Support for Implementation of NERC Requirements
NERC Compliance Audits and Support
On June 1, 2007, the National Electric Reliability Council (NERC) received the authority to fine utilities that failed to comply with NERC guidance. The potential fines NERC can impose can be quite large. To ensure compliance, NERC will begin auditing utilities and other service providers in the near term.
Previously, NERC guidance was voluntary and was adopted by utilities to varying degrees. To avoid the potentially large fines, utilities need to reassess their compliance with the regulations and develop confirmatory documentation. Sending the NERC auditor to talk to “Johnny” in the shop on a particular program is unlikely to achieve the desired results.
To this end, Loma Consulting offers to assess utility compliance with the approved NERC standards. For most of the standards – except the CIP series dealing with cyber-security – utilities already have programs in place. How to implement the CIP standard series is still being resolved. Therefore, Loma proposes only to review compliance to the “old” standards. In most cases, this review is an identification of gaps in the current processes. For instance, NERC requires particular coding of tree-caused transmission line outages. The utility may have coding in place, but the exact codes do not match what NERC wants. To restate, most utilities will already meet many of the requirements for the older standards, as these standards have been in place – to some extent - for some time in most NERC regions.
Programs complying with NERC requirements may be in place at a utility, but only in rare instances will sufficient documentation be in place for the program. Documentation of the programs will serve the following purposes:
> Identification of tasks needed to implement and perform the program
> Assignment of responsibilities
> Ensuring archiving and record keeping
> Controlling program activities
> Providing a paper trail for auditors to quickly identify how the utility is meeting the intent of the requirement.
Program documentation is therefore an exercise in interviewing utility personnel, checking paperwork records, and ensuring all the “parts” of the program are in place. Loma recommends creating a specific document that identifies how the utility meets each requirement in each NERC standard, along with discussion of measurement points identified in the standard. Additional document should outline, at a relatively high level, how the utility meets the intent of the standard. For instance, the utility does not need to create a document that instructs a worker on how to trim a tree, but rather documents that ANSI A300 is used to guide workers in this area.
Loma is ready to work with utilities in program review and documentation, in particular in those standards related to maintenance activities. For more information, contact Earl S. Hill
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