“NERC Hot Topics”. Marc Butts May 9, 2008. List of “hottest” topics Compliance - Are you ready? Compliance Filings for 2008 “Audits for Dummies”! Use the RSAWS Way’s to keep track of the NERC requirements. Hot Topics!. What are the Hottest Topics in the Industry?.
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“NERC Hot Topics”
May 9, 2008
List of “hottest” topics
Compliance - Are you ready?
Compliance Filings for 2008
“Audits for Dummies”!
Use the RSAWS
Way’s to keep track of the NERC requirements
What are the Hottest Topics in the Industry?
The way that NERC reacts to FERC pressure?
The continuous budget increases – costs?
Will compliance violation penalties be substantial?
The volume of work:
FERC NOPR’s, rulemakings
NERC standards comments, drafting teams
SERC standards comments, drafting teams
Audit processes – lack of volunteers?
Compliance – Are you Ready?
Only the “Planning Standards (18) required ‘self-certification’ by 7/1/08.
There are also “Statements of Certifications” that have to be signed by each ‘entities’ Executive Signatories.
The “Cyber Standards (8) will require ‘self-certification’ by 7/13/08.
There will be “Statements of Certification” that will need to be signed by your Compliance Officers or Executive Signatories.
This standard touches Transmission and Generation. Since the standard covers almost all functions, we’ll all have to file something.
The Cyber standards, starting this year, will require two ‘self-certifications’ instead of the normal filing one time (Order 706).
The “Operating Standards (36) will require ‘self-certification’ by 10/1/08.
What was that
SoCo Registered for
14 NERC functions
Generator Operator - G
Load Serving Entity
Purchasing-Selling Entity - G
Regional Reliability Organization
Resource Planner - G
Transmission Service Provider
As shown on the previous page, you probably have contact mostly with the Power Coordination Center (PCC) in Birmingham or the Southern Company Fleet Operations (GOP function).
In the NERC-world, the PCC in Birmingham is the TOP, BA, INT and RC functions.
The GCC, ACC and others in our system do local switching, voltage coordination and other tasks and probably communicate directly with you all also.
Who do you make contact with?
Are you Registered for the Correct Functions?
Have you reviewed the latest Version 3 of the Functional Model?
Have you referred to NERC’s Compliance Monitoring & Enforcement Plan (CMEP) for applicability?
Review Standards applicable to each Function
Are you satisfied that you are registered correctly? If not, contact Regional Entity staff.
Review all standards and all requirements for those functions you are registered for .
Who will be accountable for meeting the requirements of the standards?
Will you make a department accountable?
Or, will you make a Manager accountable?
Maybe even make the specific employee “punching the button” accountable?
What Type of Documentation is Required?
Does evidence warrant written procedure, methodology, or guideline being developed?
Is your current documentation up to date for the requirement? Does it meet the latest version of standard?
Select a Documentation Application
It protects documents/evidence from unauthorized edits.
Need formal process for making revisions; administrator of the application who is the gatekeeper for all revisions.
Review Reliability Standards Audit Worksheets for Applicable Standards
In 2007, auditor’s questions originated from the corresponding RSAWs.
Review the RSAWs thoroughly for each requirement of each standard and assemble evidence needed to prove compliance.
Assemble all Documents
Have an electronic copy of all procedures referenced and provide to the audit team; Flashdrives are great for holding large volumes of information.
Projectors are an excellent means to show evidence during the audit.
Perform “Mock” Audit Prior to Real Audit
Have internal team perform audit using RSAW questions.
Request documentation and evidence necessary for compliance. Plan to present just like a real audit!
Key Lessons Learned
Why is this so important?
Aggravating factorsincrease the sanction
Time horizon of standard – operations vs. long term (+ 0-50%)
Repetitive infractions (+ 10, 30, and 50% discrete steps)
Prior warnings (+ 25% initial; 50% multiple)
Lack of cooperation (+0-50%)
Mitigating factors decrease the sanction
Prompt disclosure (- 0-25%)
Voluntary corrective measures (- 0-25%)
Substantial cooperation (- 0-25%)
Where Do I Find These Standards?
There are ~ 120 NERC Board Approved, Reliability Standards, with a total of approximately 1,500 specific requirements and sub-requirements
94 have been FERC approved,where fines can be levied ($)!
Click here for all FERC approved standards
Click here for matrix of all standard
Requirement and what functions they apply to.
This is a great matrix to help you decide what applies to your company and to get organized!
Going back a bit…..do
you know where to find the RSAW’s?
These are the
…and Then there’s SERC!!!
Also SERC Supplements
(soon to be called ‘standards’
that we must consider as well.)