Mastering NERC RSAWs: A Step-by-Step Guide
Reliability Standard Audit Worksheets (RSAWs) are the cornerstone of a robust NERC compliance program. Utilized by NERC Compliance Enforcement Authorities (CEAs), RSAWs are critical for demonstrating compliance with applicable standards, identifying potential violations, and maintaining ongoing regulatory adherence. A well-prepared RSAW facilitates a successful audit and showcases an entity’s commitment to a thriving compliance culture. This guide delves into the everyday challenges, preparation strategies, and best practices for mastering RSAWs.
RSAWs: The Road Map of Your Compliance Program
RSAWs are essential because they:
- Determine whether sufficient evidence supports compliance with NERC standards and requirements.
- Serve as a tool for identifying non-compliances and potential violations.
- Provide a public record of your audit while supporting ongoing compliance maintenance.
Common RSAW Challenges
Over the past few years, regional and registered entities have been sharing NERC audit experiences and best practices. While helpful, they are often broad discussions of “Here’s what was required, here’s what we did, make sure you address that” type of presentations.
1. Knowledge Gaps Between Audits
- Audits occur every three or more years, leading to critical knowledge loss due to personnel changes or resource constraints.
- The lack of ongoing RSAW updates prevents dynamic compliance readiness.
2. Preparation Difficulties
- RSAWs require precise adherence to policy, procedure, narrative, evidence, formatting, and submission standards.
- Preparation often demands hundreds of hours of effort, presenting significant resource challenges.
3. Inconsistent Regional Standards
- Variances in expectations across regional make consistent RSAW narrative preparation difficult.
- Registered entities must navigate differing standards, evidence types, and audit approaches.
4. Lack of a Central Repository
- Compliance documentation is often scattered across emails, spreadsheets, and legacy systems.
- This disorganization leads to outdated RSAWs, formatting inconsistencies, and difficulty accessing evidence.
5. Inconsistent Submission Package Requirements
- Submission requirements vary by Regional Entity, including browser compatibility and file naming conventions.
- Navigating these differences can complicate the RSAW submission process.
Step-by-Step Guide to RSAW Preparation
Audit schedules are published by the Regional Entities each year, and initial notification letters and compliance surveys are typically sent six months before the audit date. Detailed audit letters are often sent three months in advance of the audit.
Well-prepared RSAWs demonstrate a company’s commitment to a thriving compliance culture before the audit date. Being prepared 30 to 60 days ahead of these milestones is recommended. Here are some areas to think through (preparing to prepare) before making assignments, gathering files, and writing responses:
Step 1: RSAW Preparation
When should we start preparing?
- When is the audit?
- What are the expectations for RSAW preparation and submittal?
- When should we kick off the RSAW process?
Where should we start?
- Have the standards changed?
- Do our facilities cross Regional Entity jurisdictions?
- What is our communication plan with the regulator?
- Have the Regional Entities’ expectations for RSAW completion changed?
- Have the RSAW requirements changed? Do we have the most up-to-date versions?
- Have we delegated any reliability standard requirements to another entity?
- Do we have multiple decentralized business areas that are involved in the audit?
- Have any reliability standard requirements been delegated to us from another entity?
Who needs to be involved?
- Who are specific subject matter experts?
- Who understands Regional Entity differences?
- Who should be on the RSAW preparation team
- Who has previous RSAW development and audit experience?
- Who needs training and indoctrination on the audit and RSAW development process?
How will we manage the documents?
- What are the RSAW formatting requirements?
- How and where are we managing the process electronically?
- What policy and procedure documents, spreadsheets, emails, messages, etc. are needed for this RSAW?
Step 2: RSAW Narrative Development
Now that you have thought through your RSAW development approach and located the appropriate documents, you are ready to develop clear RSAW narratives that support compliance while not providing unrelated or superfluous information. Here are four principles to keep in mind as you do.
- Clarity: Auditors may only look at evidence rather than reading the RSAW narrative, or the auditor may read the paragraph narrative and may or may not understand your meaning. Your narratives must be obvious.
- Consistency: Naming conventions and file descriptions should be consistent when a document is referenced repeatedly or throughout multiple RSAW narrative responses.
- Accuracy: Is the narrative accurate? Did content get overlooked or embellished?
- Full Disclosure: All narratives and documentation must be complete, regardless if they are favorable or not. Remember that you are responsible for compliance with all applicable standards, so ensure any delegated activities are carried out in a manner that is compliant with the standards for which you are responsible.
Next, RSAW narrative requirements have been changing, requiring Registered Entities to more clearly depict the linkages between the standards, requirements, and narratives to specific evidence in the requirement.
Best Practices
- Narrative responses should follow the sequence of the requirements and sub-requirements, not restate them.
- Procedures that support RSAWs should contain sufficient detail to tie to the NERC standard or requirement.
- Elaborate in concise detail on how you comply with the requirement. Provide descriptions of policies and procedures with reference to the evidence.
- Well-organized and clearly presented information facilitates the auditor’s verification process and minimizes requests for information.
Case Study: Operator’s Proactive Approach to RSAW Management ensured no NERC Audit ‘Surprises’
Nelson Industrial Steam Company (NISCO) provides 260 MWh of electricity to areas of the Southeast U.S. In April of 2011, the Southeast Electric Reliability Council (SERC) notified NISCO of their first NERC audit. SERC’s detailed Audit Compliance Letter listed eight standards that would be audited, along with a review of 58 sub-requirements, evidence of an internal compliance program, and a current organization chart.
Before SERC’s notification, NISCO recognized the importance of proactively organizing Reliability Standard Audit Worksheets (RSAW) policies, procedures, and evidence documentation well in advance of the audit period.
“As NISCO’s Compliance Manager,” says Mr. Shelley Hacker, NISCO’s Site Operations Manager, “I have found that accurate, complete, and concise RSAWs are essential to my success during an audit cycle. At audit time, we want no surprises.
“Audit success should be based upon the sum of many small efforts, repeated day in and day out, and not just before an audit’s conduct,” continued Hacker. “Our audit preparation required hundreds of hours, but we were not overwhelmed because of our early engagement and a defined internal compliance program. This experience highlighted the following factors as being essential for ensuring the quality of our RSAW responses, the supporting audit package, and ultimately successful audit:”
- Identify the reliability standards and requirements applicable to registration as a Generator Owner.
- Assign subject matter experts for each NERC reliability standard and requirement.
- Define the document file structure and file naming before beginning the RSAW response process.
- Update required policies and procedures and maintain up-to-date versions.
- Develop accurate and concise RSAW compliance narratives that support compliance with each requirement and sub-requirement and that include the rationale for the conclusions reached, yet do not provide unrelated or superfluous information.
- Link appropriate evidence to each RSAW requirement or question’s narrative and summary of evidence tables.
- Assemble all RSAWs and audit submittal information in the manner prescribed by the regional entity, as it is not always consistent between audit teams or Regional Entities.
- Ensure that appropriate resources are applied throughout the organization to support day-to-day compliance activities, as well as audits.
- Use a compliance-specific web-based document management system as a central repository to streamline the RSAW process, link all electronic documents, and automate the RSAW Package Submittal process.
- Maintain up-to-date RSAWs between audit activities for ongoing compliance management.
The SERC audit team thoroughly reviewed the documentation provided by NISCO. Data, information, and evidence submitted in the form of policies, procedures, emails, logs, studies, data sheets, etc., were validated, substantiated, and cross-checked for accuracy as appropriate. As a result of NISCO’s early and proactive RSAW preparation, SERC’s onsite audit of NISCO was highly successful.
In both examples, notice that the author avoided immaterial content that, while related, is not applicable or out of scope. This may include referencing data, policies, or procedures that don’t support compliance with the standards or sub-requirements and avoiding assumptions and ‘interpretations’ of the standards unless they are material and can be validated by evidence. The author also made sure that all documents were the final and approved versions and that unapproved content was not overlooked.
Step 3: Evidence Documentation
Every RSAW requires submission of an evidence matrix that validates your compliance narrative. Your evidence needs to be carefully organized, accurate, and citations linked to specific requirements and sub-requirements within your narrative.
To illustrate this, below is an example of evidence best practices for the 2012 VAR- 002.1.1b / Generator Operation for Maintaining Network Voltage Schedules RSAW shown above:
Best Practices
- The date/revision should be indicated as applicable.
- Evidence files should be developed so as to clearly indicate what the evidence file is by just reading its title as it relates to the RSAW narrative.
- The files in this table are linked directly to the evidence files so that evidence can be viewed by simply clicking on the file name.
RSAW Next Steps
Once the RSAW narrative and evidence components are complete, the next step is to conduct a detailed final review with all SMEs, asking:
- Was the document spell-checked?
- Are all narratives and evidence linked?
- Is anything missing?
- If completing the RSAW for multiple sites, were there any changes to versions of the RSAW that were missed?
- Did someone with strong editing skills check the document for the required formatting?
- Did you archive all compliance documentation in a central repository so that each RSAW can become a ‘living’ document that is easily updated?
Conclusion
Filling out a NERC RSAW may seem complex, but the process becomes manageable with proper preparation and attention to detail. By following the outlined steps and leveraging best practices, you can ensure effective documentation of your compliance efforts, reduce audit risks, and promote system reliability.
Need Help? Certrec specializes in NERC compliance programs and SaaS solutions tailored to the energy industry. With over 50 experts and zero fines in more than 350 audits, Certrec provides unparalleled support.
Contact us at NERCExperts@certrec.com or 817-738-7661 to learn how we can assist with your RSAW preparation and compliance needs.
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Collect all essential documentation, including policies, procedures, and records that prove your compliance. Ensure you have supporting materials such as screenshots, reports, training records, and other documentation. - Develop RSAW Narratives and Evidence Packages
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