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Dissection of the RSAW May 23, 2013 SPP Compliance Forum Todd Curl - PowerPoint PPT Presentation

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Dissection of the RSAW May 23, 2013 SPP Compliance Forum Todd Curl SERC Manager of Compliance Programs 1 Objectives Understand: o What a RSAW is. o Sections in the RSAW. o The Approach for RSAWs. o The Evidence Citation on the RSAW 2

  1. Dissection of the RSAW May 23, 2013 SPP Compliance Forum Todd Curl SERC Manager of Compliance Programs 1

  2. Objectives • Understand: o What a RSAW is. o Sections in the RSAW. o The Approach for RSAW’s. o The Evidence Citation on the RSAW 2

  3. I. What is a RSAW? • The RSAW (Reliability Standard Audit Worksheet) is a confidential electronic worksheet used to facilitate assessment of a registered entity’s compliance with the NERC Reliability Standards. • It is a audit worksheet used by both the entity and Regional audit staff. • Records listing of all policies, procedures, voice recordings, screenshots, etc., presented as evidence of compliance. 3

  4. II. Review of Sections in the RSAW. • The RSAW has different sections that are to be completed by the Registered Entity and the Compliance Enforcement Authority (Regional audit staff). 4

  5. RSAW Title Page 5

  6. Subject Matter Experts 6

  7. Supporting Evidence and Documentation • NERC Standard Requirements and Sub – Requirements 7

  8. Supporting Evidence and Documentation 8

  9. Supporting Evidence and Documentation (cont.) • Registered Entity Response; description, in narrative form, how the Registered Entity meets compliance with the Requirement (RE response) • Registered Entity Evidence; evidence submitted (RE response) • Audit Team Evidence Reviewed; evidence reviewed by the audit team (Compliance Enforcement Authority response) 9

  10. Supporting Evidence and Documentation (cont.) 10

  11. Supporting Evidence and Documentation (cont.) • Compliance Assessment Approach (checklist), with Note To Auditor (Region response) • Auditor Notes 11

  12. Supporting Evidence and Documentation (cont.) 12

  13. Compliance Finding Summary • This Section is completed by the Compliance Enforcement Authority . This section documents determination of compliance for the Requirements that are in scope for the audit. • The determinations of compliance are: – No Finding (NF) – Possible Violation (PV) – Open Enforcement Action (OEA) – Not Applicable (NA) 13

  14. Compliance Finding Summary 14

  15. Additional Information • The entire NERC Reliability Standard is included at the end of the RSAW. This includes the Purpose, Applicability, Requirements and Sub- Requirements, Measures, Data Retention, FERC Regulatory Language, and Revision History. 15

  16. Additional Information 16

  17. III. Approach • Carefully read the requirement and make sure the evidence answers every aspect of the requirement, and that it is enough evidence needed to demonstrate compliance. • Consider the Standard, Purpose, Requirement, Measures, and also the Compliance Assessment Approach (checklist) described in the RSAW. • Consider the quality and sufficiency of evidence presented. 17

  18. IV. Evidence Citations • A listing of all items in electronic format that you intend to present as evidence of compliance with a standard. o Policy and Procedure documents o Emails o Screenshots o Voice Recordings 18

  19. Evidence Citations Need To Be Organized • Each citation needs to be separate. • Helps ensure the accurate flow of information. • Helps expedite the documentation process, thereby expediting the audit process. 19

  20. Evidence Citations • Example citation using the following format: – Filename.file extension; Document Title, Revision date m/d/yyyy, Page(s) , Section and/or Section Title, Paragraph or Bullet or Heading , Description of Evidence. – FAC-003 TVMP.pdf; Transmission Vegetation Management Program, Revision 3 dated 1/7/2012, Pages 2-4, Section I, Tree Trimming Procedures, this describes the procedures for transmission line tree trimming. 20

  21. Evidence Citations 21

  22. Evidence Citations • Email citations: May 2012 RC Email.pdf; Email from the Reliability Coordinator, dated 5/1/2012, RC email with attachment of revised blackstart plans. • Screenshot citations: ACME Electric SPS Screenshot.pdf; Screenshot dated 11/2/2012, showing the Special Protection Systems monitored by the RC. 22

  23. Evidence Citations • Voice recordings : 050512 Load Shed Directive.wav; Reliability Coordinator voice recording, dated 5/5/2012, RC voice recording concerning directive given to the TOP to shed load. 23

  24. Questions? tcurl@serc1.org 24

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