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NERC CIP Program Recovery

At a Glance

Updated Documentation

Developed and updated NERC CIP documentation and trained more than 350 workers on new processes

Achieved Compliance

Helped utility achieve full compliance in the next NERC CIP regulatory audit

Facilitated Program Sustainability

Engaged more than 120 employees and facilitated long-term program sustainability

Challenge

A large electric utility had received an unfavorable audit that pointed to a significant programmatic breakdown and a lack of cultural understating of NERC CIP standards. Significant gaps existed in the organization’s roles and responsibilities to provide governance and oversight for the standards, procedures were not well maintained or did not exist, and the organization relied on manual methods to document and collect evidence. Operating and technical groups did not understand the NERC CIP standards, requirements, or the implications of not complying. Enterprise and business unit leadership were facing tight timelines to respond to audit findings and a situation where repeat issues would not be tolerated by the regulator or the board.

Process

  • Developed and updated NERC CIP documentation, including seven technical program documents, 11 new CIP procedures, and more than seven updated procedures
  • Developed more than 25 PMs and entered them into Maximo work management tool for recurring CIP requirements; allowed management visibility to oversee ongoing CIP tasks
  • Developed eight template job plans with work instructions
  • Delivered CIP technical instructor-led training at medium-impact facilities providing direct training to more than 350 workers
  • Provided initial training to compliance managers and compliance analysts

Result

  • Next NERC CIP regulatory audit contained zero findings for the business unit
  • Developed the program in a way that engaged more than 120 employees, and the entire organization (compliance, engineering, cybersecurity, and operations) was able to self-sustain the program

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