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Dissection of the RSAW

May 23, 2013 SPP Compliance Forum

Todd Curl SERC Manager of Compliance Programs

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

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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.

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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).

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RSAW Title Page

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Subject Matter Experts

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Supporting Evidence and Documentation

• NERC Standard Requirements and Sub –Requirements

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Supporting Evidence and Documentation

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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)

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Supporting Evidence and Documentation (cont.)

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Supporting Evidence and Documentation (cont.)

• Compliance Assessment Approach (checklist), with Note To Auditor (Region response)

• Auditor Notes

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Supporting Evidence and Documentation (cont.)

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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)

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Compliance Finding Summary

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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.

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Additional Information

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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.

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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

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• Each citation needs to be separate. • Helps ensure the accurate flow of information. • Helps expedite the documentation process,

thereby expediting the audit process.

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Evidence Citations Need To Be Organized

• 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.

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Evidence Citations

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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.

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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.

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Evidence Citations

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Questions?

tcurl@serc1.org