Technical Feasibility Exceptions

(TFEs)

ReliabilityFirst CIP Webinar

Thursday, September 30, 2010Steve Garn, Sr. Engineer

Discussion Topics

• TFE Part B Reviews• TFE Reporting• TFE Team• Questions?

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TFE Part B – Review

• Entity submits TFE Part B information via secure means• RFC performs Substantive Review of TFE Part B

• Latest Part A• Quantity of covered assets compared to Part A• Verification from vendors of Entity assertions• Evidence of Compensating Measures and Mitigation Measures• Dates compared to Part A• Signed by Senior Manager or Delegate

• RFC issues Approve or Disapprove decision on Part B• Decision notice issued within one year of Part A submittal• If Disapprove, include reasons why and set “Effective Date”

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TFE Part B – Amendments

• Entity may “Request Amendment” when TFE is in the following states:• “Disapproved”• “Approved”• Cannot have more than one “Amendment” pending at a time

• Normal reasons to amend:• Quantity of covered assets goes up• Dates changed• Errors in original submittal

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TFE Part B – Disapprovals

• Asset quantity exceeds that in Part A• Missing verification from the vendors

• Vendor’s Operating Guide “Silence is Golden” is not true

• Impact assessment does not include the effect on the asset AND the BES if the compensating and mitigating measures fail

• No commitment to file Quarterly and/or Annual Reports

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TFE – Miscellaneous

• For new TFE for new assets, must submit Part A before asset connected to the network and turned on• 60 days ahead would be ideal

• Changes to asset quantities should be put in the TFE Summary Spreadsheets and submitted with the Quarterly Reports

• After Amending a Part A, submit the associated Part B

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TFE Reporting by Entity

• Entity Reporting Requirements for Approved TFEs• Quarterly Reports• Annual Reports• 30 days prior to Expiration Date• All reports must be signed and dated by the Senior Manager or

Delegate and include a statement that they have read and approved the report

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TFE Quarterly Report Draft 1

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TFE Quarterly Report Draft 1 – Col. 1-4

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TFE Unique ID Approval Date Applicable Requirement of TFE Are there any changes to Device Count?

If yes, please explain. Submit new TFE Summary Spreadsheet

TFE Quarterly Report Draft 1 – Col. 5-6

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Are all compensating and/or mitigating measures being implemented as described in the approved TFE? If not, please explain.

Has the proposed time schedule for implementing the proposed compensating and/or mitigating measures in the approved TFE changed? If yes, please explain.

TFE Quarterly Report Draft 1 – Col. 7-9

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Has the proposed plan and/or time schedule for achieving strict compliance with the Applicable Requirement changed? If yes, please explain.

Entity Primary Contact Entity Primary Contact Phone

TFE Quarterly Report Draft 1 – Certification

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TFE Quarterly Report Draft 2 – Top

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TFE Quarterly Report Draft 2 – Middle

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TFE Quarterly Report Draft 2 – Bottom

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TFE Team

• Steve Garn (Lead) 330-247-3086• Karen Yoder 330-247-3078• Mike Ketchens 330-247-3079

• Call any of us at any time

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Questions

Questions should be emailed to Karen Yoder (karen.yoder@rfirst.org) Subject: “CIP WEBINAR”

Questions will be considered in the order they are received

Clarifying questions are welcome and we will do our best to answer during the question period

Challenges to a position should be addressed to the presenter and will be taken offline