By Will White, Senior NERC Reliability Compliance Specialist
Who would believe leading up to April of 2015 that over 6 years later we would still be closely monitoring the implementation plan of a NERC Standard and its Requirements? PRC-005 is just that Standard. As if the most violated O&P Standard wasn’t difficult enough, a lengthy implementation plan has added yet another factor to manage.
PRC-005 program’s typically have many moving parts, for which one could find themselves suffering from a case of tunnel vision at times. Over the years, I have found that starting from the beginning is usually the best practice to ensure a compliant PRC-005 program. I’m not necessarily recommending reviewing every aspect of the Protection System Maintenance Program (PSMP), but routine evaluation of maintenance dates and test records is certainly recommended. How are we tracking completed and upcoming testing? Is our evidence clear and concise enough that an auditor would review without conjuring up any questions? Are we logging Unresolved Maintenance Issues (UMI) if needed? These are all great questions that could determine if the PRC-005 program sinks or swims.
To ensure we understand the Requirements of PRC-005 we must first recognize the defined terms used to structure the Standard:
- Verify — Determine that the Component is functioning correctly
- Monitor — Observe the routine in-service operation of the Component
- Test — Apply signals to a Component to observe functional performance or output behavior, or to diagnose problem
- Inspect — Examine for signs of Component failure, reduced performance or degradation
- Calibrate — Adjust the operating threshold or measurement accuracy of a measuring element to meet the intended performance requirement
While this list may not constitute a high level of training needed to decipher the intricacies of PRC-005, it gives us a launch point that can prompt questions, a drive to understand what the Facility is required to do, and maybe even how we can maintain compliance.
Whether your program is time-based, condition based, or a little bit of both, the Requirements set forth in PRC-005 are clear and simple. Test all applicable protective system equipment and ensure they are reacting and functioning in a way they are designed. By documenting the findings of the testing on a required timeline, the program that follows the detailed PSMP will prove itself compliant and relieve itself of worrisome ideas of possible violations and non-compliance findings.
…I nearly forgot why we stopped by here in the first place. If your program is still tracking the implementation plan milestones, your 12-year components are nearing their 60% and 100% compliance requirements. Mind the timeline and plan to test those protective system components a tad early to avoid any last-minute mistakes!