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Auditing compliance virtually is a WAPA win

​By John Flynt

During the first week in March, Reliability Compliance Management Specialist Al Slucher connected with Vice President of Reliability and Compliance Brent Sessions. Slucher had a problem. With the eruption of COVID-19 across the western U.S., the mock audit he had been working for six months to set up at the Desert Southwest office in Phoenix, Arizona, was suddenly a big question mark.

WAPA employees and employees of peer and partner organizations had been reaching out to him with one basic concern: They did not want to risk traveling because they feared carrying or contracting COVID-19. This meant that the mock audit had to be cancelled or postponed. Or, as he ultimately decided, virtualized.

Slucher is known to many WAPA employees as an authority on Critical Infrastructure Protection standards. To ensure that WAPA fulfills the obligations CIP standards present, the Western Electric Coordinating Council audits WAPA’s regions on a regular cycle. To prepare for these audits, Slucher and other reliability compliance managers work steadily throughout the year. A big part of this preparation is the mock audit.

The WECC audit focuses on WAPA demonstrating to WECC that it meets the standards. With a “mock” or practice audit, the target is the culture of WAPA itself.

In mock audits, those who will respond to WECC auditors get to experience both being auditors and responding to audits. With guidance from Reliability Compliance, Slucher took point in assembling one team for CIP compliance and a second team for operational compliance.

These teams together consisted of roughly 30 participants from WAPA and partner and peer organizations. All participants received training, with one of the chief objectives being to learn what qualifies as good evidence of reliability in the electrical transmission industry.

Just as important as knowing what counts as evidence, however, is presenting that evidence.

As Sessions explained, audits start with being able to communicate clearly about what you are doing to ensure reliability compliance. Gathering and presenting evidence should not be a reaction; it must be a proactive effort. Proactive participation should be ongoing. But at an audit, which is the manifestation of months of preparation, it is something that emerges best when everyone involved can gather to work in close context and communicate face to face.

With the situation confronting Slucher, the advantages of such interactions were out. Everything had to shift to being online.

One aspect of the shift was convincing everyone involved—as Reliability Compliance Management Specialist Barry Jones put it—that a team can play on different fields; the game is still the same. Moving dozens of people to a virtual environment for an audit involved assuring everyone that the training they had received in the previous months would be just as effective.

Being online involved making use of communication tools and focusing clearly on the primary media of information transfer.

The documentation specialist on the Compliance team is Technical Writer Jennifer Williams. She said that a leading challenge governing a compliance reliability audit, actual or mock, is development of the reliability standard audit worksheet, or RSAW.
The RSAW is a document Slucher and other compliance managers help regions understand and develop. In a nutshell, it is a list of evidence of reliability that addresses the concerns that WECC has presented.

RSAWs are developed in the months leading up to an audit. At the start of the audit, they are presented to the auditors. The auditors examine them to discover whether they do indeed provide adequate evidence of reliability. Requests for clarification or supplemental evidence can be made within the first hour of an audit. The requests then follow for the next four days.

Evidence is an important word in a number of ways for Reliability Compliance. As Reliability Compliance Management Specialist Chris Johnson pointed out, potential problems went beyond simply being able to process RSAWs and show evidence.

Although WebEx, conference calls and applications such as SharePoint and Kiteworks have been in place for some time at WAPA, a communications network providing immediate, ongoing interactions for everyone involved in the audit was something relatively new. As Johnson explained, nonverbal communications such as postures and expressions are part of an audit. What happens with personal encounters at mock and actual audits takes a number of forms.

Among other things, one message was clear from the Reliability Compliance team: The culture of trust is something that cannot be taken for granted. Working with others on a cooperative basis to explore reliability compliance is an essential aspect of success in a demanding industry. Though it is not possible to completely replicate personal interactions in a virtual context, it is possible to focus on two key components of personal interaction: continuity and immediacy.

By the time Slucher positioned himself at his computer on March 9 to launch the DSW mock audit, everything was in place to make continuity and immediacy possible. The key to continuity was clear communication of how to ask for and respond to evidence requests. This understanding emerged from months of work by Reliability Compliance and audit participants.

Central to immediacy of communication was work by Secretary Danielle Gioso, who collaborated with Program Support Specialist Alexia Mendoza in a continuous conference session with Williams.

The session extended over the working hours of the five-day mock audit and allowed for participants to check on the status of requests and evidence as well as to get a sense of progress.

Slucher noted that the key to the success of the mock audit was “a perfect team.” One of the most important factors for success in the face of challenges such as COVID-19 is a combination of trust, cooperation, commitment and coordination. It is difficult to imagine a more effective response. 

Note: Flynt is a technical writer who works under the Wyandotte Services contract.


Pictures of the team assembled on a laptop screen, as if they were on a conference call



Page Last Updated: 6/4/2020 9:26 AM