January 8, 2024
According to the North American Energy Reliability Corporation (NERC), 2022 saw a total of 525 noncompliances reported involving Operations and Planning (O&P) standards.
At the top of the list of most frequently violated standards were PRC-005, PRC-024 and MOD-025, representing nearly half of the instances of noncompliance overall.
For electric utilities that aren’t in compliance, the risks are high, with NERC penalties totaling as much as $1 million per day depending on the severity of the violation.
With that in mind, below we explore each of these standards in more detail, and how an automated NERC compliance management system can provide greater visibility and control to minimize risk.
Learn how Velco automated its compliance process to streamline NERC audit preparation and demonstrate a continuous state of control
PRC-005: Protection System, Automatic Reclosing, and Sudden Pressure Relaying Maintenance
PRC-005 represented the lion’s share of O&P violations in 2022, accounting for 100 noncompliances in total. A full 98 of those were represented by requirement three, which centers on time-based maintenance programs.
R3 specifies maintenance activities utilities must perform on various components at intervals ranging from once every four months to once every 12 years. Evidence required to demonstrate compliance includes:
- Maintenance records
- Maintenance summaries
- Check-off lists
- Inspection records
- Work orders
An automated NERC compliance management system with a Protection System Maintenance solution provides a centralized hub for tracking compliance with NERC PRC standards, allowing you to:
- Catalog all components that require monitoring
- Create and assign maintenance tasks based on the schedules set forth in PRC-005
- Collect data and information such as work orders, test results and other supporting evidence
- Get dashboard views of compliance status for all devices and assets across the entire utility
- Create automated alerts to notify responsible parties and supervisors of approaching or overdue compliance tasks
The NERC report specifically calls out high-frequency activities like those required by PRC-005 as a common area of noncompliance. Automating your NERC compliance process eliminates the manual effort required to meet requirements. This gives teams the confidence to know that assets and devices are properly cataloged and all required tasks have been completed.
This ultimately results in a state of audit readiness, where utilities don’t have to worry about penalties due to having missed a component or deadline. It also significantly reduces the time needed to prepare for internal and external audits, an important factor for utilities needing to maintain compliance with limited resources.
PRC-024: Frequency and Voltage Protection Settings for Generating Resources
PRC-024 violations accounted for 74 total noncompliances, equally split among requirements R1 and R2. These requirements focus on setting the applicable frequency and voltage protection, respectively, to ensure that it doesn’t trip the current during frequency or voltage excursions.
Evidence here focuses on items such as:
- Setting sheets
- Calibration sheets
- Calculations
- Voltage-time boundaries
- Coordination plots
- Dynamic simulation studies
The NERC report highlights that O&P requirements such as PRC-024 R1 and R2, which require coordination or verification of generator data, are some of the most frequently reported noncompliances.
One reason for this is the vast amounts of data that must be collected and verified to maintain compliance. A compliance system built specifically around NERC requirements is essential, giving utilities the ability to:
- Pull all compliance-related data into a centralized repository
- Link documented controls to related requirements to simplify gap identification and review
- Integrate with other information systems so that all data is catalogued, organized and accessible during an audit
- Track who is responsible for performing compliance tasks and assign schedules so deadlines aren’t missed
- Automate collection and verification of data
MOD-025: Verification and Data Reporting of Generator Real and Reactive Power Capability and Synchronous Condenser Reactive Power Capability
MOD-025 was the third most frequently reported O&P noncompliance in 2022, accounting for 73 total noncompliances. The violations were split among requirements R1 and R2 of the standard, which require generator owners to verify the real and reactive power capability of generating units and synchronous condenser units.
To meet these compliance requirements, utilities must perform testing according to various time-based verification requirements ranging from 12 to 66 calendar months. For some utilities, this standard requires tracking a large amount of data, making it ripe for compliance violations.
Keeping track of this data and compliance deadlines manually is a labor-intensive and often error-prone process. Equally burdensome is the need to complete reliability standard audit worksheets (RSAWs) to document compliance with each standard.
With an automated NERC compliance management system, utilities can:
- Populate RSAW templates with all reviewed and approved documentation and download the evidence package for submission with a single click
- Create rules-driven workflows that include compliance tasks, evidence collection, approvals and corrective actions
- Link corrective actions to individual tasks to monitor progress and issue status
- Maintain compliance readiness with electronic signatures, records management and permissions-based access to protect data integrity
Conclusion
Navigating NERC compliance is an ongoing challenge for electric utilities, particularly given the large volume of data and evidence required to achieve audit readiness. A purpose-built compliance system with pre-loaded NERC standards and requirements simplifies the process, as does the ability to define workflows that streamline evidence generation and collection. More than just an issue of convenience, automation is a shield against noncompliance penalties, offering a higher level of protection and reliability for customers who rely on utilities.
About the Author
Kathryn Wagner is Vice President, Industry Solutions, Energy & Utilities at AssurX. Kathryn brings more than 25 years of experience in manufacturing systems integration and compliance while being responsible for the development and evolution of product offerings for NERC compliance and related systems that focus on reliability and resilience.
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