preventive Maintenance Procedure.

(Milestone 3)a. Emails from the Plant Manager of each plant documenting his or her

understanding of the Preventive Maintenance Procedure and communicationof the Procedure to appropriate Plant Personnel.

(Milestone 4)a. Procedure developed to allow plant personnel to download battery inspection

sheets to a central database for retention and real-time sharing ofdocumentation.

Additional actions specified in Part E of the Mitigation Plan that have beencompleted to aid in compliance with the standard:

1. Compliance monitoring procedures have been implemented through the websitedocumented in Milestone 4 whereby inspection documentation will be reviewed on amonthly basis to ensure that the required maintenance has been performed.

2. A formal Plant Goal for 2009 associated with compliance with PRC-005-1 hasbeen established pursuant to which a failure to comply will be considered inpersonnel evaluation and could affect overall compensation.

I certify that the mitigation plan for the above-named violation has been completed onthe date shown above. In doing so, I certify that all required mitigation plan actionsdescribed in Part D of the relevant mitigation plan have been completed, compliance

Appendix A-5

has been restored, the above-named entity is currently compliant with all of therequirements of the referenced standard, and that all information submitted informationis complete and correct to the best of my knowledge.

Name: Douglas E. JonesTitle: Southern Company Generation Senior Vice PresidentEntity: Georgia Power CompanyEmail: [email protected]: (404) 506-7328

[NOTE - Closure Form should be

1


Registered Entity: Georgia Power Company SERC Tracking ID: 08-169 NERC Violation No: SERC200800245 NERC Mitigation Plan ID: MIT-07-1375 Standard: PRC-005-1 Requirement(s): 2.1 Violation Summary: Entity's Protection System maintenance and testing program requires battery maintenance to be performed on a monthly basis. Entity is able to produce evidence that the maintenance has occurred, but not at the defined interval. This is a violation of PRC-005-1 R2. A High VRF is assigned in accordance with the Complete Violation Risk Factor Matrix and a LOWER VSL is assigned in accordance with the revised VSL Matrix contained in NERC's compliance filing to the Commission on December 19, 2008. The violation has endured from June 18, 2007 until mitigated. The risk to the reliability of the bulk power system is minimal because testing and maintenance is being performed at regular intervals. Mitigation Plan Summary: Georgia Power Company’s Mitigation Plan to address the referenced violation was submitted on December 12, 2008 and was accepted by SERC on January 15, 2009 and approved by NERC on February 17, 2009. The Mitigation Plan is identified as MIT-07-1371 and was submitted as non-public information to FERC on February 24, 2009 in accordance with FERC orders. The approved mitigation plan was neither revised nor was the completion date extended. In summary, the Mitigation Plan included the following:

• Batteries were inspected with confirmation that they are in good working condition and documentation was retained;

• Technical experts confirmed the integrity of all batteries; • Plant managers confirmed in writing that they understand the required monthly

inspection and documentation associated with station batteries and that they will communicate the requirements to appropriate plant maintenance personnel;

Appendix A-6

L~ERC

2

• Procedures were established for the centralized retention and real-time sharing of documentation associated with battery inspection and maintenance.

• Mitigation Plan is scheduled for completion by February 28, 2009. SERC’s Monitoring of Registered Entity’s Mitigation Plan Progress: SERC Reliability Corporation Compliance Staff (“SERC Staff”) monitors the Registered Entity’s progress towards completion of its Mitigation Plans in accordance with Section 6.0 of the uniform Compliance Monitoring and Enforcement Program, (“CMEP”). Pursuant to the CMEP, Registered Entities are required to establish implementation milestones no more than three (3) months apart. SERC Staff solicits quarterly reports from all Registered Entities with open mitigation plans to monitor the progress on completion of milestones. SERC Staff also produces and reviews daily Mitigation Plan status reports highlighting Mitigation Plans that are nearing the scheduled completion date. If the Registered Entity fails to complete its Mitigation Plan according to schedule, appropriate additional enforcement action is initiated to assure compliance is attained. Mitigation Plan Completion Review Process: Georgia Power Company certified on March 12, 2009 that the subject Mitigation Plan was completed on February 28, 2009. A SERC compliance staff member reviewed the evidence submitted in a manner similar to a compliance audit. That action was followed by another compliance staff member’s peer review of the initial conclusion. Evidence Reviewed: Georgia Power Company submitted and SERC Staff reviewed the following evidence in support of its certification that its Mitigation Plan was completed in accordance with its terms: a. Spreadsheet documenting dates of battery inspections for each applicable plant battery. b. Sample battery inspections sheets power plants documenting the inspections for selected plants where battery information was missing. c. Affidavit from Sr. Plant Services Specialist documenting expert review confirming the integrity of the batteries that were not inspected according to the Preventive Maintenance Procedure. d. Emails from the Plant Manager of each plant documenting his or her understanding of the Preventive Maintenance Procedure and communication of the Procedure to appropriate Plant Personnel. e. Procedure developed to allow plant personnel to download battery inspection sheets to a central database for retention and real-time sharing of documentation. Conclusion:

Appendix A-6

L~ERC

3

On March 27, 2009 SERC Reliability Corporation Compliance Staff (“SERC Staff”) completed its review of the evidence submitted by Georgia Power Company in support of its Certification of Completion of the subject Mitigation Plan. Based on its review of the evidence submitted, SERC Staff verifies that, in its professional judgment, all required actions in the Mitigation Plan have been completed and Georgia Power Company is in compliance with the subject Reliability Standard Requirements. This Statement, along with the subject Mitigation Plan, may become part of a public record upon final disposition of the possible violation. Respectfully Submitted, John Wolfmeyer Sam Stryker

Appendix A-6

L~ERC

6 ~SERC SERe Reliability Corporation

Mitigation Plan Submittal Form

Please refer to SERC Guidelines for Mitigation Plan Submission. pdf available at

http://www.serc1.orgIApplication/ContentPage View.aspx?Contentld=22

Date this Mitigation Plan is being submitted: April 22, 2009

If this Mitigation Plan has already been completed: • Check this box D and • Provide the Date of Completion of the Mitigation Plan:

Section A: Compliance Notices

• Section 6.2 of the CMEp1 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. This person may be the Registered Entity's point of contact described in Section 2.0.

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


(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 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 implemented.


(8) Implementation milestones no more than three (3) months apart for Mitigation Plans with expected completion dates more than three (3) months from the date

1 "Uniform Compliance Monitoring and Enforcement Program of the North American Electric Reliability Corporation;" a copy of the current version approved by the Federal Energy Regulatory Commission is posted on NERC's website.

Derived from N ERC Form Version 1.7Page 1 of 11 Form Rev. Date - 2/23/09

CONFIDENTIAL INFORMATION

Appendix A-7


6~SERCSERe Reliability Corporation

Mitigation Plan Submittal Form

Please refer toSERC Guidelines for Mitigation Plan Submission.pdf available at

http://www.serc1.org/ApplicationiContentPageView.aspx?Contentld=22

Date this Mitigation Plan is being submitted: April 22, 2009

If this Mitigation Plan has already been completed:• Check this box D and• Provide the Date of Completion of the Mitigation Plan:

Section A: Compliance Notices

• Section 6.2 of the 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) technically knowledgeableregarding the Mitigation Plan, and (iii) authorized and competent to respond toquestions regarding the status of the Mitigation Plan. This person may be theRegistered Entity's point of contact described in Section 2.0.

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


(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 orConfirmed violation(s).

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

(7) A timetable for completion of the Mitigation Plan including the completion date bywhich the Mitigation Plan will be fully implemented and the Alleged or ConfirmedViolation(s) corrected.

(8) Implementation milestones no more than three (3) months apart for MitigationPlans with expected completion dates more than three (3) months from the date

1 "Uniform Compliance Monitoring and Enforcement Program of the North American ElectricReliability Corporation;" a copy of the current version approved by the Federal Energy RegulatoryCommission is posted on NERC's website.

Derived from NERC Form Version 1.7Page 1 of 11 Form Rev. Date - 2/23/09


,!AERC SERC Reliability Corporation

of submission. Additional violations could be determined for not completing work associated with accepted milestones.



• This submittal form shall be used to provide a required Mitigation Plan for review and approval by SERC and NERC.

• The Mitigation Plan shall be submitted to SERC and NERC as confidential information in accordance with Section 1500 of the NERC Rules of Procedure.

• This Mitigation Plan form may be used to address one or more related violations of one Reliability Standard. A separate mitigation plan is required to address violations with respect to each additional Reliability Standard, as applicable.

• If the Mitigation Plan is approved by SERC and 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.

• SERC or NERC may reject Mitigation Plans that they determine to be incomplete or inadequate.

• Remedial action directives also may be issued as necessary to ensure reliability of the bulk power system.


B.1 Identify your organization:

Company Name: Georgia Power Company 241 Ralph McGill Blvd.

Atlanta, Georgia 30308 Company Address:

NERC Compliance Registry 10: NCR01247

B.2 Identify the individual in your organization who will serve as the Contact to SERC regarding this Mitigation Plan. This person shall be technically knowledgeable regarding this Mitigation Plan and authorized to respond to SERe regarding this Mitigation Plan.

Name: Title: Email: Phone:

David Gambrell Southern Nuclear Company - Chief Engineer [email protected] 205-992-6480

Derived from NERC Form Version 1.7Page 2 of 11 Form Rev. Date - 2123/09


Appendix A-7


L~ERCSERC Reliability Corporation

of submission. Additional violations could be determined for not completing workassociated with accepted milestones.


(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.

• This submittal form shall be used to provide a required Mitigation Plan for review andapproval by SERC and NERC.

• The Mitigation Plan shall be submitted to SERC and NERC as confidentialinformation in accordance with Section 1500 of the NERC Rules of Procedure.

• This Mitigation Plan form may be used to address one or more related violations ofone Reliability Standard. A separate mitigation plan is required to address violationswith respect to each additional Reliability Standard, as applicable.

• If the Mitigation Plan is approved by SERC and NERC, a copy of this Mitigation Planwill be provided to the Federal Energy Regulatory Commission in accordance withapplicable Commission rules, regulations and orders.

• SERC or NERC may reject Mitigation Plans that they determine to be incomplete orinadequate.

• Remedial action directives also may be issued as necessary to ensure reliability ofthe bulk power system.


Company Name:Company Address:

B.1 Identify your organization:

Georgia Power Company241 Ralph McGill Blvd.

Atlanta, Georgia 30308NERC Compliance Registry 10: NCR01247

8.2 Identify the individual in your organization who will serve as the Contactto SERC regarding this Mitigation Plan. This person shall be technicallyknowledgeable regarding this Mitigation Plan and authorized to respondto SERe regarding this Mitigation Plan.

Name:Title:Email:Phone:

David GambrellSouthern Nuclear Company - Chief [email protected]



Section C:

,!jiERC SERC Reliability Corporation

Identity of Reliability Standard Violations Associated with this Mitigation Plan

, This Mitigation Plan is associated with the following violation(s) of the reliability standard listed below:


C.2 Requirement(s) violated and violation dates:

NERC Violation ID # SERC Requirement Violation Date(') [if known] Violation ID Violated

# (e.g. R3.2) [if known]

SERCVYVYnnnnn 2009-01'4 R2 4/24/2008

(*) Note: The Violation Date shall be: (i) the date that the violation occurred; (ii) the date that the violation was self-reported; or (iii) the date that the violation has been deemed to have occurred on by SERC. Questions regarding the date to use should be directed to SERG.


During April 2008 and October 2008, at Vogtle Unit 1 and Vogtle Unit 2 respectively, the eXisting Main Generator Exciter control systems were upgraded to GE EX2100 control systems. This upgrade included the installation of new Current Transformers (CTs) and the replacement of existing CTs. This upgrade involved 19 CTs per unit.

These CTs are utilized to provide a signal to Generator Protection relaying within the scope of PRC-005-1. The newly installed CTs were subjected to various functional tests to ensure the integrity and reliability of the equipment. The Vogtle testing program requires, among other things, that a Secondary Resistance (Burden) Test, a Saturation Test, and a Ratio Test, be performed on all newly installed CTs. As part of an internal review of Plant Vogtle's compliance with PRC-005, it was discovered on March 27, 2009, that the newly installed CTs were not



Appendix A-7


Section C:

\'~ERCSERC Reliability Corporation

Identity of Reliability Standard ViolationsAssociated with this Mitigation Plan

. This Mitigation Plan is associated with the following violation(s) of the reliabilitystandard listed below:


C.2 Requirement(s) violated and violation dates:

NERC Violation ID # SERC Requirement Violation Date{')[if known] Violation ID Violated

# (e.g. R3.2)[if known]

SERCVYVYnnnnn 2009-01'4 R2 4/24/2008

(*) Note: The Violation Date shall be: (i) the date that the violation occurred; (ii) the date that theviolation was self-reported; or (iii) the date that the violation has been deemed to have occurredon by SERC. Questions regarding the date to use should be directed to SERC.


During April 2008 and October 2008, at Vogtle Unit 1 and Vogtle Unit 2respectively, the eXisting Main Generator Exciter control systems wereupgraded to GE EX2100 control systems. This upgrade included theinstallation of new Current Transformers (CTs) and the replacement ofexisting CTs. This upgrade involved 19 CTs per unit.

These CTs are utilized to provide a signal to Generator Protectionrelaying within the scope of PRC-005-1. The newly installed CTs weresubjected to various functional tests to ensure the integrity and reliabilityof the equipment. The Vogtle testing program requires, among otherthings, that a Secondary Resistance (Burden) Test, a Saturation Test,and a Ratio Test, be performed on all newly installed CTs. As part of aninternal review of Plant Vogtle's compliance with PRC-005, it wasdiscovered on March 27, 2009, that the newly installed CTs were not



SERC Reliability Corporation

tested in accordance with all tests required under the Vogtle testing program. Specifically, a Secondary Resistance Test was not performed on any of the newly installed CTs at Vogtle Units 1 and 2. These tests were not performed due to a failure to ciearly communicate to plant personnel the expectations that this test should be included in the work order planning process. In addition, it cannot be confirmed that a Saturation Test ancl/or a Ratio Test had been performed for five of the newly installed CTs. Upon subsequent review of the work order package for these five CT s, it was discovered that the work orders did not include evidence of these specific tests.

[provide your response here; additional detailed information may be provided as an attachment as necessary]

CA [Optional} Provide any relevant additional information regarding the violations associated with this Mitigation Plan:

Upon identification of the potential non-compliance, a plant condition report, which is part of the Southern Nuclear's Corrective Action Program (CAP), was generated to report the potential non-compliance to corporate compliance staff and to initiate an investigation to determine the cause(s).


Section D: Details of Proposed Mitigation Plan


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 violations identified above in Part C.2 of this form:

The Secondary Resistance Tests, Saturation Tests and Ratio Tests, will be performed on these new CTs where documentation of testing can not be obtained or a documented justification for why testing is not needed will be provided. Any required testing will be completed when the units are shutdown for the next Unit 1 and Unit 2 refueling outage.



Appendix A-7


SERC Reliability Corporation

tested in accordance with all tests required under the Vogtle testingprogram. Specifically, a Secondary Resistance Test was not performedon any of the newly installed CTs at Vogtle Units 1 and 2. These testswere not performed due to a failure to dearly communicate to plantpersonnel the expectations that this test should be included in the workorder planning process. In addition, it cannot be confirmed that aSaturation Test ancl/or a Ratio Test had been performed for five of thenewly installed CTs. Upon subsequent review of the work orderpackage for these five CTs, it was discovered that the work orders didnot include evidence of these specific tests.

[provide your response here; additional detailed information may be provided as anattachment as necessary]

CA [Optional} Provide any relevant additional information regarding theviolations associated with this Mitigation Plan:

Upon identification of the potential non-compliance, a plant conditionreport, which is part of the Southern Nuclear's Corrective ActionProgram (CAP), was generated to report the potential non-compliance tocorporate compliance staff and to initiate an investigation to determinethe cause(s).


Section D: Details of Proposed Mitigation Plan


D.1 Identify and describe the action plan, including specific tasks and actionsthat your organization is proposing to undertake, or which it undertook ifthis Mitigation Plan has· been completed, to correct the violationsidentified above in Part C.2 of this form:

The Secondary Resistance Tests, Saturation Tests and Ratio Tests, willbe performed on these new CTs where documentation of testing can notbe obtained or a documented justification for why testing is not neededwill be provided. Any required testing will be completed when the unitsare shutdown for the next Unit 1 and Unit 2 refueling outage.



.!ieRc SERC REliability Corporation

Site procedures and programs will be reviewed and revised as required to ensure that CTs that fall within the scope of PRC-005-1 receive the required testing per the Plant Vogtle testing program. This review will address situations when new CTs are added or when existing CTs are replaced.

In addition, site testing procedures and programs will be reviewed and revised as required to ensure that the scope of CT testing is in alignment with the Plant Vogtle testing program.

[Provide your response here; additional detailed information may be provided as an attachment as necessary}

Check this box 0 and proceed to Section E of this form if this Mitigation Plan, as set forth in Part D.1, has already been completed; otherwise respond to Part D.2, D.3 and, optionally, Part D.4, below.


0.2 Provide the timetable for completion of the Mitigation Plan, including the completion date by which the Mitigation Plan will be fully implemented and the violations associated with this Mitigation Plan are corrected:

The milestones in 0.3 provide the time table for completion of the procedure revisions and any testing required. Final completion of the mitigation plan will be 6/30/2010.

0.3 Enter Milestone Activities, with completion dates, that your organization is proposing for this Mitigation Plan:

Milestone Activity Proposed Completion Oate* (shall not be more than 3 months apart)

Review and revise site testing 7-1-2009 procedures/programs as required to ensure that testing of CTs is performed as required by the Plant Vogtle testing program.



Appendix A-7


~!AeRcSERC REliability Corporation

Site procedures and programs will be reviewed and revised as requiredto ensure that CTs that fall within the scope of PRC-005-1 receive therequired testing per the Plant Vogtle testing program. This review willaddress situations when new CTs are added or when eXisting CTs arereplaced.

In addition, site testing procedures and programs will be reviewed andrevised as required to ensure that the scope of CT testing is in alignmentwith the Plant VogUe testing program.

[Provide your response here; additional detailed information may be provided as anattachment as necessaryJ

Check this box 0 and proceed to Section E of this form if this MitigationPlan, as set forth in Part D.1, has already been completed; otherwiserespond to Part D.2, D.3 and, optionally, Part D.4, below.


0.2 Provide the timetable for completion of the Mitigation Plan, including thecompletion date by which the Mitigation Plan will be fully implementedand the violations associated with this Mitigation Plan are corrected:

The milestones in 0.3 provide the time table for completion of theprocedure revisions and any testing required. Final completion of themitigation plan will be 6/30/2010.

0.3 Enter Milestone Activities, with completion dates, that your organizationis proposing for this Mitigation Plan:

Milestone Activity Proposed Completion Oate*(shall not be more than 3 months apart)

Review and revise site testing 7-1-2009procedures/programs as required toensure that testing of CTs is performedas required by the Plant Vogtle testingprogram.



,!AERC SERC Reliability Corporation

Review and revise site 10-1-2009 procedures/programs as required to ensure that all CT s that fall within the scope of PRC-005-1 receive the required testing as prescribed in the Plant Vogtle testing program. This includes CTs that are added or CTs that are replaced.

For the identified CTs, perform testing 12-1-2009 where documentation of testing can not be obtained or provide documented justification for not performing testing of the Unit 1 CTs.

For the identified CT s, perform testing 5-30-2010 where documentation of testing can not be obtained or provide documented justification for not performing testing of the Unit 2 CTs

(*) Note: 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.

[Note: Provide your response here; additional detailed information may be provided as an attachment as necessary]

Additional Relevant Information (Optional)

D.4 If you have any relevant additional information that you wish to include regarding the mitigation plan, milestones, milestones dates and completion date proposed above you may include it here:

The timeframes for completing the required CT testing are based on scheduled Refueling Plant outage start and finish dates. Milestone dates associated with procedure and program changes are set to allow time for the review/approval process of procedures.



Appendix A-7


~~ERCSERC Reliability Corporation

Review and revise site 10-1-2009procedures/programs as required toensure that all CTs that fall within thescope of PRC-005-1 receive therequired testing as prescribed in thePlant Vogtle testing program. Thisincludes CTs that are added or CTsthat are replaced.

For the identified CTs, perform testing 12-1-2009where documentation of testing cannot be obtained or providedocumented justification for notperforming testing of the Unit 1 CTs.

For the identified CTs, perform testing 5-30-2010where documentation of testing cannot be obtained or providedocumented justification for notperforming testing of the Unit 2 CTs

(*) Note: Implementation milestones no more than three (3) months apart for Mitigation Plans withexpected completion dates more than three (3) months from the date of submission. Additionalviolations could be determined for not completing work associated with accepted milestones.

[Note: Provide your response here; additional detailed information may be provided as anattachment as necessary]

Additional Relevant Information (Optional)

D.4 If you have any relevant additional information that you wish to includeregarding the mitigation plan, milestones, milestones dates andcompletion date proposed above you may include it here:

The timeframes for completing the required CT testing are based onscheduled Refueling Plant outage start and finish dates. Milestonedates associated with procedure and program changes are set to allowtime for the review/approval process of procedures.



'~ERC SERC Reliability Corporation

The CT testing can only be performed during a unit outage that requires the plant to be placed into a "cold shutdown" condition of 14 days or more. This is required to support the extensive clearance and tagging requirements to safely perform the test and to facilitate the evolution of removing the generator's dome to access these CTs. Accordingly, any required testing of the CTs will be performed during each unit's next scheduled refueling outage. Any required testing will be added to each unit's forced outage contingency plan. In the event such a shutdown occurs, the site will promptly evaluate conditions and, if prudent, make every reasonable effort to perform the requisite testing (barring unforeseen circumstances) which may prohibit access or otherwise preclude our ability to perform the test. This contingency will be put in place to support inclusion of this work during an outage of such duration, if it were to occur after 7-17-2009.

A quarterly update will be provided to SERC regarding the status of the milestones identified in Section D.3, beginning 7/1/09 and each quarter thereafter until the Unit 1 and Unit 2 CT testing has been performed. This update also will report on any forced outages that occurred during the quarter.



Check this box [gJ and proceed and respond to Part E.2 and E.3, below, if this Mitigation Plan, as set forth in Part D. 1, has already been completed.


E.1 While your organization is implementing the Mitigation Plan proposed in Part D of this form, the reliability of the Bulk Power System 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 or is proposing as part of the Mitigation Plan to mitigate any increased risk to the reliability of the bulk power system while the Mitigation Plan is being implemented:



Appendix A-7


~~ERCSERC Reliability Corporation

The CT testing can only be performed during a unit outage that requiresthe plant to be placed into a "cold shutdown" condition of 14 days ormore. This is required to support the extensive clearance and taggingrequirements to safely perform the test and to facilitate the evolution ofremoving the generator's dome to access these CTs. Accordingly, anyrequired testing of the CTs will be performed during each unit's nextscheduled refueling outage. Any required testing will be added to eachunit's forced outage contingency plan. In the event such a shutdownoccurs, the site will promptly evaluate conditions and, if prudent, makeevery reasonable effort to perform the requisite testing (barringunforeseen circumstances) which may prohibit access or otherwisepreclude our ability to perform the test. This contingency will be put inplace to support inclusion of this work during an outage of such duration,if it were to occur after 7-17-2009.

A quarterly update will be provided to SERC regarding the status of themilestones identified in Section D.3, beginning 7/1/09 and each quarterthereafter until the Unit 1 and Unit 2 CT testing has been performed.This update also will report on any forced outages that occurred duringthe quarter.



Check this box [gJ and proceed and respond to Part E.2 and E.3, below, ifthis Mitigation Plan, as set forth in Part D. 1, has already been completed.


E.1 While your organization is implementing the Mitigation Plan proposed inPart D of this form, the reliability of the Bulk Power System may remainat higher risk or be otherwise negatively impacted until the plan issuccessfully completed. To the extent they are, or may be, known oranticipated: (i) identify any such risks or impacts; and (ii) discuss anyactions that your organization is planning to take or is proposing as partof the Mitigation Plan to mitigate any increased risk to the reliability ofthe bulk power system while the Mitigation Plan is being implemented:



£i . ~ERC SERC REliability Corporation

These CTs were added as new components in association with the upgrade of each Unit's exciter control systems. These upgrades were installed as part of long range strategies to enhance reliability. Collectively, the installation of the new exciter control systems and these CTs is considered more reliable than the previous configuration.

Although the subject CT s were not subjected to all of the testing as described in the Vogtle testing program when they were installed, the CT loops were tested and verified to be complete and functional. No problems or issues have occurred since they were installed and commissioned. The CTs were subjected to megger and polarity tests. Therefore, delaying the Secondary Resistance, Saturation and Ratio tests until each Unit is shutdown for refueling will not impact the reliability of the Bulk Power System.



E.2 Describe how successful completion of the Mitigation Plan as laid out in Part D of this form will prevent or minimize the probability that your organization incurs further violations of the same or similar reliability standards requirements in the future:

The action planned for review/revision of site procedures/programs will ensure that CTs that fall within the scope of PRC-005-1, including CTs that are added or CTs that are replaced, receive the required testing as prescribed in the Plant Vogtle testing program. It will align our testing procedures with the Vogtle test program.


E.3 Your organization may be taking or planning other action, beyond that listed in the Mitigation Plan, as proposed in Part D.1, to prevent or minimize the probability of incurring further violations of the same or similar standards requirements listed in Part C.2, or of other reliability standards. If so, identify and describe any such action, including milestones and completion dates:



Appendix A-7


£i .~ERCSERC REliability Corporation

These CTs were added as new components in association with theupgrade of each Unit's exciter control systems. These upgrades wereinstalled as part of long range strategies to enhance reliability.Collectively, the installation of the new exciter control systems and theseCTs is considered more reliable than the previous configuration.

Although the subject CTs were not subjected to all of the testing asdescribed in the Vogtle testing program when they were installed, the CTloops were tested and verified to be complete and functional. Noproblems or issues have occurred since they were installed andcommissioned. The CTs were subjected to megger and polarity tests.Therefore, delaying the Secondary Resistance, Saturation and Ratiotests until each Unit is shutdown for refueling will not impact the reliabilityof the Bulk Power System.



E.2 Describe how successful completion of the Mitigation Plan as laid out inPart D of this form will prevent or minimize the probability that yourorganization incurs further violations of the same or similar reliabilitystandards requirements in the future:

The action planned for review/revision of site procedures/programs willensure that CTs that fall within the scope of PRC-005-1, including CTsthat are added or CTs that are replaced, receive the required testing asprescribed in the Plant VogUe testing program. It will align our testingprocedures with the Vogtle test program.


E.3 Your organization may be taking or planning other action, beyond thatlisted in the Mitigation Plan, as proposed in Part D.1, to prevent orminimize the probability of incurring further violations of the same orsimilar standards requirements listed in Part C.2, or of other reliabilitystandards. If so, identify and describe any such action, includingmilestones and completion dates:



'~eRC SERC Reliability Corporation





Appendix A-7


l,,~eRCSERC Reliability Corporation





,!iERC SERC Reliability Corporation


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


b) If applicable, certifies that the Mitigation Plan, as laid out in Section D of this form, was completed (i) as laid out in Section D of this form and (ii) on or before the date provided as the 'Date of Completion of the Mitigation Plan' on this form, and

c) Acknowledges:

1. I am Sr. Vice President, Compliance Officer and General Counsel of Georgia Power Company.

2. I am qualified to sign this Mitigation Plan on behalf of Georgia Power Company.

3. I have read and understand Georgia Power Company obligations to comply with Mitigation Plan requirements and ERO remedial action directives as well as ERO documents, including, but not limited to, the NERC Rules of Procedure, including Appendix 4(C) (Compliance Monitoring and Enforcement Program of the North American Electric Reliability Corporation" (NERC CMEP)).

4. I have read and am familiar with the contents of the foregoing Mitigation Plan.

5. Georgia Power Company agrees to be bound by, and comply with, the Mitigation Plan, including the timetable completion date, as approved by SERC and approved by NERC.

Authorized Individual Signature (Electronic signatures are acceptable; see C

Name: Thomas P. Bishop Title: Sr. Vice President, Compliance Officer and General Counsel Date: April 22, 2009



Appendix A-7


\"~ERCSERC Reliability Corporation


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

a) Submits the Mitigation Plan, as laid out in Section D of this form, toSERC for acceptance by SERC and approval by NERC, and

b) If applicable, certifies that the Mitigation Plan, as laid out in Section D ofthis form, was completed (i) as laid out in Section D of this form and (ii)on or before the date provided as the 'Date of Completion of theMitigation Plan' on this form, and

c) Acknowledges:

1. I am Sr. Vice President, Compliance Officer and General Counselof Georgia Power Company.

2. I am qualified to sign this Mitigation Plan on behalf of GeorgiaPower Company.

3. I have read and understand Georgia Power Company obligations tocomply with Mitigation Plan requirements and ERO remedial actiondirectives as well as ERO documents, including, but not limited to,the NERC Rules of Procedure, including Appendix 4(C)(Compliance Monitoring and Enforcement Program of the NorthAmerican Electric Reliability Corporation" (NERC CMEP)).

4. I have read and am familiar with the contents of the foregoingMitigation Plan.

5. Georgia Power Company agrees to be bound by, and comply with,the Mitigation Plan, including the timetable completion date, asapproved by SERC and approved by NERC.

Authorized Individual Signature(Electronic signatures are acceptable; see C

Name: Thomas P. BishopTitle: Sr. Vice President, Compliance Officer and General CounselDate: April 22, 2009



.. !iERC SERC Reliability Corporation


You may use this area to provide comments or any additional relevant information not previously addressed in this form.



Please convert the completed and signed document to a text-searchable Adobe .pdf document using the following naming convention:

[(MP EntityName (STD~XXX) MM~DD-YY.pdf)]



Ken Keels Manager, Compliance Enforcement SERC Reliability Corporation 704-357-7372 [email protected]



Appendix A-7


"~ERCSERC Reliability Corporation


You may use this area to provide comments or any additional relevantinformation not previously addressed in this form.



Please convert the completed and signed document to a text-searchableAdobe .pdf document using the following naming convention:

[(MP EntityName (STD;XXX) MM-OO·YY.pdf)]



Ken KeelsManager, Compliance EnforcementSERC Reliability [email protected]



Attachment e

Georgia Power’s Certification of Completion of the Mitigation Plan for the April 14, 2009 self-

reported violation SERC200800259 dated June 28, 2010

Public Homepage Portal Homepage

SERC Member Portal6Georgia Power Company

Logged in as:

Helen Nalley

Log Out

System Administration

Committees Compliance Self Reports Complaints Data Reporting Mitigation Plans Violation Retractions Reliability

Assessments Surveys Recommendations Meetings

Edit

Save ItemSave Item | Delete Item | Cancel ChangesCancel Changes | Save PDF | Return to Mitigation Plan

All Mitigation Plan Completion Certification submittals shall include data or information sufficient for SERC to verify completion of the Mitigation Plan. SERC may request such additional data or information and conduct follow-up assessments, on-site or other Spot Checking, or Compliance Audits as it deems necessary to verify that all required actions in the Mitigation Plan have been completed and the Registered Entity is in compliance with the subject Reliability Standard. (CMEP Section 6.6) Data or information submitted may become part of a public record upon final disposition of the possible violation, therefore any confidential information contained therein should be marked as such in accordance with the provisions of Section 1500 of the NERC Rules of Procedure.


Name of Standard of mitigation violation(s): PRC-005-1

Mitigated information:

Date of completion of the Mitigation Plan:

Summary of all actions described in Part D of the releveant mitigation plan:


I certify that the mitigation plan for the above-named violation has been completed on the date shown above. In doing so, I certify that all required mitigation plan actions described in Part D of the relevant mitigation plan have been completed, compliance has been restored, the above-named entity is currently compliant with all of th requirements of the referenced standard, and that all information submitted is complete and correct to the best of my knowledge. Submit all supporting documentation.

*Required Fields Status: Saved

Requirement Tracking Number Violation ID

R2. 09-014 SERC200900259

6/28/2010

The Secondary Resistance Tests, Saturation Tests and Ratio Tests, were performed, or test results were verified, or provide documented justification for not performing testing on the new CTs where documentation of testing could not be obtained. Required testing was completed when the units were shutdown for the Unit 1 and Unit 2 refueling outage. Site procedures and programs were reviewed and revised as required to ensure that CTs that fall within the scope of PRC-005-1 receive the required testing per the Plant Vogtle testing program. This review addressed situations when new CTs are added or when existing CTs are replaced. In addition, site testing procedures and programs were reviewed and revised as required to ensure that the scope of CT testing is in alignmentwith the Plant Vogtle testing program.

1. Plant Vogtle Program Summary Document – Program requirements to meet the NERC standard PRC-005 requirements (20210-C, Appendix A). 2. Evidence to meet milestone requirements in Part D of the Mitigation Plan: a. Milestone 1: “Review and revise site testing procedures/programs as required to ensure that testing of CTs is performed as required by the Plant Vogtle testing program.” 25086-C – A new procedure was written that provides instruction on how to perform the required testing on CTs 29401-C – This procedure establishes guidelines/requirements for assignment of functional tests on Work Orders. Post maintenance testing ensures equipment WILL perform its intended function when returned to service following maintenance activities. This procedure was revised to include the required testing from the Program Summary Document for NERC required CTs. AI 2009201653 – This is an action item created to place special indicators on the NERC required CTs. This special indicator will flag the individual that is planning the work order that it is a NERC required CT. b. Milestone 2: “Review and revise site procedures/programs as required to ensure that all CTs that fall within the scope of PRC-005-1 receive the required testing as prescribed in the Plant Vogtle testing program. This includes CTs that are added or CTs that are replaced.” 29401-C – This procedure establishes guidelines/requirements for assignment of functional tests on Work Orders. Post maintenance testing ensures equipment WILL perform its intended function when returned to service following maintenance activities. This procedure was revised to include the required testing from the Program Summary Document for NERC required CTs. 25086-C – A new procedure was written that provides instruction on how to perform the required testing on CTs NMP-ES-038-GL01 – This procedure is General Engineering Guidance. This procedure provides guidance for all engineering activities. This procedure was revised to include a review of NERC requirements that are affected by the engineering activity. c. Milestone 3: “For the identified CTs, perform testing where documentation of testing can not be obtained or provide documented justification for not performing testing of the Unit 1 CTs.” Various work orders (maintenance work orders or MWO) and field testing (Temporary Engineering procedures or T-ENG) were used to satisfy this milestone. A spreadsheet was developed to aid in identifying the location of the test performed for each CT. d. Milestone 3: “For the identified CTs, perform testing where documentation of testing can not be obtained or provide documented justification for not performing testing of the Unit 2 CTs” Various work orders (maintenance work orders or MWO) and field testing (Temporary Engineering procedures or T-ENG) were used to satisfy this milestone. A spreadsheet was developed to aid in identifying the location of the test performed for each CT.

Authorized Individual Signature Sign

Name: Helen NalleyTitle: Compliance DirectorEntity: Georgia Power CompanyEmail: [email protected]: 205-257-2055

6/28/2010 3:58:05 PM Page 1 / 2

Public Homepage Portal Homepage

SERC Member Portal6Georgia Power Company

Logged in as:

Helen Nalley

Log Out

System Administration

Committees Compliance Self Reports Complaints Data Reporting Mitigation Plans Violation Retractions Reliability

Assessments Surveys Recommendations Meetings

Edit

Save ItemSave Item | Delete Item | Cancel ChangesCancel Changes | Save PDF | Return to Mitigation Plan

All Mitigation Plan Completion Certification submittals shall include data or information sufficient for SERC to verify completion of the Mitigation Plan. SERC may request such additional data or information and conduct follow-up assessments, on-site or other Spot Checking, or Compliance Audits as it deems necessary to verify that all required actions in the Mitigation Plan have been completed and the Registered Entity is in compliance with the subject Reliability Standard. (CMEP Section 6.6) Data or information submitted may become part of a public record upon final disposition of the possible violation, therefore any confidential information contained therein should be marked as such in accordance with the provisions of Section 1500 of the NERC Rules of Procedure.


Name of Standard of mitigation violation(s): PRC-005-1

Mitigated information:

Date of completion of the Mitigation Plan:

Summary of all actions described in Part D of the releveant mitigation plan:


I certify that the mitigation plan for the above-named violation has been completed on the date shown above. In doing so, I certify that all required mitigation plan actions described in Part D of the relevant mitigation plan have been completed, compliance has been restored, the above-named entity is currently compliant with all of th requirements of the referenced standard, and that all information submitted is complete and correct to the best of my knowledge. Submit all supporting documentation.

*Required Fields Status: Saved

Requirement Tracking Number Violation ID

R2. 09-014 SERC200900259

6/28/2010

The Secondary Resistance Tests, Saturation Tests and Ratio Tests, were performed, or test results were verified, or provide documented justification for not performing testing on the new CTs where documentation of testing could not be obtained. Required testing was completed when the units were shutdown for the Unit 1 and Unit 2 refueling outage. Site procedures and programs were reviewed and revised as required to ensure that CTs that fall within the scope of PRC-005-1 receive the required testing per the Plant Vogtle testing program. This review addressed situations when new CTs are added or when existing CTs are replaced. In addition, site testing procedures and programs were reviewed and revised as required to ensure that the scope of CT testing is in alignmentwith the Plant Vogtle testing program.

1. Plant Vogtle Program Summary Document – Program requirements to meet the NERC standard PRC-005 requirements (20210-C, Appendix A). 2. Evidence to meet milestone requirements in Part D of the Mitigation Plan: a. Milestone 1: “Review and revise site testing procedures/programs as required to ensure that testing of CTs is performed as required by the Plant Vogtle testing program.” 25086-C – A new procedure was written that provides instruction on how to perform the required testing on CTs 29401-C – This procedure establishes guidelines/requirements for assignment of functional tests on Work Orders. Post maintenance testing ensures equipment WILL perform its intended function when returned to service following maintenance activities. This procedure was revised to include the required testing from the Program Summary Document for NERC required CTs. AI 2009201653 – This is an action item created to place special indicators on the NERC required CTs. This special indicator will flag the individual that is planning the work order that it is a NERC required CT. b. Milestone 2: “Review and revise site procedures/programs as required to ensure that all CTs that fall within the scope of PRC-005-1 receive the required testing as prescribed in the Plant Vogtle testing program. This includes CTs that are added or CTs that are replaced.” 29401-C – This procedure establishes guidelines/requirements for assignment of functional tests on Work Orders. Post maintenance testing ensures equipment WILL perform its intended function when returned to service following maintenance activities. This procedure was revised to include the required testing from the Program Summary Document for NERC required CTs. 25086-C – A new procedure was written that provides instruction on how to perform the required testing on CTs NMP-ES-038-GL01 – This procedure is General Engineering Guidance. This procedure provides guidance for all engineering activities. This procedure was revised to include a review of NERC requirements that are affected by the engineering activity. c. Milestone 3: “For the identified CTs, perform testing where documentation of testing can not be obtained or provide documented justification for not performing testing of the Unit 1 CTs.” Various work orders (maintenance work orders or MWO) and field testing (Temporary Engineering procedures or T-ENG) were used to satisfy this milestone. A spreadsheet was developed to aid in identifying the location of the test performed for each CT. d. Milestone 3: “For the identified CTs, perform testing where documentation of testing can not be obtained or provide documented justification for not performing testing of the Unit 2 CTs” Various work orders (maintenance work orders or MWO) and field testing (Temporary Engineering procedures or T-ENG) were used to satisfy this milestone. A spreadsheet was developed to aid in identifying the location of the test performed for each CT.

Authorized Individual Signature Sign

Name: Helen NalleyTitle: Compliance DirectorEntity: Georgia Power CompanyEmail: [email protected]: 205-257-2055

6/28/2010 3:58:05 PM Page 2 / 2

Attachment f

SERC’s Verification of Completion of the Mitigation Plan for the April 14, 2009 self-

reported violation SERC200800259 dated August 27, 2010

1


Registered Entity: Georgia Power Company SERC Tracking ID: 09-014 NERC Violation No: SERC200900259 NERC Mitigation Plan ID: MIT-08-1735 Standard: PRC-005-1 Requirement(s): R2 Violation Summary: Georgia Power Company’s (“Georgia Power”) Protection System maintenance and testing program for its Plant Vogtle (“Program”) requires a Secondary Resistance (burden) Test to be performed on all newly installed Current Transformers (“CT”)s. On March 27, 2009, as part of an internal review, Georgia Power discovered that the newly installed CTs at its Plant Vogtle were not tested as required by its Program. Specifically, a Secondary Resistance (burden)Test was not performed on any of the newly installed CTs on two units. Georgia Power completed and has documentation for all other tests required upon installation except the Secondary Resistance (burden) test for these CTs. Georgia Power was unable to produce evidence that the CTs on those two units were maintained and tested as required by its Program in violation of PRC-005-1, R2. Mitigation Plan Summary: Georgia Power’s mitigation plan to address the referenced violation was submitted on April 22, 2009 and was accepted by SERC on May 21, 2009 and approved by NERC on June 8, 2009. The mitigation plan is identified as MIT-08-1735 and was submitted as non-public information to FERC on June 8, 2009 in accordance with FERC orders. To correct the violation of PRC-005-1, R2, Georgia Power was required to complete the following actions detailed in its mitigation plan:

• Perform the Secondary Resistance (burden) Tests, Saturation Tests and Ratio Tests, on the new CTs where documentation of testing was missing or Georgia Power will provide a documented justification for why testing is not necessary. Any required testing will be completed when the units are shutdown for the next Unit 1 and Unit 2 refueling outage; and

• Site procedures and programs applicable to Plant Vogtle will be reviewed and revised as required to ensure that all CTs subject to PRC-005-1 are tested accordingly. This review will address required testing when new CTs are added or when existing CTs are replaced; and

2

• Site testing procedures and programs will be reviewed and revised as required to

ensure that the method and scope of CT testing at Plant Vogtle is in alignment with the Plant Vogtle Program.

SERC’s Monitoring of Registered Entity’s Mitigation Plan Progress: SERC Reliability Corporation Compliance staff (“SERC staff”) monitors the Registered Entity’s progress towards completion of its mitigation plan in accordance with Section 6.0 of the uniform Compliance Monitoring and Enforcement Program, (“CMEP”). Pursuant to the CMEP, Registered Entities are required to establish implementation milestones no more than three (3) months apart. SERC staff solicits quarterly reports from all Registered Entities with open mitigation plans to monitor the progress on completion of milestones. SERC staff also produces and reviews daily mitigation plan status reports highlighting mitigation plans that are nearing the scheduled completion date. If the Registered Entity fails to complete its mitigation plan according to schedule, appropriate additional enforcement action is initiated to assure compliance is attained. Mitigation Plan Completion Review Process: Georgia Power certified on June 28, 2010 that the subject mitigation plan was completed on June 28, 2010. A SERC staff member reviewed the evidence submitted in a manner similar to a compliance audit. That action was followed by another SERC compliance staff member’s peer review of the initial conclusion. Evidence Reviewed: Georgia Power submitted and SERC staff reviewed the following evidence in support of Georgia Power’s certification that its mitigation plan was completed in accordance with its terms:

• Current Transformer Testing 25086-C Rev 1 dated 6/26/09 – A pdf file of a new procedure developed to provide instruction on how to perform required testing on new CTs or CTs that are installed as replacements for existing CTs.

• Work Order Functional Tests 29401-C Rev 28 dated 6/25/09 – A pdf file of a revised procedure that establishes guidelines/requirements for assignment of functional tests on Work Orders.

• Southern Nuclear Company Guideline NMP-ES-038-GL01 – General Engineering Guidance Version 4 dated 10/09 - A pdf file of a procedure providing guidance for all engineering activities revised to include a review of such activities required by NERC Reliability Standards.

• Testing Cross Reference Vogtle Unit 1 (2) - An undated spreadsheet Georgia Power developed to aid SERC in identifying the location of the data related to the tests performed for each CT.

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• Maintenance Work Order (“MWO”) 1049001580 and MWO 2049001681 - Pdf

files of MWOs originated May 22, 2009 for Unit 1 and October 17, 2008 for Unit 2 respectively which state that the purpose of the MWO is to test newly installed CTs. These documents also contain logs of data for the tests performed including secondary resistance test and the manufacturers’ saturation test results.

Following review of this evidence, SERC staff noted that the data was either provided by the manufacturer or resulted from activities performed during the 2009 outage, not the 2010 outage as the mitigation plan proposed. On July 26, 2010 SERC staff requested additional evidence to verify completion of the mitigation plan. On August 23, 2010 SERC staff requested information regarding the justification for not performing the tests during the 2010 outage. Georgia Power provided and SERC staff reviewed the following additional evidence in support of Georgia Power’s certification that its mitigation plan was completed in accordance with its terms:

• SERC 09-014 Attestation for CT Testing .pdf – An attestation dated July 29, 2010 signed by Georgia Power’s Fleet design director stating “Prior to beginning the refueling outages the necessary test data to satisfy the mitigation plan was obtained for the secondary resistance tests and the saturation and ratio test. In some cases the test information was factory tests. In lieu of performing the tests the factory test data was reviewed and accepted…”

• An August 27, 2010 email from Georgia Power to SERC that includes the rationale for accepting the resistance tests that had been performed during installation and which eliminated the need for a “burden” test. The email also includes a statement that the manufacturers saturation testing results were included as an amendment to the completed work order.

• System Eng Email.pdf - an email dated June 9, 2009 from a Georgia Power system engineer stating that the resistance tests had been performed on all the CTs.

Conclusion: On August 27, 2010 SERC staff completed its review of the evidence submitted by Georgia Power in support of its Certification of Completion of the subject mitigation plan. Based on its review of the evidence submitted, SERC staff verifies that, in its professional judgment, all required actions in the mitigation plan have been completed and Georgia Power is in compliance with the subject Reliability Standard Requirement as of the certified date of completion of the mitigation plan, June 28, 2010.

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This Statement, along with the subject mitigation plan, may become part of a public record upon final disposition of the possible violation. Respectfully Submitted, John Wolfmeyer Linda Lynch

Attachment g

Notice of Filing

UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

Georgia Power Company Docket No. NP11-___-000

NOTICE OF FILING November 5, 2010

Take notice that on November 5, 2010, the North American Electric Reliability

Corporation (NERC) filed a Notice of Penalty regarding Georgia Power Company in the SERC Reliability 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

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