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Compliance Audit Report Public Version
ExxonMobil Corporation-Baton Rouge NERC ID # NCR00128
Confidential Information (including Privileged and Critical Energy Infrastructure Information) – Has Been Removed

Date of Audit: July 17-19, 2012 Date of Report: August 11, 2012

Confidential information (including Privileged and Critical Energy Infrastructure Information) – Has Been Removed

TABLE OF CONTENTS
Executive Summary ........................................................................................................ 3 Audit Process .................................................................................................................. 3
Objectives ................................................................................................................................................ 3 Scope ....................................................................................................................................................... 4 Confidentiality and Conflict of Interest ................................................................................................ 4 Methodology............................................................................................................................................ 4 Company Profile ..................................................................................................................................... 5 Audit Participants ................................................................................................................................... 5 Findings ................................................................................................................................................... 6

Compliance Culture ......................................................................................................... 6 Areas of Concerns........................................................................................................... 7

ExxonMobil-BR Compliance Audit Report August 11, 2012 Page i

Confidential information (including Privileged and Critical Energy Infrastructure Information) – Has Been Removed

Executive Summary
An on-site compliance audit of ExxonMobil Corporation-Baton Rouge (ExxonMobil-BR) NCR00128 was conducted July 17-19, 2012. At the time of the audit, ExxonMobil-BR was registered for the Generator Owner (GO) and Transmission Owner (TO) functions. The audit team evaluated ExxonMobil-BR for compliance with 13 requirements in the 2012 NERC Compliance Monitoring and Enforcement Program (CMEP). The audit team assessed compliance with the NERC Reliability Standards for the period of 8/28/2008 to 7/19/2012 for the GO registration and 3/11/2009 to 7/19/2012 for the TO registration. ExxonMobil-BR submitted information and documentation for the audit team’s evaluation of compliance with requirements. The audit team reviewed and evaluated all information provided by ExxonMobil-BR to assess compliance with standards applicable to ExxonMobil-BR at this time. Based on the information and documentation provided by ExxonMobil-BR, the audit team found ExxonMobil-BR to have no findings of non-compliance with eleven (11) applicable requirements. The audit team determined that two (2) requirements were not applicable to ExxonMobil-BR. These audit results are further explained in the Audit Results Findings section of this report which includes detailed information of the audit team’s findings of applicability and compliance for the NERC Reliability Standards within the scope of the compliance audit. Any Possible Violations will be processed through the NERC and SERC Reliability Corporation (SERC) CMEP. There were no ongoing or recently completed mitigation plans and therefore none were reviewed by the audit team. The SERC audit team lead certifies that the audit team adhered to all applicable requirements of the NERC Rules of Procedure (ROP) and CMEP with the following exceptions: the SERC audit team did not adhere to the NERC Compliance Checklist or NERC Compliance Auditor Manual regarding Reliability Coordinator Questionnaires due to the fact that SERC Reliability Corporation only sends Reliability Coordinator Questionnaires when auditing entities registered as Balancing Authorities (BA) and Transmission Operators (TOP).

Audit Process
The compliance audit process steps are detailed in the SERC CMEP. The SERC CMEP generally conforms to the United States Government Accountability Office Government Auditing Standards and other generally accepted audit practices.

Objectives
All registered entities are subject to an audit for compliance with all reliability standards applicable to the functions for which the registered entity is registered. 1 The audit objectives are to:

1

North American Electric Reliability Corporation CMEP, paragraph 3.1, Compliance Audits

ExxonMobil-BR Compliance Audit Report August 11, 2012 Page 3 of 7

Confidential information (including Privileged and Critical Energy Infrastructure Information) – Has Been Removed • • • • • • Review compliance with the requirements of reliability standards that are applicable to ExxonMobil-BR, based on the functions that ExxonMobil-BR is registered to perform; Validate compliance with applicable reliability standards from the NERC 2012 Implementation Plan list of actively monitored standards, and additional NERC Reliability Standards selected by SERC; Validate compliance with applicable regional standards from the SERC 2012 Implementation Plan list of actively monitored standards; Validate evidence of self-reported violations and previous self-certifications; Observe and document ExxonMobil-BR’s compliance program and culture; Review the status of mitigation plans.

Scope
The scope of the compliance audit included the NERC Reliability Standards from the SERC 2012 Implementation Plan. In addition, this audit included a review of mitigation plans or remedial action directives which have been completed or pending in the year of the compliance audit. At the time of the audit, ExxonMobil-BR was registered for the Generator Owner (GO) and Transmission Owner (TO) functions. The audit team evaluated ExxonMobil-BR for compliance during the period of the lesser of: 1) date of registration to date of audit exit presentation; 2) date of last audit or spot check to date of audit exit presentation; or, 3) June 18, 2007 to date of audit exit presentation.

Confidentiality and Conflict of Interest
Confidentiality and Conflict of Interest of the audit team are governed under the SERC Delegation Agreement with NERC, and Section 1500 of the NERC Rules of Procedure. ExxonMobil-BR was informed of SERC’s obligations and responsibilities under the agreement and procedures. The work history for each audit team member was provided to ExxonMobilBR. ExxonMobil-BR was given an opportunity to object to an audit team member’s participation on the basis of a possible conflict of interest or the existence of other circumstances that could interfere with an audit team member’s impartial performance of duties. ExxonMobil-BR had not submitted any objections by the stated 15 day objection due date and accepted the audit team member participants without objection. There have been no denials of or access limitations placed upon this audit team by ExxonMobil-BR.

Methodology
The audit team reviewed the information, data, and evidence submitted by ExxonMobil-BR and assessed compliance with requirements of the applicable reliability standards. Submittal of information and data were sent to SERC 30 days before the scheduled date of the entity review. Additional information relevant to the audit could be submitted until the conclusion of the exit briefing. The audit team requested and received additional information and sought clarification from subject matter experts during the audit. The audit team reviewed documentation provided by ExxonMobil-BR. Data, information, and evidence submitted in the form of policies, procedures, emails, logs, studies, data sheets, etc. were validated, substantiated, and cross-checked for accuracy as appropriate. Requirements ExxonMobil-BR Compliance Audit Report August 11, 2012 Page 4 of 7

Confidential information (including Privileged and Critical Energy Infrastructure Information) – Has Been Removed which required a sampling to be conducted were developed based upon the significance of the sampling to the reliability of the bulk electric system (BES). Findings were based on the audit team’s knowledge of the BES, the NERC Reliability Standards, and their professional judgment. All findings were developed based upon the consensus of the audit team.

Company Profile
Exxon Mobil Corporation is a global, integrated petrochemical energy corporation with upstream, downstream chemicals and marketing divisions. Exxon-Baton Rouge’s Refinery is a wholly owned asset of Exxon Mobil Corporation and is roughly divided into process operations, maintenance, technical, engineering and support divisions. The Exxon-BR facility’s generating plant is located in Baton Rouge, East Baton Rouge Parish, Louisiana. Exxon-BR owns no transmission lines and has no interconnection points. Entergy owns the transmission line that connects Exxon-BR substations to the grid. The Entergy Reliability Coordinator function is performed by Southwest Power Pool (SPP).

Audit Participants
The following is a listing of all personnel from the Audit Team and ExxonMobil-BR who were present during the meetings or interviews. Audit Team Participants Role Audit Team Lead Team Member Team Member Title Senior Compliance Auditor Senior Compliance Auditor Senior Compliance Auditor Entity SERC SERC SERC

ExxonMobil-BR Audit Participants Title Refinery Manager Site Utilities Department Manager Site Utilities Technical Supervisor BR Complex Power Engineer Power Distribution SLS Electrical SME BRPP Maintenance Supervisor Central Services Maintenance DH BRPP Maintenance Manager BRPP Plant Manager Machinery, Electrical, Process Control Dept. Head Electrical Instrumentation & Analyzers Supervisor Entity ExxonMobil-BR ExxonMobil-BR ExxonMobil-BR ExxonMobil-BR ExxonMobil-BR ExxonMobil Research & Engineering ExxonMobil-BR ExxonMobil-BR ExxonMobil-BR ExxonMobil-BR ExxonMobil-BR ExxonMobil-BR

ExxonMobil-BR Compliance Audit Report August 11, 2012 Page 5 of 7

Confidential information (including Privileged and Critical Energy Infrastructure Information) – Has Been Removed

Audit Results
The audit team evaluated ExxonMobil-BR for compliance with 13 requirements in the 2012 NERC Compliance Monitoring and Enforcement Program (CMEP). The audit team assessed compliance with the NERC Reliability Standards, for the period of 8/28/2008 to 7/19/2012 for the GO registration and 3/11/2009 to 7/19/2012 for the TO registration. ExxonMobil-BR submitted information and documentation for the audit team’s evaluation of compliance with requirements. The audit team reviewed and evaluated all information provided by ExxonMobil-BR to assess compliance with standards applicable to ExxonMobil-BR at this time. Based on the information and documentation provided by ExxonMobil-BR, the audit team found ExxonMobil-BR to have no findings of non-compliance with eleven (11) applicable requirements. The audit team determined that two (2) requirements were not applicable to ExxonMobil-BR.

Findings
The following table details the findings for compliance for the scope identified for this audit. Reliability Std. CIP-002 through CIP-009 FAC-001-0 FAC-002-1 FAC-003-1 FAC-003-1 FAC-008-1 FAC-009-1 FAC-009-1 PRC-004-1 PRC-004-1 PRC-004-1 PRC-005-1 PRC-005-1 PRC-023-1 R2. R1. R1. R2. R1. R1. R2. R1. R2. R3. R1. R2. R1. Req. Finding Reviewed by a separate Monitoring Process No Finding No Finding Not Applicable Not Applicable No Finding No Finding No Finding No Finding No Finding No Finding No Finding No Finding No Finding

Compliance Culture
The audit team assessed ExxonMobil-BR’s Internal Compliance Program in conjunction with the audit. Evidence reviewed in assessing the program included: ExxonMobil-BR’s Compliance Pre-Audit Survey, NERC Compliance Governance, compliance staff organizational charts, interviews with ExxonMobil-BR staff, and observation of staff responses in preparation for and during the audit. Four factors that characterize a vigorous and effective compliance program are: active engagement and leadership by a company’s senior management; preventive measures appropriate to the individual circumstances of the company; promptly detecting, stopping, and ExxonMobil-BR Compliance Audit Report August 11, 2012 Page 6 of 7

Confidential information (including Privileged and Critical Energy Infrastructure Information) – Has Been Removed reporting a violation; and, ultimately fixing the problem and working to avoid future possible violations. SERC recognizes that there isn’t one standard formula for an effective compliance program, and that there will be variations in each company’s program and culture based on countless factors, including the size and age of the company, as well as the nature and extent of its business. Ultimately what matters are the results and whether the compliance program worked as it should. The audit team determined that ExxonMobil-BR’s Internal Compliance Program documents and their staff’s demonstrated compliance culture indicate an effective compliance program. Additional information pertaining to the compliance culture of ExxonMobil-BR can be found in the Internal Compliance Survey.

Areas of Concerns
The audit team notified ExxonMobil-BR that it did not identify any Areas of Concern.

ExxonMobil-BR Compliance Audit Report August 11, 2012 Page 7 of 7

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