COMPLIANCE AUDIT REPORT - nerc.com Repots DL/2013_public_MRO_MPW.pdf · MPW’s Primary Compliance...
Transcript of COMPLIANCE AUDIT REPORT - nerc.com Repots DL/2013_public_MRO_MPW.pdf · MPW’s Primary Compliance...
380 St Peter Street Ste 800 Saint Paul MN 55102 MidwestReliabilityorg P6518551760 F6518551712
COMPLIANCE AUDIT
REPORT
PUBLIC VERSION
Confidential and Non-Public Information Removed (Does Not Contain Privileged and Critical Energy
Infrastructure Information)
Date(s) of On-Site Field Work May 13 ndash 15 2013
Date of Report June 21 2013
Muscatine Power amp Water
NERC Compliance Registry ID NCR00967
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | i
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Table of Contents Executive Summary 1
Registered Entity Profile 2
Internal Compliance Program and Controls 3
Audit Scope 3
Audit Process 5
Objectives 5
Methodology 6
Conflict of Interest and Confidentiality Rules 6
Audit Results 7
Possible Violation(s) 7
MRO Contact Information 8
Appendix I 9
MRO Audit Staff 9
Registered Entity Participants and Observers 9
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 1
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Executive Summary
Midwest Reliability Organization (MRO)1 conducted a compliance audit of Muscatine Power amp
Water (MPW) North American Electric Reliability Corporation (NERC) Compliance Registry
Number NCR00967 for the planned audit period July 1 2009 to April 28 2013 Within the
scope of the audit MPW was registered2 for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
MPWrsquos Primary Compliance Officer was provided notice of the compliance audit on February
12 2013 and an initial Request for Information (RFI) was provided to MPWrsquos Primary
Compliance Contact on February 12 2013 The on-site portion of the compliance audit was
conducted during the period of May 13 2013 to May 15 2013
The audit scope included the applicable Reliability Standards from the 2012 Compliance
Monitoring and Enforcement Program (CMEP) MROrsquos audit team reviewed the applicable
Reliability Standards3 for the period of July 1 2009 to April 28 2013
During the course of the audit a possible violation was discovered for the following
requirement(s)
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
1 MRO is a Regional Entity in North America operating under authority from regulators in the United States and Canada through
a delegation agreement with the North American Electric Reliability Corporation (NERC) In the United States MRO operates
under the authority found in Section 215 of the Federal Power Act through the Federal Energy Regulatory Commission (FERC
or Commission) and through other arrangements in Manitoba and Saskatchewan The primary focus of MRO is assessing
compliance with Reliability Standards on entities that own operate or use the Bulk Electric System (BES) performing
assessments of the BES and technical analysis of matters impacting the reliability of the BES in the north central part of North
America For more information on MRO please refer to wwwmidwestreliabilityorg
2 Each owner user or operator of the BES is listed on a registry which can be found on NERCrsquos website Entities on the registry
are referred to as ldquoRegistered Entitiesrdquo
3 An entire list of Reliability Standards can be found on NERCrsquos website
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 2
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
R12 Each Reliability Coordinator Balancing Authority and Transmission
Operator shall design and develop learning objectives and training materials
based on the task list created in R11
2 PRC-005-1b R2 Transmission and Generation Protection System Maintenance and
Testing Each Transmission Owner and any Distribution Provider that owns a
transmission Protection System and each Generator Owner that owns a generation
Protection System shall provide documentation of its Protection System maintenance
and testing program and the implementation of that program to its Regional Reliability
Organization on request (within 30 calendar days) The documentation of the program
implementation shall include
R21 Evidence Protection System devices were maintained and tested within the
defined intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider
with a UFLS program (as required by its Regional Reliability Organization) shall
implement its UFLS equipment maintenance and testing program and shall provide
UFLS maintenance and testing program results to its Regional Reliability Organization
and NERC on request (within 30 calendar days)
These audit results are further explained later in this report Any possible violations are
processed through the CMEP
MRO staff followed the applicable requirements of the Rules of Procedure (ROP) and CMEP in
the conduct of the compliance audit
The scope of the audit included review of mitigation plans from past enforcement proceedings
andor open remedies from settlements as a result of past enforcement proceedings related to
violations
Registered Entity Profile
Muscatine Power and Water (MPW) is a customer-driven municipal utility They provide
electric water and communications products and services MPW is headquartered in Muscatine
Iowa a historic town of 22719 located on the banks of the Mississippi River 20 miles
downstream from the IllinoisIowa Quad Cities
MPW provides electricity to approximately 11225 customers and water to more than 9500
customers They own and operate three coal-fired electric generating facilities with a combined
nameplate capacity of 29355 MW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 3
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
As of June 1 2010
Electric Utility
Unit 7 generator capacity ndash 25 MW
Unit 8 generator capacity ndash 75 MW
Unit 8A generator capacity ndash 1805 MW
Unit 9 generator capacity ndash 17550 MW
Total nameplate generator nameplate capacity ndash 29355 MW
Previous years peak load (6232009) ndash 139 MW
All-time peak load (7291999) ndash 14990 MW
Average residential electric rate for the year ending 123109 - $00727kWh
Muscatine Electric Light Company was formed in 1922 and merged with Muscatine Water
Works in 1929 They changed their name in 1967 from Muscatine Water and Light to Muscatine
Power and Water
Internal Compliance Program and Controls
Within the scope of the compliance audit MPWrsquos compliance program and related controls
applicable to the Reliability Standards were reviewed during the audit For enforcement
purposes internal compliance program and other pertinent information are reviewed by the
MRO enforcement staff and may be considered during any enforcement proceedings resulting
from a finding of a possible violation as a result of the compliance audit
Audit Scope
MRO performed the compliance audit according to the planned scope and timing previously
communicated to MPW and included the Reliability Standards from MROrsquos Implementation
Plan for an audit period of July 1 2009 to April 28 2013
MPW is registered for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 4
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The following Reliability Standards were included in the scope of the compliance audit
Standard(s) Requirements Title
BAL-002-1 R3 Disturbance Control Performance
CIP-001-2a R2 R3 Sabotage Reporting
COM-001-11 R1 R2 Telecommunications
COM-002-2 R2 Communications and Coordination
EOP-001-0b R3 R7 Emergency Operations Planning
EOP-002-3 R7 Capacity and Energy Emergencies
EOP-004-1 R3 Disturbance Reporting
EOP-005-1 R2 R4 R6 R10 R11 System Restoration Plans
EOP-008-0 R1 Loss of Control Center Functionality
FAC-001-0 R2 Facility Connection Requirements
FAC-002-1 R1 Coordination of Plans For New Generation Transmission and
End-User Facilities
FAC-003-1 R1 R2 Transmission Vegetation Management Program
FAC-008-3 R1 R2 R3 R6 R7 Facility Ratings
FAC-014-2 R2 R4 Establish and Communicate System Operating Limits
IRO-004-2 R1 Reliability Coordination - Operations Planning
IRO-005-3a R9 R10 Reliability Coordination - Current Day Operations
MOD-001-1a R1 R6 Available Transmission System Capability
MOD-004-1 R3 R4 R6 R8 R9
R10 R11
Capacity Benefit Margin
MOD-008-1 R1 R2 R3 R4 R5 Transmission Reliability Margin Calculation Methodology
NUC-001-2 R4 R5 Nuclear Plant Interface Coordination
PER-005-1 R1 R2 R3 System Personnel Training
PRC-001-1 R1 R2 R3 System Protection Coordination
PRC-005-1b R1 R2 Transmission and Generation Protection System Maintenance
and Testing
PRC-008-0 R1 R2 Implementation and Documentation of Underfrequency Load
Shedding Equipment Maintenance Program
PRC-017-0 R1 R2 Special Protection System Maintenance and Testing
PRC-023-2 R1 R2 R3 R4 R5 Transmission Relay Loadability
TOP-002-2b R17 R18 Normal Operations Planning
TOP-004-2 R4 R6 Transmission Operations
TOP-007-0 R1 R2 R3 Reporting System Operating Limit (SOL) and Interconnection
Reliability Operating Limit (IROL) Violations
TPL-003-0a R1 R2 R3 System Performance Following Loss of Two or More Bulk
Electric System Elements (Category C)
TPL-004-0 R2 System Performance Following Extreme Events Resulting in the
Loss of Two or More Bulk Electric System Elements (Category
D)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 5
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The MRO audit team determined that the following Reliability Standard(s) or requirement(s) were
not applicable to MPW during the compliance audit
1 BAL-002-1 Disturbance Control Performance
2 FAC-003-1 Transmission Vegetation Management Program
3 NUC-001-2 Nuclear Plant Interface Coordination
4 PRC-017-0 Special Protection System Maintenance and Testing
5 PRC-023-2 Transmission Relay Loadability
Audit Process
MRO conducts compliance audits in accordance with the current version of the CMEP and ROP
(as approved by the Federal Energy Regulatory Commission for entities in the United States or
through other arrangements in Manitoba and Saskatchewan) and generally conforms to the
United States Government Accountability Office Government Auditing Standards and other
generally accepted audit practices applicable to the conduct of the work The compliance audit
process steps can be found in the NERC CMEP
Compliance audits are conducted to obtain reasonable assurance of compliance with the
applicable Reliability Standards The compliance audit includes requests for data such as
program documents procedures and performance records considered necessary to provide
reasonable assurance of any findings or conclusions Audit procedures include tests of
documentary evidence supporting compliance tests of the assertions made regarding
compliance and direct confirmation of actions taken as part of compliance with the Reliability
Standards
If possible violations are identified the matter is turned over to MRO Risk Assessment and
Mitigation staff to initiate mitigation and enforcement proceedings under the CMEP The staff
will contact the designated Primary Compliance Contact or MPW may contact MRO staff at any
time Upon validation by Enforcement staff MPW will be provided a written notice of the
alleged violation within a reasonable timeframe that shall include the due process protections
under the CMEP
MPW is encouraged to maintain an adequate internal compliance program designed to ensure
compliance with Reliability Standards to protect the reliability of the Bulk Electric System
(BES) The program should contain internal controls designed to detect correct and prevent
recurrence of compliance violations
Objectives
Entities that own operate or use the BES in North America are subject to compliance audits for
applicable Reliability Standards based upon the functions performed within the scope of the
compliance audit The primary audit objectives are to
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | i
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Table of Contents Executive Summary 1
Registered Entity Profile 2
Internal Compliance Program and Controls 3
Audit Scope 3
Audit Process 5
Objectives 5
Methodology 6
Conflict of Interest and Confidentiality Rules 6
Audit Results 7
Possible Violation(s) 7
MRO Contact Information 8
Appendix I 9
MRO Audit Staff 9
Registered Entity Participants and Observers 9
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 1
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Executive Summary
Midwest Reliability Organization (MRO)1 conducted a compliance audit of Muscatine Power amp
Water (MPW) North American Electric Reliability Corporation (NERC) Compliance Registry
Number NCR00967 for the planned audit period July 1 2009 to April 28 2013 Within the
scope of the audit MPW was registered2 for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
MPWrsquos Primary Compliance Officer was provided notice of the compliance audit on February
12 2013 and an initial Request for Information (RFI) was provided to MPWrsquos Primary
Compliance Contact on February 12 2013 The on-site portion of the compliance audit was
conducted during the period of May 13 2013 to May 15 2013
The audit scope included the applicable Reliability Standards from the 2012 Compliance
Monitoring and Enforcement Program (CMEP) MROrsquos audit team reviewed the applicable
Reliability Standards3 for the period of July 1 2009 to April 28 2013
During the course of the audit a possible violation was discovered for the following
requirement(s)
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
1 MRO is a Regional Entity in North America operating under authority from regulators in the United States and Canada through
a delegation agreement with the North American Electric Reliability Corporation (NERC) In the United States MRO operates
under the authority found in Section 215 of the Federal Power Act through the Federal Energy Regulatory Commission (FERC
or Commission) and through other arrangements in Manitoba and Saskatchewan The primary focus of MRO is assessing
compliance with Reliability Standards on entities that own operate or use the Bulk Electric System (BES) performing
assessments of the BES and technical analysis of matters impacting the reliability of the BES in the north central part of North
America For more information on MRO please refer to wwwmidwestreliabilityorg
2 Each owner user or operator of the BES is listed on a registry which can be found on NERCrsquos website Entities on the registry
are referred to as ldquoRegistered Entitiesrdquo
3 An entire list of Reliability Standards can be found on NERCrsquos website
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 2
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
R12 Each Reliability Coordinator Balancing Authority and Transmission
Operator shall design and develop learning objectives and training materials
based on the task list created in R11
2 PRC-005-1b R2 Transmission and Generation Protection System Maintenance and
Testing Each Transmission Owner and any Distribution Provider that owns a
transmission Protection System and each Generator Owner that owns a generation
Protection System shall provide documentation of its Protection System maintenance
and testing program and the implementation of that program to its Regional Reliability
Organization on request (within 30 calendar days) The documentation of the program
implementation shall include
R21 Evidence Protection System devices were maintained and tested within the
defined intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider
with a UFLS program (as required by its Regional Reliability Organization) shall
implement its UFLS equipment maintenance and testing program and shall provide
UFLS maintenance and testing program results to its Regional Reliability Organization
and NERC on request (within 30 calendar days)
These audit results are further explained later in this report Any possible violations are
processed through the CMEP
MRO staff followed the applicable requirements of the Rules of Procedure (ROP) and CMEP in
the conduct of the compliance audit
The scope of the audit included review of mitigation plans from past enforcement proceedings
andor open remedies from settlements as a result of past enforcement proceedings related to
violations
Registered Entity Profile
Muscatine Power and Water (MPW) is a customer-driven municipal utility They provide
electric water and communications products and services MPW is headquartered in Muscatine
Iowa a historic town of 22719 located on the banks of the Mississippi River 20 miles
downstream from the IllinoisIowa Quad Cities
MPW provides electricity to approximately 11225 customers and water to more than 9500
customers They own and operate three coal-fired electric generating facilities with a combined
nameplate capacity of 29355 MW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 3
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
As of June 1 2010
Electric Utility
Unit 7 generator capacity ndash 25 MW
Unit 8 generator capacity ndash 75 MW
Unit 8A generator capacity ndash 1805 MW
Unit 9 generator capacity ndash 17550 MW
Total nameplate generator nameplate capacity ndash 29355 MW
Previous years peak load (6232009) ndash 139 MW
All-time peak load (7291999) ndash 14990 MW
Average residential electric rate for the year ending 123109 - $00727kWh
Muscatine Electric Light Company was formed in 1922 and merged with Muscatine Water
Works in 1929 They changed their name in 1967 from Muscatine Water and Light to Muscatine
Power and Water
Internal Compliance Program and Controls
Within the scope of the compliance audit MPWrsquos compliance program and related controls
applicable to the Reliability Standards were reviewed during the audit For enforcement
purposes internal compliance program and other pertinent information are reviewed by the
MRO enforcement staff and may be considered during any enforcement proceedings resulting
from a finding of a possible violation as a result of the compliance audit
Audit Scope
MRO performed the compliance audit according to the planned scope and timing previously
communicated to MPW and included the Reliability Standards from MROrsquos Implementation
Plan for an audit period of July 1 2009 to April 28 2013
MPW is registered for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 4
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The following Reliability Standards were included in the scope of the compliance audit
Standard(s) Requirements Title
BAL-002-1 R3 Disturbance Control Performance
CIP-001-2a R2 R3 Sabotage Reporting
COM-001-11 R1 R2 Telecommunications
COM-002-2 R2 Communications and Coordination
EOP-001-0b R3 R7 Emergency Operations Planning
EOP-002-3 R7 Capacity and Energy Emergencies
EOP-004-1 R3 Disturbance Reporting
EOP-005-1 R2 R4 R6 R10 R11 System Restoration Plans
EOP-008-0 R1 Loss of Control Center Functionality
FAC-001-0 R2 Facility Connection Requirements
FAC-002-1 R1 Coordination of Plans For New Generation Transmission and
End-User Facilities
FAC-003-1 R1 R2 Transmission Vegetation Management Program
FAC-008-3 R1 R2 R3 R6 R7 Facility Ratings
FAC-014-2 R2 R4 Establish and Communicate System Operating Limits
IRO-004-2 R1 Reliability Coordination - Operations Planning
IRO-005-3a R9 R10 Reliability Coordination - Current Day Operations
MOD-001-1a R1 R6 Available Transmission System Capability
MOD-004-1 R3 R4 R6 R8 R9
R10 R11
Capacity Benefit Margin
MOD-008-1 R1 R2 R3 R4 R5 Transmission Reliability Margin Calculation Methodology
NUC-001-2 R4 R5 Nuclear Plant Interface Coordination
PER-005-1 R1 R2 R3 System Personnel Training
PRC-001-1 R1 R2 R3 System Protection Coordination
PRC-005-1b R1 R2 Transmission and Generation Protection System Maintenance
and Testing
PRC-008-0 R1 R2 Implementation and Documentation of Underfrequency Load
Shedding Equipment Maintenance Program
PRC-017-0 R1 R2 Special Protection System Maintenance and Testing
PRC-023-2 R1 R2 R3 R4 R5 Transmission Relay Loadability
TOP-002-2b R17 R18 Normal Operations Planning
TOP-004-2 R4 R6 Transmission Operations
TOP-007-0 R1 R2 R3 Reporting System Operating Limit (SOL) and Interconnection
Reliability Operating Limit (IROL) Violations
TPL-003-0a R1 R2 R3 System Performance Following Loss of Two or More Bulk
Electric System Elements (Category C)
TPL-004-0 R2 System Performance Following Extreme Events Resulting in the
Loss of Two or More Bulk Electric System Elements (Category
D)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 5
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The MRO audit team determined that the following Reliability Standard(s) or requirement(s) were
not applicable to MPW during the compliance audit
1 BAL-002-1 Disturbance Control Performance
2 FAC-003-1 Transmission Vegetation Management Program
3 NUC-001-2 Nuclear Plant Interface Coordination
4 PRC-017-0 Special Protection System Maintenance and Testing
5 PRC-023-2 Transmission Relay Loadability
Audit Process
MRO conducts compliance audits in accordance with the current version of the CMEP and ROP
(as approved by the Federal Energy Regulatory Commission for entities in the United States or
through other arrangements in Manitoba and Saskatchewan) and generally conforms to the
United States Government Accountability Office Government Auditing Standards and other
generally accepted audit practices applicable to the conduct of the work The compliance audit
process steps can be found in the NERC CMEP
Compliance audits are conducted to obtain reasonable assurance of compliance with the
applicable Reliability Standards The compliance audit includes requests for data such as
program documents procedures and performance records considered necessary to provide
reasonable assurance of any findings or conclusions Audit procedures include tests of
documentary evidence supporting compliance tests of the assertions made regarding
compliance and direct confirmation of actions taken as part of compliance with the Reliability
Standards
If possible violations are identified the matter is turned over to MRO Risk Assessment and
Mitigation staff to initiate mitigation and enforcement proceedings under the CMEP The staff
will contact the designated Primary Compliance Contact or MPW may contact MRO staff at any
time Upon validation by Enforcement staff MPW will be provided a written notice of the
alleged violation within a reasonable timeframe that shall include the due process protections
under the CMEP
MPW is encouraged to maintain an adequate internal compliance program designed to ensure
compliance with Reliability Standards to protect the reliability of the Bulk Electric System
(BES) The program should contain internal controls designed to detect correct and prevent
recurrence of compliance violations
Objectives
Entities that own operate or use the BES in North America are subject to compliance audits for
applicable Reliability Standards based upon the functions performed within the scope of the
compliance audit The primary audit objectives are to
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 1
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Executive Summary
Midwest Reliability Organization (MRO)1 conducted a compliance audit of Muscatine Power amp
Water (MPW) North American Electric Reliability Corporation (NERC) Compliance Registry
Number NCR00967 for the planned audit period July 1 2009 to April 28 2013 Within the
scope of the audit MPW was registered2 for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
MPWrsquos Primary Compliance Officer was provided notice of the compliance audit on February
12 2013 and an initial Request for Information (RFI) was provided to MPWrsquos Primary
Compliance Contact on February 12 2013 The on-site portion of the compliance audit was
conducted during the period of May 13 2013 to May 15 2013
The audit scope included the applicable Reliability Standards from the 2012 Compliance
Monitoring and Enforcement Program (CMEP) MROrsquos audit team reviewed the applicable
Reliability Standards3 for the period of July 1 2009 to April 28 2013
During the course of the audit a possible violation was discovered for the following
requirement(s)
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
1 MRO is a Regional Entity in North America operating under authority from regulators in the United States and Canada through
a delegation agreement with the North American Electric Reliability Corporation (NERC) In the United States MRO operates
under the authority found in Section 215 of the Federal Power Act through the Federal Energy Regulatory Commission (FERC
or Commission) and through other arrangements in Manitoba and Saskatchewan The primary focus of MRO is assessing
compliance with Reliability Standards on entities that own operate or use the Bulk Electric System (BES) performing
assessments of the BES and technical analysis of matters impacting the reliability of the BES in the north central part of North
America For more information on MRO please refer to wwwmidwestreliabilityorg
2 Each owner user or operator of the BES is listed on a registry which can be found on NERCrsquos website Entities on the registry
are referred to as ldquoRegistered Entitiesrdquo
3 An entire list of Reliability Standards can be found on NERCrsquos website
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 2
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
R12 Each Reliability Coordinator Balancing Authority and Transmission
Operator shall design and develop learning objectives and training materials
based on the task list created in R11
2 PRC-005-1b R2 Transmission and Generation Protection System Maintenance and
Testing Each Transmission Owner and any Distribution Provider that owns a
transmission Protection System and each Generator Owner that owns a generation
Protection System shall provide documentation of its Protection System maintenance
and testing program and the implementation of that program to its Regional Reliability
Organization on request (within 30 calendar days) The documentation of the program
implementation shall include
R21 Evidence Protection System devices were maintained and tested within the
defined intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider
with a UFLS program (as required by its Regional Reliability Organization) shall
implement its UFLS equipment maintenance and testing program and shall provide
UFLS maintenance and testing program results to its Regional Reliability Organization
and NERC on request (within 30 calendar days)
These audit results are further explained later in this report Any possible violations are
processed through the CMEP
MRO staff followed the applicable requirements of the Rules of Procedure (ROP) and CMEP in
the conduct of the compliance audit
The scope of the audit included review of mitigation plans from past enforcement proceedings
andor open remedies from settlements as a result of past enforcement proceedings related to
violations
Registered Entity Profile
Muscatine Power and Water (MPW) is a customer-driven municipal utility They provide
electric water and communications products and services MPW is headquartered in Muscatine
Iowa a historic town of 22719 located on the banks of the Mississippi River 20 miles
downstream from the IllinoisIowa Quad Cities
MPW provides electricity to approximately 11225 customers and water to more than 9500
customers They own and operate three coal-fired electric generating facilities with a combined
nameplate capacity of 29355 MW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 3
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
As of June 1 2010
Electric Utility
Unit 7 generator capacity ndash 25 MW
Unit 8 generator capacity ndash 75 MW
Unit 8A generator capacity ndash 1805 MW
Unit 9 generator capacity ndash 17550 MW
Total nameplate generator nameplate capacity ndash 29355 MW
Previous years peak load (6232009) ndash 139 MW
All-time peak load (7291999) ndash 14990 MW
Average residential electric rate for the year ending 123109 - $00727kWh
Muscatine Electric Light Company was formed in 1922 and merged with Muscatine Water
Works in 1929 They changed their name in 1967 from Muscatine Water and Light to Muscatine
Power and Water
Internal Compliance Program and Controls
Within the scope of the compliance audit MPWrsquos compliance program and related controls
applicable to the Reliability Standards were reviewed during the audit For enforcement
purposes internal compliance program and other pertinent information are reviewed by the
MRO enforcement staff and may be considered during any enforcement proceedings resulting
from a finding of a possible violation as a result of the compliance audit
Audit Scope
MRO performed the compliance audit according to the planned scope and timing previously
communicated to MPW and included the Reliability Standards from MROrsquos Implementation
Plan for an audit period of July 1 2009 to April 28 2013
MPW is registered for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 4
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The following Reliability Standards were included in the scope of the compliance audit
Standard(s) Requirements Title
BAL-002-1 R3 Disturbance Control Performance
CIP-001-2a R2 R3 Sabotage Reporting
COM-001-11 R1 R2 Telecommunications
COM-002-2 R2 Communications and Coordination
EOP-001-0b R3 R7 Emergency Operations Planning
EOP-002-3 R7 Capacity and Energy Emergencies
EOP-004-1 R3 Disturbance Reporting
EOP-005-1 R2 R4 R6 R10 R11 System Restoration Plans
EOP-008-0 R1 Loss of Control Center Functionality
FAC-001-0 R2 Facility Connection Requirements
FAC-002-1 R1 Coordination of Plans For New Generation Transmission and
End-User Facilities
FAC-003-1 R1 R2 Transmission Vegetation Management Program
FAC-008-3 R1 R2 R3 R6 R7 Facility Ratings
FAC-014-2 R2 R4 Establish and Communicate System Operating Limits
IRO-004-2 R1 Reliability Coordination - Operations Planning
IRO-005-3a R9 R10 Reliability Coordination - Current Day Operations
MOD-001-1a R1 R6 Available Transmission System Capability
MOD-004-1 R3 R4 R6 R8 R9
R10 R11
Capacity Benefit Margin
MOD-008-1 R1 R2 R3 R4 R5 Transmission Reliability Margin Calculation Methodology
NUC-001-2 R4 R5 Nuclear Plant Interface Coordination
PER-005-1 R1 R2 R3 System Personnel Training
PRC-001-1 R1 R2 R3 System Protection Coordination
PRC-005-1b R1 R2 Transmission and Generation Protection System Maintenance
and Testing
PRC-008-0 R1 R2 Implementation and Documentation of Underfrequency Load
Shedding Equipment Maintenance Program
PRC-017-0 R1 R2 Special Protection System Maintenance and Testing
PRC-023-2 R1 R2 R3 R4 R5 Transmission Relay Loadability
TOP-002-2b R17 R18 Normal Operations Planning
TOP-004-2 R4 R6 Transmission Operations
TOP-007-0 R1 R2 R3 Reporting System Operating Limit (SOL) and Interconnection
Reliability Operating Limit (IROL) Violations
TPL-003-0a R1 R2 R3 System Performance Following Loss of Two or More Bulk
Electric System Elements (Category C)
TPL-004-0 R2 System Performance Following Extreme Events Resulting in the
Loss of Two or More Bulk Electric System Elements (Category
D)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 5
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The MRO audit team determined that the following Reliability Standard(s) or requirement(s) were
not applicable to MPW during the compliance audit
1 BAL-002-1 Disturbance Control Performance
2 FAC-003-1 Transmission Vegetation Management Program
3 NUC-001-2 Nuclear Plant Interface Coordination
4 PRC-017-0 Special Protection System Maintenance and Testing
5 PRC-023-2 Transmission Relay Loadability
Audit Process
MRO conducts compliance audits in accordance with the current version of the CMEP and ROP
(as approved by the Federal Energy Regulatory Commission for entities in the United States or
through other arrangements in Manitoba and Saskatchewan) and generally conforms to the
United States Government Accountability Office Government Auditing Standards and other
generally accepted audit practices applicable to the conduct of the work The compliance audit
process steps can be found in the NERC CMEP
Compliance audits are conducted to obtain reasonable assurance of compliance with the
applicable Reliability Standards The compliance audit includes requests for data such as
program documents procedures and performance records considered necessary to provide
reasonable assurance of any findings or conclusions Audit procedures include tests of
documentary evidence supporting compliance tests of the assertions made regarding
compliance and direct confirmation of actions taken as part of compliance with the Reliability
Standards
If possible violations are identified the matter is turned over to MRO Risk Assessment and
Mitigation staff to initiate mitigation and enforcement proceedings under the CMEP The staff
will contact the designated Primary Compliance Contact or MPW may contact MRO staff at any
time Upon validation by Enforcement staff MPW will be provided a written notice of the
alleged violation within a reasonable timeframe that shall include the due process protections
under the CMEP
MPW is encouraged to maintain an adequate internal compliance program designed to ensure
compliance with Reliability Standards to protect the reliability of the Bulk Electric System
(BES) The program should contain internal controls designed to detect correct and prevent
recurrence of compliance violations
Objectives
Entities that own operate or use the BES in North America are subject to compliance audits for
applicable Reliability Standards based upon the functions performed within the scope of the
compliance audit The primary audit objectives are to
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 2
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
R12 Each Reliability Coordinator Balancing Authority and Transmission
Operator shall design and develop learning objectives and training materials
based on the task list created in R11
2 PRC-005-1b R2 Transmission and Generation Protection System Maintenance and
Testing Each Transmission Owner and any Distribution Provider that owns a
transmission Protection System and each Generator Owner that owns a generation
Protection System shall provide documentation of its Protection System maintenance
and testing program and the implementation of that program to its Regional Reliability
Organization on request (within 30 calendar days) The documentation of the program
implementation shall include
R21 Evidence Protection System devices were maintained and tested within the
defined intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider
with a UFLS program (as required by its Regional Reliability Organization) shall
implement its UFLS equipment maintenance and testing program and shall provide
UFLS maintenance and testing program results to its Regional Reliability Organization
and NERC on request (within 30 calendar days)
These audit results are further explained later in this report Any possible violations are
processed through the CMEP
MRO staff followed the applicable requirements of the Rules of Procedure (ROP) and CMEP in
the conduct of the compliance audit
The scope of the audit included review of mitigation plans from past enforcement proceedings
andor open remedies from settlements as a result of past enforcement proceedings related to
violations
Registered Entity Profile
Muscatine Power and Water (MPW) is a customer-driven municipal utility They provide
electric water and communications products and services MPW is headquartered in Muscatine
Iowa a historic town of 22719 located on the banks of the Mississippi River 20 miles
downstream from the IllinoisIowa Quad Cities
MPW provides electricity to approximately 11225 customers and water to more than 9500
customers They own and operate three coal-fired electric generating facilities with a combined
nameplate capacity of 29355 MW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 3
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
As of June 1 2010
Electric Utility
Unit 7 generator capacity ndash 25 MW
Unit 8 generator capacity ndash 75 MW
Unit 8A generator capacity ndash 1805 MW
Unit 9 generator capacity ndash 17550 MW
Total nameplate generator nameplate capacity ndash 29355 MW
Previous years peak load (6232009) ndash 139 MW
All-time peak load (7291999) ndash 14990 MW
Average residential electric rate for the year ending 123109 - $00727kWh
Muscatine Electric Light Company was formed in 1922 and merged with Muscatine Water
Works in 1929 They changed their name in 1967 from Muscatine Water and Light to Muscatine
Power and Water
Internal Compliance Program and Controls
Within the scope of the compliance audit MPWrsquos compliance program and related controls
applicable to the Reliability Standards were reviewed during the audit For enforcement
purposes internal compliance program and other pertinent information are reviewed by the
MRO enforcement staff and may be considered during any enforcement proceedings resulting
from a finding of a possible violation as a result of the compliance audit
Audit Scope
MRO performed the compliance audit according to the planned scope and timing previously
communicated to MPW and included the Reliability Standards from MROrsquos Implementation
Plan for an audit period of July 1 2009 to April 28 2013
MPW is registered for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 4
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The following Reliability Standards were included in the scope of the compliance audit
Standard(s) Requirements Title
BAL-002-1 R3 Disturbance Control Performance
CIP-001-2a R2 R3 Sabotage Reporting
COM-001-11 R1 R2 Telecommunications
COM-002-2 R2 Communications and Coordination
EOP-001-0b R3 R7 Emergency Operations Planning
EOP-002-3 R7 Capacity and Energy Emergencies
EOP-004-1 R3 Disturbance Reporting
EOP-005-1 R2 R4 R6 R10 R11 System Restoration Plans
EOP-008-0 R1 Loss of Control Center Functionality
FAC-001-0 R2 Facility Connection Requirements
FAC-002-1 R1 Coordination of Plans For New Generation Transmission and
End-User Facilities
FAC-003-1 R1 R2 Transmission Vegetation Management Program
FAC-008-3 R1 R2 R3 R6 R7 Facility Ratings
FAC-014-2 R2 R4 Establish and Communicate System Operating Limits
IRO-004-2 R1 Reliability Coordination - Operations Planning
IRO-005-3a R9 R10 Reliability Coordination - Current Day Operations
MOD-001-1a R1 R6 Available Transmission System Capability
MOD-004-1 R3 R4 R6 R8 R9
R10 R11
Capacity Benefit Margin
MOD-008-1 R1 R2 R3 R4 R5 Transmission Reliability Margin Calculation Methodology
NUC-001-2 R4 R5 Nuclear Plant Interface Coordination
PER-005-1 R1 R2 R3 System Personnel Training
PRC-001-1 R1 R2 R3 System Protection Coordination
PRC-005-1b R1 R2 Transmission and Generation Protection System Maintenance
and Testing
PRC-008-0 R1 R2 Implementation and Documentation of Underfrequency Load
Shedding Equipment Maintenance Program
PRC-017-0 R1 R2 Special Protection System Maintenance and Testing
PRC-023-2 R1 R2 R3 R4 R5 Transmission Relay Loadability
TOP-002-2b R17 R18 Normal Operations Planning
TOP-004-2 R4 R6 Transmission Operations
TOP-007-0 R1 R2 R3 Reporting System Operating Limit (SOL) and Interconnection
Reliability Operating Limit (IROL) Violations
TPL-003-0a R1 R2 R3 System Performance Following Loss of Two or More Bulk
Electric System Elements (Category C)
TPL-004-0 R2 System Performance Following Extreme Events Resulting in the
Loss of Two or More Bulk Electric System Elements (Category
D)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 5
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The MRO audit team determined that the following Reliability Standard(s) or requirement(s) were
not applicable to MPW during the compliance audit
1 BAL-002-1 Disturbance Control Performance
2 FAC-003-1 Transmission Vegetation Management Program
3 NUC-001-2 Nuclear Plant Interface Coordination
4 PRC-017-0 Special Protection System Maintenance and Testing
5 PRC-023-2 Transmission Relay Loadability
Audit Process
MRO conducts compliance audits in accordance with the current version of the CMEP and ROP
(as approved by the Federal Energy Regulatory Commission for entities in the United States or
through other arrangements in Manitoba and Saskatchewan) and generally conforms to the
United States Government Accountability Office Government Auditing Standards and other
generally accepted audit practices applicable to the conduct of the work The compliance audit
process steps can be found in the NERC CMEP
Compliance audits are conducted to obtain reasonable assurance of compliance with the
applicable Reliability Standards The compliance audit includes requests for data such as
program documents procedures and performance records considered necessary to provide
reasonable assurance of any findings or conclusions Audit procedures include tests of
documentary evidence supporting compliance tests of the assertions made regarding
compliance and direct confirmation of actions taken as part of compliance with the Reliability
Standards
If possible violations are identified the matter is turned over to MRO Risk Assessment and
Mitigation staff to initiate mitigation and enforcement proceedings under the CMEP The staff
will contact the designated Primary Compliance Contact or MPW may contact MRO staff at any
time Upon validation by Enforcement staff MPW will be provided a written notice of the
alleged violation within a reasonable timeframe that shall include the due process protections
under the CMEP
MPW is encouraged to maintain an adequate internal compliance program designed to ensure
compliance with Reliability Standards to protect the reliability of the Bulk Electric System
(BES) The program should contain internal controls designed to detect correct and prevent
recurrence of compliance violations
Objectives
Entities that own operate or use the BES in North America are subject to compliance audits for
applicable Reliability Standards based upon the functions performed within the scope of the
compliance audit The primary audit objectives are to
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 3
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
As of June 1 2010
Electric Utility
Unit 7 generator capacity ndash 25 MW
Unit 8 generator capacity ndash 75 MW
Unit 8A generator capacity ndash 1805 MW
Unit 9 generator capacity ndash 17550 MW
Total nameplate generator nameplate capacity ndash 29355 MW
Previous years peak load (6232009) ndash 139 MW
All-time peak load (7291999) ndash 14990 MW
Average residential electric rate for the year ending 123109 - $00727kWh
Muscatine Electric Light Company was formed in 1922 and merged with Muscatine Water
Works in 1929 They changed their name in 1967 from Muscatine Water and Light to Muscatine
Power and Water
Internal Compliance Program and Controls
Within the scope of the compliance audit MPWrsquos compliance program and related controls
applicable to the Reliability Standards were reviewed during the audit For enforcement
purposes internal compliance program and other pertinent information are reviewed by the
MRO enforcement staff and may be considered during any enforcement proceedings resulting
from a finding of a possible violation as a result of the compliance audit
Audit Scope
MRO performed the compliance audit according to the planned scope and timing previously
communicated to MPW and included the Reliability Standards from MROrsquos Implementation
Plan for an audit period of July 1 2009 to April 28 2013
MPW is registered for the following functions
Member MISO CFR JRO00001 (BA)
Distribution Provider (DP)
Generator Operator (GOP)
Generator Owner (GO)
Load Serving Entity (LSE)
Purchasing Selling Entity (PSE)
Resource Planner (RP)
Transmission Operator (TOP)
Transmission Owner (TO)
Transmission Planner (TP)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 4
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The following Reliability Standards were included in the scope of the compliance audit
Standard(s) Requirements Title
BAL-002-1 R3 Disturbance Control Performance
CIP-001-2a R2 R3 Sabotage Reporting
COM-001-11 R1 R2 Telecommunications
COM-002-2 R2 Communications and Coordination
EOP-001-0b R3 R7 Emergency Operations Planning
EOP-002-3 R7 Capacity and Energy Emergencies
EOP-004-1 R3 Disturbance Reporting
EOP-005-1 R2 R4 R6 R10 R11 System Restoration Plans
EOP-008-0 R1 Loss of Control Center Functionality
FAC-001-0 R2 Facility Connection Requirements
FAC-002-1 R1 Coordination of Plans For New Generation Transmission and
End-User Facilities
FAC-003-1 R1 R2 Transmission Vegetation Management Program
FAC-008-3 R1 R2 R3 R6 R7 Facility Ratings
FAC-014-2 R2 R4 Establish and Communicate System Operating Limits
IRO-004-2 R1 Reliability Coordination - Operations Planning
IRO-005-3a R9 R10 Reliability Coordination - Current Day Operations
MOD-001-1a R1 R6 Available Transmission System Capability
MOD-004-1 R3 R4 R6 R8 R9
R10 R11
Capacity Benefit Margin
MOD-008-1 R1 R2 R3 R4 R5 Transmission Reliability Margin Calculation Methodology
NUC-001-2 R4 R5 Nuclear Plant Interface Coordination
PER-005-1 R1 R2 R3 System Personnel Training
PRC-001-1 R1 R2 R3 System Protection Coordination
PRC-005-1b R1 R2 Transmission and Generation Protection System Maintenance
and Testing
PRC-008-0 R1 R2 Implementation and Documentation of Underfrequency Load
Shedding Equipment Maintenance Program
PRC-017-0 R1 R2 Special Protection System Maintenance and Testing
PRC-023-2 R1 R2 R3 R4 R5 Transmission Relay Loadability
TOP-002-2b R17 R18 Normal Operations Planning
TOP-004-2 R4 R6 Transmission Operations
TOP-007-0 R1 R2 R3 Reporting System Operating Limit (SOL) and Interconnection
Reliability Operating Limit (IROL) Violations
TPL-003-0a R1 R2 R3 System Performance Following Loss of Two or More Bulk
Electric System Elements (Category C)
TPL-004-0 R2 System Performance Following Extreme Events Resulting in the
Loss of Two or More Bulk Electric System Elements (Category
D)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 5
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The MRO audit team determined that the following Reliability Standard(s) or requirement(s) were
not applicable to MPW during the compliance audit
1 BAL-002-1 Disturbance Control Performance
2 FAC-003-1 Transmission Vegetation Management Program
3 NUC-001-2 Nuclear Plant Interface Coordination
4 PRC-017-0 Special Protection System Maintenance and Testing
5 PRC-023-2 Transmission Relay Loadability
Audit Process
MRO conducts compliance audits in accordance with the current version of the CMEP and ROP
(as approved by the Federal Energy Regulatory Commission for entities in the United States or
through other arrangements in Manitoba and Saskatchewan) and generally conforms to the
United States Government Accountability Office Government Auditing Standards and other
generally accepted audit practices applicable to the conduct of the work The compliance audit
process steps can be found in the NERC CMEP
Compliance audits are conducted to obtain reasonable assurance of compliance with the
applicable Reliability Standards The compliance audit includes requests for data such as
program documents procedures and performance records considered necessary to provide
reasonable assurance of any findings or conclusions Audit procedures include tests of
documentary evidence supporting compliance tests of the assertions made regarding
compliance and direct confirmation of actions taken as part of compliance with the Reliability
Standards
If possible violations are identified the matter is turned over to MRO Risk Assessment and
Mitigation staff to initiate mitigation and enforcement proceedings under the CMEP The staff
will contact the designated Primary Compliance Contact or MPW may contact MRO staff at any
time Upon validation by Enforcement staff MPW will be provided a written notice of the
alleged violation within a reasonable timeframe that shall include the due process protections
under the CMEP
MPW is encouraged to maintain an adequate internal compliance program designed to ensure
compliance with Reliability Standards to protect the reliability of the Bulk Electric System
(BES) The program should contain internal controls designed to detect correct and prevent
recurrence of compliance violations
Objectives
Entities that own operate or use the BES in North America are subject to compliance audits for
applicable Reliability Standards based upon the functions performed within the scope of the
compliance audit The primary audit objectives are to
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 4
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The following Reliability Standards were included in the scope of the compliance audit
Standard(s) Requirements Title
BAL-002-1 R3 Disturbance Control Performance
CIP-001-2a R2 R3 Sabotage Reporting
COM-001-11 R1 R2 Telecommunications
COM-002-2 R2 Communications and Coordination
EOP-001-0b R3 R7 Emergency Operations Planning
EOP-002-3 R7 Capacity and Energy Emergencies
EOP-004-1 R3 Disturbance Reporting
EOP-005-1 R2 R4 R6 R10 R11 System Restoration Plans
EOP-008-0 R1 Loss of Control Center Functionality
FAC-001-0 R2 Facility Connection Requirements
FAC-002-1 R1 Coordination of Plans For New Generation Transmission and
End-User Facilities
FAC-003-1 R1 R2 Transmission Vegetation Management Program
FAC-008-3 R1 R2 R3 R6 R7 Facility Ratings
FAC-014-2 R2 R4 Establish and Communicate System Operating Limits
IRO-004-2 R1 Reliability Coordination - Operations Planning
IRO-005-3a R9 R10 Reliability Coordination - Current Day Operations
MOD-001-1a R1 R6 Available Transmission System Capability
MOD-004-1 R3 R4 R6 R8 R9
R10 R11
Capacity Benefit Margin
MOD-008-1 R1 R2 R3 R4 R5 Transmission Reliability Margin Calculation Methodology
NUC-001-2 R4 R5 Nuclear Plant Interface Coordination
PER-005-1 R1 R2 R3 System Personnel Training
PRC-001-1 R1 R2 R3 System Protection Coordination
PRC-005-1b R1 R2 Transmission and Generation Protection System Maintenance
and Testing
PRC-008-0 R1 R2 Implementation and Documentation of Underfrequency Load
Shedding Equipment Maintenance Program
PRC-017-0 R1 R2 Special Protection System Maintenance and Testing
PRC-023-2 R1 R2 R3 R4 R5 Transmission Relay Loadability
TOP-002-2b R17 R18 Normal Operations Planning
TOP-004-2 R4 R6 Transmission Operations
TOP-007-0 R1 R2 R3 Reporting System Operating Limit (SOL) and Interconnection
Reliability Operating Limit (IROL) Violations
TPL-003-0a R1 R2 R3 System Performance Following Loss of Two or More Bulk
Electric System Elements (Category C)
TPL-004-0 R2 System Performance Following Extreme Events Resulting in the
Loss of Two or More Bulk Electric System Elements (Category
D)
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 5
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The MRO audit team determined that the following Reliability Standard(s) or requirement(s) were
not applicable to MPW during the compliance audit
1 BAL-002-1 Disturbance Control Performance
2 FAC-003-1 Transmission Vegetation Management Program
3 NUC-001-2 Nuclear Plant Interface Coordination
4 PRC-017-0 Special Protection System Maintenance and Testing
5 PRC-023-2 Transmission Relay Loadability
Audit Process
MRO conducts compliance audits in accordance with the current version of the CMEP and ROP
(as approved by the Federal Energy Regulatory Commission for entities in the United States or
through other arrangements in Manitoba and Saskatchewan) and generally conforms to the
United States Government Accountability Office Government Auditing Standards and other
generally accepted audit practices applicable to the conduct of the work The compliance audit
process steps can be found in the NERC CMEP
Compliance audits are conducted to obtain reasonable assurance of compliance with the
applicable Reliability Standards The compliance audit includes requests for data such as
program documents procedures and performance records considered necessary to provide
reasonable assurance of any findings or conclusions Audit procedures include tests of
documentary evidence supporting compliance tests of the assertions made regarding
compliance and direct confirmation of actions taken as part of compliance with the Reliability
Standards
If possible violations are identified the matter is turned over to MRO Risk Assessment and
Mitigation staff to initiate mitigation and enforcement proceedings under the CMEP The staff
will contact the designated Primary Compliance Contact or MPW may contact MRO staff at any
time Upon validation by Enforcement staff MPW will be provided a written notice of the
alleged violation within a reasonable timeframe that shall include the due process protections
under the CMEP
MPW is encouraged to maintain an adequate internal compliance program designed to ensure
compliance with Reliability Standards to protect the reliability of the Bulk Electric System
(BES) The program should contain internal controls designed to detect correct and prevent
recurrence of compliance violations
Objectives
Entities that own operate or use the BES in North America are subject to compliance audits for
applicable Reliability Standards based upon the functions performed within the scope of the
compliance audit The primary audit objectives are to
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 5
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
The MRO audit team determined that the following Reliability Standard(s) or requirement(s) were
not applicable to MPW during the compliance audit
1 BAL-002-1 Disturbance Control Performance
2 FAC-003-1 Transmission Vegetation Management Program
3 NUC-001-2 Nuclear Plant Interface Coordination
4 PRC-017-0 Special Protection System Maintenance and Testing
5 PRC-023-2 Transmission Relay Loadability
Audit Process
MRO conducts compliance audits in accordance with the current version of the CMEP and ROP
(as approved by the Federal Energy Regulatory Commission for entities in the United States or
through other arrangements in Manitoba and Saskatchewan) and generally conforms to the
United States Government Accountability Office Government Auditing Standards and other
generally accepted audit practices applicable to the conduct of the work The compliance audit
process steps can be found in the NERC CMEP
Compliance audits are conducted to obtain reasonable assurance of compliance with the
applicable Reliability Standards The compliance audit includes requests for data such as
program documents procedures and performance records considered necessary to provide
reasonable assurance of any findings or conclusions Audit procedures include tests of
documentary evidence supporting compliance tests of the assertions made regarding
compliance and direct confirmation of actions taken as part of compliance with the Reliability
Standards
If possible violations are identified the matter is turned over to MRO Risk Assessment and
Mitigation staff to initiate mitigation and enforcement proceedings under the CMEP The staff
will contact the designated Primary Compliance Contact or MPW may contact MRO staff at any
time Upon validation by Enforcement staff MPW will be provided a written notice of the
alleged violation within a reasonable timeframe that shall include the due process protections
under the CMEP
MPW is encouraged to maintain an adequate internal compliance program designed to ensure
compliance with Reliability Standards to protect the reliability of the Bulk Electric System
(BES) The program should contain internal controls designed to detect correct and prevent
recurrence of compliance violations
Objectives
Entities that own operate or use the BES in North America are subject to compliance audits for
applicable Reliability Standards based upon the functions performed within the scope of the
compliance audit The primary audit objectives are to
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 6
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
1 Provide reasonable assurance of compliance to the identified applicable Reliability
Standards
2 Provide a reasonable basis for all determinations of any findings or conclusions
3 Evaluate and identify the internal controls utilized by the Registered Entity for performance
measurement(s) within their compliance program
Methodology
The audit team reviewed the information data and evidence submitted by MPW and assessed
compliance with requirements of the applicable Reliability Standards Submittal of information
and data to MRO occurred before the scheduled date of the entity review or within the submittal
parameters as described in subsequent RFIs
Based upon the evaluation of initial information provided to the audit team supplemental RFIs
were requested and clarifications were sought from subject matter experts
MRO staff was provided the necessary information and adequate access to subject matter experts
without unreasonable restrictions
The audit team reviewed documentation and evidence provided by MPW such as programs
policies procedures emails logs studies data sheets and other relevant information Where
evaluation of compliance with a Requirement involved sampling the necessary samples were
developed according to the NERC Sampling Methodology Guidelines MRO audit staff obtained
sufficient appropriate evidence to provide a reasonable basis for any findings and conclusions
The audit report is subject to review by MRO executive staff and any findings are subject to a
second independent review by MRO Risk Assessment and Mitigation staff which is not
included in this report If there are findings as a result of the compliance audit Risk Assessment
and Mitigation staff from MRO will contact MPW
Conflict of Interest and Confidentiality Rules
Confidentiality and Conflict of Interest of MRO audit staff are governed under the MRO
Regional Delegation Agreement with NERC Section 1500 of the NERC ROP MRO Policy and
Procedure 5 Confidentiality MRO Policy and Procedure 10 Conflict of Interest and the MRO
employee handbook MPW was informed of MROrsquos obligations and responsibilities under the
Regional Delegation Agreement and NERC ROP and was provided with a list of MRO audit
staff and corresponding work histories There have been no denials of or access limitations
placed upon this audit team and no objections to MRO staff assignments on the compliance
audit
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 7
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Audit Results
Possible Violation(s)
Based upon the scope and conduct of the compliance audit the audit team identified the
following possible violations
1 PER-005-1 R1 System Personnel Trainings Each Reliability Coordinator Balancing
Authority and Transmission Operator shall use a systematic approach to training to
establish a training program for the BES company-specific reliability-related tasks
performed by its System Operators and shall implement the program
R12 Each Reliability Coordinator Balancing Authority and Transmission Operator
shall design and develop learning objectives and training materials based on the task list
created in R11
2 PRC-005-1 R2 Transmission and Generation Protection System Maintenance and Testing
Each Transmission Owner and any Distribution Provider that owns a transmission
Protection System and each Generator Owner that owns a generation Protection System
shall provide documentation of its Protection System maintenance and testing program and
the implementation of that program to its Regional Reliability Organization on request
(within 30 calendar days) The documentation of the program implementation shall include
R21 Evidence Protection System devices were maintained and tested within the defined
intervals
R22 Date each Protection System device was last testedmaintained
3 PRC-008-0 R2 Implementation and Documentation of Underfrequency Load Shedding
Equipment Maintenance Program The Transmission Owner and Distribution Provider with
a UFLS program (as required by its Regional Reliability Organization) shall implement its
UFLS equipment maintenance and testing program and shall provide UFLS maintenance
and testing program results to its Regional Reliability Organization and NERC on request
(within 30 calendar days)
The aforementioned possible violation(s) and the audit report will be provided to MRO Risk
Assessment and Mitigation staff to initiate mitigation and enforcement proceedings under the
CMEP which will consider the matters in this report consistent with the applicable requirements
of the CMEP The staff will contact the designated Primary Compliance Contact or MPW may
contact MRO staff at any time
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 8
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
MRO Contact Information
Any questions regarding this compliance audit report can be directed to
Midwest Reliability Organization
Attn Thomas P Tierney Director of Compliance
380 St Peter Street Suite 800
St Paul MN 55102
tptierneymidwestreliabilityorg
(651) 855-1745
On behalf of MRO this report was prepared and reviewed by
Audit Team Lead Signature Date
Carol A Gerou
6212013
Director of Compliance Signature Date
Thomas P Tierney
6212013
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 9
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Appendix I
MRO Audit Staff
Title Entity
Audit Team Lead Compliance Engineer MRO
Senior Compliance Engineer MRO
Compliance Audit Specialist MRO
Compliance Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
CIP Audit Specialist MRO
Registered Entity Participants and Observers
Title Entity
Manager Reliability Standards Compliance MPW
Director Legal amp Regulatory Services MPW
Director Employee and Customer Relations MPW
Control Center Supervisor and Trainer MPW
System Operator II MPW
System Operator II MPW
Manager Control Center MPW
SCADA System Administrator MPW
SCADA Specialist MPW
Summer Intern MPW
Planning Engineer MPW
Manager Transmission and Distribution MPW
System Maintenance Specialist II MPW
General Manager MPW
Manager Telecommunications MPW
Administrative Assistant MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW
Does Not Contain Confidential and Non-Public Information
(Privileged and Critical Energy Infrastructure Information Removed)
Muscatine Power amp Water P a g e | 10
Report Date June 21 2013
MIDWEST RELIABILITY
ORGANIZATION
Title Entity
System Specialist MPW
Generation Technical Supervisor MPW
Director Power Production and Supply MPW
Director Utility Service Delivery MPW
System Operator II MPW
Assistant Generation Operations Supervisor MPW
Communications Chief Technician MPW