December 18, 2009 VIA ELECTRONIC FILING Ms. Kimberly D. Bose

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December 18, 2009 VIA ELECTRONIC FILING Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426 Re: North American Electric Reliability Corporation, Docket No. RM08-3-000 Dear Ms. Bose: The North American Electric Reliability Corporation (“NERC”) hereby submits this filing in compliance with paragraphs 143, 156, 164, 168, 173, 179 and 187 of the Federal Energy Regulatory Commission’s (“FERC”) Order No. 716 1 that required NERC to revise Violation Risk Factors (“VRFs”) for the NUC-001-1 — Nuclear Plant Interface Coordination Reliability Standard, Requirements R2 (from Lower to Medium), R4, R5, R7, and R8 (Medium to High), and R9 (Lower to Medium). The NERC Board of Trustees approved the proposed Reliability Standard VRF assignments on December 16, 2009. NERC believes this filing fully satisfies FERC’s directives in Order No. 716. NERC’s filing consists the following: This transmittal letter; A table of contents for the entire filing; Discussion of the filing; Reliability Standard NUC-001-1 Violation Risk Factor Modifications as Directed in Order No. 716 (Exhibit A); and 1 Mandatory Reliability Standard for Nuclear Plant Interface Coordination, (“Order No. 716”), 125 FERC ¶ 61,065 (October 16, 2008).