Managing Change and Maintaining Compliance

Sean Thompson, Supervisor, NERC Services

Throughout the life of a power plant, many changes will affect all phases of operations and maintenance. Due to the sophistication of most power plants, it is critical to ensure that all operations and maintenance activities are performed based on accurate technical information, which often requires a Management of Change Program (MOC). This year, Management of Change is an area of focus for the ERO as identified in the 2020 Compliance Monitoring Enforcement Program (CMEP).  NERC states that “Change management weaknesses have also led to significant violations related to Facility Ratings and maintenance of Protection System devices”.

This weakness led to Facility Ratings being inaccurate due to several reasons, including inaccurate equipment inventories, or the ratings not being updated during projects or following severe weather events. The ERO also notes that when records are not kept up to date, inaccurate models and damaged equipment can result. Failing to keep accurate inventories of equipment, following asset transfers, addition of new equipment, or mergers and acquisitions, also results in incomplete Protection System Maintenance and Testing Programs. Asset inventories typically change following asset transfers, additions of new equipment, or mergers and acquisitions. Failure to keep accurate inventories can also result in incomplete Protection System Maintenance and Testing Programs.

An effective mechanism to mitigate these concerns is to implement a of Management of Change Program.  It is important that this program establishes procedures to provide accurate and complete information and to ensure proper control over the plant.  This program should consist of:

Procedures or policies regarding request for improvements (procedural or physical), Procedures used to decide if the improvement is beneficial to the facility and company, and Procedures that identify the components and procedures that should be managed


Documentation Control to ensure that any changes to the facility are properly authorized and that temporary modifications and “work-arounds” do not become the norm within the plant.

Technical Library Control to maintain accurate technical documentation and reflect the “as-built” conditions.

The principles and procedures of an effective program should be applied to all operations, maintenance, and service manuals associated with any area of the plant.  Facility leadership should ensure that only authorized changes can be made, and that all documentation accurately reflects actual conditions.

While many facilities have existing MOC programs it is important to update those with NERC standards in mind.  When evaluating the effectiveness of MOC, pertaining to NERC review programs that require large amounts of data, inventories of equipment, or additional equipment. Specific standards to address are:

CIP-002-5.1a – Include the facility Cyber Asset and BES Cyber Asset and System lists in the MOC program.

FAC-008-3 – Ensure equipment lists are updated during maintenance projects and after severe weather events.

PRC-005-6 – Ensure inventories are monitored and equipment changes are addressed within the program.