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Objectives
- Understand:
- What a RSAW is.
- Sections in the RSAW.
- The Approach for RSAW’s.
- The Evidence Citation on the RSAW
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Dissection of the RSAW May 23, 2013 SPP Compliance Forum Todd Curl - - PowerPoint PPT Presentation
Dissection of the RSAW May 23, 2013 SPP Compliance Forum Todd Curl - - PowerPoint PPT Presentation
Dissection of the RSAW May 23, 2013 SPP Compliance Forum Todd Curl SERC Manager of Compliance Programs 1 Objectives Understand: o What a RSAW is. o Sections in the RSAW. o The Approach for RSAWs. o The Evidence Citation on the RSAW 2
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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.
- Policy and Procedure documents
- Emails
- Screenshots
- 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
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- 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
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- 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
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- 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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