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108
RELIABILITY | RESILIENCE | SECURITY Welcome! NERC 2019 Compliance and Standards Workshop Embassy Suites by Hilton Minneapolis July 23, 2019

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Page 1: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY

WelcomeNERC 2019 Compliance and Standards Workshop Embassy Suites by Hilton Minneapolis

July 23 2019

RELIABILITY | RESILIENCE | SECURITY2

It is NERCrsquos policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition This policy requires the avoidance of any conduct that violates or that might appear to violate the antitrust laws Among other things the antitrust laws forbid any agreement between or among competitors regarding prices availability of service product design terms of sale division of markets allocation of customers or any other activity that unreasonably restrains competition

NERC Antitrust Compliance Guidelines

RELIABILITY | RESILIENCE | SECURITY3

Participants are reminded that this meeting is public Notice of the meeting was posted on the NERC website and widely distributed The notice included the number for dial-in participation Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities

Public Announcement

RELIABILITY | RESILIENCE | SECURITY4

bull Safety Fire exits Calling 911 Alerting hotel staff CPR

bull Other Logistics QampA Restrooms

General Announcements

RELIABILITY | RESILIENCE | SECURITY5

bull 900 ndash 1200 pm NERC 101 Howard Gugel Steve Noess

bull 1200 ndash 100 pm Lunchbull 100 ndash 110 pm Welcome and Introductions Chris Boyd-Witherspoon

bull 110 ndash 130 pm Keynote Remarks Sara Patrick

bull 130 ndash 200 pm Application of the ERO Enterprisersquos Reliability Toolkit Mark Lauby

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY6

bull 200 ndash 330 pm Internal Controls Joseph Baugh Keith Smith

bull 330 ndash 345 pm Breakbull 345 ndash 445 pm Internal Controls Panel Ryan Mauldin Paolo DrsquoAlessandro Kristen Long Thad Ness

bull 445 ndash 500 pm General QampA | Closing Announcements Chris Boyd-Witherspoon

bull 530 ndash 630 pm Reception

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY7

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 2: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY2

It is NERCrsquos policy and practice to obey the antitrust laws and to avoid all conduct that unreasonably restrains competition This policy requires the avoidance of any conduct that violates or that might appear to violate the antitrust laws Among other things the antitrust laws forbid any agreement between or among competitors regarding prices availability of service product design terms of sale division of markets allocation of customers or any other activity that unreasonably restrains competition

NERC Antitrust Compliance Guidelines

RELIABILITY | RESILIENCE | SECURITY3

Participants are reminded that this meeting is public Notice of the meeting was posted on the NERC website and widely distributed The notice included the number for dial-in participation Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities

Public Announcement

RELIABILITY | RESILIENCE | SECURITY4

bull Safety Fire exits Calling 911 Alerting hotel staff CPR

bull Other Logistics QampA Restrooms

General Announcements

RELIABILITY | RESILIENCE | SECURITY5

bull 900 ndash 1200 pm NERC 101 Howard Gugel Steve Noess

bull 1200 ndash 100 pm Lunchbull 100 ndash 110 pm Welcome and Introductions Chris Boyd-Witherspoon

bull 110 ndash 130 pm Keynote Remarks Sara Patrick

bull 130 ndash 200 pm Application of the ERO Enterprisersquos Reliability Toolkit Mark Lauby

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY6

bull 200 ndash 330 pm Internal Controls Joseph Baugh Keith Smith

bull 330 ndash 345 pm Breakbull 345 ndash 445 pm Internal Controls Panel Ryan Mauldin Paolo DrsquoAlessandro Kristen Long Thad Ness

bull 445 ndash 500 pm General QampA | Closing Announcements Chris Boyd-Witherspoon

bull 530 ndash 630 pm Reception

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY7

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 3: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY3

Participants are reminded that this meeting is public Notice of the meeting was posted on the NERC website and widely distributed The notice included the number for dial-in participation Participants should keep in mind that the audience may include members of the press and representatives of various governmental authorities

Public Announcement

RELIABILITY | RESILIENCE | SECURITY4

bull Safety Fire exits Calling 911 Alerting hotel staff CPR

bull Other Logistics QampA Restrooms

General Announcements

RELIABILITY | RESILIENCE | SECURITY5

bull 900 ndash 1200 pm NERC 101 Howard Gugel Steve Noess

bull 1200 ndash 100 pm Lunchbull 100 ndash 110 pm Welcome and Introductions Chris Boyd-Witherspoon

bull 110 ndash 130 pm Keynote Remarks Sara Patrick

bull 130 ndash 200 pm Application of the ERO Enterprisersquos Reliability Toolkit Mark Lauby

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY6

bull 200 ndash 330 pm Internal Controls Joseph Baugh Keith Smith

bull 330 ndash 345 pm Breakbull 345 ndash 445 pm Internal Controls Panel Ryan Mauldin Paolo DrsquoAlessandro Kristen Long Thad Ness

bull 445 ndash 500 pm General QampA | Closing Announcements Chris Boyd-Witherspoon

bull 530 ndash 630 pm Reception

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY7

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 4: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY4

bull Safety Fire exits Calling 911 Alerting hotel staff CPR

bull Other Logistics QampA Restrooms

General Announcements

RELIABILITY | RESILIENCE | SECURITY5

bull 900 ndash 1200 pm NERC 101 Howard Gugel Steve Noess

bull 1200 ndash 100 pm Lunchbull 100 ndash 110 pm Welcome and Introductions Chris Boyd-Witherspoon

bull 110 ndash 130 pm Keynote Remarks Sara Patrick

bull 130 ndash 200 pm Application of the ERO Enterprisersquos Reliability Toolkit Mark Lauby

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY6

bull 200 ndash 330 pm Internal Controls Joseph Baugh Keith Smith

bull 330 ndash 345 pm Breakbull 345 ndash 445 pm Internal Controls Panel Ryan Mauldin Paolo DrsquoAlessandro Kristen Long Thad Ness

bull 445 ndash 500 pm General QampA | Closing Announcements Chris Boyd-Witherspoon

bull 530 ndash 630 pm Reception

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY7

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 5: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY5

bull 900 ndash 1200 pm NERC 101 Howard Gugel Steve Noess

bull 1200 ndash 100 pm Lunchbull 100 ndash 110 pm Welcome and Introductions Chris Boyd-Witherspoon

bull 110 ndash 130 pm Keynote Remarks Sara Patrick

bull 130 ndash 200 pm Application of the ERO Enterprisersquos Reliability Toolkit Mark Lauby

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY6

bull 200 ndash 330 pm Internal Controls Joseph Baugh Keith Smith

bull 330 ndash 345 pm Breakbull 345 ndash 445 pm Internal Controls Panel Ryan Mauldin Paolo DrsquoAlessandro Kristen Long Thad Ness

bull 445 ndash 500 pm General QampA | Closing Announcements Chris Boyd-Witherspoon

bull 530 ndash 630 pm Reception

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY7

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 6: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY6

bull 200 ndash 330 pm Internal Controls Joseph Baugh Keith Smith

bull 330 ndash 345 pm Breakbull 345 ndash 445 pm Internal Controls Panel Ryan Mauldin Paolo DrsquoAlessandro Kristen Long Thad Ness

bull 445 ndash 500 pm General QampA | Closing Announcements Chris Boyd-Witherspoon

bull 530 ndash 630 pm Reception

Todayrsquos Agenda

RELIABILITY | RESILIENCE | SECURITY7

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 7: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY7

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 8: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY

Keynote Remarks

Sara Patrick President and CEO MRO2019 Compliance and Standards WorkshopJuly 23 2019

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 9: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Welcome to MinnesotaNERC Compliance and Standards Workshop

July 23 2019

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 10: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Whyte Ridge retention pond Winnipeg Manitoba Source Winnipeg Free Press

White Bear Lake Minnesota

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 11: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

A highly reliable and

secure North

American bulk power

system

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 12: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY

Framework to Address Known and Emerging Reliability Risks

Mark Lauby NERC Senior Vice President and Chief Reliability Officer2019 Compliance and Standards WorkshopJuly 23 2019

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 13: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY2

Bulk Power System Reliability

and Security

Bulk Power System Resilience

Bulk Electric System Reliability

Resilience is a Characteristic of a Reliable System

Solely the Bulk Power System Does not include local distribution systems

NERC Reliability Assurance bull Standardsbull Compliancebull Enforcementbull Registrationbull Certification

NERC Reliability Assessments and Performance Analysisbull Reliability Assessmentsbull System Analysisbull Events Analysisbull Performance Analysisbull Situational Awareness

Operator Training

E-ISAC

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 14: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY3

Resilience Indicators

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Trecovered

Disruptive Event

Rel

iabi

lity

RTarget

Degradation Recovery Recovery State

Improved

Deteriorated

Robustness

t

If Detectable Pre-Position

Amplitude

Stable

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 15: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY4

Ensuring ALR

R(t)

Tdisruption

RALR-Nadir

Trebound

R100 Reliable

Disruptive Event

Reliable Operation

Avoid amp control (eg serve critical load)

Rel

iabi

lity

RTarget

Recovered Steady-State

If Detectable Pre-Position

Trecovered t

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 16: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY5

Declaration amp Problem

bull DeclarationThe Electric Reliability Organization (ERO) Enterprise requires a consistent framework to address and prioritize known and emerging reliability risks

bull Problem Statement ERO Enterprise has continued to lead industry in reliability and security

initiatives to identify known and emerging risks and their mitigation The reliability toolkit for risk mitigation the ERO currently deploys includes

for example webinars and conferences lessons learned Alerts Guidelines and standard development

A framework is needed to that provides a transparent process using industry and ERO Enterprise experts

Framework must include risk identification deployment of mitigation strategies to monitoring the success of these mitigations

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 17: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY6

Six-Step Framework

1 Risk Identification2 Risk Prioritization3 Mitigation Identification and Evaluation4 Mitigation Deployment5 Measurement of Success6 Monitor Residual Risk

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 18: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY7

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 19: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY8

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 20: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY9

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 21: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY10

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 22: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY11

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 23: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY12

Six-Step Framework

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 24: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY13

Guiding Principles

1 Reliability Standards address sustained risks with moderate impacts which are probable and severe impacts which are probable or improbable

2 Reliability Guidelines used to address sustained risks that are probable or improbable Guidelines are also used for items not in the ERO Enterprisersquos jurisdiction or are practices that improve reliability beyond standards

3 Lessons Learned used for sustain risks or a one-and-done activities with moderate impacts and are both probable and improbable

4 Alerts will be used for time sensitive information for information to request action or direct action

5 A combination of tools can be used towards gaining industry action setting the stage for standards as well as addressing a risk while a Standard is being developed Likelihood pervasiveness and severity have a bearing when a Reliability Standard is required

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 25: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY14

Risk Tools and Time Horizon

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 26: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY15

Illustrative Diagram

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 27: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY16

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 28: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1Supply Chain

Risk Management Audit Approach amp Internal Controls

NERC Compliance

amp Standards Workshop

Minneapolis MN

July 23 2019

Dr Joseph B BaughSenior Compliance

AuditormdashCyber Security

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 29: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

WECC SCRM Outreach Disclaimer

This presentation discusses best practices for risk identification and assessment as well as common project management and procurement principles (see also NERC 2017 April Implementation Guidance pp 1ndash10)

It may provide an entity with a basic road map to develop its CIP-013 SCRM program risk identification and assessment methodology processes and procedures to support compliance with the Standard and enhance the reliability and security of the BES

Information and suggestions supplied in this presentation should not be considered a prescriptive solution that will guarantee compliance with CIP-013-1 as each entity has a unique blend of applicable BCS vendors products and required services that may require a different approach

Thus one size does not fit all as the devil is always in the details of any specific plan

2

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 30: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

SCRM amp Internal Controls What is an internal control relative to compliance

bull One or more processes that ensure an entity meets its objectives and goals for operational effectiveness efficiency and accurate reporting to demonstrate compliance with the NERC Reliability Standards Requirements andor Parts and addresses risks associated with the reliable operations of its business during the implementation of the Standards

In order to develop a strong set of internal controls for CIP-013-1 an entity must develop and document its R1- R3 SCRM plan(s) processes and procedures

A prudent entity will develop internal controls for ensuring timely and accurate compliance and effective artifacts in conjunction with its documented CIP-013-1 plans and processes or shortly thereafter

3

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 31: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

SCRM Security Objective

CIP-013-1 impacts the procurement of products and services from vendors that are related to High and Medium BCS

The SCRM security objective states ldquoTo mitigate cyber security risks to the reliable operation of the Bulk Electric System (BES) by implementing security controls for supply chain risk management of BES Cyber Systemsrdquo (CIP-013-1 Purpose section p 1)

CIP-013-1 audits will begin next year

4

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 32: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Developing SCRM Plans amp Internal Controls

What should I consider or include when developing my CIP-013-1 SCRM procurement plan

bull R1 procurement plan and processes Part R11

Part 12 (Parts R121 ndash R126)

CIP-005-6 (Parts 24 25)

CIP-010-3 (Part 16)

bull R2 implementation aspects (ie How will I document each applicable procurement implementation)

bull R3 review and approval processes

Develop internal controls to ensure timely and accurate compliance and effective artifacts in conjunction with the CIP-013-1 plans and processes

5

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 33: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Specific Vendor Risks The Standard establishes minimum expectations for six key

areas [R121 ndash R126] that require specific processes to address various components of vendor access and other risks to high and medium impact BCS through vendor products andor services

1 Notifications of vendor-identified incidents

2 Coordination of responses to such incidents

3 Notification of termination of remote or onsite access to BCS for vendor representatives

4 Disclosure by vendors of known vulnerabilities

5 Verification of software and patch integrity and authenticity and

6 Coordination of controls for vendor-initiated IRA and system-to-system remote access

6

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 34: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 R1

CIP-013-1 recognizes the risks posed by compromised BCS through vendor products andor services and expressly requires applicable Responsible Entities to ldquodevelop one or more documented supply chain cyber security risk management plan(s) for high and medium impact BES Cyber Systems The plan(s) shall includerdquo [see Parts R11 and R12] How can I comply with R1

bull ldquoResponsible entities should consider how to leverage the various components and phases of their processes (eg defined requirements request for proposal bid evaluation external vendor assessment tools and data third party certifications and audit reports etc) to help them meet the objective of Requirement R1 and give them flexibility to negotiate contracts with vendors to efficiently mitigate risksrdquo(NERC 2017 April SCRM Implementation Guidance General Considerations p 1)

7 Bold font indicates [emphasis added] where applicable to draw attention to specific items

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 35: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R11

One or more process(es) used in planning for the procurement of BES Cyber Systems to identify and assess cyber security risk(s) to the Bulk Electric System from vendor products or services resulting from

i procuring and installing vendor equipment and software and ii transitions from one vendor(s) to another vendor(s)

What does ldquoidentify and assessrdquo mean in terms of developing and documenting the R1 SCRM plan

Should an entity mitigate identified cyber security risksbull Yes remember the CIP-013-1 Security Objective ldquoTo mitigate cyber

security riskshelliprdquo (p 1) which is reinforced by the note in the Requirement 1 Rationale section ldquoThe security objective is to ensure entities consider hellip options for mitigating these risks (Part 11 p 11)

8

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 36: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R12

One or more process(es) used in procuring BES Cyber Systems that address the following as applicable Do I really need to include specific processes

andor procedures for each of the six R12 Parts in my SCRM procurement plan

What does ldquoas applicablerdquo mean in terms of my R1 plan and R2 implementation

9

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 37: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R121

Notification by the vendor of vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity encourage vendors to

provide such notifications What would a prudent entity do to mitigate

identified risks

10

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 38: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R122

Coordination of responses to vendor-identified incidents related to the products or services provided to the Responsible Entity that pose cyber security risk to the Responsible Entity How can an entity establish this coordination

of responses for such incidents What would a prudent entity do if and when

notified of vendor-identified SCRM-related incidents

11

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 39: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R123

Notification by vendors when remote or onsite access should no longer be granted to vendor representatives How can an entity encourage vendors to

provide such notifications What would a prudent entity do upon such

access notifications

12

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 40: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R124

Disclosure by vendors of known vulnerabilities related to the products or services provided to the Responsible Entity How can an entity encourage vendors to

provide such disclosures How would a prudent entity mitigate the risks

of such vulnerabilities

13

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 41: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R125

Verification of software integrity and authenticity of all software and patches provided by the vendor for use in the BES Cyber System and How can an entity verify the software integrity

and authenticity of software and patches provided by vendors

What would a prudent entity do once the integrity and authenticity of a software update or patch is verified

14

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 42: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

CIP-013-1 Part R126

Coordination of controls for (i) vendor-initiated Interactive Remote Access and (ii) system-to-system remote access with a vendor(s) How would a prudent entity establish

coordination of controls for remote access

15

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 43: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Documenting Parts 121-126

How can an entity document compliance with Parts 121 through 126

bull In its R1 procurement planbull For each applicable R2 implementation

16

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 44: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Donrsquot Forget CIP-005 amp CIP-010

A prudent entity will prepare for compliance with CIP-005-6 Part 24 and Part 25 as well as CIP-010-3 Part 16 on or before the effective date (July 1 2020)

These components will be audited by the CIP-005 and CIP-010 audit teams as applicable

17

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 45: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Auditing CIP-013-1 R1

What R1 evidence will the CIP-013 audit team expect

What R1 internal controls would a prudent entity develop

18

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 46: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Implementing the SCRM Plan (R2)

Each Responsible Entity shall implement its supply chain cyber security risk management plan(s) specified in Requirement R1 What R2 evidence demonstrating an

implementation of the SCRM plan will the CIP-013 audit team expect for each applicable procurement after the effective date

Archive SCRM evidence on a case-by-case basis What R2 internal controls would a prudent entity

develop

19

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 47: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Approving the SCRM Plan (R3)

Each Responsible Entity shall review and obtain CIP Senior Manager or delegate approval of its supply chain cyber security risk management plan(s) specified in Requirement R1 at least once every 15 calendar months Initial review and approval is due on or before July 1

2020 (NERC 2017 July Implementation Plan Initial Performance section p 3)

No more than 15 calendar months apart thereafter What R3 evidence will the CIP-013 audit team expect What R3 internal controls would a prudent entity develop

20

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 48: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Looking Ahead to CIP-013-2 Review the 2019 NERC Staff Report on SCRM

bull Addresses FERCrsquos directive to ldquodevelop modifications to include EACMS associated with medium and high BES Cyber Systemsrdquo (FERC Order 850 para 5 p 54994) within 24 months of the effective date of Order 850

bull Also addresses FERC concerns relative to the SCRM impacts of PACS PCA and LIBCS

bull Provides insight into various industry white papers (NERC Supply Chain Risk Mitigation Program)

Expect additional SCRM compliance obligations for EACMS associated with high and medium impact BCS with more to come later on from FERC NERC and the SDT

The SCWG is developing SCRM procurement documents which may be rolled into CIP-013-2 Requirements or into future implementation guidance documents

21

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 49: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

ERO References FERC (2018 October 26) Order No 850 CIP-013-1mdashSupply Chain Risk

Management Reliability Standard Final Rule 165 FERC para 61 020 18 CFR Part 40 Docket No RM17-13-000 In Federal Register 83(208) pp 53992-54005 Retrieved from httpswwwgpogovfdsyspkgFR-2018-10-26pdf2018-23201pdf

NERC (2019 February 9) Cybersecurity Supply Chain Risks Staff Report and Recommended Actions [Draft] In MRC Agenda Item 9 pp 4-43 Retrieved from httpswwwrtoinsidercomwp-contentuploadsDraft-NERC-Supply-Chain-Report-2-6-19pdf

NERC (2018 October 18) CIP-013-1 ndash Cyber Security - Supply Chain Risk Management [Reliability Standard] Retrieved fromhttpswwwnerccompaStandReliability20StandardsCIP-013-1pdf

NERC (n d) Supply Chain Risk Mitigation Program [Links to Industry White Papers] Retrieved from httpswwwnerccompacompPagesSupply-Chain-Risk-Mitigation-Programaspx

22

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 50: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Industry References Executive Order 13873 (2019 May 17) Securing the Information and Communications Technology

and Services Supply Chain In Federal Register 84(96) pp 22689-22692 Retrieved fromhttpswwwgovinfogovcontentpkgFR-2019-05-17pdf2019-10538pdf

Executive Order 13636 (2013 February 19) Improving Critical Infrastructure Cybersecurity In Federal Register 78(33) pp 11739-11744 Retrieved fromhttpswwwfederalregistergovdocuments201302192013-03915improving-critical-infrastructure-cybersecurity

NATF (2017 November 6) Software Integrity amp Authenticity Implementation Guidance for CIP-010-3 R1 Requirement Part 16 [ERO Approved Guidance Document] Retrieved fromhttpswwwnerccompacompguidanceEROEndorsedImplementationGuidanceCIP-010-320R1620Software20Integrity20and20Authenticitypdf

24

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 51: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Other References Department of Homeland Security [DHS-CISA] (2019 May 20) Unmanned Aircraft

Systems (UAS) - Critical Infrastructure Retrieved fromhttpswwwdhsgovcisauas-critical-infrastructure

Network Security (2018 August) Russian Hackers Breach US Electricity Network Elsevier Press ISSN 1353-4858 (pp 1-3) Retrieved fromhttpswwwsciencedirectcomsciencearticlepiiS1353485818300722via3Dihub

Smith R (2018 July 23) Russian Hackers Reach US Utility Control Rooms The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesrussian-hackers-reach-u-s-utility-control-rooms-homeland-security-officials-say-1532388110

Smith R amp Barry R (2019 January 10) Americarsquos Electric Grid Has a Vulnerable Back Doormdashand Russia Walked Through It The Wall Street Journal [Online] Retrieved from httpswwwwsjcomarticlesamericas-electric-grid-has-a-vulnerable-back-doorand-russia-walked-through-it-11547137112

25

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 52: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Audit Approach amp IC Summary

Approach CIP-013-1 compliance as a project with well-defined tasks timelines and processes designed to

bull Develop and document the R1 SCRM procurement planbull Develop an R2 implementation plan for the R1 SCRM planbull Approve the initial R1 SCRM plan on or before July 1 2020bull Ensure the R1 SCRM procurement plan is reviewed updated and approved at

least once every 15 calendar months thereafter

Maintain R1-R3 audit evidence relative to new procurement of all vendor products andor services obtained for High and Medium BCS after July 1 2020

Develop CIP-013-1 R1-R3 internal controls concurrently with SCRM procurement plans processes and procedures

Be proactive and monitor for future changes in CIP-013-2 Time permitting are there any other questions

26

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 53: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Contact

Dr Joseph B BaughSenior Compliance AuditormdashCyber Security

jbaughweccorg

27

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 54: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Keith SmithManager OampP Compliance Monitoring

Facility Rating Internal Controls

Meeting Title Date

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 55: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

2

Objectives

Establish Facility Ratings that respect the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility Consideration of all applicable equipment Accurate Equipment Ratings

Ensure established Facility Ratings are consistently utilized Protection Analysis Monitoring

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 56: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

3

Internal Controls

Internal controls are the processes and tools an entity utilizes to meet the identified objectives

All entities will have some level of internal controls in place

Internal control expectations dependent on inherent risk of entity

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 57: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

4

Internal Controls

Methodology

Inventory

Verification

Change Management

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 58: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

5

Facility Rating Methodology

FAC-008 requires registered entities to have a methodology

andor documentation that includes the method

assumptions and process for determining

Facility Ratings

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 59: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

6

Facility Rating Methodology Example 1

Low Bar Power Company has a methodology addressing each item required by the Standard at a high level

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 60: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

7

Facility Rating Methodology Example 2

Max Reliability Power Company has a detailed methodology that address each item in the Standard and includes Annual reviews Roles and responsibilities Identification of tools Step-by-step work instructions

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 61: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

8

Inventory

Inventory tracking of Facility Ratings the equipment that comprises each Facility and

all Equipment Ratings is necessary for

- Establishing Facility Ratings- Evaluating change impacts- Verifying Facility Ratings

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 62: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

9

Inventory Example 1

Low Bar Power Company maintains a spreadsheet that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 63: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

10

Inventory Example 2

Max Reliability Power Company maintains a database that identifies the series equipment Equipment Ratings and Facility Rating for its Facilities and includes Equipment Rating documentation Flagging when Equipment Rating changes impact Facility Ratings Identification of Facilities with unique characteristics Required fields dependent on characteristics of Facilities Automated notification for Facility Rating changes

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 64: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

11

Verification

Verification of Facility Ratings is a detective control to help ensure

Facility Ratings respect the most limiting

applicable Equipment Rating of the individual

equipment that comprises that Facility

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 65: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

12

Verification Example 1

Low Bar Power Company states that it verified its Facility Ratings using as-built one-line diagrams at the time it established its Facility Ratings

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 66: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

13

Verification Example 2

Max Reliability Power Company performs annual field inspections of a percentage of its Facilities to ensure all applicable equipment has been considered in Facility Ratings documentation and Equipment Ratings are accurate Anomalies evaluated for applicability to other Facilities Identified Facilities prioritized for future field inspections

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 67: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

14

Change Management

Change management processes are necessary to ensurebull Equipment Rating changes are

evaluated to identify impacts to Facility Ratings

bull Facility Rating changes are evaluated to identify impacts to protection analysis and monitoring of the Bulk Electric System

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 68: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

15

Change Management Example

Facility Ratings

TOP-003-3

TOP-001-4

TOP-002-4

TPL-001-4

IRO-010-2

MOD-032-1

PRC-023-4

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 69: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

16

Change Management Example 1

Low Bar Power Company has no documented change management processes but states Its personnel will know to review Facility Ratings if equipment changes

occur Appropriate personnel should receive an email when Facility Ratings

change

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 70: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

17

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for equipment changes that include Evaluation of changes by subject matter experts Required change approvals prior to changes being implemented Notification to update inventory after changes implemented Confirmation that changes implemented as planned

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 71: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

18

Change Management Example 2

Max Reliability Power Company has robust documented change management processes for Facility Rating changes that include Automated notification of Facility Rating changes

bull Protection Engineeringbull System Planningbull System Operationsbull Operations Support

Checklist to verify appropriate follow-up action(s) taken Periodic comparisons with internal and external models

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 72: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

19

Questions

Meeting Title Date

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 73: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | RESILIENCE | SECURITY

BreakWebinar participants We will return at 345 pm Central

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 74: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

NERC 2019 Compliance amp Standards Workshop

Eversource Energy Service Company

July 23 ndash 24th 2019

Minneapolis MN 55402

Paolo DrsquoAlessandro JDSenior Specialist Reliability Compliance

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 75: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

Eversource Energy Service Territories Eversource provides electric service in CT

MA and NH states through the following regulated subsidiaries (all doing business as Eversource Energy)ndash Connecticut Light amp Power with over

1270000 electric customersndash NSTAR Electric including former Western

Massachusetts Electric Company with 1380000 electric customers

ndash Public Service of New Hampshire with 528000 electric customers

Eversource Energy Service Company provides certain functions such as transmission operations and transmission planning

Eversource provides gas distribution through Yankee Gas Services Company and NSTAR Gas delivering natural gas to approximately 524000 customers

Eversource serves nearly 230000 water customers through Aquarion Water Company

Eversource has approx 8000 employees

ISO-NENSTAR

CONVEX

ESCC

2

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 76: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

Eversource Energy One Registered Entity

bull Effective January 1 2018 Eversource Energy Service Company (NCR07176) registration was consolidated with

bull Connecticut Light and Power (NCR07044)bull NSTAR Electric Company (NCR7180)bull Public Service of New Hampshire (NCR07203)bull Western Massachusetts Electric (NCR07232)

bull Benefits of registration consolidation include the followingbull Supports efforts for consistency and best practice across 3 statesbull Efficiency through consolidation of external audits

bull In January 2018 PSNH completed the sale of its fossil fuel and generation units therefore Eversource is no longer a GO or GOP

bull As of January 2018 Eversource Energyrsquos functional registration is nowDi

strib

utio

nPr

ovid

er

Tran

smiss

ion

Ow

ner

Tran

smiss

ion

Ope

rato

r

Tran

smiss

ion

Plan

ner

Tran

smiss

ion

Serv

ice P

rovi

der

DP TO TOP TP TSPEversource Energy Service CompanyNCR07176 X X X X X

Sheet1

Sheet2

Sheet3

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
DistributionProvider Transmission Owner Transmission Operator Transmission Planner Transmission Service Provider
DP TO TOP TP TSP
Eversource Energy Service CompanyNCR07176 X X X X X
Page 77: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

A Strong Compliance Culture

bull Continued efforts to consolidate three state organizations for consistency and identification of best practices tools and controls

bull Strong senior management commitment Executives are regularly engaged in supporting compliance related activities

bull Dedicated departments to focus on compliance (Reliability Compliance Operational Compliance and Internal Audit)

bull Work activities foster a systematic approach to operational excellence and compliance Reportability Determinations Root Cause Analysis Self Assessments gt Lessons Learned gt Roadshow Presentations Internal Audits Events Analysis Training (ie CIP annual training)

bull Eversource SMEs lead on embedding compliance within their respective functional teams SME responsibilities primarily effect the following enterprise level groups

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 78: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

Organization Dedicated Committees amp Departments to Ensure Compliance

Committees

Compliance and Ethics Committee

Reliability Steering Committee - Quarterly

Compliance Work Plan (CWP) - Monthly

Departments

Reliability Compliance Operational Compliance

Internal Audit

Enterprise Risk Management

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 79: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

Examples of internal controls that support NERC compliance at an enterprise-wide level consist of the following

Eversource - Enterprise-Wide Controls

Reliability Compliance Department

Oversee and assist the business in ensuring compliance with all applicable Reliability Standards amp Requirements

Compliance and Ethics Committee

Executive level committee that oversees all compliance activity within the organization

Internal Audit Independently conducts periodic audits of compliance activities including NERC Reliability Standards

Enterprise Risk Management

Framework and process that enables enterprise wide view of business risks and how they are appropriately managed and mitigated

Compliance Work Plan Monthly meetings to brief leadership on compliance activity including (1) KPIrsquos (2) standards development amp implementation (3) review of compliance activity (4) emerging issues

CATSWeb Database system used to track and ensure completion of gap analysis and action plans for applicable NERC Standards and NPCC Directories

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 80: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

Ensure New Technologies are Secure (IT amp OT)bull Privilege Access Mgmtbull Application testingbull Penetration testingbull Mobile device security

Ensure Cloud Technologies are Securebull 3rd party reviewsbull Identity amp Access Mgmtbull End Point Security bull Application isolation

Eversource Cyber Strategy

Ensure Strong Cyber Hygiene

Policies Vulnerability Management Anti-malware technology Security Monitoring Security Awareness Incident Response Encryption Secure Architecture

Secure Legacy Systems

Technologies that isolate or protect vulnerable systems from being exploited

Risk Based Defense In Depth strategy that evolves based on the business and industry trends

Ensure OTSCADA Systems are SecureDevice authentication Device and network monitoringStrict externalremote access protocols

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 81: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

Eversource OampPCIP ICE Lessons Learned

In 2018 Eversource participated in both an OampP and CIP ICE exercise Positive feedback was received from SMEs and Senior Management on the following

While resource intensive the benefit of having a full review of internal controls enhancement to existing controls and the reduction in audit scope outweighed the impact to the line

Flowcharts were useful to demonstrate internal controls (detective preventative) that support ongoing compliance

If an entity decides to participate donrsquot underestimate the time needed to work with SMEs to review controls complete the ICE Template and create flowcharts

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 82: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

FAC-003-4 Flowchart

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 83: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

TOP-002-4 Flowchart

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 84: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

MOD-032-1 Flowchart

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 85: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

CIP-011-2 Flowchart

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 86: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Safety First and Always

Questions

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 87: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

C r e a t i n g s u s t a i n a b l e v a l u e f o r a l l

Control DevelopmentKristen Long Sr Analyst

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 88: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 2

NERC CONTROLS DEVELOPMENT OVERVIEW

Gather existing information

bullNERC standardbullCurrent RSAWbullPolicies and procedures

bullEnforcement history

bullExisting controlsbullEtc

Kickoff meeting with BU

bullOutline the processbullCreate schedulebullDefine deliverables

Development meetings

bullReview the standard

bullDetermine the need for a process map

bullReview and updated existing controls

bullDevelop new controls and tests to address risks

Approval

bullControl ownersbullNERC Compliance SMEs

bullNERC Compliance management

Upload to GRC Tool

Purpose NERC Compliance will lead a complete review of existing controls and work with the Business Units to develop new controls utilizing the appropriate control type (detective corrective preventative) to address compliance reliability security financial andor operational risks and document the updated controls in Archer

DRAFT

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 89: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 3

Control Development

End Goal ndash develop rigorous preventative controls and tests for NERC reliability standards applicable to Entergy

Priority ndash start with CMEP standards focus on CMEP requirements with MedHigh VRF (2019)

Approach ndash tailored to the individual standardbull CMEP medhigh requirements vs entire standard

bull Complete process mapping where applicable

bull Consider all risks ndash compliance reliability security etc

bull Control amp Testing rigor based on violation risk factor VRF and enforcement history

bull Partner with Projects SME and BU SMEs

bull RSAW updates ndash where applicable

Archer ndash NERC Compliance

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 90: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 4

All controls address some type of risk compliance (RSAW measures) reliability (relay settings being in sync preventing cascading outages) security (unauthorized physical or cyber intrusion) financial operational

Items that could affect riskbull Monitoring objectives bull Inherent risk (CMEP)bull Known or potential internal deficiencies (eg inexperience of ownerstesters

complicated manual process etc) andbull Previous enforcement history

Risk Drives Robustness of Internal Controls

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 91: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 5

Approach to Control amp Test Deployment bull Requires a balancing of considerations

Control amp Test Balancing

No Violations

Established Process

Less persuasive evidence documentation fewer controls amp tests

More persuasive evidence documentation increased controls amp tests

= =

Lower Risk

Higher Risk

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 92: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 6

bull Create Process Map ndash process map is a visual depiction of the high level process It should include the following information

bull Flowchart style picture of process(es)bull Implementing ProceduresPoliciesbull Critical stepsbull Area responsibilitiesbull Known Risks bull Procedure stepsbull Link to requirements

How do I start

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 93: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 7FOR ILLUSTRATIVE PURPOSES ONLY

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 94: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 8

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 95: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 9

bull Is the control to the largest extent possible automatedbull Are compensating and supporting internal controls neededbull Is the level of documentation available for the control sufficientbull Are any controls necessary to meet the objective missingbull Even if the control operates as designed will it fail to meet the objective (if

so = improperly designed)

Additional Considerations

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 96: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 10

Quiz

a) A control captured in the GRC tool that automatically kicks off annually directing a specific employee perform a required compliance action 1 month ahead of the deadline

b) A yellow sticky note attached to the same employees monitor reminding them to perform the same action by the mandated deadline

Identify the Preventative Control

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 97: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

HIGHLY SENSITIVE CONFIDENTIAL AND PROPRIETARY SEE NOTICE ON LAST PAGE Page 11

Quiz

a) A bus full of nuns that testify they personally witnessed the patch control management performed on January 1 2019 well within the mandated time periods

b) An electronic time stamped entry into the GRC tool or another application showing when the patch management was performed

c) A now convicted felon stating that when he was still unindicted he personally performed the patch management on the same date

d) Contemporarily made video of the employee performing the patch management on January 1 2019

What qualifies as evidence

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 98: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Xcel Energy Overview

July 23 2019

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 99: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Employees 11865Natural gas operationsbull Customers 20 millionbull Transmission 2209 milesbull Distribution 35112 milesElectricity operationsbull Customers 36 millionbull Transmission 20000 milesbull Distribution 75000 miles

Company Profile ndash Xcel Energy

Xcel Energy is an electric and natural gas company with annual revenues of $114 billion Based in Minneapolis Minn we have regulated operations in eight Midwestern and Western states and provide a comprehensive portfolio of energy-related products through four operating companies

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 100: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Xcel Energy

3

Northern States Power Company-

MinnesotaNorthern States

Power Company-Wisconsin

Public Service Company of

Colorado

Southwestern Public Service

MRO- NSP (NSPM amp NPSW)- SPS

WECC- PSCO

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 101: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

Our Strategic Priorities

Service Revenue amp customer-Focused Assets

Customer Effort amp Cost to Serve

4

BROADENEconomic growth and use of clean energy

HELP Customers be more efficient and lower energy use

IMPROVEGrid utilization effectiveness and economics

EXPAND Role and scope of propositions we offer

LOWER Total cost effort and time to serve customers

Lead the Clean Energy Transition

Enhance the Customer Experience Keep Bills Low

LEAD THE CLEAN ENERGY TRANSITION

ENHANCE THE CUSTOMER EXPERIENCE KEEP BILLS LOW

Leverage competitive advantages to reduce emissionsimprove grid performance and provide customer value

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers
Page 102: North American Electric Reliability Corporation - NERC … › pa › Stand › Workshops › Day One... · 2019-07-31 · 1.Reliability Standards address sustained risks with moderate

RELIABILITY | ACCOUNTABILITY1

  • 1 Opening Announcements
    • Welcome
    • NERC Antitrust Compliance Guidelines
    • Public Announcement
    • General Announcements
    • Todayrsquos Agenda
    • Todayrsquos Agenda
    • Question and Answers
      • 2 Keynote Remarks
        • Slide Number 1
        • Welcome to Minnesota
        • Slide Number 3
        • Slide Number 4
        • Slide Number 5
        • Slide Number 6
        • Slide Number 7
        • Slide Number 8
        • Slide Number 9
          • 3 Application of the ERO Enterprises Reliability Toolkit
            • Slide Number 1
            • Resilience is a Characteristic of a Reliable System
            • Resilience Indicators
            • Ensuring ALR
            • Declaration amp Problem
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Six-Step Framework
            • Guiding Principles
            • Slide Number 14
            • Illustrative Diagram
            • Questions and Answers
              • 4 CIP-013-1 Case Study
              • 5 FAC-008 Case Study
                • Facility Rating Internal Controls
                • Objectives
                • Internal Controls
                • Internal Controls
                • Facility Rating Methodology
                • Facility Rating Methodology Example 1
                • Facility Rating Methodology Example 2
                • Inventory
                • Inventory Example 1
                • Inventory Example 2
                • Verification
                • Verification Example 1
                • Verification Example 2
                • Change Management
                • Change Management Example
                • Change Management Example 1
                • Change Management Example 2
                • Change Management Example 2
                • Questions
                  • 6 July 23 Afternoon Break
                  • 7 Compliance Standards Workshop Eversource
                    • NERC 2019 Compliance amp Standards WorkshopEversource Energy Service Company
                    • Eversource Energy Service Territories
                    • Eversource Energy One Registered Entity
                    • A Strong Compliance Culture
                    • Organization Dedicated Committees amp Departments to Ensure Compliance
                    • Slide Number 6
                    • Eversource Cyber Strategy
                    • Eversource OampPCIP ICE Lessons Learned
                    • FAC-003-4 Flowchart
                    • TOP-002-4 Flowchart
                    • MOD-032-1 Flowchart
                    • CIP-011-2 Flowchart
                    • Slide Number 13
                      • 8 Compliance Standards Workshop Entergy
                        • Slide Number 1
                        • Slide Number 2
                        • Archer ndash NERC Compliance
                        • Risk Drives Robustness of Internal Controls
                        • Control amp Test Balancing
                        • How do I start
                        • Slide Number 7
                        • Slide Number 8
                        • Additional Considerations
                        • Slide Number 10
                        • Slide Number 11
                          • 9 Compliance Standards Workshop Xcel Energy
                            • Slide Number 1
                            • Company Profile ndash Xcel Energy
                            • Xcel Energy
                            • Our Strategic Priorities
                            • Slide Number 5
                              • 10 General Questions and Answers