By Daniel Jenkins, NERC Reliability Compliance Specialist
Have you been requested to perform an Internal Risk Assessment (IRA) from your Regional Entity? Did you know that some facilities have been extended to a nine-year interval while others have been moved to a three-year interval?
The answers to those questions can be found in the NERC Rules of Procedure and guide the way individual regions perform their audits. NERC Generator Audits are performed on a cyclical basis with a standard six-year periodicity. Over the last few years, the regions have been working with registered entities to update their IRA’s in order to evaluate the risk to the electric grid and possibly extend the periodicity of NERC audit up to every nine years.
When an audit approaches, it is important to thoroughly review the NERC program to ensure all evidence and documents are organized and reviewed. This is where everyone involved in NERC should be engaged. By working with subject matter experts at the facility as well as any available corporate support, many hands make work light, and this will reduce the stress and anxiety that can accompany an audit.
The Audit will begin with a request for a Reliability Standard Audit Worksheet (RSAW) and accompanying evidence due by a defined due date. It is advised to provide this information as soon as possible to allow more time for subsequent data requests. After this initial audit evidence has been submitted, it’s a waiting game until the initial review has been completed and a supplemental request for information (RFI) is presented. This RFI should be responded to clearly and within the provided time frame. If more time is required, then reach out to the audit team and request additional time as soon as possible.
The best way to go through an audit is as a team working together to provide the requested documentation. Working together can be the difference between a possible non-compliance and a recommendation.