NERC Focus on PRC Program Presents New Challenges, Opportunities
Over the last year, there has been more discussion among utilities and trade associations regarding how registered entities are going to develop their internal controls based on new standards and discussions with NERC and the Regional Entities. NERC’s emphasis is its Critical Infrastructure Protection (CIP) program. CIP coordinates NERC’s efforts to improve physical and cybersecurity for the North American bulk power system as it relates to reliability. Companies that are working with such groups as the North American Transmission Forum and the North American Generator Forum are benefiting by sharing programs, lessons learned and best practices that will help improve a registered entities internal compliance programs.
Here’s a good example: the new PRC-004-3, “Protection System Misoperation Identification and Correction” standard that currently in draft. There is specific guidance inside that registered entities will have internal corrective and preventative (CAPA) action plans and reports for Misoperations. This includes specific timeframes for the investigation of a Misoperations, the determination of the cause, and documenting findings in a report.
As stated in the PRC-004-3 Project 2010-05.1 Protection Systems: Phase 1 (Misoperations)
A Misoperation investigation report or documented findings may include the following information:
- initial evidence,
- probable causes,
- tests and studies, and
A brief description of the event surrounding the Misoperation may be included if not separately documented.
It’s clear that registered entities are ready to embrace building a CAPA process that is accepted by employees and vendors. It will also require oversight and accountability to their senior management team in order to make certain that all these controls are implemented properly and periodically reviewed for lessons learned. The nuclear, life science and other regulated industries have been doing this for decades. The registered entities working with trade groups, consultants, peer reviews and attending workshops, the registered entities will continue to develop a mature internal compliance program.
AssurX has been working with clients for close to 20 years building CAPA processes. These companies know that by quickly identifying an issue, and with proper disposition, it will not only improve their compliance program, but also their overall business.
The industry should continue to support the direction NERC and the Regions are headed with their Reliability Assurance Initiatives. Further, registered entities should continue to be engaged with their regional compliance committees to encourage the ERO that is the best way to ensure reliability of our bulk electric system.
Read more: NERC Reliability Assurance Initiative
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