Assessing Compliance. 2 NERC Compliance Workshop 11/02/07 Documentation of Compliance with NERC Reliability Standards Jeff Whitmer.

TEXAS REGIONAL ENTITY

AN INDEPENDENT DIVISION OF ERCOT

Assessing Compliance

NERC Compliance Workshop11/02/07

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Documentation of Compliance with NERC Reliability Standards

Jeff Whitmer




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Documenting Compliance

● Texas RE will not tell you how to become compliant with a standard.

● Texas RE will not provide an interpretation of a standard.● All requests for interpretations should be submitted to

NERC.● It is important that the entity provide evidence of

compliance.


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How Do You Determine Expectations?

● Review the Measures and Compliance sections of the NERC Reliability Standards.

Locate the NERC Reliability Standards:

https://standards.nerc.net/

● Review the Reliability Standard Auditors Work Sheet (RSAWS).

Locate RSAWS: http://www.nerc.com/~comply/auditor_resources.html


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Example: RSAW PRC-008-0 1

Measure: Each transmission owner’s and distribution provider’sUFLS equipment maintenance and testing program containsthe elements specified in Reliability Standard PRC-008-0_R1.

Audit approach and notes specific to R1:__ Review the evidence provided by the entity to determine if the

entity has a UFLS program. If yes:__(R1.):Review the evidence provided by the entity to determine

if the entity has a UFLS equipment maintenance and testing program.

__(R1.):Review the evidence provided by the entity to determine if the UFLS maintenance program has the following:__(R1.):UFLS equipment identification__(R1.):Schedule for UFLS equipment testing__(R1.):Schedule for UFLS equipment maintenance


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Verifying Compliance

Determine expectations:● Agreements, training, records, procedures, processes,

plans, methodologies● Verifications● Perform● Request, communicate, act● Provide data or information● Assessments, analyses, and follow-up plans● Maintain data and models and develop ratings


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Agreements, Training, Records, Procedures, Processes, Plans, and Methodologies

Requirement Type Expectation

Have an agreement: Dated document Electronic communication with confirmation

of agreement

Document authority: Job description that includes statement of authority with respect to other operating entities

Letter declaring authority signed by corporate officer

Department notice signed on corporate letterhead

Agreement with authority documented

Have a specific record with no mention of update:

Specified record in electronic or hard copy format


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Agreements, Training, Records, Procedures, Processes, Plans, and Methodologies


Have specific operational plan (real-time, next day, seasonal) with specified elements:

Actual plan with specified elements

Have a set of requirements, process, plan, procedure, methodology, or other document – no requirement to update:

Current, in-force document with specified elements

Have a set of requirements, process, plan, procedure, methodology, or other document – requirement to update:

Current, in-force document with specified elements and evidence of last issue


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Verifications


Verify personnel qualifications: Certification records Training records showing successful

completion with description of training activity and employee name, date

Supervisor check sheets showing employee name, date performance noted

Records showing mastery or completion with employee name, date

Verify accuracy of data: Verification process and results with date verified

Verify accuracy of data – requirement to update on a specified periodicity:

Verification process and results with date verified


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Verifications (cont.)


Verify facility meets specified criteria:

Demonstration that facility meets criteria Equipment specification showing facility

meets criteria Installation documentation showing that

facility meets criteria Dated test results to show that facility

meets criteria Computer output to show that facility

meets criteria

Verify specific training occurred – no minimum hour requirement:

Actual training program materials or description with dated completion records for employees

Verify specific training occurred – minimum hour requirement:

Actual training program materials or description with dated completion records for employees and # of course hours


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Perform


Perform a mathematical calculation via computer and report results on a periodic basis:

Data to support the calculation retained in an electronic format

Hard copy of output of mathematical calculation plus documented formula and input

Copies of periodic reports

Perform maintenance in accordance with schedule:

Schedule plus maintenance records showing date and what was done

Perform testing or simulation in accordance with schedule:

Schedule plus test records (or simulation records) showing date of test, type of test, what was tested, test procedure, test results


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Request, Communicate, Act


Request data or information: Paper or electronic notice used to request data showing data, recipient, and data or information requested

Communicate operating information (requirements to notify, direct, inform, or communicate operating information to others who need the information to take action):

Operator logs Voice recordings or transcripts of

voice recordings

Take a control action on the BES: Computer printouts, operator logs


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Request, Communicate, Act (cont.)


Operate within defined parameters:

Parameters and report of any event with operation outside defined parameters including date, time, duration, details of how far outside parameters

Respond to reliability-related concerns:

Paper or electronic notice of response showing date, name and title of responder and any action to be taken in response to reliability-related concern with


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Provide Data or Information


Distribute or make a set of limits, procedure, process, plan, report or other prepared document available to others:

E-mail notice with updated web page Postal receipt showing recipient,

date, contents

Post information on Web and ensure entities know of updated information:

Link to Web page and either a copy of the electronic notice sent to advise recipients of the posting or a postal receipt showing recipient, date and contents

Post updated information on Web: Link to Web page


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Provide Data or Information (cont.)


Submit operating data or information as requested and according to schedule:

Request for data with schedule accompanied by copy of transmittal notice including identification of data submitted, date submitted

Submit planning data or information as requested and according to schedule:

Request for data with schedule accompanied by copy of transmittal notice including identification of data submitted, date submitted

Submit data related to a disturbance or event:

Request for data with transmittal notice including identification of data submitted, date submitted


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Assessments, Analyses, and Follow-up Plans


Assessment (impact of connecting new facilities; effectiveness of SPS; SPS operations; long-range plan):

Results of assessment with assumptions, contingencies, models used

Analysis of an event with a follow up plan (mitigation plan, corrective action plan):

Analysis report and follow-up plan that includes time table for implementation

Implement follow-up plan: Follow-up plan that includes timetable for implementation with checklist to show date each milestone achieved


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Maintain Data and Models and Develop Ratings


Maintain specified data: Database with specified data List in hard copy or electronic format

with specified data

Have a model: Model.

Develop ratings or limits according to methodology:

Methodology accompanied by ratings or limits

Demonstrate limits developed according to methodology


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Miscellaneous


Have and follow a maintenance, testing, or other program (vegetation management):

Paper or electronic copy of program with schedule and records showing what was done to implement the program with dates and activities accomplished

Staff with certified operators: Staffing plan Certification numbers for personnel

in staffing plan


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Self-Reports

Rashida Williams




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Self-Reporting

● What is self-reporting? A method for reporting a violation that a registered entity

discovers Optional – but shows cooperation by a registered entity

● What should be self-reported? Violations of any of the NERC-approved reliability standards Should be reported regardless of whether the standard is

included in active compliance monitoring for the year● When should self-reporting be done?

When the registered entity becomes aware of a violation of a NERC reliability standard

When the registered entity becomes aware of a change in the violation severity level of a previous reported violation


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Where to Find the Self-Reporting Form

http://www.ercot.com/mktrules/compliance/tre/enforcement/index.html

NERC Compliance WorkshopNovember 2, 2007

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Example Self-Reporting Form

ERCOT Region- NERC 2007 Approved Reliability Standards Self-Reporting

PART 1 - GENERAL INFORMATION

Date: 7/15/2007

Company Name: Fictional Energy

Contact Person:Sample Name

Contact Number: 512-555-1234 Contact Email: [email protected]

PART 2 - APPROVED NERC RELIABILITY STANDARDS SELF-REPORTING

NERC Standard Number Requirement Number Explanation of Non-Compliance

CIP-001-1 R4 Fictional Energy has not established communication contacts with local FBI. A reporting procedure is being developed for communication with the local FBI office as required for a Generator Operator

Instructions: This form is intended for NERC Registered Entities to self-report the 83 reliability standards approved for 2007. Please fill in General Information in Part 1. In Part 2, list the NERC Standards Numbers and Requirement Numbers for the NERC Standards that are not in compliance at this time. Please complete the "Explanation on Non-Compliance" Column for those NERC standards. E-mail completed forms to: [email protected]


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Completed Self-Reporting Forms

● Completed self-reporting forms should be sent to:

[email protected]● Mitigation plans may also be submitted at the same time

for any self-reported violations.


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Self-Certifications

Rashida Williams




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Self-Certification

● Registered entities self-certify to the applicable actively monitored standards.

● Registered entities are required to self-certify each year.● There are separate forms for different functions.● Registered entities that have been audited that year do

not participate in the self-certification process for that year.

● Texas RE will send out a self-certification notice to the registered entities with at least thirty (30) days advance notice.


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Completing the Self-Certification

When filling out the self-certification form, registered entities should review the Standards and Reliability Standard Audit Worksheet (RSAWS) to assist in determining compliance.

Find the NERC Reliability Standards on the NERC website:

https://standards.nerc.net/

Find RSAWS on the NERC website:

http://www.nerc.com/~comply/auditor_resources.html


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Example Self-Certification Form

INSTRUCTIONS: This form is intended for entities that are NERC registered as a Generator Operator. Please fill in General Information in Part 1. In Part 2, respond YES, NO, or N/A for each item under column D, "Full Compliance for 2007?". If "NO", please attach a short explanation separately; if "YES" or "N/A", no further explanation is required. Additional documentation to validate responses is not required with the form submittal but may be requested in the future. E-mail completed forms to: [email protected], by 10/1/07, after approval by a company executive officer (named on the form in Part 1).

TRE 2007 Self-Certification for Generator Operator

Part 1- GENERAL INFORMATION

Date: 11/2/2007

Entity Name: Fictional Energy

Contact Name: Sample Name

Contact Phone: 512-555-1234

Contact E-mail: [email protected]

Officer name: Officer Sample Name

Officer title: Vice President of Operations


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Example Self-Certification Form (cont.)

Standard Number Requirement Number Text of Requirement Full Compliance for 2007?

CIP-001-1 R2. Each Reliability Coordinator, Balancing Authority, Transmission Operator, Generator Operator, and Load-Serving Entity shall have procedures for the communication of information concerning sabotage events to appropriate parties in the Interconnection.

YES

CIP-001-1 R3. Each Reliability Coordinator, Balancing Authority, Transmission Operator, Generator Operator, and Load-Serving Entity shall provide its operating personnel with sabotage response guidelines, including personnel to contact, for reporting disturbances due to sabotage events.

YES

CIP-001-1 R4. Each Reliability Coordinator, Balancing Authority, Transmission Operator, Generator Operator, and Load-Serving Entity shall establish communications contacts, as applicable, with local Federal Bureau of Investigation (FBI) or Royal Canadian Mounted Police (RCMP) officials and develop reporting procedures as appropriate to their circumstances.

NO, Self-Reported on 7/15/07. Mitigation Plan in place.

Part 2- NERC Reliability Standards Self-Certification


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Completed Self-Certification Forms

● Registered entity should provide attached explanations with the form when compliance is not met or “Not Applicable” is answered.

● Self-certifications must be approved by a company officer.

● Completed self-certifications are expected to be returned by the required due date.

● Completed self-certification forms should be sent to:

[email protected]


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Process for Non-Submittal of Requested Data

If data, information or other reports requested from a registered entity are not received by the required submittal date, Texas RE may sequentially execute the following steps:

Step 1 5 business days after due date Follow-up notification sent to entity’s compliance contact

Step 2 10 business days after due date Follow-up notification sent to entity’s officer and compliance contact; NERC copied

Step 3 15 business days after due date Follow-up notification sent to entity’s CEO, officer and compliance contact; NERC copied. A full audit may be scheduled

Step 4 30 days after due date A Reliability Standard Violation may be applied


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Assessing Compliance

Questions?

Assessing Compliance. 2 NERC Compliance Workshop 11/02/07 Documentation of Compliance with NERC Reliability Standards Jeff Whitmer.

Documents

act nerc compliance

evidence of compliance

documentation of compliance

compliance sections

active compliance monitoring

nerc reliability standardwhen

ufls program

reliability standard