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Compliance Audit · Preliminary Findings Public Utility District No. 1 of Okanogan County (OCPD) NCR05286 07/17/2012 - 07/18/2012 Audits & Investigations WECC Compliance Department

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Page 1: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Compliance Audit ·

Preliminary Findings Public Utility District No. 1 of Okanogan

County (OCPD) NCR05286

07/17/2012 - 07/18/2012 Audits & Investigations

WECC Compliance Department

Page 2: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Thank You

• We appreciate your responses to our needs and requests

• The OCPD personnel demonstrated a commitment to compliance and the protection of the Bulk Electric System

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Page 3: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Explanation of Terms Identified in this Presentation • No Finding (NF)

o Audit Team did not discover areas of non-compliance

• Possible Violation (PV) o Audit Team discovered areas of non-compliance

• Not Applicable (NA) o Requirement does not apply to Registered Entity either based on functions

for which the entity is registered or the entity does not possess the system referenced by the Requirement.

• Open Enforcement Action (OEA) o Previously identified; typically self-reported

o May or may not have a NOAV issued

o May include an open mitigation plan, self-report, or settlement agreement

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Page 4: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Sabotage Recognition and Reporting

(CIP-001-2a)

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Page 5: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Audit Team findings for Sabotage Reporting Standards and Requirements:

ICIP-001-2a: Sabotage Reporting INF-R2,R3

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Page 6: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results ·

Emergency Preparedness And Operations

(EOP)

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Page 7: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

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Reliability Standard Audit Results

Audit Team findings for EOP Standards and Requirements:

IEOP-004-1 : Disturbance Reporting

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Page 8: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Facilities Design, Connections & Maintenance

(FAC)

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Page 9: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Audit Team findings for FAC Standards and Requirements:

FAC-001-0: Facility Connection Requirements NF-R2

FAC-002-1: Coordination of Plans For New Generation, Transmission, and End-User Facilities

NF- R1

FAC-003-1: Transmission Vegetation Management Program NA-R1,R2

FAC-009-1: Establish and Communicate Facility Ratings NF-R1,R2

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Page 10: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

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Reliability Standard Audit Results

Interconnection Reliability Operations & Coordination

(IRO)

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Page 11: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Audit Team findings for IRO Standards and Requirements:

IR0-005-3a: Reliability Coordination - Current-Day Operations

NF ­ R10

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Page 12: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Modeling, Data & Analysis

(MOD)

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Page 13: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

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Reliability Standard Audit Results

Audit Team findings for MOD Standards and Requirements:

MOD-004-1: Capacity Benefit Margin NF ­ R3,R10

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Page 14: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Protection and Control . (PRC)

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Page 15: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Audit Team findings for PRC Standards and Requirements: PRC-005-1 b: Transmission & Generation Protection System NF_ R

2Maintenance &Testing

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Page 16: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Transmission Operations .

(TOP)

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Page 17: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Audit Team findings for TOP Standards and Requirements:

TOP-002-2b: Normal Operations Planning NF - R18

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Page 18: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

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Reliability Standard Audit Results

WECC Regional Standards

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Page 19: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Audit Team findings for WECC Regional Standards: PRC-STD-003-1 (until 9/30/11 ): Protective Relay and Remedial Action Scheme Misoperation

NA-WR1

PRC-004-WECC-1 (begins 10/1/11 ): Protective Relay and Remedial Action Scheme M isoperation NA - R1-R3

PRC-STD-005-1 (until 6/30/11 ): Transmission Maintenance NA-WR1

FAC-501-WECC-1 (begins 7/1/11): Transmission Maintenance NA- R1-R3

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Page 20: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Critical Infrastructure Protection

(CIP-002 - CIP-003)

--.

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Page 21: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Reliability Standard Audit Results

Audit Team findings for Critical Infrastructure Protection (CIP) Standards and Requirements:

CIP-002: Critical Cyber Asset Identification NF- R1-R4

CIP-003: Security Management Controls NF ­ R2

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Page 22: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

OCPD 2012 Compliance Audit

Post Audit

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Page 23: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Documentation and Confidentiality

• Compliance Audit Documentation:

o Can be used only for compliance purposes

o WECC Compliance Staff will keep one copy of materials for the official audit record

o All other copies will be destroyed or returned by all audit team members upon completion of the audit report .

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Page 24: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Audit Reporls

• Draft Audit Reports will be prepared o Audit Team members will provide input and review drafts o OCPD will have a chance to review the draft report and provide technical

corrections

• WECC will submit Final Audit Reports to NERC and OCPD

• Final Public Audit Report (O&P only) will be posted on the NERC website

o Confidential and critical infrastructure information redacted from the Public Report

o Report will not be posted while any violations are being contested

• Final Audit Reports will be submitted to FERC

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Page 25: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Violation Process

• Audit Team determines Possible Violations o Notifies Enforcement Staff o WECC reports Possible Violations to NERC o NERC reports to FERC

• WECC Enforcement Staff determines Alleged Violation(s) o Enforcement performs a second WECC review o if PV is confirmed, Enforcement will consider disposition through one of

the following processes. • Notice of Alleged Violation including Penalties and Sanctions • Proposal for Expedited Settlement Agreement • Proposal for Find, Fix and Track (FFT)

• WECC notifies Registered Entity of the method of disposition and specific next actions.

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Page 26: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Alleged Violation Response Process

• Entity can accept or contest Alleged Violation(s)

• Violation

• Penalty and Sanction

·•Or both

• Settlement

• Regional Hearing

• NERC Appeal

• FERC Appeal

• U.S. Court of Appeals ·

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Page 27: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

Feedback Forms

• Should be returned to:

o [email protected] - Robert Smith, Audit Team Lead

o [email protected] - Taud Olsen, Managing Director of Compliance

o [email protected]

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Page 28: WECC Compliance Audit Preliminary Findings...Sabotage Recognition and Reporting (CIP-001-2a) 4 l WECC . Reliability Standard Audit Results Audit Team findings for Sabotage Reporting

OCPD 2012 Compliance Audit

Questions?

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