SACRAMENTO MUNICIPAL UTILITY DISTRICT



SACRAMENTO MUNICIPAL UTILITY DISTRICT

General Procedures Implementing Standards of Conduct

1. Emergency Operations

(a) Under emergency operating conditions that affect system reliability, SMUD employees shall take whatever steps are deemed necessary to keep SMUD’s power system in operation and satisfy SMUD’s obligation to the Western Interconnection consistent with NERC and WECC policies and criteria.

(b) Any actions taken in the event of an emergency that causes SMUD to deviate from its Standards of Conduct requirements shall be posted on the OASIS within 24 hours of such deviation.

2. Separation of Functions

SMUD has separated its Transmission Function Employees from its Marketing Function Employees.

(a) Separation of Transmission Function Employees from Marketing Function Employees

All employees of SMUD who perform Transmission Functions report directly to the Director, System Operation and Reliability. Departments performing Transmission Functions include: System Protection and Control; Power System Operations; Energy Management System; Power Operations Engineer; and Energy Coordination—Special Projects.

All employees of SMUD who perform Marketing Functions report under the Manager, Energy Trading and Contracts. Departments performing Marketing Functions include: Energy Coordinator; Supervisor, Energy Trading; Supervisor, Fuels.

(b) Separation of Facilities and Security Measures

(1) Energy Management Center

SMUD’s Transmission Function Employees and SMUD’s Marketing Function Employees reside in separate buildings. SMUD’s Transmission Function Employees are located in the Energy Management Center (EMC) at 6001 S Street, Sacramento, CA. Physical access to the EMC is restricted to authorized District employees and controlled by a proximity card key access control system. SMUD Asset Protection Officers control access to the EMC for non-employees. All non- employee visitors must sign in at the Asset Protection Security Control Center located in the EMC prior to gaining access to the building, and must be escorted by an authorized District employee. The Security Control Center is staffed twenty-four hours a day, seven days a week. SMUD’s PSO control room is housed within the EMC and is also staffed twenty-four hours a day, seven days a week, by Power System Operations personnel. Authorized unescorted physical access to the control room is controlled by a proximity card key access control system located at the EMC-DSO hallway door and at two entry doors into the PSO control room. Unescorted physical access is restricted to only those individuals authorized by the Director, Systems Operations and Reliability, or his designated representative, as having been cleared and authorized unescorted physical access to “critical cyber assets”. All persons permitted to enter the control room that do not have unescorted physical access authorization must be signed in on a visitor log and escorted at all times by an individual that is cleared and authorized unescorted physical access to “critical cyber assets.” The proximity card key access control system prevents Sales and Marketing employees from gaining unescorted physical access to the control room.

c) Separation of Computer Systems and Security Measures

SMUD’s LANs

SMUD has two Local Area Network systems (LANs) that are shared by its Transmission Function Employees and its Marketing Function Employees. The first is the System Operations and Reliability (SOAR) LAN, which was established to isolate Transmission Function data and its systems and provide security from outside access. The other is SMUD’s Corporate LAN. SMUD’s Marketing Function Employees are restricted from accessing Transmission Function Information and the files of Transmission Function Employees on these LANs through the use of secure shares and firewall protection. SMUD has a third LAN dedicated to the SMUD’s EMS. This LAN is further isolated through routers.

(i) System Operations and Reliability LAN

The SOAR LAN is protected through the use of secure shares and routers. SOAR utilizes an OSI PI Historian data base to store near-real time EMS data. This PI data base resides on servers on the SOAR LAN. SMUD’s Transmission Function Employees have access to all data on this LAN. SMUD’s Marketing Function Employees’ ability to view data on servers on the SOAR LAN is restricted to a single directory on a single share and a small subset of the PI Historian data. This data is the transmission schedules for SMUD’s own Marketing Function transactions and generation and load data for SMUD only. Marketing Function employees do not have access to any transmission or generation information of other parties.

(ii) Corporate LAN

Within SMUD’s Corporate LAN are sub-LANs created for individual departments. The departmental sub-LANs were created to facilitate interdepartmental and intradepartmental access to documents, data, charts and graphs by employees working on different parts of a project. SMUD’s Transmission Function Employees have access to the Corporate LAN but do not utilize this LAN for the storage of Transmission Operations/Reliability data.

(iii) EMS LAN

SMUD’s EMS, which is used to operate SMUD’s transmission and generation system, is located on the EMS LAN. Marketing Function Employees cannot access the EMS LAN. The EMS utilizes a Sybase database and client server system. The functions of the EMS – Supervisory Control and Data Acquisition (“SCADA”) and Network Applications – are accessible only to Transmission Function Employees and distribution system operations employees. The EMS LAN is isolated from the other LANs through firewalls. Additionally, the EMS itself is protected through the use of individual user accounts and passwords. Each employee’s user name and password is associated with areas of responsibility that determine which displays can be viewed on the EMS. The Marketing Function Employees are restricted to a very small set of displays that give the ability to view real time generation and load data for SMUD only. This EMS data, however, is available to the Marketing Function Employees through the System Operations and Reliability LAN, as opposed to the EMS LAN. Marketing Function Employees do not have access to any data related to COI, WAPA, or any other entity outside of the SMUD service area.

(iv) Other Computer Equipment

SMUD has no other computer equipment or databases that are shared between Marketing Function Employees and Transmission Function employees.

d) Operation of OASIS and Requirements for OASIS Posting

SMUD operates and maintains an OASIS (Internet address ) that substantially conforms with the requirements set forth in 18 C.F.R. § 37.6.

The organizational chart, job descriptions and descriptions of chains of command for SMUD employees responsible for Transmission Functions or Marketing Functions are posted on SMUD’s OASIS site on and are updated as required.

e) Training

SMUD provides training on the Standards of Conduct and Written Procedures for all SMUD Transmission Function Employees and all Marketing Function Employees. Training is also provided, as necessary, to SMUD employees who provide support services to either or both of these functions to ensure that no prohibited information transfer takes place inadvertently. All such employees who are required to receive such training sign acknowledgement forms certifying that they have attended a training class on the Standards of Conduct and have received a copy of the Standards of Conduct and Written Procedures.

f) Compliance Auditing

SMUD’s Audit Services Department may perform compliance auditing on a periodic and random basis to ensure that SMUD maintains conformity with the Standards of Conduct through the enforcement of these Standards of Conduct Procedures.

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