Strong Document Control Critical For NERC Compliance
Document control is invaluable to utilities trying to prevent or learn from system outages. Stakes are high. Consider the cost of outdated or insufficient documentation in terms of legal, financial, regulatory and public satisfaction consequences.
$1 Million Fines Each Day
Failure to meet reliability performance and other North American Electric Reliability Corporation (NERC) and Federal Energy Regulatory Commission (FERC) regulations can result in fines of up to $1 million per day.
Inevitably, as summer and its accompanying storms approach, it’s a timely reminder that electric utilities often go toe-to-toe with some of the worst weather Mother Nature can dish out. In some cases, that collision becomes a power outage.
Regardless of the reason for an outage, pressure is on utilities from regulators and customers to demonstrate preparedness. Were preventive internal controls in place? Was this information available and accessible? Finally, how effective was document control in prevention and remediation?
NERC Compliance Standards
Official government data shows rough weather and other issues pose a genuine threat to the power grid. As many in the industry know all too well, it’s not an uncommon problem. NERC is expected to extend audit event response and recovery plans and look for stringent “internal controls design and implementation effectiveness.”
Unfortunately, the NERC regulatory compliance climate isn’t getting any easier for utilities. In 2016 the NERC Board of Trustees Compliance Committee (BOTCC) approved 18 Full Notices of Penalty (Full NOPs) resolving CIP and non-CIP violations with penalties in the millions of dollars.
Recent Energy Information Agency (EIA) Report
A recent Energy Information Agency (EIA) report showing average frequency and duration of electric power outages in calendar year 2015 tells the story:
- Among all utility types, there was an average of one minor power service interruption per customer in 2015. Major outages occurred about ¼ as often, according to the Annual Electric Power Industry Report.
- Municipal utilities generally fared best, followed by investor-owned utilities. Co-op utilities were about twice as likely to have a service interruption as a municipal utility in 2015.
- Outage duration times ranged from about two hours for municipal utilities (including minor and major events), and nearly five hours for co-ops.
How is Reliability Measured?
Typically, reliability of electricity supply systems is measured by duration, frequency, and scale of the service interruptions using standards and metrics developed by the Institute of Electrical and Electronics Engineers, an industry trade association.
Document Control Important For Utilities of All Sizes
Smaller utilities tend to struggle more with weather-related outages. However, it is still important for all utilities to track and record reliability statistics in a defensible manner.
“Starting an outage record program is the key to building a wealth of information” according to Reliability Statistics for Small Utilities, a guidebook developed by the American Public Power Association’s DEED (Demonstration of Energy-Efficient Developments) program. “Even if this information is never used to calculate reliability indices, it can still be beneficial for understanding the operation of the electric system.”
While the report is directed at smaller utilities, or those defined as having fewer than 2,000 customers, it’s advice worth heeding for utilities of any size.
Utilities need data storage and document management enterprise-wide while adhering to document lifespans and NERC compliance management requirements. For example, utilities must be aware of how long a given record must be archived and easily accessible.
The Power of Document Control Software
Used properly, document control software integrated within a versatile compliance management platform like AssurX will automate the creation, modification, review and dissemination of documents in a controlled, centralized manner.
For example, many utilities, including PG&E and Vermont Electric Power Company (VELCO), have used best practices and software tools to tighten their document control programs. VELCO manages a system including 738 miles of transmission; 13,000 acres of rights-of-way; 55 substations, switching stations and terminal facilities.
VELCO has been using AssurX software to track incident analyses and near misses for the past several years. The process categorizes and trends causes of events, that information is then leveraged to improve risk-based compliance.
Inevitably, there will be rough weather ahead. But electric utilities can and should worry about controlling documents and data, too. NERC will continue to assess whether sufficient documentation controls exists for processes and procedures, as well as for providing post-event evidence.