Assuring continued power system reliability is a complex undertaking for utilities. Balancing the demands of system changes and regulatory compliance is an essential strategy for optimizing ongoing operations. Given the wide range of NERC standard families that require simultaneous data management for compliance, data integrity, data flow and data verification are critical for avoiding violations that can impact electric service to customers and communities.
Compliance Monitoring and Enforcement
NERC’s 2020 Compliance Monitoring and Enforcement Plan focuses on change management and gaps in compliance program execution. NERC notes that utility change management weaknesses have led to compliance violations. For example, accurate modeling of the power system is integral to both operational and long-term planning of the power system and to the protective relay setting process. The utility business functions of operations and long-term planning along with the management of protection system devices are dependent on maintaining an effective system configuration change management process.
There are significant interdependencies between Transmission Planning (TPL), System Modelling (MOD) and Facilities Design, Connection and Maintenance (FAC) standards families which are not fully identified in NERC’s Reliability Standard Audit Worksheets (RSAWs). Simple completion of the RSAWs on a department by department basis can lead to a false sense of security when preparing for a compliance audit.For example, using facility ratings based on inaccurate equipment inventories or ratings that were not updated during capital construction projects can result in inaccurate system models which in turn can result in multiple mandatory standard violations.
Independent Data Review
It is important for utility NERC compliance assurance programs to independently identify the dependent data linkages between NERC standards families (and their respective RSAWs). This is to ensure that the information upon which compliance is determined is fully and accurately propagated through the utility’s compliance assurance process.
The Limits of RSAWs
Pre-audit, independent reviews of the compliance program and the testing of the utility compliance process data flow by knowledgeable subject matter experts is necessary to ensure timely and accurate data flow.
While NERC RSAWs will have some limited cross-standard notations, they do not delve into the completeness of that shared data. RSAWs were created for each standard and completed individually by utility functional departments. This approach can lead to data inaccuracies and gaps. Organizational and functional silos are an ongoing issue in the utility industry. Procedural controls that ensure the responsible staff members within separate organizations in the utility will cross-coordinate with their dependent data users to ensure that recently (since the last audit period) modified data moves into the dependent standard audit worksheet. Compliance management teams must remain aware of the data flow and explicitly observe and be involved in the review and approval of the data and data flow (often “as-built” drawing and other documentation updates lag the commercial operation of facilities, sometimes by years. This is one source of data errors). This procedural control must be satisfied before the technically accountable group can approve system modifications for field implementation and commercial operation (as opposed to test operation).
Building a Cross-functional Data Integrity Program
Cross-family and cross-standards dependencies among the enforceable NERC standards should be identified well in advance of evidence preparation for the audit.
- Identify the internal organizations primarily responsible for the source data. Note where one department’s work product is the source data for another department.
- Verify the data linkages and data flows between various individuals and departments
- Check for timeliness of data preparation within a given audit period.
Conduct a pre-audit review of the audit evidence to be submitted.
- Early preparation and assessment of the RSAWS for the expected scope of the audit
- Review prior reports on past audits for likely areas of focus in the upcoming audit scope
- Review of spot-check results prior to the audit
- Review of past Notices of Penalty, including other utilities
- Take into account any mitigation plans currently underway.
Early preparation of draft RSAWs allows time for testing interdependent evidence for up-to-date source data.
- FAC-008 ratings to MOD standards requirements
- MOD standards models to TPL standard related studies
Independent review of draft RSAWs for in-scope standards prior to regional entity audit notification and scope letter is highly recommended.
Conclusion
Utilities face an increasing range of changing mandatory NERC compliance obligations across and between all families of reliability standards. These continually evolving regulatory requirements call for careful monitoring to effectively manage compliance risk. Simultaneously, the utility’s power delivery system is undergoing continuous change which may lead to data gaps as each piece of power delivery equipment is modified.
It is important to understand the many interrelated NERC requirements across standards families and how these relationships impact the evolution of your power delivery system. Compliance assurance programs should properly consider and incorporate the following areas:
- Pre-audit evaluations including data integrity checking
- Post-audit program support including mitigation plan development and implementation
- Internal controls evaluation
- Inherent risk assessment evaluation
- Compliance program development
- Ongoing standard compliance tracking
- Maintenance procedures
James Whitaker, PE, is TRC’s Supervisor of Power System Studies. James Whitaker, PE, is TRC’s Supervisor of Power System Studies. Dylan Achey is TRC’s Manager of Generation Engineering Services.
