By Brent Sessions
During the week of Feb. 12, the Rocky Mountain region completed its mock audit six months ahead of its audit by the Western Electric Coordinating Council.
The main purpose of a mock audit is to identify problem areas so that participants know where to focus their efforts in final preparation for the WECC audit in August. WECC audits each of WAPA's regions every three years as extensive "checkups" of how each region is complying with North American Electric Reliability Corporation Reliability Standards.
Behind the curtains
A mock audit can be thought of as a large-scale dress rehearsal. It simulates a WECC audit as closely as practical, including document reviews, interviews, tours, determination of compliance and a presentation from the mock auditors regarding any issues identified.
One major difference between the two is that a WECC audit takes place over a two-week period, while the mock audit is completed in three and a half days.
The mock audit was conducted by two teams, one for Critical Infrastructure Protection, which deals with cybersecurity and physical security, and another for Operations and Planning, which deals with operations, planning and maintenance. These teams consisted of WAPA employees from other regions, customers and business partners. They reviewed the relevant documentation and performed tours, just as actual WECC auditors would.
All hands on deck
Conducting a mock audit requires a lot of preparation of compliance documents, which was handled in this case by RM's compliance specialists, subject matter experts, supervisors and managers. They worked long hours to not only produce evidence of compliance, but to explain what the evidence shows and how it demonstrates compliance. In many cases, other WAPA regions helped make sure these documents were ready on time.
Further support was provided by the data request team, which served as the critical interface between RM and the mock auditors. There was also a CIP "war room," where employees constructed responses to questions from the mock auditors, and a team of reliability compliance managers, who reviewed all responses and had the overall responsibility for the mock audit process.
Administrative assistants arranged meals for the teams and provided logistical support. Information Technology scheduled rooms, provided guest connectivity and addressed telecommunications needs. Additionally, Facilities personnel reconfigured rooms as necessary between presentations and breakout sessions.
From the point of view of compliance managers and leadership, the number of issues identified is not what determines the success of a mock audit. Instead, a successful audit is measured by how well documents and subject matter experts explain the evidence, how quickly data requests are responded to and how much material is effectively assessed by the mock audit team.
The successful mock audit at RM gauged how ready the region is for WECC, and where problem areas may be. This allows the region to focus on whichever areas need the most work.
RM received positive feedback from the mock audit teams about professionalism and responsiveness. Problem areas were successfully identified, and both teams felt they were able to "dig into" the documentation provided.
A mock audit can be an intense experience, with a much faster pace than a WECC audit due to the condensed time frame. Previous participants have said that, compared to a mock audit, the WECC audit is relatively calm and there aren't any surprises.
RM rose to the challenge of its mock audit, and was able to make it a value-added experience for all participants.
What do WECC audits involve?
A typical WECC audit consists of large preaudit data requests, offsite document review, and an onsite visit to confirm compliance. Auditors also conduct interviews and tour facilities. The size of the audit team is typically 16-20 people.
Members of the Operations and Planning mock audit team work to prepare for August's Western Electricity Coordinating Council audit of the Rocky Mountain region.
(Photo by Brent Sessions)