Seattle City LightSeattle City LightReliability Standards Reliability Standards Compliance ProgramCompliance Program

Presented To the APPAPresented To the APPA

January 10January 10thth, 2007, 2007

By Chris TurnerBy Chris Turner

Compliance ProgramCompliance Program

• Compliance ranges across multiple Compliance ranges across multiple departments in the company.departments in the company.

• Sufficient authority needed by the Sufficient authority needed by the compliance director to get resultscompliance director to get results

• A SCL NERC Reliability Compliance A SCL NERC Reliability Compliance Steering Committee was established.Steering Committee was established.– Composed of executive sponsorship and Composed of executive sponsorship and

all necessary department directorsall necessary department directors

Compliance ProgramCompliance Program

• The Director of System Operations The Director of System Operations was given responsibility for was given responsibility for overseeing compliance and heading overseeing compliance and heading efforteffort

• Protocols and processes to manage Protocols and processes to manage the flow of information were the flow of information were developed – these will evolvedeveloped – these will evolve

• A compliance matrix (spreadsheet) A compliance matrix (spreadsheet) was developedwas developed

Issues and StructureIssues and Structure

• How to How to communicate/process/implementcommunicate/process/implement– New standardsNew standards– Changes to existing standardsChanges to existing standards– Regional standardsRegional standards

• Where will records and documentation Where will records and documentation required by standards residerequired by standards reside

• Who will assign standards and Who will assign standards and requirementsrequirements

Issues and StructureIssues and Structure

• Standards were broken down by Standards were broken down by requirement – over 1,400 requirementsrequirement – over 1,400 requirements

• Each requirement was assigned to a Each requirement was assigned to a department directordepartment director

• Each director assigns a person to be Each director assigns a person to be responsible for that requirementresponsible for that requirement

• Creates a clear communication stream Creates a clear communication stream and accountability for complianceand accountability for compliance

Issues and StructureIssues and Structure

• If we are in compliance and level of non-If we are in compliance and level of non-compliance trackedcompliance tracked

• Action plan to become compliant trackedAction plan to become compliant tracked• Departments encourage to list when Departments encourage to list when

they are non-compliantthey are non-compliant• One FTE added to assist with complianceOne FTE added to assist with compliance• New regional standards will add to the New regional standards will add to the

loadload

Issues and StructureIssues and Structure

• Support for compliance comes from Support for compliance comes from the top – superintendent and officersthe top – superintendent and officers

• Budget needs being addressed per Budget needs being addressed per department in the budget processdepartment in the budget process

• Enhanced focus on now mandatory Enhanced focus on now mandatory standard compliance is changing standard compliance is changing some processes in the company – some processes in the company – somewhat a culture changesomewhat a culture change

Issues and StructureIssues and Structure

• Compliance program will continue to Compliance program will continue to evolve as more experience is gained evolve as more experience is gained and lessons learned exchangedand lessons learned exchanged