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Assessing Compliance

Assessing Compliance. Documentation of Compliance with NERC Reliability Standards. Jeff Whitmer. 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.

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Assessing Compliance

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  1. Assessing Compliance

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

  3. 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. NERC Compliance Workshop 11/02/07

  4. 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 NERC Compliance Workshop 11/02/07

  5. Example: RSAW PRC-008-0 1 Measure: Each transmission owner’s and distribution provider’s UFLS equipment maintenance and testing program contains the 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 NERC Compliance Workshop 11/02/07

  6. 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 NERC Compliance Workshop 11/02/07

  7. Agreements, Training, Records, Procedures, Processes, Plans, and Methodologies NERC Compliance Workshop 11/02/07

  8. Agreements, Training, Records, Procedures, Processes, Plans, and Methodologies NERC Compliance Workshop 11/02/07

  9. Verifications NERC Compliance Workshop 11/02/07

  10. Verifications (cont.) NERC Compliance Workshop 11/02/07

  11. Perform NERC Compliance Workshop 11/02/07

  12. Request, Communicate, Act NERC Compliance Workshop 11/02/07

  13. Request, Communicate, Act (cont.) NERC Compliance Workshop 11/02/07

  14. Provide Data or Information NERC Compliance Workshop 11/02/07

  15. Provide Data or Information (cont.) NERC Compliance Workshop 11/02/07

  16. Assessments, Analyses, and Follow-up Plans NERC Compliance Workshop 11/02/07

  17. Maintain Data and Models and Develop Ratings NERC Compliance Workshop 11/02/07

  18. Miscellaneous NERC Compliance Workshop 11/02/07

  19. Self-Reports Rashida Williams NERC Compliance Workshop 11/02/07

  20. 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 NERC Compliance Workshop 11/02/07

  21. Where to Find the Self-Reporting Form http://www.ercot.com/mktrules/compliance/tre/enforcement/index.html NERC Compliance Workshop 11/02/07

  22. Example Self-Reporting Form 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: TRESelfreporting@ercot.com NERC Compliance Workshop November 2, 2007

  23. Completed Self-Reporting Forms • Completed self-reporting forms should be sent to: TRESelfReporting@ercot.com • Mitigation plans may also be submitted at the same time for any self-reported violations. NERC Compliance Workshop 11/02/07

  24. Self-Certifications Rashida Williams NERC Compliance Workshop 11/02/07

  25. 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. NERC Compliance Workshop 11/02/07

  26. 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 NERC Compliance Workshop 11/02/07

  27. Example Self-Certification Form TRE 2007 Self-Certification for Generator Operator NERC Compliance Workshop 11/02/07

  28. Example Self-Certification Form (cont.) NERC Compliance Workshop 11/02/07

  29. 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: TRESelfCert@ercot.com NERC Compliance Workshop 11/02/07

  30. 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: NERC Compliance Workshop 11/02/07

  31. Assessing Compliance Questions? NERC Compliance Workshop 11/02/07

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