The North American Electric Reliability Corporation (NERC) Reliability Standard PRC-012-2 – Remedial Action Schemes will go into effect on January 1, 2021, making it mandatory and enforceable, and all applicable entities responsible for compliance with the Requirements. The purpose of the Standard is to ensure that Remedial Action Schemes (RAS) do not introduce unintentional or unacceptable reliability risks to the Bulk Electric System (BES). Applicable entities include Reliability Coordinators (RC), Planning Coordinators (PC), and RAS Entities – the Transmission Owner (TO), Generator Owner (GO), or Distribution Provider (DP) that owns all or part of a RAS.
So… Are you an applicable entity and if so, WILL YOU BE COMPLIANT ON JANUARY 1, 2021? Below are some key points to consider as the effective date of this Standard quickly approaches.
RAS Review Content, Logistics, Response, Documentation and Follow-up
Remedial Action Scheme is defined in the NERC Glossary of Terms as: A scheme designed to detect predetermined System conditions and automatically take corrective actions that may include, but are not limited to, adjusting or tripping generation (MW and Mvar), tripping load, or reconfiguring a System(s). The glossary also includes some additional information regarding a RAS that your Subject Matter Experts (SMEs) may find helpful.
PRC-012-2 includes three Attachments that are referenced in Requirements R1, R2, R9, the Process Flow Diagram, and throughout the Technical Justification sections of the Standard. The Attachments and Supplemental Material provide checklists and important guidance that will assist entities in completing their implementation of the Standard, assuring they have compiled sufficient documentation, and confirming that they have addressed each of their compliance responsibilities identified in each Requirement.
Phased-In Implementation – Assure You’re Aware of the Various Dates
Because PRC-012-2 established a new working framework between RAS-entities, Planning Coordinators, and Reliability Coordinators that involved considerable start-up effort, the effective date of the Standard was set to occur more than three years after the effective date of FERC’s final order approving the Standard. In addition, this particular Standard also has a Phased-In Implementation which means some Requirements will be effective on a later date. This table provides the various dates. Additional background information and specific details can be found in the Implementation Plan for PRC-012-2.
Retirement and Withdrawal of Various PRC Standards
The PRC-012-2 Standard was developed to consolidate previously unapproved Standards which were designated by the Commission as “fill-in-the-blank” Standards and to replace other RAS-related Standards. As you’re updating your NERC compliance program, be sure to keep this information in mind to assure you procedures and processes contain accurate instructions, information, and references.
The following Standards will be retired or withdrawn the date PRC-012-2 goes into effect:
- PRC-012-1 – Remedial Action Scheme Review Procedure – Withdrawn
- PRC-013-1 – Remedial Action Scheme Database – Withdrawn
- PRC-014-1 – Remedial Action Scheme Assessment Requested Retirements – Withdrawn
- PRC-015-1 – Remedial Action Scheme Data and Documentation – Retired
- PRC-016-1 – Remedial Action Scheme Misoperations – Retired
Evidence Retention
The PRC-012-2 Standard has identified the retention period that an entity is required to retain specific evidence to demonstrate compliance for each of the Requirements as “…since the last audit, unless directed by its Compliance Enforcement Authority to retain specific evidence for a longer period of time as part of an investigation.” Considering that PRC-012-2 is new, and entities have not yet been audited for compliance to this Standard, we recommend you retain all of your evidence through the completion of its first audit.
About PCS
Proven Compliance Solutions Inc. (PCS) provides NERC Reliability Standards compliance consulting services that cover all aspects of the Operations & Planning Standards and the Critical Infrastructure Protection Standards. Our services include audit support and preparation, compliance assessments, mock audits, gap analyses, staff training, authoring and implementation of Internal Compliance Programs, development, and implementation of reliability compliance documentation, and advising clients on reliability compliance issues. We work with the entity to develop and implement sound operational procedures that support all aspects of regulatory compliance. PCS has developed a web-based Standards Compliance Intelligence Portal (SCIP) that identifies Standards in development and upcoming Standards enforcement that is customized to each client’s needs. Industry news and events, as well as regional and provincial activities are also tracked. Our team is unique in that we have extensive expertise from both sides of the audit table, as well as in the implementation and management of NERC compliance programs. The team includes two former NERC auditors, a former WECC CIP auditor, five former compliance program managers, and a track record of excellence in Regional audits that sets us apart.
For more information on how we can assist your organization with its NERC Reliability Standards compliance needs, contact Dale Zahn at dzahn@provencompliance.com or (262) 436-4116. To learn more about Proven Compliance Solutions Inc., visit our website at www.provencompliance.com.
