Blank Llc Operating Agreement Arizona

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					                                                                                                                                                                                                        ATTACHMENT A - OMNIBUS II SPREADSHEET




            A            B              C           D            E            F            G                                         H                                         I         J       K         L                                    M                             N         O           P                                    Q                                    R           S           T             U               V             W

                                                                             Date         Date                                                                                                                                                                                                                                                                                                  Registered
                                                                                                                                                                                                                                                                                                                                                                                                                Regional
                                                                        Identified or Identified                                                                                                                                                                                                  Total                                                                                           Entity
                                                                                           or                                                                                                                                                                                                                                                                                                                    Entity                         Prior
                                                                          Received                                                                                                           Regional Violation                                                                                  Penalty                                                                  Mitigation Mitigation Certification
                                      NOC- NERC Violation ID                            Received                                                                          Reliability                                                                                     Violation Violation                                                                                                                 Verification    Discovery       Violation
      Region     Registered Entity                             NCR_ID    (Pre-June                                      Description of the Violation                                    Req. Reliability Risk                        Risk Assessment                                               or                         Basis for the Penalty                         Plan       Plan          of
                                       ID         #                                    (Post-June                                                                         Standard                                                                                        Start Date End Date                                                                                                                 of Mitigation    Method          Filing
                                                                        18 Violation)*                                                                                                       Standard Factor                                                                                     Sanction                                                                 Number Completed Mitigation
                                                                                           18                                                                                                                                                                                                                                                                                                                     Plan                        Dockets
                                                                                                                                                                                                                                                                                                   ($)                                                                                             Plan
                                                                                                                                                                                                                                                                                                                                                                                                               Completion
 1
                                                                        *if applicable Violation)                                                                                                                                                                                                                                                                                               Completion
      WECC            Black Hills-    508    WECC200801842 NCR00089                    2/5/2008     Aquila, Inc. did not maintain and test 22 Protection System relays    PRC-005-1      2              Lower /   WECC determined this violation did not pose a           6/17/2007 12/26/2008      $0      The violation was the first violation of this Reliability     MIT-07-    12/26/2008 12/26/2008      3/8/2010      Spot Check
                 Colorado Electric                                                                  within its defined intervals. Black Hills-Colorado Electric Utility                                  High     serious or substantial risk to the bulk power system                                      Standard incurred by BHCE and it did not constitute a          2373
                Utility Company, LP                                                                 Company, LP acquired Aquila, Inc. and assumed this violation in                                               because the relays associated with this violation are                                     serious or substantial risk to the bulk power system.
                                                                                                    the acquisition. BHCE has 146 total protective devices.                                                       either electronic or micro-processor based. The
                                                                                                                                                                                                                  electronic relays send an alarm to the control center                                     BHCE assumed this violation through an acquisition on
                                                                                                                                                                                                                  upon failure of their power supply and the                                                July 14, 2008 and mitigated the prior entity's non-
                                                                                                                                                                                                                  microprocessor-based relays are self-diagnostic and                                       compliance. Although Black Hills entered the NERC
                                                                                                                                                                                                                  report relay problems when they occur. Upon alarm,                                        Compliance Registry on September 18, 2008, the
                                                                                                                                                                                                                  system operations will notify the substation                                              acquired entity was registered on the NERC
                                                                                                                                                                                                                  maintenance manager to respond and maintain or                                            Compliance Registry on June 18, 2007.
                                                                                                                                                                                                                  replace the suspect relay. Additionally, BHCE is a
                                                                                                                                                                                                                  small system in southeastern Colorado.




 2
      WECC         California         509   WECC200800662 NCR05047                     2/28/2008 CDWR did not have a Protection System Maintenance and                    PRC-005-1      1               High     WECC determined that the violation did not constitute 6/18/2007 11/25/2009        $0      The violation was self-reported, it was a documentation       MIT-08- 11/25/2009 11/30/2009         2/19/2010     Self-Report     NP10-2-
                 Department of                                                                   Testing Program, including maintenance and testing intervals and                                                 a serious or substantial risk to the bulk power system                                    issue, it was the first violation of this Reliability          0717                                                                000
                Water Resources                                                                  a summary of maintenance and testing procedures for battery,                                                     because maintenance and testing for Protection                                            Standard incurred by CDWR and it did not constitute a
                                                                                                 current & voltage sensing devices, relay calibration and DC                                                      System devices were being performed, but not as                                           serious or substantial risk to the bulk power system.
                                                                                                 control circuitry maintenance and testing needs to be formalized.,                                               required by the Standard.
                                                                                                 as required by R1.                                                                                                                                                                                         CDWR submitted three extensions to complete this
                                                                                                                                                                                                                                                                                                            Mitigation Plan, two of which were submitted after its
                                                                                                                                                                                                                                                                                                            approved completion date (CDWR's extension
                                                                                                                                                                                                                                                                                                            requests were 3 days and 5 days late). According to
                                                                                                                                                                                                                                                                                                            CDWR, during the implementation period, mandated
                                                                                                                                                                                                                                                                                                            furloughs were in place further delaying completion of
                                                                                                                                                                                                                                                                                                            the Mitigation Plans.

                                                                                                                                                                                                                                                                                                            WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                            notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                            Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                            violation.
 3
      WECC         California         509   WECC200800663 NCR05047                     2/28/2008 As noted above, CDWR did not have a Protection System                    PRC-005-1      2              Lower /   WECC determined that the violation did not constitute 6/18/2007 2/26/2010         $0      The violation was self-reported, it was the first violation   MIT-08-    2/26/2010    2/26/2010     3/8/2010      Self-Report     NP10-2-
                 Department of                                                                   Maintenance and Testing Program including defined intervals as                                          High     a serious or substantial risk to the bulk power system                                    of this Reliability Standard incurred by CDWR and it did       0717                                                                000
                Water Resources                                                                  required by R1. CDWR did not have evidence that its Protection                                                   because maintenance and testing for relays,                                               not constitute a serious or substantial risk to the bulk
                                                                                                 System devices had been tested with the defined intervals, nor                                                   batteries, current and voltage sensing devices, and                                       power system.
                                                                                                 the date each Protection System device was last maintained or                                                    DC control circuitry were being performed by CDWR,
                                                                                                 tested to demonstrate program implementation, as required by                                                     but not within defined intervals as required.                                              CDWR submitted three extensions to complete this
                                                                                                 R2.                                                                                                                                                                                                        Mitigation Plan, two of which were submitted after its
                                                                                                                                                                                                                                                                                                            approved completion date (CDWR's extension
                                                                                                    CDWR had been conducting maintenance and testing for these                                                                                                                                              requests were 3 days and 5 days late). Additionally, its
                                                                                                    Protection System devices.                                                                                                                                                                              November 30, 2009 certification of completion was
                                                                                                                                                                                                                                                                                                            rejected for PRC-005-1 R2. CDWR submitted a
                                                                                                                                                                                                                                                                                                            revised Mitigation Plan on February 1, 2010, which was
                                                                                                                                                                                                                                                                                                            completed on February 26, 2010.

                                                                                                                                                                                                                                                                                                            WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                            notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                            Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                            violation.
 4
      WECC        City of Forest      510   WECC200801561 NCR10040                     5/9/2008     CYFG did not have an Underfrequency Loadshedding (UFLS)               PRC-008-0      1              Medium WECC determined that the violation did not pose a          8/23/2007 11/30/2009      $0      The violation was the first violation of this Reliability     MIT-07- 11/30/2009 12/8/2009         12/18/2009        Self-
                 Grove Light and                                                                    equipment maintenance and testing program in place that                                                    serious or substantial risk to the bulk power system                                         Standard incurred by CYFG and it did not constitute a          2191                                               Certification
                      Power                                                                         included UFLS equipment identification, the schedule for UFLS                                              because CYFG’s UFLS program was designed to trip                                             serious or substantial risk to the bulk power system.
                                                                                                    equipment testing, and the schedule for UFLS equipment                                                     a single breaker and represents a small load in a
                                                                                                    maintenance.                                                                                               much larger system.




 5




1/13/2011                                                                                                                                                                                                                                                                                                                                                                                                                                             PAGE 1 OF 14
                                                                                                                                                                                                         ATTACHMENT A - OMNIBUS II SPREADSHEET




            A            B              C           D            E            F            G                                          H                                         I         J       K         L                                    M                          N          O           P                                    Q                                    R           S           T             U               V             W

                                                                             Date         Date                                                                                                                                                                                                                                                                                                 Registered
                                                                                                                                                                                                                                                                                                                                                                                                               Regional
                                                                        Identified or Identified                                                                                                                                                                                                 Total                                                                                           Entity
                                                                                           or                                                                                                                                                                                                                                                                                                                   Entity                         Prior
                                                                          Received                                                                                                            Regional Violation                                                                                Penalty                                                                  Mitigation Mitigation Certification
                                      NOC- NERC Violation ID                            Received                                                                           Reliability                                                                                 Violation Violation                                                                                                                   Verification    Discovery       Violation
      Region    Registered Entity                              NCR_ID    (Pre-June                                       Description of the Violation                                    Req. Reliability Risk                        Risk Assessment                                             or                          Basis for the Penalty                        Plan       Plan          of
                                       ID         #                                    (Post-June                                                                          Standard                                                                                    Start Date End Date                                                                                                                   of Mitigation    Method          Filing
                                                                        18 Violation)*                                                                                                        Standard Factor                                                                                   Sanction                                                                 Number Completed Mitigation
                                                                                           18                                                                                                                                                                                                                                                                                                                    Plan                        Dockets
                                                                                                                                                                                                                                                                                                  ($)                                                                                             Plan
                                                                                                                                                                                                                                                                                                                                                                                                              Completion
 1
                                                                        *if applicable Violation)                                                                                                                                                                                                                                                                                              Completion
      WECC       City of Forest       510   WECC200801562 NCR10040                     5/9/2008     Because CYFG did not have a UFLS equipment maintenance                 PRC-008-0      2              Medium WECC determined that the violation did not pose a      8/23/2007 11/30/2009        $0      The violation was the first violation of this Reliability     MIT-07- 11/30/2009 12/8/2009         12/18/2009        Self-
                Grove Light and                                                                     and testing program as required by R1, it could not respond to                                              serious or substantial risk to the bulk power system                                       Standard incurred by CYFG and it did not constitute a          2191                                               Certification
                     Power                                                                          WECC's request for UFLS maintenance and equipment testing                                                   because CYFG’s UFLS program was designed to trip                                           serious or substantial risk to the bulk power system.
                                                                                                    results (for an off-site audit) within 30 day as required by R2.                                            a single breaker and represents a small load in a
                                                                                                                                                                                                                much larger system.




 6
      WECC        City of Ukiah       521    WECC200701840 NCR05494                   11/30/2007 CYUK did not annually update its Underfrequency Loadshedding              PRC-007-0      2               Lower    WECC determined this violation did not pose a          8/10/2007 6/10/2008      $0      The violation was self-reported, it was the first violation   MIT-07-    6/10/2008    6/23/2008     3/8/2010      Self-Report     NP10-2-
                                                                                                 (UFLS) data. CYUK did not have documented operations settings                                                     serious or substantial risk to the bulk power system                                    of this Reliability Standard incurred by CYUK and it did       2371                                                                000
                                                                                                 related to the UFLS system, could not ensure its UFLS system                                                      because CYUK was connected to the bulk power                                            not constitute a serious or substantial risk to the bulk
                                                                                                 met WECC Criteria, and did not have a procedure to report and                                                     system by a single 115 kV single circuit transmission                                   power system.
                                                                                                 annually update information in a UFLS program database.                                                           line that served CYUK's system. Additionally, 1)
                                                                                                                                                                                                                   CYUK represents a small load, 34 MW, within a larger                                    CYUK did not complete the November 2007 Mitigation
                                                                                                                                                                                                                   entity's footprint, and 2) inconsistencies with CYUK's                                  Plan. Thus WECC issued a NAVAPS, and CYUK
                                                                                                                                                                                                                   UFLS program would have little effect on the UFLS in                                    submitted a revised Mitigation Plan on June 23, 2008,
                                                                                                                                                                                                                   CYUK's area. This was later evidenced by the larger                                     stating completion on June 10, 2008.
                                                                                                                                                                                                                   entity's determination that CYUK's load provided such
                                                                                                                                                                                                                   marginal benefit to the overall UFLS program, that                                      WECC considered these factors and determined that,
                                                                                                                                                                                                                   the larger entity ultimately removed CYUK from the                                      notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                   area's UFLS program.                                                                    Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                           violation.




 7
      WECC      Imperial Irrigation   512    WECC200810402 NCR05195      5/15/2007     7/1/2008     IID did not study transient stability studies demonstrating that its   TPL-003-0      1              High / WECC determined this violation did not pose a           6/18/2007   3/5/2009       $0      The violation was self-reported, it was the first violation   MIT-07-     3/5/2009     3/5/2009     4/8/2009      Self-Report
                     District                                                                       system performance meets Table 1 for Category C contingencies.                                       Medium serious or substantial risk to the bulk power system                                       of this Reliability Standard incurred by IID and it did not    1579
                                                                                                                                                                                                                because IID completed power flow studies, even                                             constitute a serious or substantial risk to the bulk
                                                                                                                                                                                                                though it did not evaluate the risks and consequences                                      power system. This pre-June 18 violation became an
                                                                                                                                                                                                                of Category C contingencies. IID has a peak load of                                        enforceable post-June 18, 2007 violation when WECC
                                                                                                                                                                                                                950 MW, located in the Southeastern part of the State                                      rejected IID's pre-June 18, 2007 completed mitigation
                                                                                                                                                                                                                of California, surrounded by, and interconnecting with,                                    plan.
                                                                                                                                                                                                                multiple Transmission Operators and Balancing
                                                                                                                                                                                                                Authorities.                                                                               IID's completed Mitigation Plan for the related pre-June
                                                                                                                                                                                                                                                                                                           18 violation (also WECC200810402) was submitted to
                                                                                                                                                                                                                                                                                                           WECC on 6/30/2008, however, IID's pre-June 18
                                                                                                                                                                                                                                                                                                           Mitigation did not include a transient stability analysis
                                                                                                                                                                                                                                                                                                           under a N-2 condition. WECC rejected the pre-June
                                                                                                                                                                                                                                                                                                           18 completed Mitigation Plan on 2/20/2009, which
                                                                                                                                                                                                                                                                                                           resulted in this post-June 18 violation.

                                                                                                                                                                                                                                                                                                           WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                           notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                           Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                           violation.
 8
      WECC      Imperial Irrigation   512    WECC200810403 NCR05195      5/18/2007     7/1/2008     IID did not study transient stability studies demonstrating that its   TPL-004-0      1              Medium WECC determined this violation did not pose a          6/18/2007    3/5/2009       $0      The violation was self-reported, it was the first violation   MIT-07-     3/5/2009     3/5/2009     4/8/2009      Self-Report
                     District                                                                       system performance meets Table 1 for Category D                                                             serious or substantial risk to the bulk power system                                       of this Reliability Standard incurred by IID and it did not    1580
                                                                                                    contingencies.                                                                                              because IID completed power flow studies, even                                             constitute a serious or substantial risk to the bulk
                                                                                                                                                                                                                though it did not evaluate the risks and consequences                                      power system. This pre-June 18 violation became a
                                                                                                                                                                                                                of Category C contingencies. IID has a peak load of                                        post-June 18, 2007 violation when WECC rejected
                                                                                                                                                                                                                950 MW, located in the Southeastern part of the State                                      IID's pre-June 18, 2007 completed mitigation plan.
                                                                                                                                                                                                                of California, surrounded by and interconnecting with,
                                                                                                                                                                                                                multiple Transmission Operators and Balancing                                              IID's completed Mitigation Plan for the related pre-June
                                                                                                                                                                                                                Authorities.                                                                               18 violation (also WECC200810403) was submitted to
                                                                                                                                                                                                                                                                                                           WECC on 6/30/2008, however IID did not complete its
                                                                                                                                                                                                                                                                                                           pre-June 18 Mitigation Plan because it did not include
                                                                                                                                                                                                                                                                                                           a transient stability analysis under extreme contingency
                                                                                                                                                                                                                                                                                                           conditions. WECC rejected the pre-June 18 completed
                                                                                                                                                                                                                                                                                                           Mitigation Plan on 2/20/2009, which resulted in this
                                                                                                                                                                                                                                                                                                           post-June 18 violation.

                                                                                                                                                                                                                                                                                                           WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                           notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                           Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                           violation.


 9




1/13/2011                                                                                                                                                                                                                                                                                                                                                                                                                                            PAGE 2 OF 14
                                                                                                                                                                                                         ATTACHMENT A - OMNIBUS II SPREADSHEET




            A            B              C           D            E            F            G                                          H                                         I         J       K         L                                    M                            N           O          P                                    Q                                    R           S           T             U              V            W

                                                                             Date         Date                                                                                                                                                                                                                                                                                                   Registered
                                                                                                                                                                                                                                                                                                                                                                                                                 Regional
                                                                        Identified or Identified                                                                                                                                                                                                   Total                                                                                           Entity
                                                                                           or                                                                                                                                                                                                                                                                                                                     Entity                       Prior
                                                                          Received                                                                                                            Regional Violation                                                                                  Penalty                                                                  Mitigation Mitigation Certification
                                      NOC- NERC Violation ID                            Received                                                                           Reliability                                                                                   Violation Violation                                                                                                                   Verification    Discovery     Violation
      Region     Registered Entity                             NCR_ID    (Pre-June                                      Description of the Violation                                     Req. Reliability Risk                        Risk Assessment                                               or                          Basis for the Penalty                        Plan       Plan          of
                                       ID         #                                    (Post-June                                                                          Standard                                                                                      Start Date End Date                                                                                                                   of Mitigation    Method        Filing
                                                                        18 Violation)*                                                                                                        Standard Factor                                                                                     Sanction                                                                 Number Completed Mitigation
                                                                                           18                                                                                                                                                                                                                                                                                                                      Plan                      Dockets
                                                                                                                                                                                                                                                                                                    ($)                                                                                             Plan
                                                                                                                                                                                                                                                                                                                                                                                                                Completion
 1
                                                                        *if applicable Violation)                                                                                                                                                                                                                                                                                                Completion
      WECC      Imperial Irrigation   512    WECC200810404 NCR05195      5/18/2007     7/1/2008     IID did not study transient stability studies demonstrating that its   TPL-004-0      2               Lower    WECC determined this violation did not pose a           6/18/2007   3/5/2009      $0      The violation was self-reported, it was the first violation   MIT-07-     3/5/2009     3/5/2009     4/8/2009      Self-Report
                     District                                                                       system performance meets Table 1 for Category D contingencies                                                  serious or substantial risk to the bulk power system                                      of this Reliability Standard incurred by IID and it did not    1580
                                                                                                    as required by R1, and therefore did not have documentation and                                                because IID completed power flow studies, even                                            constitute a serious or substantial risk to the bulk
                                                                                                    would not have been able to provide it to WECC.                                                                though it did not evaluate the risks and consequences                                     power system. This pre-June 18 violation became a
                                                                                                                                                                                                                   of Category C contingencies. IID has a peak load of                                       post-June 18, 2007 violation when WECC rejected
                                                                                                                                                                                                                   950 MW, located in the Southeastern part of the State                                     IID's pre-June 18, 2007 completed mitigation plan.
                                                                                                                                                                                                                   of California, surrounded by, and interconnecting with,
                                                                                                                                                                                                                   multiple Transmission Operators and Balancing                                             IID's completed Mitigation Plan for the related pre-June
                                                                                                                                                                                                                   Authorities.                                                                              18 violation (also WECC200810404) was submitted to
                                                                                                                                                                                                                                                                                                             WECC on 6/30/2008, however IID did not to complete
                                                                                                                                                                                                                                                                                                             its pre-June 18 Mitigation Plan because it did not
                                                                                                                                                                                                                                                                                                             include a transient stability analysis under extreme
                                                                                                                                                                                                                                                                                                             contingency conditions. WECC rejected the pre-June
                                                                                                                                                                                                                                                                                                             18 completed Mitigation Plan on 2/20/2009, which
                                                                                                                                                                                                                                                                                                             resulted in this post-June 18 violation.

                                                                                                                                                                                                                                                                                                             WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                             notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                             Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                             violation.


 10
      WECC       National Nuclear     N/A   WECC200700190 NCR05515                    4/10/2008 NNSAL 1) was not testing or maintaining all of its Protection              PRC-005-1      2              Lower /   WECC determined that the violation did not constitute 8/10/2007 2/22/2010         $0      The violation was self-reported, it was the first violation   MIT-08-    2/22/2010    3/1/2010      3/8/2010      Self-Report   NP10-2-
                     Security                                                                   System devices and 2) was not maintaining and testing all of its                                          High     a serious or substantial risk to the bulk power system                                    of this Reliability Standard incurred by NNSAL and it          1012                                                              000
                 Administration -                                                               Protection System devices that were included in its program                                                        because NNSAL's non-compliance was confined to its                                        did not constitute a serious or substantial risk to the
                   Los Alamos                                                                   within defined intervals. Further NNSAL did not have                                                               115 kV system's Protection System devices. Any                                            bulk power system.
                National Laboratory                                                             documentation of its Protection System maintenance and testing                                                     failure on NNSAL's 115 kV system would be
                                                                                                as required by the Standard.                                                                                       prevented from impacting the bulk power system by                                         NNSAL submitted two extensions to complete this
                                                                                                                                                                                                                   the Protection System devices NNSAL had on its 230                                        Mitigation Plan, one of which was submitted two
                                                                                                                                                                                                                   kV system, and NNSAL was maintaining and testing                                          months after its last approved completion date.
                                                                                                                                                                                                                   its Protection System devices on its 230 kV system.
                                                                                                                                                                                                                                                                                                              WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                             notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                             Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                             violation.




 11
      WECC         Navopache          514   WECC200800776 NCR05260                     3/31/2008 Navopache's Protection System Maintenance and Testing                     PRC-005-1      1               High     WECC determined that the violation did not constitute 6/18/2007 10/22/2009        $0      The violation was self-reported, it was the first violation   MIT-08- 10/22/2009 10/23/2009         1/15/2010     Self-Report   NP10-2-
                    Electric                                                                     Program did not contain maintenance and testing intervals and                                                     a serious or substantial risk to the bulk power system                                    of this Reliability Standard incurred by NPEC and it did       1008                                                              000
                 Cooperative, Inc.                                                               their basis, nor a summary of its maintenance and testing                                                         because it was limited to one facility which is                                           not constitute a serious or substantial risk to the bulk
                                                                                                 procedures as required by the Standard.                                                                           connected to the bulk power system at one radial                                          power system.
                                                                                                                                                                                                                   connection.
                                                                                                                                                                                                                                                                                                             NPEC submitted five extensions to complete this
                                                                                                                                                                                                                                                                                                             Mitigation Plan, the last of which was submitted two
                                                                                                                                                                                                                                                                                                             months after its approved completion date.

                                                                                                                                                                                                                                                                                                             WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                             notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                             Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                             violation.




 12
      WECC         Navopache          514   WECC200800777 NCR05260                     3/31/2008 Navopache did not maintain and test its Protection System                 PRC-005-1      2              Lower /   WECC determined that the violation did not constitute 6/18/2007 10/22/2009        $0      The violation was self-reported, it was the first violation   MIT-08- 10/22/2009 10/23/2009         1/15/2010     Self-Report   NP10-2-
                    Electric                                                                     devices within defined intervals at the Navopache Coronado                                               High     a serious or substantial risk to the bulk power system                                    of this Reliability Standard incurred by NPEC and it did       1008                                                              000
                 Cooperative, Inc.                                                               Substation delivery point in St. Johns, Arizona.                                                                  because it was limited to one facility which is                                           not constitute a serious or substantial risk to the bulk
                                                                                                                                                                                                                   connected to the bulk power system at one radial                                          power system.
                                                                                                                                                                                                                   connection.
                                                                                                                                                                                                                                                                                                             NPEC submitted five extensions to complete this
                                                                                                                                                                                                                                                                                                             Mitigation Plan, the last of which was submitted two
                                                                                                                                                                                                                                                                                                             months after its approved completion date.

                                                                                                                                                                                                                                                                                                             WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                             notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                             Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                             violation.




 13




1/13/2011                                                                                                                                                                                                                                                                                                                                                                                                                                            PAGE 3 OF 14
                                                                                                                                                                                                  ATTACHMENT A - OMNIBUS II SPREADSHEET




            A           B             C           D            E            F            G                                        H                                      I         J       K         L                                    M                              N         O          P                                    Q                                    R           S           T             U              V            W

                                                                           Date         Date                                                                                                                                                                                                                                                                                              Registered
                                                                                                                                                                                                                                                                                                                                                                                                          Regional
                                                                      Identified or Identified                                                                                                                                                                                              Total                                                                                           Entity
                                                                                         or                                                                                                                                                                                                                                                                                                                Entity                       Prior
                                                                        Received                                                                                                       Regional Violation                                                                                  Penalty                                                                  Mitigation Mitigation Certification
                                    NOC- NERC Violation ID                            Received                                                                      Reliability                                                                                      Violation Violation                                                                                                                Verification    Discovery     Violation
      Region    Registered Entity                            NCR_ID    (Pre-June                                     Description of the Violation                                 Req. Reliability Risk                        Risk Assessment                                               or                          Basis for the Penalty                        Plan       Plan          of
                                     ID         #                                    (Post-June                                                                     Standard                                                                                         Start Date End Date                                                                                                                of Mitigation    Method        Filing
                                                                      18 Violation)*                                                                                                   Standard Factor                                                                                     Sanction                                                                 Number Completed Mitigation
                                                                                         18                                                                                                                                                                                                                                                                                                                 Plan                      Dockets
                                                                                                                                                                                                                                                                                             ($)                                                                                             Plan
                                                                                                                                                                                                                                                                                                                                                                                                         Completion
 1
                                                                      *if applicable Violation)                                                                                                                                                                                                                                                                                           Completion
      WECC        Navopache         514   WECC200800778 NCR05260                     3/31/2008 NPEC did not have a Underfrequency Load Shedding (UFLS)              PRC-008-0      1              Medium WECC determined that the violation did not constitute 6/18/2007 10/14/2008           $0      The violation was self-reported, it was the first violation   MIT-08- 10/14/2008 10/23/2009         12/2/2009     Self-Report   NP10-2-
                   Electric                                                                    equipment maintenance and testing program as required by the                                              a serious or substantial risk to the bulk power system                                       of this Reliability Standard incurred by NPEC and it did       1009                                                              000
                Cooperative, Inc.                                                              Standard.                                                                                                 because limited to one facility which is connected to                                        not constitute a serious or substantial risk to the bulk
                                                                                                                                                                                                         the bulk power system at one radial connection.                                              power system.

                                                                                                                                                                                                                                                                                                      NPEC submitted five extensions to complete this
                                                                                                                                                                                                                                                                                                      Mitigation Plan, the last of which was submitted two
                                                                                                                                                                                                                                                                                                      months after its approved completion date.

                                                                                                                                                                                                                                                                                                      WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                      notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                      Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                      violation.




 14
      WECC        Navopache         514   WECC200800779 NCR05260                     3/31/2008     NPEC did not implement its Underfrequency Loadshedding           PRC-008-0      2              Medium WECC determined that the violation did not constitute 6/18/2007 10/14/2009           $0      The violation was self-reported, it was the first violation   MIT-08- 10/14/2009 10/23/2009         12/2/2009     Self-Report   NP10-2-
                   Electric                                                                       (UFLS) equipment maintenance and testing program and could                                             a serious or substantial risk to the bulk power system                                       of this Reliability Standard incurred by NPEC and it did       1009                                                              000
                Cooperative, Inc.                                                                 not provide its UFLS maintenance and testing program results to                                        because it was limited to one facility which is                                              not constitute a serious or substantial risk to the bulk
                                                                                                  WECC and NERC within 30 days of WECC's request.                                                        connected to the bulk power system at one radial                                             power system.
                                                                                                  Maintenance and testing of Navopache's UFLS equipment has                                              connection.
                                                                                                  not been on regular intervals at the Navopache Coronado                                                                                                                                             NPEC submitted five extensions to complete this
                                                                                                  Substation delivery point in St. Johns, Arizona.                                                                                                                                                    Mitigation Plan, the last of which was submitted two
                                                                                                                                                                                                                                                                                                      months after its approved completion date.

                                                                                                                                                                                                                                                                                                      WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                      notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                      Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                      violation.




 15
      WECC       Public Service     515    WECC200810410 NCR05333       6/4/2007     9/5/2007     PNM did not coordinate its protection systems on major            PRC-001-1      4               High     WECC determined that the violation did not constitute    6/18/2007 3/31/2009      $0      The violation was self-reported, it was the first violation   MIT-07-    3/31/2009     7/7/2009     9/23/2009     Self-Report    NP10-
                Company of New                                                                    transmission lines and interconnections with neighboring                                                  a serious or substantial risk to the bulk power system                                    of this Reliability Standard incurred by PNM and it did        1583                                                             158-000
                    Mexico                                                                        Generator Operators, Transmission Operators, and Balancing                                                because PNM was communicating with neighboring                                            not constitute a serious or substantial risk to the bulk
                                                                                                  Authorities.                                                                                              Generator Operators, Transmission Operators, and                                          power system.
                                                                                                                                                                                                            Balancing Authorities, even though it did not
                                                                                                                                                                                                            coordinate its protection systems as required by the                                      This pre-June 18 violation became a post-June 18,
                                                                                                                                                                                                            Standard.                                                                                 2007 violation when WECC rejected PNM's pre-June
                                                                                                                                                                                                                                                                                                      18, 2007 completed mitigation plan (also
                                                                                                                                                                                                                                                                                                      WECC200702835).




 16
      WECC       Sacramento         110    WECC200800791 NCR05368                    3/5/2008     SMUD did not operate nine generating units with the AVR control   VAR-STD-              WR1      N/A      WECC determined that the violation did not constitute 6/18/2007 2/29/2008, $35,000 SMUD's violation occurred for three consecutive                      MIT-08-     3/5/2008    5/2/2008      11/7/2008     Self-Report NP10-29-
                Municipal Utility                                                                 mode operating in the automatic voltage control mode. SMUD's        002a                                  a serious or substantial risk to the bulk power system           when the          calendar quarters. SMUD's violation is a Level 4 in the               1016                                                            000,
                    District                                                                      nine generating units associated with this violation have an                                              because the GE excitation systems were controlling                actions          Levels of Non-Compliance because the generating                                                                                      NP10-2-
                                                                                                  aggregate capability of 732 MW.                                                                           voltage under all conditions, even when placed in                creating          units involved in this violation were not in automatic                                                                                000,
                                                                                                                                                                                                            Power Factor (PF) or VAR control modes.                            non-            voltage control mode for all hours prior to February 29                                                                               NP10-
                                                                                                                                                                                                                                                                            compliance         2008. The violation was self-reported, it was the first                                                                              106-000
                                                                                                                                                                                                                                                                              ceased           violation of this Reliability Standard incurred by SMUD
                                                                                                                                                                                                                                                                                               and it did not constitute a serious or substantial risk to
                                                                                                                                                                                                                                                                                               the bulk power system.

                                                                                                                                                                                                                                                                                                      Although the violation began on June 18, 2007, for the
                                                                                                                                                                                                                                                                                                      purposes of assessing a penalty, WECC considered
                                                                                                                                                                                                                                                                                                      three quarters of non-compliance, from July 1, 2008
                                                                                                                                                                                                                                                                                                      through March 31, 2009.




 17




1/13/2011                                                                                                                                                                                                                                                                                                                                                                                                                                     PAGE 4 OF 14
                                                                                                                                                                                                       ATTACHMENT A - OMNIBUS II SPREADSHEET




            A             B               C           D            E            F            G                                       H                                        I         J       K         L                                    M                               N         O           P                                    Q                                    R           S           T             U                V             W

                                                                               Date         Date                                                                                                                                                                                                                                                                                                 Registered
                                                                                                                                                                                                                                                                                                                                                                                                                 Regional
                                                                          Identified or Identified                                                                                                                                                                                                 Total                                                                                           Entity
                                                                                             or                                                                                                                                                                                                                                                                                                                   Entity                          Prior
                                                                            Received                                                                                                        Regional Violation                                                                                    Penalty                                                                  Mitigation Mitigation Certification
                                        NOC- NERC Violation ID                            Received                                                                       Reliability                                                                                       Violation Violation                                                                                                                 Verification     Discovery       Violation
      Region    Registered Entity                                NCR_ID    (Pre-June                                    Description of the Violation                                   Req. Reliability Risk                        Risk Assessment                                                 or                          Basis for the Penalty                        Plan       Plan          of
                                         ID         #                                    (Post-June                                                                      Standard                                                                                          Start Date End Date                                                                                                                 of Mitigation     Method          Filing
                                                                          18 Violation)*                                                                                                    Standard Factor                                                                                       Sanction                                                                 Number Completed Mitigation
                                                                                             18                                                                                                                                                                                                                                                                                                                    Plan                         Dockets
                                                                                                                                                                                                                                                                                                    ($)                                                                                             Plan
                                                                                                                                                                                                                                                                                                                                                                                                                Completion
 1
                                                                          *if applicable Violation)                                                                                                                                                                                                                                                                                              Completion
      WECC      Southern Nevada         N/A   WECC200801841 NCR05400                     6/18/2007 SNWA did not have evidence that it was providing information as       TOP-005-1      4              Medium WECC determined this violation did not pose a                6/18/2007 11/18/2008      $0      This was the first violation of this Reliability Standard     MIT-08- 11/18/2008 11/18/2008            final          Self-
                 Water Authority                                                                   requested by its Host Balancing Authorities and Transmission                                               serious or substantial risk to the bulk power system                                           incurred by SNWA and it did not constitute a serious or        2372                                verification    Certification
                                                                                                   Operators to enable them to conduct operational reliability                                                because SNWA's load is constant from an operations                                             substantial risk to the bulk power system.                                                         letter 3/8/10
                                                                                                   assessments and coordinate reliable operations.                                                            standpoint and represents a relatively small portion of
                                                                                                                                                                                                              its Host Balancing Authority and Transmission
                                                                                                                                                                                                              Operator's total load.




 18
      WECC TransAlta Centralia          517    WECC200801004 NCR05533                    7/10/2008 Because TACG did not include five relay types in its generation       PRC-005-1      2              Lower /   WECC determined that the violation did not constitute 8/10/2007 7/10/2009           $0      The violation was self-reported, it was the first violation   MIT-08-    7/10/2009    7/10/2009     9/29/2009      Self-Report     NP10-2-
            Generation, LLC                                                                        Protection System Maintenance and Testing Program.                                                   High     a serious or substantial risk to the bulk power system                                      of this Reliability Standard incurred by the registered        0955                                                                 000
                                                                                                   Therefore, TACG could not provide documentation of                                                            because all relays included in TACG's Protection                                            entity TACG and it did not constitute a serious or
                                                                                                   implementation of its program for these five relay types, including                                           System Maintenance and Testing Program were                                                 substantial risk to the bulk power system.
                                                                                                   evidence Protection System devices were maintained and tested                                                 tested. The relays that were not included were for the
                                                                                                   within the defined intervals and the date each Protection System                                              5 TACG Big Hanaford units, which had run for a
                                                                                                   device was last tested or maintained.                                                                         maximum of 3 months every year since they were
                                                                                                                                                                                                                 built in 2002 and all of the untested relays were either
                                                                                                                                                                                                                 continuously monitored, had alarm monitoring
                                                                                                                                                                                                                 systems or had back-up relays with the exception of
                                                                                                                                                                                                                 Relay 259 (earth fault protection with very low
                                                                                                                                                                                                                 probability of fault occurring (5%)). All the generator
                                                                                                                                                                                                                 Protection System relays were tested when the units
                                                                                                                                                                                                                 were commissioned in 2002. The generation
                                                                                                                                                                                                                 protection relays were due for testing in 2008 based
                                                                                                                                                                                                                 on a six year testing interval. TACG was unable to
                                                                                                                                                                                                                 locate the test records for the trip relays only.
 19
      WECC      Tri-Dam Project of      N/A   WECC200801575 NCR05431                     7/10/2008 OSJID did not have a documented methodology used for                  FAC-008-1      1             Medium WECC determined that the violation did not pose a             6/18/2007 12/28/2009      $0      The violation was the first violation of this Reliability     MIT-07- 12/28/2009 1/15/2010          1/29/2010         Self-        NP10-2-
                 the Oakdale and                                                                   developing Facility Ratings (Facility Ratings Methodology) for its                                 / Lower serious or substantial risk to the bulk power system                                           Standard incurred by OSJID and it did not constitute a         1988                                                Certification    000
                   South Joaquin                                                                   solely and jointly owned Facilities.                                                                       because OSJID had facility ratings in place. OSJID                                             serious or substantial risk to the bulk power system.
                 Irrigation Districts                                                                                                                                                                         was using manufacturer's suggested ratings and was
                                                                                                                                                                                                              considering the most limiting factor.

 20
      WECC      Tri-Dam Project of      N/A   WECC200801576 NCR05431                     7/10/2008 OSJID did not have a Protection System Maintenance and                PRC-005-1      1               High     WECC determined that the violation did not pose a         6/18/2007 12/28/2009      $0      The violation was the first violation of this Reliability     MIT-07- 12/28/2009 12/28/2009         2/9/2010          Self-        NP10-2-
                 the Oakdale and                                                                   Testing Program as required by the Standard.                                                                  serious or substantial risk to the bulk power system                                        Standard incurred by OSJID and it did not constitute a         1988                                                Certification    000
                   South Joaquin                                                                                                                                                                                 because OSJID had some maintenance procedures                                               serious or substantial risk to the bulk power system.
                 Irrigation Districts                                                                                                                                                                            and was maintaining its protection systems, although
                                                                                                                                                                                                                 not as required by the Standard. Additionally, the
                                                                                                                                                                                                                 violation did not pose a serious or substantial risk to
                                                                                                                                                                                                                 the bulk power system because of the nature and
                                                                                                                                                                                                                 location of OSJID's system.


 21
      WECC      Tri-Dam Project of      N/A   WECC200801577 NCR05431                     7/10/2008 OSJID did not provide evidence of maintenance and testing, or         PRC-005-1      2              Lower /   WECC determined that the violation did not pose a         6/18/2007 2/25/2010       $0      The violation was the first violation of this Reliability     MIT-07-    2/25/2010    2/25/2010     3/8/2010          Self-        NP10-2-
                 the Oakdale and                                                                   the date its Protection System devices were last tested, and                                         High     serious or substantial risk to the bulk power system                                        Standard incurred by OSJID and it did not constitute a         1988                                                Certification    000
                   South Joaquin                                                                   therefore could not have provided it to WECC within 30 calendar                                               because OSJID has some maintenance procedures                                               serious or substantial risk to the bulk power system.
                 Irrigation Districts                                                              days as required by the Standard.                                                                             and was maintaining its protection systems, although
                                                                                                                                                                                                                 not as required by the Standard. Additionally, the
                                                                                                                                                                                                                 violation did not pose a serious or substantial risk to
                                                                                                                                                                                                                 the bulk power system because of the nature and
                                                                                                                                                                                                                 location of OSJID's system.


 22
      WECC      USACE-Portland          519    WECC200801717 NCR05538                    6/30/2008 USACE-Portland District did not include all applicable Protection     PRC-005-1      1               High     WECC determined that the violation did not constitute     8/10/2007 12/31/2008      $0      The violation did not pose serious or substantial risk to     MIT-08-    12/31/2008 12/31/2008     11/11/2009         Self-        NP10-2-
                   District                                                                        System devices, specifically voltage and current sensing devices                                              a serious or substantial risk to the bulk power system                                      the bulk power system. As explained in the cover NOP,          2126                                                Certification    000
                                                                                                   and DC control circuitry, in its maintenance and testing program.                                             because USACE-Portland District had a Protection                                            WECC considered that USACE-Portland District had a
                                                                                                                                                                                                                 System Maintenance and Testing Program, and                                                 separate prior violation of this Reliability Standard.
                                                                                                                                                                                                                 USACE-Portland District's Maintenance and Testing
                                                                                                                                                                                                                 Program included protective relays, associated
                                                                                                                                                                                                                 communication systems, and station batteries.


 23
      WECC      USACE-Portland          519    WECC200801718 NCR05538                    6/30/2008 USACE-Portland District did not include all applicable Protection     PRC-005-1      2              Lower /   WECC determined that the violation did not constitute     8/10/2007 12/31/2008      $0      The violation did not pose serious or substantial risk to     MIT-08-    12/31/2008 12/31/2008     11/11/2009         Self-        NP10-2-
                   District                                                                        System devices, specifically voltage and current sensing devices                                     High     a serious or substantial risk to the bulk power system                                      the bulk power system. As explained in the cover NOP,          2126                                                Certification    000
                                                                                                   and DC control circuitry, in its maintenance and testing program                                              because USACE-Portland District had a Protection                                            WECC considered that USACE-Portland District had a
                                                                                                   and therefore was not conducting the testing of the missing                                                   System Maintenance and Testing Program, and                                                 separate prior violation of this Reliability Standard.
                                                                                                   devices.                                                                                                      USACE-Portland District's maintenance and testing
                                                                                                                                                                                                                 program included protective relays, associated
                                                                                                                                                                                                                 communication systems, and station batteries.



 24




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                                                                                                                                                                                                   ATTACHMENT A - OMNIBUS II SPREADSHEET




            A           B             C           D            E            F            G                                        H                                       I         J       K         L                                    M                              N         O          P                                    Q                                    R           S           T             U               V             W

                                                                           Date         Date                                                                                                                                                                                                                                                                                               Registered
                                                                                                                                                                                                                                                                                                                                                                                                           Regional
                                                                      Identified or Identified                                                                                                                                                                                               Total                                                                                           Entity
                                                                                         or                                                                                                                                                                                                                                                                                                                 Entity                         Prior
                                                                        Received                                                                                                        Regional Violation                                                                                  Penalty                                                                  Mitigation Mitigation Certification
                                    NOC- NERC Violation ID                            Received                                                                       Reliability                                                                                      Violation Violation                                                                                                                Verification    Discovery       Violation
      Region    Registered Entity                            NCR_ID    (Pre-June                                     Description of the Violation                                  Req. Reliability Risk                        Risk Assessment                                               or                          Basis for the Penalty                        Plan       Plan          of
                                     ID         #                                    (Post-June                                                                      Standard                                                                                         Start Date End Date                                                                                                                of Mitigation    Method          Filing
                                                                      18 Violation)*                                                                                                    Standard Factor                                                                                     Sanction                                                                 Number Completed Mitigation
                                                                                         18                                                                                                                                                                                                                                                                                                                  Plan                        Dockets
                                                                                                                                                                                                                                                                                              ($)                                                                                             Plan
                                                                                                                                                                                                                                                                                                                                                                                                          Completion
 1
                                                                      *if applicable Violation)                                                                                                                                                                                                                                                                                            Completion
      WECC      USACE-Seattle       520   WECC200801190 NCR05539                     6/30/2008 USACE-Seattle District did not have procedures for the                CIP-001-1      1              Medium WECC determined that the violation did not constitute 8/10/2007 10/8/2008            $0      The violation was a documentation issue, it was the           MIT-08-    10/8/2008 12/31/2008       8/28/2009        Self-        NP10-2-
                   District                                                                    recognition of and for making its operating personnel aware of                                             a serious or substantial risk to the bulk power system                                       first violation of this Reliability Standard incurred by       1215                                               Certification    000
                                                                                               sabotage events on its facilities, as required by the Reliability                                          because 1) USACE has a set of emergency plans and                                            USACE-Seattle District and it did not constitute a
                                                                                               Standard.                                                                                                  physical security procedures that cover sabotage                                             serious or substantial risk to the bulk power system.
                                                                                                                                                                                                          generally, 2) of the nature and the location of USACE-
                                                                                                                                                                                                          Seattle District's assets, and 3) the violation was a
                                                                                                                                                                                                          documentation issue.


 25
      WECC      USACE-Seattle       520   WECC200801191 NCR05539                     6/30/2008 USACE-Seattle District did not provide its operating personnel        CIP-001-1      3              Medium WECC determined that the violation did not constitute 8/10/2007 10/8/2008            $0      The violation was the first violation of this Reliability     MIT-08-    10/8/2008 12/31/2008       8/28/2009        Self-        NP10-2-
                   District                                                                    with sabotage response guidelines, including personnel to                                                  a serious or substantial risk to the bulk power system                                       Standard incurred by USACE-Seattle District and it did         1215                                               Certification    000
                                                                                               contact for reporting disturbances due to sabotage events.                                                 because 1) USACE has a set of emergency plans and                                            not constitute a serious or substantial risk to the bulk
                                                                                                                                                                                                          physical security procedures that cover sabotage                                             power system.
                                                                                                                                                                                                          generally and 2) of the nature and the location of
                                                                                                                                                                                                          USACE-Seattle District's assets and the
                                                                                                                                                                                                          documentation nature of the violation.



 26
      WECC      USACE-Seattle       520   WECC200801192 NCR05539                     6/30/2008 USACE-Seattle District did not establish communications               CIP-001-1      4              Medium WECC determined that the violation did not constitute 8/10/2007 10/8/2008            $0      The violation was the first violation of this Reliability     MIT-08-    10/8/2008 12/31/2008       8/28/2009        Self-        NP10-2-
                   District                                                                    contacts, as applicable, with local Federal Bureau of Investigation                                        a serious or substantial risk to the bulk power system                                       Standard incurred by USACE-Seattle District and it did         1215                                               Certification    000
                                                                                               (FBI) officials and did not develop reporting procedures as                                                because 1) USACE has a set of emergency plans and                                            not constitute a serious or substantial risk to the bulk
                                                                                               appropriate to the circumstances.                                                                          physical security procedures that cover sabotage                                             power system.
                                                                                                                                                                                                          generally and 2) of the nature and the location of
                                                                                                                                                                                                          USACE-Seattle District's assets and the
                                                                                                                                                                                                          documentation nature of the violation.


 27
      WECC        Unidentified      511   WECC200800XXX NCRXXXXX                     6/30/2008 URE did not have test procedures for two Critical Cyber Assets,       CIP-007-1      1             Medium WECC determined that the violation did not constitute        7/1/2008 10/15/2009      $0      The violation was self-reported, it was a documentation       MIT-08- 10/15/2009 10/15/2009        11/11/2009     Self-Report     NP10-2-
                Registered Entity                                                              URE's Energy Control Center and Backup Energy Control                                              / Lower a serious or substantial risk to the bulk power system                                       issue, it was the first violation of this Reliability          1453                                                                000
                     (URE)                                                                     Center. URE's test methodology did not outline baseline                                                    because procedures existed, even though the                                                  Standard incurred by URE and it did not constitute a
                                                                                               production and development parameters and URE could not                                                    procedures did not include all of the elements                                               serious or substantial risk to the bulk power system.
                                                                                               demonstrate that its testing procedure minimized adverse effects                                           required by the Standard.
                                                                                               on URE's production system or its operations. URE did not                                                                                                                                               URE did not complete its original Mitigation Plan by the
                                                                                               document that it conducted its testing in a manner that reflected                                                                                                                                       approved 6/12/2009 completion date. WECC
                                                                                               URE's production environment and URE did not document all test                                                                                                                                          approved the 9/4/2009 revised Mitigation Plan that was
                                                                                               results.                                                                                                                                                                                                completed on 10/15/2009.

                                                                                                                                                                                                                                                                                                       WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                       notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                       Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                       violation.




 28
      WECC        Unidentified      N/A   WECC200800XXX NCRXXXXX                     6/30/2008 URE’s Cyber Security Policy did not address all the requirements      CIP-003-1      1              Lower     WECC determined that the violation did not constitute    7/1/2008 10/16/2009      $0      The violation was self-reported, it was the first violation   MIT-08- 10/16/2009 10/16/2009        11/11/2009     Self-Report     NP10-2-
                Registered Entity                                                              in Standards CIP-002 through CIP-009.                                                                         a serious or substantial risk to the bulk power system                                    of this Reliability Standard incurred by URE and it did        1452                                                                000
                     (URE)                                                                                                                                                                                   because URE had a Cyber Security Policy but did not                                       not constitute a serious or substantial risk to the bulk
                                                                                                                                                                                                             have all required elements.                                                               power system.

                                                                                                                                                                                                                                                                                                       WECC rejected URE's 6/12/2009 Certification of
                                                                                                                                                                                                                                                                                                       Completion. WECC approved URE's 9/4/2009
                                                                                                                                                                                                                                                                                                       revised Mitigation Plan that was completed on
                                                                                                                                                                                                                                                                                                       10/15/2009.

                                                                                                                                                                                                                                                                                                       WECC considered these factors and determined that,
                                                                                                                                                                                                                                                                                                       notwithstanding the late completion of the Mitigation
                                                                                                                                                                                                                                                                                                       Plan, a zero dollar penalty was appropriate for this
                                                                                                                                                                                                                                                                                                       violation.




 29




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                                                                                                                                                                                      ATTACHMENT A - OMNIBUS II SPREADSHEET




            A        B         C            D             E              F               G                            H                            I         J       K                              L                               M           N            O                                P                                 Q            R               S                  T               U           V


                                                                  Date Identified       Date
                                                                                                                                                                                                                                                           Total                                                                                       Registered
                                                                   or Received      Identified or                                                                                                                                                                                                                                                                        Regional Entity                  Prior
                                                                                                                                                                Violation                                                                                 Penalty                                                           Mitigation   Mitigation        Entity
                Registered   NOC-     NERC Violation              (Pre-June 18        Received                                                Reliability                                                                       Violation Violation End                                                                                                                  Verification of   Discovery    Violation
     Region                                            NCR_ID                                            Description of the Violation                       Req. Risk                       Risk Assessment                                                 or          Additional Factors for the Basis of Penalty           Plan         Plan       Certification of
                  Entity      ID          ID #                      Violation)*      (Post-June                                               Standard                                                                          Start Date     Date                                                                                                                      Mitigation Plan    Method       Filing
                                                                                                                                                                 Factor                                                                                   Sanction                                                          Number       Completed    Mitigation Plan
                                                                                    18 Violation)                                                                                                                                                                                                                                                                         Completion1                   Dockets
                                                                                                                                                                                                                                                            ($)                                                                                        Completion
                                                                   *if applicable
 1
     SPP RE      USACE -       NOC-   SPP200700036     NCR06038                     12/31/2007 USACE-Tulsa's sabotage procedures did          CIP-001-1      2   Medium SPP determined that this violation did not              7/10/2007   12/10/2009       $0      The violation was a documentation issue, it was        MIT-07-      12/10/2009     6/26/2009           3/2/2010          Self-      NP09-26-
                Tulsa District 189                                                             not require the notification of non-                                     constitute a serious or substantial risk to the bulk                                         the first violation of this Reliability Standard        1278                                                          Certification 000
                                                                                               governmental authorities. Specifically,                                  power system because USACE-Tulsa had security                                                incurred by USACE-Tulsa, and it did not
                                                                                               the notification of parties in the                                       procedures and these procedures included                                                     constitute a serious or substantial risk to the bulk
                                                                                               Interconnection, such as the                                             communication of sabotage events to the local law                                            power system.
                                                                                               Transmission Operator and Host                                           enforcement, District Security Personnel,
                                                                                               Balancing Authority, was not addressed                                   Headquarters US Army Corps of Engineers,
                                                                                               in the USACE-Tulsa procedure.                                            Department of Homeland Security, and the
                                                                                                                                                                        Federal Bureau of Investigation. In addition,
                                                                                                                                                                        USACE-Tulsa is in regular communication with its
                                                                                                                                                                        Transmission Operator.

 2
     SPP RE      USACE -       NOC-   SPP200700037     NCR06038                     12/31/2007 USACE-Tulsa self-certified that it was         EOP-004-1      2   Medium SPP determined that the violation did not create a      7/10/2007   8/28/2009        $0      The violation was a documentation issue, it was        MIT-07-      8/28/2009      6/26/2009          12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                             non-compliant with Requirement 2, which                                  serious or substantial risk to the BPS because                                               the first violation of this Reliability Standard        1279                                                          Certification 000
                                                                                               requires an Entity to promptly analyze                                   USACE-Tulsa was performing analysis of                                                       incurred by USACE-Tulsa, and it did not
                                                                                               Bulk Electric System disturbances on its                                 disturbances on its system, but was not formally                                             constitute a serious or substantial risk to the bulk
                                                                                               system facilities. According to USACE-                                   documenting the process.                                                                     power system.
                                                                                               Tulsa it did not have written procedures
                                                                                               to ensure and document that it analyzed
                                                                                               system disturbances.

 3
     SPP RE      USACE -       NOC-   SPP200700038     NCR06038                     12/31/2007 USACE-Tulsa did not have a                     FAC-008-1      1   Medium SPP RE determined that the violation did not            7/10/2007   10/22/2009       $0      The violation was a documentation issue, it was        MIT-07-      10/22/2009     11/16/2009         12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                             documented Facility Ratings                                              create a serious or substantial risk to the bulk                                             the first violation of this Reliability Standard        1280                                                          Certification 000
                                                                                               Methodology and therefore did not                                        power system because although USACE-Tulsa did                                                incurred by USACE-Tulsa, and it did not
                                                                                               address the method by which the ratings                                  not have a documented Facilities Rating                                                      constitute a serious or substantial risk to the bulk
                                                                                               were determined. According to USACE-                                     Methodology, USACE-Tulsa was establishing                                                    power system.
                                                                                               Tulsa, it was using the original equipment                               ratings for its facilities based upon original
                                                                                               ratings and capacity and was providing                                   equipment ratings and these facility ratings were
                                                                                               the equipment ratings to its Transmission                                communicated to the Transmission Operator and                                                SPP considered these factors and determined
                                                                                               Operator.                                                                SPP                                                                                          that, notwithstanding the late completion of the
                                                                                                                                                                                                                                                                     Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                     appropriate for this violation.




 4
     SPP RE      USACE -       NOC-   SPP200700039     NCR06038                     12/31/2007 - USACE-Tulsa self certified that it was       FAC-008-1      2    Lower     SPP RE determined that the violation did not        7/10/2007   10/22/2009       $0      The violation was a documentation issue, it was        MIT-07-      10/22/2009     11/16/2009         12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                               non-compliant with Requirement 2, which                                    create a serious or substantial risk to the bulk                                         the first violation of this Reliability Standard        1281                                                          Certification 000
                                                                                                 required USACE-Tulsa to make its                                           power system because although USACE-Tulsa did                                            incurred by USACE-Tulsa, and it did not
                                                                                                 Facility Ratings Methodology available                                     not have a documented Facilities Rating                                                  constitute a serious or substantial risk to the bulk
                                                                                                 for inspection and technical review within                                 Methodology, USACE-Tulsa was establishing                                                power system.
                                                                                                 15 business days of receipt of request,                                    ratings for its facilities based upon original
                                                                                                 as required by the Reliability Standard.                                   equipment ratings and these facility ratings were                                        SPP considered these factors and determined
                                                                                                                                                                            communicated to the Transmission Operator.                                               that, notwithstanding the late completion of the
                                                                                                                                                                                                                                                                     Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                     appropriate for this violation.




 5
     SPP RE      USACE -       NOC-   SPP200700040     NCR06038                     12/31/2007 USACE-Tulsa did not have a                     FAC-009-1      1   Medium SPP RE determined that the violation did not            7/10/2007   3/12/2010        $0      The violation was a documentation issue, it was        MIT-07-      3/12/2010       5/7/2010          5/10/2010          Self-      NP09-26-
                Tulsa District 189                                                             documented Facilities Rating                                             create a serious or substantial risk to the BPS                                              the first violation of this Reliability Standard        1282                                                          Certification 000
                                                                                               Methodology and had not established                                      because although USACE-Tulsa did not have a                                                  incurred by USACE-Tulsa, and it did not
                                                                                               ratings for its facilities consistent with                               documented Facilities Rating Methodology,                                                    constitute a serious or substantial risk to the bulk
                                                                                               such a Facility Ratings Methodology, as                                  USACE-Tulsa was establishing ratings for its                                                 power system.
                                                                                               required by the standard.                                                facilities based upon original equipment ratings
                                                                                                                                                                        and these facility ratings were communicated to                                              USACE-Tulsa District submitted a request on
                                                                                                                                                                        the Transmission Operator.                                                                   January 21, 2010, almost two months after its
                                                                                                                                                                                                                                                                     approved completion date of November 28,
                                                                                                                                                                                                                                                                     2009, to extended its completion date to March
                                                                                                                                                                                                                                                                     15, 2010.

 6




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                                                                                                                                                                                     ATTACHMENT A - OMNIBUS II SPREADSHEET




            A        B         C            D             E              F               G                           H                           I         J       K                                L                                 M           N            O                                P                                 Q            R               S                  T               U           V


                                                                  Date Identified       Date
                                                                                                                                                                                                                                                             Total                                                                                       Registered
                                                                   or Received      Identified or                                                                                                                                                                                                                                                                          Regional Entity                  Prior
                                                                                                                                                              Violation                                                                                     Penalty                                                           Mitigation   Mitigation        Entity
                Registered   NOC-     NERC Violation              (Pre-June 18        Received                                              Reliability                                                                           Violation Violation End                                                                                                                  Verification of   Discovery    Violation
      Region                                           NCR_ID                                           Description of the Violation                      Req. Risk                        Risk Assessment                                                    or          Additional Factors for the Basis of Penalty           Plan         Plan       Certification of
                  Entity      ID          ID #                      Violation)*      (Post-June                                             Standard                                                                              Start Date     Date                                                                                                                      Mitigation Plan    Method       Filing
                                                                                                                                                               Factor                                                                                       Sanction                                                          Number       Completed    Mitigation Plan
                                                                                    18 Violation)                                                                                                                                                                                                                                                                           Completion1                   Dockets
                                                                                                                                                                                                                                                              ($)                                                                                        Completion
                                                                   *if applicable
 1
      SPP RE     USACE -       NOC-   SPP200700041     NCR06038                     12/31/2007 USACE-Tulsa self-certified that it was       FAC-009-1      2   Medium SPP RE determined that the violation did not                7/10/2007   3/12/2010        $0      The violation was a documentation issue, it was        MIT-07-      3/12/2010       5/7/2010          5/10/2010          Self-      NP09-26-
                Tulsa District 189                                                             non-compliant with Requirement 2, which                                create a serious or substantial risk to the BPS                                                  the first violation of this Reliability Standard        1283                                                          Certification 000
                                                                                               required USACE-Tulsa to provide Facility                               because although USACE-Tulsa did not have a                                                      incurred by USACE-Tulsa, and it did not
                                                                                               Ratings for its solely and jointly owned                               documented Facilities Rating Methodology,                                                        constitute a serious or substantial risk to the bulk
                                                                                               Facilities to its associated Reliabilty                                USACE-Tulsa was establishing ratings for its                                                     power system.
                                                                                               Coordinator(s), Planning Authority(ies),                               facilities based upon original equipment ratings
                                                                                               Transmission Planner(s) and                                            and these facility ratings were communicated to                                                  USACE-Tulsa District submitted a request on
                                                                                               Transmission Operator(s) as scheduled                                  the Transmission Operator.                                                                       January 21, 2010, almost two months after its
                                                                                               by such requesting entities.                                                                                                                                            approved completion date of November 28,
                                                                                                                                                                                                                                                                       2009, to extended its completion date to March
                                                                                                                                                                                                                                                                       15, 2010.
 7
      SPP RE     USACE -       NOC-   SPP200700042     NCR06038                     12/31/2007 USACE-Tulsa self-certified that it was       PRC-001-1      2     High     SPP RE determined that the violation did not            7/10/2007   8/28/2009        $0      The violation was the first violation of this          MIT-07-      8/28/2009      6/26/2009          12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                             non-compliant with Requirement 2                                           create a serious or substantial risk to the bulk                                             Reliability Standard incurred by USACE-Tulsa            1284                                                          Certification 000
                                                                                               because it did not have a formal policy to                                 power system because, although USACE-Tulsa                                                   and it did not constitute a serious or substantial
                                                                                               notify its Transmission Operator and                                       did not have a written policy requiring its operators                                        risk to the bulk power system.
                                                                                               Host Balancing Authority if protective                                     to notify its Transmission Operator and Balancing
                                                                                               relay or equipment failures reduced                                        Authority of equipment failures at its power plants,
                                                                                               system reliability.                                                        USACE-Tulsa states it was notifying its
                                                                                                                                                                          Transmission Operator and Balancing Authority of
                                                                                                                                                                          equipment failures affecting the output of its
                                                                                                                                                                          generating facilities.
 8
      SPP RE     USACE -       NOC-   SPP200700043     NCR06038                     12/31/2007 USACE-Tulsa self-certified that it was       PRC-001-1      3   <blank> SPP RE determined that the violation did not               7/10/2007   8/28/2009        $0      The violation was a documentation issue, it was        MIT-07-      8/28/2009      6/26/2009          12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                             non-compliant with Requirement 3, which                                 create a serious or substantial risk to the bulk                                                the first violation of this Reliability Standard        1285                                                          Certification 000
                                                                                               required it to coordinate new protective                                power system because, although USACE-Tulsa                                                      incurred by USACE-Tulsa and it did not
                                                                                               systems and all protective system                                       did not have a written policy requiring coordination                                            constitute a serious or substantial risk to the bulk
                                                                                               changes with its Transmission Operator                                  of all new Protection Systems and all Protection                                                power system.
                                                                                               and Host Balancing Authority.                                           System changes with its Transmission Operator
                                                                                                                                                                       and Balancing Authority, USACE-Tulsa states it
                                                                                                                                                                       was coordinating all new Protection Systems and
                                                                                                                                                                       all Protection System changes with its
                                                                                                                                                                       Tansmission Operator and Balancing Authority.


 9
      SPP RE     USACE -       NOC-   SPP200700044     NCR06038                     12/31/2007 USACE-Tulsa self-certified that it was       PRC-004-1      2     High     SPP RE determined that the violation did not            7/10/2007   12/11/2009       $0      The violation was the first violation of this          MIT-07-      12/11/2009     6/26/2009           3/2/2010          Self-      NP09-26-
                Tulsa District 189                                                             non-compliant with Requirement 2, which                                    create a serious or substantial risk to the bulk                                             Reliability Standard incurred by USACE-Tulsa            1286                                                          Certification 000
                                                                                               required it to analyze its generator                                       power system because USACE-Tulsa states it                                                   and it did not constitute a serious or substantial
                                                                                               Protection System Misoperations, and                                       was performing analysis of generator Protection                                              risk to the bulk power system.
                                                                                               develop and implement a Corrective                                         System Misoperations occurring on its system.
                                                                                               Action Plan to avoid future Misoperations
                                                                                               of a similar nature according to the
                                                                                               Regional Entity's procedures developed
                                                                                               for PRC-003 R1. USACE-Tulsa did not
                                                                                               have documented procedures requiring
                                                                                               analysis of generation Protection System
                                                                                               Misoperations and the development of
                                                                                               Corrective Action Plans.



 10
      SPP RE     USACE -       NOC-   SPP200700046     NCR06038                     12/31/2007 USACE-Tulsa self-certified that it was       PRC-005-1      1     High     SPP RE determined that the violation did not            7/10/2007   4/29/2009        $0      The violation was the first violation of this          MIT-07-      4/29/2009      6/26/2009          12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                             non-compliant with Requirement 1, which                                    create a serious or substantial risk to the bulk                                             Reliability Standard incurred by USACE-Tulsa            1288                                                          Certification 000
                                                                                               required it to have a Protection System                                    power system because the USACE-Tulsa had a                                                   and it did not constitute a serious or substantial
                                                                                               maintenance and testing program for                                        comprehensive Protection System maintenance                                                  risk to the bulk power system. USACE-Tulsa
                                                                                               Protection Systems that impact the                                         and testing program, although it did not have a                                              completed its Mitigation Plan on April 29, 2009,
                                                                                               reliability of BES. Further, its program                                   documented program that met all of the                                                       approximately one month after its approved
                                                                                               was required to include maintenance and                                    requirements of the standard, and USACE-Tulsa                                                completion date of March 31, 2009.
                                                                                               testing intervals and their basis and a                                    was conducting the testing for its relays.
                                                                                               summary of maintenance and testing                                                                                                                                      SPP considered these factors and determined
                                                                                               procedures.                                                                                                                                                             that, notwithstanding the late completion of the
                                                                                                                                                                                                                                                                       Mitigation Plan, a zero dollar penalty was
                                                                                                                                                                                                                                                                       appropriate for this violation.


 11




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                                                                                                                                                                                                      ATTACHMENT A - OMNIBUS II SPREADSHEET




            A         B           C             D                  E                 F                G                              H                             I         J       K                               L                              M           N            O                                P                                 Q            R               S                  T               U           V


                                                                              Date Identified       Date
                                                                                                                                                                                                                                                                           Total                                                                                       Registered
                                                                               or Received      Identified or                                                                                                                                                                                                                                                                            Regional Entity                  Prior
                                                                                                                                                                                Violation                                                                                 Penalty                                                           Mitigation   Mitigation        Entity
                Registered     NOC-     NERC Violation                        (Pre-June 18        Received                                                    Reliability                                                                       Violation Violation End                                                                                                                  Verification of   Discovery    Violation
      Region                                                   NCR_ID                                                  Description of the Violation                         Req. Risk                        Risk Assessment                                                or          Additional Factors for the Basis of Penalty           Plan         Plan       Certification of
                  Entity        ID          ID #                                Violation)*      (Post-June                                                   Standard                                                                          Start Date     Date                                                                                                                      Mitigation Plan    Method       Filing
                                                                                                                                                                                 Factor                                                                                   Sanction                                                          Number       Completed    Mitigation Plan
                                                                                                18 Violation)                                                                                                                                                                                                                                                                             Completion1                   Dockets
                                                                                                                                                                                                                                                                            ($)                                                                                        Completion
                                                                               *if applicable
 1
      SPP RE     USACE -       NOC-     SPP200700047         NCR06038                            12/31/2007 USACE-Tulsa's Protection System                   PRC-005-1      2    Lower     SPP RE determined that the violation did not        7/10/2007   4/29/2009        $0      The violation was the first violation of this          MIT-07-      4/29/2009      6/26/2009          12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                                          Maintenance and Testing Program did                                             create a serious or substantial risk to the bulk                                         Reliability Standard incurred by USACE-Tulsa            1289                                                          Certification 000
                                                                                                            not include documentation of testing for                                        power system because the USACE-Tulsa had a                                               and it did not constitute a serious or substantial
                                                                                                            its protective relays. USACE-Tulsa                                              comprehensive Protection System Maintenance                                              risk to the bulk power system. USACE-Tulsa
                                                                                                            identified 381 protective relays in their                                       and Testing Program and was conducting the                                               completed its Mitigation Plan on April 29, 2009,
                                                                                                            program – 166 are the new                                                       testing for its relays.                                                                  approximately one month after its approved
                                                                                                            microprocessor relays and 215 are                                                                                                                                        completion date of March 31, 2009. SPP
                                                                                                            electromechanical. USACE-Tulsa was                                                                                                                                       considered these factors and determined that,
                                                                                                            testing its relays on an annual basis.                                                                                                                                   notwithstanding the late completion of the
                                                                                                            However, USACE-Tulsa did not have                                                                                                                                        Mitigation Plan, a zero dollar penalty was
                                                                                                            complete documentation regarding the                                                                                                                                     appropriate for this violation.
                                                                                                            historical tests. Therefore, it could not
                                                                                                            provide the documentation upon request.

 12
      SPP RE     USACE -       NOC-     SPP200700048         NCR06038                            12/31/2007 USACE-Tulsa self-certified that it was       TOP-002-2           18   Medium SPP RE determined the violation did not pose a         7/10/2007   9/24/2009        $0      The violation was a documentation issue, it was        MIT-07-      9/24/2009      9/29/2009          12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                                          non-compliant with Requirement 18,                                           serious or substantial risk to the bulk electric                                            the first violation of this Reliability Standard        1290                                                          Certification 000
                                                                                                            which required it to use uniform line                                        system because USACE-Tulsa was utilizing                                                    incurred by USACE-Tulsa, and it did not
                                                                                                            identifiers when referring to transmission                                   consistent line identifiers in their communications                                         constitute a serious or substantial risk to the bulk
                                                                                                            facilities of an interconnected network.                                     with its Transmission Operator despite not having                                           power system.
                                                                                                            Specifically, USACE-Tulsa did not have a                                     a procedure in place identifying the uniform line
                                                                                                            policy in place identifying the uniform line                                 identifiers or requiring its operators to use them.
                                                                                                            identifiers for the USACE equipment and
                                                                                                            requiring its operators to utilize uniform
                                                                                                            line identifiers.


 13
      SPP RE     USACE -       NOC-     SPP200700049         NCR06038                            12/31/2007 USACE-Tulsa self-certified that it was            VAR-002-1      1    Medium SPP RE determined the violation did not pose a         7/10/2007   4/29/2009        $0      The violation was the first violation of this          MIT-07-      4/29/2009      6/26/2009          12/9/2009          Self-      NP09-26-
                Tulsa District 189                                                                          non-compliant with Requirement 1, which                                      serious or substantial risk to the bulk electric                                            Reliability Standard incurred by USACE-Tulsa            1291                                                          Certification 000
                                                                                                            required it to operate each generator                                        system because USACE-Tulsa normally operates                                                and it did not constitute a serious or substantial
                                                                                                            connected to the interconnected                                              its generating units in Automatic Voltage Control                                           risk to the bulk power system. USACE-Tulsa
                                                                                                            transmission system in the automatic                                         Mode and states it shuts down a unit if it is unable                                        completed its Mitigation Plan on April 29, 2009,
                                                                                                            voltage control mode unless it has                                           to operate in the Automatic Voltage Control Mode.                                           approximately two months after its approved
                                                                                                            notified the Transmission                                                                                                                                                completion date of February 27, 2009.
                                                                                                            Operator. USACE-Tulsa did not have a
                                                                                                            written policy requiring its operators to                                                                                                                                SPP considered these factors and determined
                                                                                                            operate its generation units in the                                                                                                                                      that, notwithstanding the late completion of the
                                                                                                            Automatic Voltage Regulation Mode, but,                                                                                                                                  Mitigation Plan, a zero dollar penalty was
                                                                                                            according to USACE-Tulsa, it was                                                                                                                                         appropriate for this violation.
                                                                                                            operating its generators in Automatic
                                                                                                            Voltage Control Mode.




 14
      SPP RE     USACE -       NOC-     SPP200700050         NCR06038                            12/31/2007      USACE-Tulsa self-certified that it was       VAR-002-1      2    Medium SPP RE determined the violation did not pose a         7/10/2007   12/20/2009       $0      The violation was a documentation issue, it was        MIT-07-      12/20/2009     6/26/2009           3/2/2010          Self-      NP09-26-
                Tulsa District 189                                                                              non-compliant with Requirement 2, which                                  serious or substantial risk to the bulk power                                               the first violation of this Reliability Standard        1292                                                          Certification 000
                                                                                                                required it to maintain the                                              system because USACE-Tulsa normally operates                                                incurred by USACE-Tulsa, and it did not
                                                                                                                generator voltage or Reactive Power                                      its generating units in Automatic Voltage Control                                           constitute a serious or substantial risk to the bulk
                                                                                                                output (within applicable Facility Ratings)                              Mode and states it shuts down a unit if it is unable                                        power system.
                                                                                                                as directed by the Transmission Operator                                 to operate in the Automatic Voltage Control Mode.
                                                                                                                (TOP). USACE-Tulsa did not have a                                        While it did not have a policy, USACE-Tulsa states                                          USACE-Tulsa completed its Mitigation Plan on
                                                                                                                written policy requiring its operators to                                it compiles with directives from the Transmission                                           December 20, 2009, approximately eight
                                                                                                                use alternative methods to control                                       Operator.                                                                                   months after its approved completion date of
                                                                                                                generator voltage and reactive power                                                                                                                                 April 29, 2009.
                                                                                                                output to meet voltage or reactive power
                                                                                                                schedules as directed by the TOP.                                                                                                                                    SPP considered these factors and determined
                                                                                                                Additionally, USACE-Tulsa did not have                                                                                                                               that, notwithstanding the late completion of the
                                                                                                                operating procedures in place requiring                                                                                                                              Mitigation Plan, a zero dollar penalty was
                                                                                                                its operators to respond to voltage or                                                                                                                               appropriate for this violation.
                                                                                                                reactive power schedules from its TOP,
                                                                                                                although USACE-Tulsa stated that it
                                                                                                                complies with directions from its TOP.


 15
      1 The date for verification is the later of SPP RE's review or SPP RE's date of notification to USACE - Tulsa District.

 16




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                                                                                                                                                                  ATTACHMENT A - OMNIBUS II SPREADSHEET




        A         B         C           D            E              F               G                        H                        I           J        K       L                         M                  N           O          P                              Q                            R          S             T             U             V           W

                                                             Date Identified      Date                                                                                                                                                                                                                               Registered     Regional
                                                                                Identified                                                                                                                                           Total
                                                              or Received                                                                                                                                                                                                                                               Entity        Entity                      Prior
                                                                                   or                                                         Regional         Violation                                                            Penalty                                                    Mitigation Mitigation
     Regio   Registered   NOC- NERC Violation                (Pre-June 18                                                         Reliability                                                              Violation    Violation                                                                                    Certification Verification    Discovery    Violation
                                                   NCR_ID                       Received         Description of the Violation                 Reliability Req.   Risk               Risk Assessment                                   or        Additional Factors for the Basis of Penalty      Plan       Plan
       n       Entity      ID      ID #                        Violation)*                                                        Standard                                                                 Start Date   End Date                                                                                     of Mitigation of Mitigation    Method       Filing
                                                                               (Post-June                                                     Standard          Factor                                                              Sanction                                                   Number Completed
                                                                                                                                                                                                                                                                                                                         Plan          Plan                     Dockets
                                                                                   18                                                                                                                                                 ($)
 1
                                                              *if applicable                                                                                                                                                                                                                                         Completion Completion
                                                                                Violation)
      TRE     USACE -       NOC-   TRE200700022   NCR04156                      10/3/2007 USACE-Tulsa did not have a              FAC-008-                1    Lower / TRE determined that the violation did 6/28/2007 11/22/2009      $0      The violation was the first violation of this   MIT-07-   11/22/2009    1/29/2010     2/26/2010        Self-      NP09-26-
             Tulsa District 430                                                            documented Facility Ratings               1                         Medium not create a serious or substantial risk                                 Reliability Standard incurred by USACE-          0600                                               Certification 000
                                                                                           Methodology and therefore did not                                           to the bulk power system because                                        Tulsa and it did not constitute a serious or
                                                                                           address the method by which the                                             although USACE-Tulsa did not have a                                     substantial risk to the bulk power system.
                                                                                           ratings were determined.                                                    documented Facilities Rating
                                                                                                                                                                       Methodology, ratings for the                                            USACE-Tulsa did not complete its original
                                                                                                                                                                       generation equipment is fully                                           Mitigation Plan by its completion date of
                                                                                                                                                                       documented and established, both in                                     9/31/2008 and submitted a revised
                                                                                                                                                                       operating criteria and in the protective                                Mitigation Plan on 6/26/2009. The
                                                                                                                                                                       systems and control equipment.                                          6/26/2009 Mitigation Plan was completed
                                                                                                                                                                                                                                               four months prior to its completion date of
                                                                                                                                                                                                                                               3/31/2010.

                                                                                                                                                                                                                                               TRE considered these factors and
                                                                                                                                                                                                                                               determined that, notwithstanding the late
                                                                                                                                                                                                                                               completion of the Mitigation Plan, a zero
                                                                                                                                                                                                                                               dollar penalty was appropriate for this
                                                                                                                                                                                                                                               violation.
 2
      TRE     USACE -       NOC-   TRE200700023   NCR04156                     10/3/2007 USACE-Tulsa self-certified that it was FAC-008-                  2     Lower TRE determined that the violation did 6/28/2007 11/22/2009       $0      The violation was the first violation of this   MIT-07-   11/22/2009    1/29/2010     2/26/2010        Self-      NP09-26-
             Tulsa District 430                                                          non-compliant with Requirement 2,         1                                  not create a serious or substantial risk                                 Reliability Standard incurred by USACE-          0600                                               Certification 000
                                                                                         which required it to make its Facility                                       to the bulk power system because                                         Tulsa and it did not constitute a serious or
                                                                                         Ratings Methodology available for                                            although USACE-Tulsa did not have a                                      substantial risk to the bulk power system.
                                                                                         inspection and technical review by the                                       documented Facilities Rating
                                                                                         entities specified by the Standard that                                      Methodology, its ratings for the                                         USACE-Tulsa did not complete its original
                                                                                         have responsibility for the area in                                          generation equipment were                                                Mitigation Plan by its completion date of
                                                                                         which the associated Facilities are                                          documented and established, both in                                      9/31/2008 and submitted a revised
                                                                                         located, within 15 days business of                                          operating criteria and in the protective                                 Mitigation Plan on 6/26/2009. The
                                                                                         receipt of a request. USACE-Tulsa did                                        systems and control equipment.                                           6/26/2009 Mitigation Plan was completed
                                                                                         not have a documented Facility                                                                                                                        four months prior to its completion date of
                                                                                         Ratings Methodology and would not                                                                                                                     3/31/2010.
                                                                                         have been able to provide one.
                                                                                                                                                                                                                                               TRE considered these factors and
                                                                                                                                                                                                                                               determined that, notwithstanding the late
                                                                                                                                                                                                                                               completion of the Mitigation Plan, a zero
                                                                                                                                                                                                                                               dollar penalty was appropriate for this
 3                                                                                                                                                                                                                                             violation.
      TRE     USACE -       NOC-   TRE200700024   NCR04156                     10/3/2007 USACE-Tulsa self-certified that it was   FAC-008-                3     Lower TRE determined that the violation did 6/28/2007 11/22/2009       $0      The violation was the first violation of this   MIT-07-   11/22/2009    1/29/2010     2/26/2010        Self-      NP09-26-
             Tulsa District 430                                                          non-compliant with Requirement 3 of         1                                not create a serious or substantial risk                                 Reliability Standard incurred by USACE-          0600                                               Certification 000
                                                                                         this Reliability Standard because                                            to the bulk power system because                                         Tulsa and it did not constitute a serious or
                                                                                         USACE-Tulsa did not have a                                                   although USACE-Tulsa did not have a                                      substantial risk to the bulk power system.
                                                                                         documented Facility Ratings                                                  documented Facilities Rating
                                                                                         Methodology and therefore could not                                          Methodology, ratings for the                                             USACE-Tulsa did not complete its original
                                                                                         have provided it for comments.                                               generation equipment were                                                Mitigation Plan by its completion date of
                                                                                                                                                                      documented and established, both in                                      9/31/2008 and submitted a revised
                                                                                                                                                                      operating criteria and in the protective                                 Mitigation Plan on 6/26/2009. The
                                                                                                                                                                      systems and control equipment.                                           6/26/2009 Mitigation Plan was completed
                                                                                                                                                                                                                                               four months prior to its completion date of
                                                                                                                                                                                                                                               3/31/2010.

                                                                                                                                                                                                                                               TRE considered these factors and
                                                                                                                                                                                                                                               determined that, notwithstanding the late
                                                                                                                                                                                                                                               completion of the Mitigation Plan, a zero
                                                                                                                                                                                                                                               dollar penalty was appropriate for this
                                                                                                                                                                                                                                               violation.
 4
 5




1/13/2011                                                                                                                                                                                                                                                                                                                                                       PAGE 10 OF 14
                                                                                                                                                                                         ATTACHMENT A - OMNIBUS II SPREADSHEET




            A        B           C             D               E            F             G                                  H                                 I            J        K       L                        M                    N           O           P                                Q                              R             S             T            U            V           W
                                                                         Date
                                                                       Identified
                                                                                         Date                                                                                                                                                                                                                                                                            Regional
                                                                           or                                                                                                                                                                                                                                                                             Registered
                                                                                     Identified or                                                                                                                                                               Total                                                                                                  Entity and
                                                                       Received                                                                                                                                                        Violation                                                                                                            Entity                                 Prior
                                                                                       Received                                                                         Regional         Violation                                                              Penalty                                                                     Mitigation                    NERC
                Registered                                             (Pre-June                                                                          Reliability                                                                  Start Date   Violation                             Additional Factors                   Mitigation                Certification               Discovery   Violation
      Region                   NOC-ID NERC Violation ID #    NCR_ID                   (Post-June                Description of the Violation                            Reliability Req.   Risk               Risk Assessment                                      or                                                                         Plan                      Verification
                  Entity                                                   18                                                                             Standard                                                                    (Post-June    End Date                            for the Basis of Penalty              Plan Number              1 of Mitigation of Mitigation  Method      Filing
                                                                                     18 Violation)                                                                      Standard          Factor                                                                Sanction                                                                    Completed
                                                                       Violation)*                                                                                                                                                     18, 2007)                                                                                                             Plan                                Dockets
                                                                                                                                                                                                                                                                  ($)                                                                                                 2    Plan
                                                                                                                                                                                                                                                                                                                                                         Completion
                                                                                                                                                                                                                                                                                                                                                                        Completion3
                                                                          *if
 1                                                                     applicable

                                                                                                                                                                                                                                                                           The violation was the first violation of this
                                                                                                                                                                                                                                                                           Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                     CEA for processing.
                                                                                                                                                                                                                                                                           system.
                 WECC RC
                [California                                                                          CMRC had not established communications
                                                                                                                                                                                                NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
     NERC as      Mexico               WECC200700499 /                                               contacts, as applicable, with local Federal Bureau
                                N/A                         NCR05049                  1129/2007                                                           CIP-001-1                  4   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      CMRC was in the process of being replaced as       MIT-07-1171    1/1/2009      1/8/2010      3/4/2009      Audit
       CEA       Reliability            NCEA200700064                                                of Investigation (FBI) or Royal Canadian Mounted
                                                                                                                                                                                                responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                Coordinator                                                                          Police (RCMP) officials and had not developed
                                                                                                                                                                                                                                                                           to have an impact on the reliability of the bulk
                    OC]                                                                              reporting procedures as appropriate to its
                                                                                                                                                                                                                                                                           power system, and 2) the purpose of the
                                                                                                     circumstances.
                                                                                                                                                                                                                                                                           assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 2

                                                                                                                                                                                                                                                                           The violation was the first violation of this
                                                                                                                                                                                                                                                                           Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                     WECC turned over this violation to NERC as                                                                                                                            system.
                 WECC RC
                                                                                                     CEA for processing.
                [California
                                                                                                                                                                                                NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
     NERC as      Mexico               WECC200700500 /
                                N/A                         NCR05049                 11/29/2007 No evidence was provided to show that CMRC                COM-001-1                  3    LOWER which assumed the RC                  6/18/2007     1/1/2009       $0      CMRC was in the process of being replaced as       MIT-07-1172    1/1/2009      1/8/2010      3/4/2009      Audit
       CEA       Reliability            NCEA200700066
                                                                                                had the ability to investigate problems with                                                    responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                Coordinator
                                                                                                telecommunications facilities and to recommend                                                                                                                             to have an impact on the reliability of the bulk
                    OC]
                                                                                                solutions as required by the Standard.                                                                                                                                     power system, and 2) the purpose of the
                                                                                                                                                                                                                                                                           assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 3

                                                                                                     WECC turned over this violation to NERC as                                                                                                                            The violation was the first violation of this
                                                                                                     CEA for processing.                                                                                                                                                   Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                CMRC self-reported that it was non-compliant                                                                                                                               system.
                 WECC RC
                                                                                                with Requirement 4, which required it to have
                [California
                                                                                                formal operating agreements with each entity to                                                 NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
     NERC as      Mexico               WECC200700501 /
                                N/A                         NCR05049                 11/29/2007 which it delegates tasks. CMRC did not have               IRO-001-1                  4   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      CMRC was in the process of being replaced as       MIT-07-0980    1/1/2009      1/8/2010      3/4/2009      Audit
       CEA       Reliability            NCEA200700067
                                                                                                formal agreements in place with California                                                      responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                Coordinator
                                                                                                Independent System Operator (CAISO) for CISO                                                                                                                               to have an impact on the reliability of the bulk
                    OC]
                                                                                                to provide voice and data communication circuits,                                                                                                                          power system, and 2) the purpose of the
                                                                                                and monitoring, testing, alarming on those                                                                                                                                 assessment of a financial penalty is to further
                                                                                                circuits, even though CISO is the entity providing                                                                                                                         the reliability of the bulk power system, no
                                                                                                those services.                                                                                                                                                            penalty was warranted.
 4

                                                                                                                                                                                                                                                                           The violation was the first violation of this
                                                                                                                                                                                                                                                                           Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as                                                                                                                            serious or substantial risk to the bulk power
                                                                                                     CEA for processing.                                                                                                                                                   system.
                 WECC RC
                [California
                                                                                                The WECC Operating Agreement with adjacent                                                           NERC certified WECC as the RC,                                        NERC as CEA determined that, because 1)
     NERC as      Mexico               WECC200700503 /
                                N/A                         NCR05049                 11/29/2007 Reliability Coordinators was not signed until             IRO-001-1                  7     HIGH      which assumed the RC             6/18/2007     1/1/2009       $0      CMRC was in the process of being replaced as       MIT-07-0981    1/1/2009      1/8/2010      3/4/2009      Audit
       CEA       Reliability            NCEA200700069
                                                                                                October 2, 2007, resulting in a violation for the                                                    responsibilities on 1/1/2009.                                         the RC and therefore would not have an ability
                Coordinator
                                                                                                prior period in which there was no agreement.                                                                                                                              to have an impact on the reliability of the bulk
                    OC]
                                                                                                                                                                                                                                                                           power system, and 2) the purpose of the
                                                                                                                                                                                                                                                                           assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 5

                                                                                                                                                                                                                                                                           The violation was the first violation of this
                                                                                                                                                                                                                                                                           Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                     CEA for processing.
                                                                                                                                                                                                                                                                           system.
                 WECC RC
                [California                                                                          CMRC has not listed CISO as an entity to which it
                                                                                                                                                                                                NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
     NERC as      Mexico               WECC200700502 /                                               was delegating the tasks of providing voice and
                                N/A                         NCR05049                 11/29/2007                                                           IRO-001-1                  5    LOWER which assumed the RC                  6/18/2007     1/1/2009       $0      CMRC was in the process of being replaced as       MIT-07-0980    1/1/2009      1/8/2010      3/4/2009      Audit
       CEA       Reliability            NCEA200700068                                                communication circuits, as well as providing the
                                                                                                                                                                                                responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                Coordinator                                                                          testing, monitoring, alarming on those same
                                                                                                                                                                                                                                                                           to have an impact on the reliability of the bulk
                    OC]                                                                              communications circuits, as required by the
                                                                                                                                                                                                                                                                           power system, and 2) the purpose of the
                                                                                                     Reliability Standard.
                                                                                                                                                                                                                                                                           assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 6




1/13/2011                                                                                                                                                                                                                                                                                                                                                                                                PAGE 11 OF 14
                                                                                                                                                                                         ATTACHMENT A - OMNIBUS II SPREADSHEET




            A        B           C             D               E            F             G                                   H                                I            J        K       L                        M                    N           O           P                                Q                              R             S             T            U            V           W
                                                                         Date
                                                                       Identified
                                                                                         Date                                                                                                                                                                                                                                                                            Regional
                                                                           or                                                                                                                                                                                                                                                                             Registered
                                                                                     Identified or                                                                                                                                                               Total                                                                                                  Entity and
                                                                       Received                                                                                                                                                        Violation                                                                                                            Entity                                 Prior
                                                                                       Received                                                                         Regional         Violation                                                              Penalty                                                                     Mitigation                    NERC
                Registered                                             (Pre-June                                                                          Reliability                                                                  Start Date   Violation                             Additional Factors                   Mitigation                Certification               Discovery   Violation
       Region                  NOC-ID NERC Violation ID #    NCR_ID                   (Post-June                Description of the Violation                            Reliability Req.   Risk               Risk Assessment                                      or                                                                         Plan                      Verification
                  Entity                                                   18                                                                             Standard                                                                    (Post-June    End Date                            for the Basis of Penalty              Plan Number              1 of Mitigation of Mitigation  Method      Filing
                                                                                     18 Violation)                                                                      Standard          Factor                                                                Sanction                                                                    Completed
                                                                       Violation)*                                                                                                                                                     18, 2007)                                                                                                             Plan                                Dockets
                                                                                                                                                                                                                                                                  ($)                                                                                                 2    Plan
                                                                                                                                                                                                                                                                                                                                                         Completion
                                                                                                                                                                                                                                                                                                                                                                        Completion3
                                                                          *if
 1                                                                     applicable

                                                                                                     WECC turned over this violation to NERC as                                                                                                                            The violation was the first violation of this
                                                                                                     CEA for processing.                                                                                                                                                   Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                CMRC was not aware of all Interchange                                                                                                                                      system.
                 WECC RC
                                                                                                Transactions that wheel through, source, or sink
                [California
                                                                                                in its Reliability Coordinator Area, and make that                                                   NERC certified WECC as the RC,                                        NERC as CEA determined that, because 1)
      NERC as     Mexico               WECC200710001 /                                                                                                                                                                                                                                                                                                                                 Self-
                                N/A                         NCR05049   5/11/2007     11/29/2007 Interchange Transaction information available to          IRO-005-2                  2     HIGH      which assumed the RC             6/18/2007     1/1/2009       $0      CMRC was in the process of being replaced as       MIT-07-1312    1/1/2009      1/8/2010      3/4/2009
        CEA      Reliability            NCEA200700070                                                                                                                                                                                                                                                                                                                                 Report
                                                                                                all Reliability Coordinators in the Interconnection,                                                 responsibilities on 1/1/2009.                                         the RC and therefore would not have an ability
                Coordinator
                                                                                                as required by the Reliability Standard. CMRC                                                                                                                              to have an impact on the reliability of the bulk
                    OC]
                                                                                                was not using the WIT tool is to view dynamic                                                                                                                              power system, and 2) the purpose of the
                                                                                                schedules as required by R2.                                                                                                                                               assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 7

                                                                                                                                                                                                                                                                           The violation was the first violation of this
                                                                                                                                                                                                                                                                           Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                     CEA for processing.
                                                                                                                                                                                                                                                                           system.
                 WECC RC
                                                                                                     PNSC was not able to provide evidence that it
                  [Pacific                                                                                                                                                                      NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
      NERC as                          WECC200700400 /                                               had established communications contacts, as
                 Northwest      N/A                         NCR05302                  9/21/2007                                                           CIP-001-1                  4   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      PNSC was in the process of being replaced as       MIT-07-0759    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700058                                                applicable, with local Federal Bureau of
                  Security                                                                                                                                                                      responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                                                                                                     Investigation (FBI) or Royal Canadian Mounted
                Coordinator]                                                                                                                                                                                                                                               to have an impact on the reliability of the bulk
                                                                                                     Police (RCMP) officials and had not developed
                                                                                                                                                                                                                                                                           power system, and 2) the purpose of the
                                                                                                     reporting procedures as appropriate to their
                                                                                                                                                                                                                                                                           assessment of a financial penalty is to further
                                                                                                     circumstances.
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 8

                                                                                                                                                                                                                                                                           The violation was the first violation of this
                                                                                                                                                                                                                                                                           Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as                                                                                                                            serious or substantial risk to the bulk power
                                                                                                     CEA for processing.                                                                                                                                                   system.
                 WECC RC
                  [Pacific                                                                           PNSC had been using the NWPP restoration                                                   NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
      NERC as                          WECC200700401 /
                 Northwest      N/A                         NCR05302                  9/21/2007      manual as the Reliability Coordination restoration   EOP-006-1                  3   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      PNSC was in the process of being replaced as       MIT-07-1056    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700059
                  Security                                                                           plan. The manual did not specify coordination                                              responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                Coordinator]                                                                         protocols between PNSC's Transmission                                                                                                                                 to have an impact on the reliability of the bulk
                                                                                                     Operators to ensure that reliability would be                                                                                                                         power system, and 2) the purpose of the
                                                                                                     maintained during system restoration events.                                                                                                                          assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 9

                                                                                                                                                                                                                                                                           The violation was the first violation of this
                                                                                                                                                                                                                                                                           Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                     CEA for processing.
                                                                                                                                                                                                                                                                           system.
                 WECC RC
                                                                                                     PNSC did not provide evidence that it could
                  [Pacific                                                                                                                                                                      NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
      NERC as                          WECC200700402 /                                               determine that an operating emergency had been
                 Northwest      N/A                         NCR05302                  9/27/2007                                                           EOP-006-1                  6   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      PNSC was in the process of being replaced as       MIT-07-1056    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700060                                                mitigated in accordance with its restoration plan,
                  Security                                                                                                                                                                      responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                                                                                                     as required by the Reliability Standard. PNSC
                Coordinator]                                                                                                                                                                                                                                               to have an impact on the reliability of the bulk
                                                                                                     provided the WECC Interconnection Disturbance
                                                                                                                                                                                                                                                                           power system, and 2) the purpose of the
                                                                                                     Assessment and Restoration Guidelines
                                                                                                                                                                                                                                                                           assessment of a financial penalty is to further
                                                                                                     documentation in support of this requirement.
                                                                                                                                                                                                                                                                           the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                           penalty was warranted.
 10


                                                                                                     WECC turned over this violation to NERC as                                                                                                                            The violation was the first violation of this
                                                                                                     CEA for processing.                                                                                                                                                   Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                           serious or substantial risk to the bulk power
                                                                                                     PNSC was not aware of the restoration plan of                                                                                                                         system.
                 WECC RC                                                                             each Transmission Operator in its Reliability
                  [Pacific                                                                           Coordinator Area as required by the Standard.                                              NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
      NERC as                          WECC200810296 /                                                                                                                                                                                                                                                                                                                                 Self-
                 Northwest      N/A                         NCR05302   5/18/2007      9/21/2007      PNSC had 17 Transmission Operators'                EOP-006-1                    1   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      PNSC was in the process of being replaced as       MIT-07-1056    1/1/2009      1/8/2010      3/4/2009
        CEA                             NCEA200800071                                                                                                                                                                                                                                                                                                                                 Report
                  Security                                                                           restoration plans and had requested current                                                responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                Coordinator]                                                                         updated copies of the restoration plans for all                                                                                                                       to have an impact on the reliability of the bulk
                                                                                                     Transmission operators within its footprint on May                                                                                                                    power system, and 2) the purpose of the
                                                                                                     18, 2007. PNSC had not received or verified all                                                                                                                       assessment of a financial penalty is to further
                                                                                                     of the current restoration plans for Transmission                                                                                                                     the reliability of the bulk power system, no
                                                                                                     Operators in its Reliability Coordinator area.                                                                                                                        penalty was warranted.
 11




1/13/2011                                                                                                                                                                                                                                                                                                                                                                                                PAGE 12 OF 14
                                                                                                                                                                                        ATTACHMENT A - OMNIBUS II SPREADSHEET




            A        B           C             D               E            F             G                                  H                                I            J        K       L                        M                    N           O           P                                Q                              R             S             T            U            V           W
                                                                         Date
                                                                       Identified
                                                                                         Date                                                                                                                                                                                                                                                                           Regional
                                                                           or                                                                                                                                                                                                                                                                            Registered
                                                                                     Identified or                                                                                                                                                              Total                                                                                                  Entity and
                                                                       Received                                                                                                                                                       Violation                                                                                                            Entity                                 Prior
                                                                                       Received                                                                        Regional         Violation                                                              Penalty                                                                     Mitigation                    NERC
                Registered                                             (Pre-June                                                                         Reliability                                                                  Start Date   Violation                             Additional Factors                   Mitigation                Certification               Discovery   Violation
       Region                  NOC-ID NERC Violation ID #    NCR_ID                   (Post-June                Description of the Violation                           Reliability Req.   Risk               Risk Assessment                                      or                                                                         Plan                      Verification
                  Entity                                                   18                                                                            Standard                                                                    (Post-June    End Date                            for the Basis of Penalty              Plan Number              1 of Mitigation of Mitigation  Method      Filing
                                                                                     18 Violation)                                                                     Standard          Factor                                                                Sanction                                                                    Completed
                                                                       Violation)*                                                                                                                                                    18, 2007)                                                                                                             Plan                                Dockets
                                                                                                                                                                                                                                                                 ($)                                                                                                 2    Plan
                                                                                                                                                                                                                                                                                                                                                        Completion
                                                                                                                                                                                                                                                                                                                                                                       Completion3
                                                                          *if
 1                                                                     applicable

                                                                                                                                                                                                                                                                          The violation was the first violation of this
                                                                                                                                                                                                                                                                          Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                          serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                          system.
                                                                                                     WECC turned over this violation to NERC as
                 WECC RC
                                                                                                     CEA for processing.
                  [Pacific                                                                                                                                                                          NERC certified WECC as the RC,                                        NERC as CEA determined that, because 1)
      NERC as                           WECC200700397/
                 Northwest      N/A                         NCR05302                  9/21/2007                                                          IRO-004-1                  1     HIGH      which assumed the RC             6/18/2007     1/1/2009       $0      PNSC was in the process of being replaced as       MIT-07-2520    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700056                                                PNSC did not provide evidence that it conducts
                  Security                                                                                                                                                                          responsibilities on 1/1/2009.                                         the RC and therefore would not have an ability
                                                                                                     voltage and stability analysis in its next day
                Coordinator]                                                                                                                                                                                                                                              to have an impact on the reliability of the bulk
                                                                                                     studies as required by the Standard.
                                                                                                                                                                                                                                                                          power system, and 2) the purpose of the
                                                                                                                                                                                                                                                                          assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                          the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                          penalty was warranted.
 12

                                                                                                                                                                                                                                                                          The violation was the first violation of this
                                                                                                                                                                                                                                                                          Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                          serious or substantial risk to the bulk power
                                                                                                                                                                                                                                                                          system.
                 WECC RC                                                                             WECC turned over this violation to NERC as
                  [Pacific                                                                           CEA for processing.                                                                       NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
      NERC as                          WECC200700399 /
                 Northwest      N/A                         NCR05302                  9/21/2007                                                          TOP-003-0                  4   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      PNSC was in the process of being replaced as       MIT-07-0758    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700057
                  Security                                                                           PNSC did not provide evidence that it had the                                             responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                Coordinator]                                                                         authority to resolve scheduling conflicts.                                                                                                                           to have an impact on the reliability of the bulk
                                                                                                                                                                                                                                                                          power system, and 2) the purpose of the
                                                                                                                                                                                                                                                                          assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                          the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                          penalty was warranted.
 13

                                                                                                                                                                                                                                                                          The violation was the first violation of this
                                                                                                                                                                                                                                                                          Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as                                                                                                                           serious or substantial risk to the bulk power
                 WECC RC                                                                             CEA for processing.                                                                                                                                                  system.
                  [Rocky
                Mountain –                                                                           The RDRC did not have a copy of each                                                      NERC certified WECC as the RC,                                             NERC as CEA determined that, because 1)
      NERC as                          WECC200700451 /
                  Desert        N/A                         NCR05364                  11/1/2007      Transmission Operator's restoration plan for the    EOP-006-1                  1   MEDIUM which assumed the RC                  6/18/2007     1/1/2009       $0      RDRC was in the process of being replaced as       MIT-07-0977    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700065
                Southwest                                                                            RDRC Reliability Coordinator Area. Only                                                   responsibilities on 1/1/2009.                                              the RC and therefore would not have an ability
                 Reliability                                                                         PacifiCorp’s Utah (PACE) restoration plan was                                                                                                                        to have an impact on the reliability of the bulk
                Coordinator]                                                                         provided.                                                                                                                                                            power system, and 2) the purpose of the
                                                                                                                                                                                                                                                                          assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                          the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                          penalty was warranted.
 14

                                                                                                                                                                                                                                                                          The violation was the first violation of this
                                                                                                                                                                                                                                                                          Reliability Standard and it did not constitute a
                                                                                                     WECC turned over this violation to NERC as                                                                                                                           serious or substantial risk to the bulk power
                 WECC RC                                                                             CEA for processing.                                                                                                                                                  system.
                  [Rocky
                Mountain –                                                                           RDRC did not have a documented training                                                        NERC certified WECC as the RC,                                        NERC as CEA determined that, because 1)
      NERC as                          WECC200700446 /
                  Desert        N/A                         NCR05364                  11/1/2007      program inorder to be staffed with adequately       PER-004-1                  1     HIGH      which assumed the RC             6/18/2007     1/1/2009       $0      RDRC was in the process of being replaced as       MIT-07-0976    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700061
                Southwest                                                                            trained and NERC-certified Reliability                                                         responsibilities on 1/1/2009.                                         the RC and therefore would not have an ability
                 Reliability                                                                         Coordinator operators, 24 hours per day, seven                                                                                                                       to have an impact on the reliability of the bulk
                Coordinator]                                                                         days per week, as required by the Reliability                                                                                                                        power system, and 2) the purpose of the
                                                                                                     Standard.                                                                                                                                                            assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                          the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                          penalty was warranted.
 15

                                                                                                                                                                                                                                                                          The violation was the first violation of this
                                                                                                                                                                                                                                                                          Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                          serious or substantial risk to the bulk power
                 WECC RC                                                                             WECC turned over this violation to NERC as                                                                                                                           system.
                  [Rocky                                                                             CEA for processing.
                Mountain –                                                                                                                                                                          NERC certified WECC as the RC,                                        NERC as CEA determined that, because 1)
      NERC as                          WECC200700447 /
                  Desert        N/A                         NCR05364                  11/1/2007      RDRC did not have a comprehensive                   PER-004-1                  3     HIGH      which assumed the RC             6/18/2007     1/1/2009       $0      RDRC was in the process of being replaced as       MIT-07-0976    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                             NCEA200700062
                Southwest                                                                            understanding of the Reliability Coordinator Area                                              responsibilities on 1/1/2009.                                         the RC and therefore would not have an ability
                 Reliability                                                                         and interactions with neighboring Reliability                                                                                                                        to have an impact on the reliability of the bulk
                Coordinator]                                                                         Coordinator Areas.                                                                                                                                                   power system, and 2) the purpose of the
                                                                                                                                                                                                                                                                          assessment of a financial penalty is to further
                                                                                                                                                                                                                                                                          the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                          penalty was warranted.
 16




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                                                                                                                                                                                                    ATTACHMENT A - OMNIBUS II SPREADSHEET




            A            B             C               D                 E             F             G                                   H                                I            J        K       L                        M                    N           O           P                                Q                              R             S             T            U            V           W
                                                                                    Date
                                                                                  Identified
                                                                                                    Date                                                                                                                                                                                                                                                                            Regional
                                                                                      or                                                                                                                                                                                                                                                                             Registered
                                                                                                Identified or                                                                                                                                                               Total                                                                                                  Entity and
                                                                                  Received                                                                                                                                                        Violation                                                                                                            Entity                                 Prior
                                                                                                  Received                                                                         Regional         Violation                                                              Penalty                                                                     Mitigation                    NERC
                    Registered                                                    (Pre-June                                                                          Reliability                                                                  Start Date   Violation                             Additional Factors                   Mitigation                Certification               Discovery   Violation
       Region                       NOC-ID NERC Violation ID #        NCR_ID                     (Post-June                 Description of the Violation                           Reliability Req.   Risk               Risk Assessment                                      or                                                                         Plan                      Verification
                      Entity                                                          18                                                                             Standard                                                                    (Post-June    End Date                            for the Basis of Penalty              Plan Number              1 of Mitigation of Mitigation  Method      Filing
                                                                                                18 Violation)                                                                      Standard          Factor                                                                Sanction                                                                    Completed
                                                                                  Violation)*                                                                                                                                                     18, 2007)                                                                                                             Plan                                Dockets
                                                                                                                                                                                                                                                                             ($)                                                                                                 2    Plan
                                                                                                                                                                                                                                                                                                                                                                    Completion
                                                                                                                                                                                                                                                                                                                                                                                   Completion3
                                                                                     *if
 1                                                                                applicable

                                                                                                                                                                                                                                                                                      The violation was the first violation of this
                                                                                                                WECC turned over this violation to NERC as                                                                                                                            Reliability Standard and it did not constitute a
                                                                                                                CEA for processing.                                                                                                                                                   serious or substantial risk to the bulk power
                     WECC RC                                                                                                                                                                                                                                                          system.
                      [Rocky                                                                                    RDRC did not have an extensive understanding
                    Mountain –                                                                                  of the Balancing Authorities, Transmission                                                      NERC certified WECC as the RC,                                        NERC as CEA determined that, because 1)
      NERC as                                 WECC200700448 /
                      Desert          N/A                           NCR05364                     11/1/2007      Operators, and Generation Operators within the       PER-004-1                  4     HIGH      which assumed the RC             6/18/2007     1/1/2009       $0      RDRC was in the process of being replaced as       MIT-07-0976    1/1/2009      1/8/2010      3/4/2009      Audit
        CEA                                    NCEA200700063
                    Southwest                                                                                   Reliability Coordinator Area, including the                                                     responsibilities on 1/1/2009.                                         the RC and therefore would not have an ability
                     Reliability                                                                                operating staff, operating practices and                                                                                                                              to have an impact on the reliability of the bulk
                    Coordinator]                                                                                procedures, restoration priorities and objectives,                                                                                                                    power system, and 2) the purpose of the
                                                                                                                outage plans, equipment capabilities, and                                                                                                                             assessment of a financial penalty is to further
                                                                                                                operational restrictions.                                                                                                                                             the reliability of the bulk power system, no
                                                                                                                                                                                                                                                                                      penalty was warranted.
 17


                                                                                                                The pre-June 18 violation identified PNSC's non-
                                                                                                                                                                                                                                                                                      The violation was the first violation of this
                                                                                                                compliance with R1.2 and R1.6.
                                                                                                                                                                                                                                                                                      Reliability Standard and it did not constitute a
                                                                                                                                                                                                                                                                                      serious or substantial risk to the bulk power
                                                                                                                With respect to R1.2, PNSC's WebSAS RC tool
                                                                                                                                                                                                                                                                                      system.
                                                                                                                was not robust enough to provide the RC
                     WECC RC
                                                                                                                coordinators with all interchange schedules and
                      [Pacific                                                                                                                                                                              NERC certified WECC as the RC,                                            NERC as CEA determined that, because 1)
      NERC as                                 WECC200810328/N                                                   tags, including dynamic schedules.                                                                                                                                                                                                                                                Self-
                     Northwest        N/A                           NCR05302      5/20/2007     12/31/2007                                                           EOP-008-0                  1    Medium which assumed the RC                 6/18/2007     1/1/2009       $0      PNSC was in the process of being replaced as       MIT-07-2615    1/1/2009      1/8/2010      3/4/2009
        CEA                                    CEA200800072                                                                                                                                                                                                                                                                                                                                      Report
                      Security                                                                                                                                                                              responsibilities on 1/1/2009.                                             the RC and therefore would not have an ability
                                                                                                                With respect to R1.6, PNSC did not have a formal
                    Coordinator]                                                                                                                                                                                                                                                      to have an impact on the reliability of the bulk
                                                                                                                training plan for the control center and all
                                                                                                                                                                                                                                                                                      power system, and 2) the purpose of the
                                                                                                                reliability coordinators. This violation became a
                                                                                                                                                                                                                                                                                      assessment of a financial penalty is to further
                                                                                                                post-June 18, 2007 violation because PNSC did
                                                                                                                                                                                                                                                                                      the reliability of the bulk power system, no
                                                                                                                not complete its Mitigation Plan by the approved
                                                                                                                                                                                                                                                                                      penalty was warranted.
                                                                                                                completion date.
 18
                1
 19                 Although some of the Mitigation Plans may have been completed at an earlier date, the completion cannot be substantiated. Therefore, the Mitigation Plan completion is the date the new WECC RC assumed responsibility for the funciton.
                2
 20                 Registered Entity Certification of Completion was provided for documentation purposes by the new WECC RC to verify that the violations had been mitigated by its assumption of the function.
                3
 21                 The NCEA Verification of Completion is the NERC Certification of the new WECC RC.




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