By Wanda Niemann-Marshall, Power Market Compliance Services Specialist

With thirteen years of mandatory NERC compliance in the rearview mirror, it’s time to take a step back and review one of the basic tenants of good compliance. Compliance managers tend to focus their time on the NERC standards that are frequently updated, carry the most risk, and those that the Regional Entity is focusing on – while focusing less on other standards that are more static. It is important to take time to re-read the language in these standards and review the NERC definitions in order to not miss key components and concepts. Two examples are TOP-003 and IRO-010. These two standards are very similar in nature and data required to meet compliance requirements. When reviewing program documents, pay close attention to the definitions contained in the NERC Glossary of Terms as they are pertinent. In this example the two terms below should be focused on: 

• Operational Analysis: An evaluation of projected system conditions to assess anticipated (pre-Contingency) and potential (post-Contingency) conditions for next-day operations. The evaluation shall reflect applicable inputs including, but not limited to, load forecasts; generation output levels; Interchange; known Protection System and Special Protection System status or degradation; Transmission outages; generator outages; Facility Ratings; and identified phase angle and equipment limitations. (Operational Planning Analysis may be provided through internal systems or through third-party services)  
• Real Time Assessments: An evaluation of system conditions using Real-time data to assess existing (pre-Contingency) and potential (post-Contingency) operating conditions. The assessment shall reflect applicable inputs including, but not limited to: load, generation output levels, known Protection System and Special Protection System status or degradation, Transmission outages, generator outages, Interchange, Facility Ratings, and identified phase angle and equipment limitations. (Real-time Assessment may be provided through internal systems or through third-party services)  

By reading the definitions in the NERC Glossary of Terms, it is made clear that the data required is collected on an ongoing basis by facilities. With appropriate controls it is easy to document generation output levels, status of special protection systems and outages on a regular basis. Often these obligations are met through our participation in ISO’s, in conjunction with Energy Managers and others who may be acting on the facilities’ behalf. Encouraging strong logbook practices and requiring Energy Managers or those acting on the facilities’ behalf to provide evidence of communications should be one primary internal control when managing compliance with TOP-003 and IRO-010. 

Remember the basics when evaluating your internal controls. The data requests may be as simple as reporting an outage. It may be a change to your facility rating or changes in equipment. Document retain documentation and evaluate if your controls in place need to be updated with your Energy Manager if you are using one.