1 Power System Restoration

2 Not Active

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4 Compliance Audit Process APPA E&O Technical Conference – Atlanta April 16, 2007

5 NERC Compliance Enforcement Program Works to ensure compliance with NERC and regional reliability standards Each region has the responsibility to implement their own regional compliance enforcement program NERC oversees each region’s compliance review and enforcement process

6 NERC Compliance Enforcement Program Compliance efforts comprise two key activities  Compliance reviews  Compliance enforcement

7 Reliability Standards The NERC Reliability Standards define the reliability requirements for planning and operating the North American bulk power system.  All Approved Reliability Standards are subject to audit (based on entity registration)  NERC is/has registered entities: BA, TO, TOP, GO, GOP, RC, LSE, PSE, DP, TSP, PA, TPL, RP, RRO, RSG

8 Reliability Standards 83 of the NERC Reliability Standards have been approved by FERC and are subject to fines 24 of the NERC Reliability Standards remain pending before FERC Many of these 24 standards are the “fill-in-the-blank” standards NERC expects registered entities to be in full compliance with all the NERC approved standards

9 Reliability Standards In 2006, there were 17 Monitored standards in a Compliance Audit This year there are 43 Monitored standards in a Compliance Audit

10 Before The Audit Logistics for Audit Team of documentation  Lodging Information  Possibly Transportation  On site Meals, Snacks, Beverages  Badges  2-3 Conferences Rooms  Projectors  Staff Support

11 Before The Audit Pre-Audit Questionnaire  Request Information on all “monitored” standards  To assist the audit team in preparation  Documentation is normally sent electronically

Monitored Standards Standard #StandardReq.Who BAL Real Power Balancing Control Performance AllBA BAL Disturbance Control Performance AllBA, RSG, RRO BAL Frequency Response and Bias AllBA CIP-001-1Sabotage ReportingAll RC, BA, TOP, GOP, LSE CIP thru CIP Critical Infrastructure Protection Standards All BA, GO, GOP, IA, LSE, NERC, RC, RRO, TO, TOP, TSP

13 Monitored Standards Standard #StandardReq.Who COM-001-1TelecommunicationsR2, R5 TO, BA, RC, NERCNet User Organizations EOP Emergency Operations Planning AllBA, TOP EOP-003-1Load Shedding PlansAllBA, TOP EOP System Restoration Plans AllBA, TOP EOP Reliability Coordination – System Restoration AllRC

Monitored Standards Standard #StandardReq.Who EOP Plans for Loss of Control Center AllBA, RC, TOP EOP Documentation of Blackstart Generating Unit Test Results AllGO, GOP FAC Vegetation Management AllRRO, TO FAC Facility Ratings Methodology AllGO, TO FAC Establish and Communicate Facility Ratings AllGO, TO

Monitored Standards Standard #StandardReq.Who IRO Reliability Coordination – Responsibilities and Authorities All BA, GOP, LSE, PSE, RC, RRO, TOP, TSP IRO Reliability Coordination – Operations Planning All BA, GO, GOP, LSE, RC, TO, TOP, TSP IRO Procedures, Processes, or Plans to Support Coordination AllRC IRO Notifications and Information Exchange Between RCs AllRC IRO Coordination of Real-time Activities Between RCs AllRC

Monitored Standards Standard #StandardReq.Who PER Operating Personnel Training AllBA, TOP PER Operating Personnel Credentials AllBA, RC, TOP PER Reliability Coordination – Staffing AllRC PRC Protection System Misoperations AllDP, GO, TO PRC Protection System Maintenance and Testing AllDP, GO, TO

Monitored Standards Standard #StandardReq.Who PRC UFLS Equipment Maintenance Program AllDP, TO PRC-010-0UVLS ProgramAllDP, LSE, TO, TOP PRC UVLS System Maintenance and Testing AllDP, TO PRC-016-0SPS MisoperationsAllDP, GO, TO PRC SPS Maintenance and Testing AllDP, GO, TO

Monitored Standards Standard #StandardReq.Who PRC-021-1UVLS Program DataAllDP, TO TOP Planned Outage Coordination AllBA, GOP, RC, TOP TOP Transmission Operations R6TOP TOP Operational Reliability Information AllBA, PSE, RC, TOP TOP Reporting SOL and Interconnection Reliability AllRC, TOP

Monitored Standards Standard #StandardReq.Who TPL System Performance Under Normal Conditions AllPA, TPL TPL System Performance Following Loss of Single Element AllPA, TPL TPL System Performance Following Loss of Two or More Elements AllPA, TPL TPL System Performance Following Extreme Events AllPA, TPL VAR Voltage and Reactive Control AllPSE, TOP

20 Pre-Audit Questionnaire

21 On-Site Audit The audit team is lead by a member of the Regional Reliability Organization  Members may include: NERC Staff, FERC Staff, Volunteer Auditors, RRO Staff The team typically breaks up into 2 groups  The 2 groups are assigned separate tracks to audit simultaneously

22 On-Site Audit Track 1 may include  Review of documentation  Review of Training and Certifications  Review data (CPS1, CPS2) Track 2 may include  System Operator Interviews  Review Operator Tools  Stand-by Control Center Operations and Procedures (may include site visit)

23 On-Site Audit On Site Documentation  All Documentation supplied with questionnaire  Sensitive Data: CIP Information, Nuclear Agreements, Site Security  Training Records  Large Documents: Emergency Plans, Disaster Plans, etc.

24 On-Site Audit Audit team conducts an exit briefing summarizing team’s preliminary conclusions including:  Items of non-compliance with supporting information  Any added information required, and  Expected timeline for review and issuance of audit report

25 After the Audit Audit team prepares audit report  Items of non-compliance are identified  Entity has 5 business days to review report before release to public  “Critical Infrastructure Sensitive” information is removed from report prior to release to the public

26 Audit Process – Where It’s Going? Audit Team Composition  Previously comprised of volunteers  Moving toward “Paid Staff”

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28 Reliability Standard Format A.Introduction - Title, Number, Purpose, Applicability, & Effective Date B.Requirements (R1, R2, etc.) C.Measures (M1, M2, etc.) D.Compliance - Compliance Monitoring Process & Levels of Non-Compliance E.Regional Differences F.Version History

29 Reliability Standard Format TOP Eight Requirements - Seven Measures

30 Compliance Documentation

31 Compliance Documentation

32 Wrap-Up and Review