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​​Power Generation Compliance Maturity Gap Identification and Resolution Project

Location: California   |   Client: Confidential   |   Contact: Confidential   |   Contract Value: $2.0 million

Orion Vegetation Management
Key Outcomes
  • Developed comprehensive compliance registry (blind, third-party assessment)
  • Compiled documentation requirements
  • Updated compliance tracking database and notification system
  • Identified process improvements
  • Updated standards, procedures, and training documents

Project Background

A large investor-owned utility recently adopted a compliance maturity model to address third-party and regulatory concerns addressing ongoing safe operability of its assets. A recent audit of compliance maturity against the criteria established in the model found several gaps to be addressed by the utility’s power generation division. OMS Group, LLC (OMS) staff were engaged to close the gaps and to help the utility in its journey toward operational excellence and its goal to have top decile compliance, safety, and reliability performance.

Scope

OMS staff initial engagement was to conduct a third-party independent review of compliance requirements to develop a comprehensive compliance registry for the power generation division of the utility. The work was conducted over a 12-month period and included comprehensive review of existing licenses, permits, memorandums of agreement, settlement agreements, commitments, and regulatory requirements applicable to power facility operations, maintenance, dispatch, construction, decommissioning and asset transfer for hydroelectric, fossil, and renewable fleet facilities.


OMS staff compiled a comprehensive registry of compliance requirements and assessed these compliance requirements, due dates, reporting requirements, and open actions against the existing utility compliance tracking databases.  Gaps in utility compliance records were identified and reconciled by OMS and utility SME’s.  OMS staff were engaged to update utility database records. OMS staff also compiled a comprehensive registry of utility non-regulatory commitments (e.g., contractual agreements, operating agreements, etc.).


Data gaps and inconsistencies were identified, and a gap closure plan was developed and implemented on behalf of the utility.

During development of the gap closure plan, OMS staff worked with utility SME’s, department heads and other stakeholders to assess going forward training requirements, levels of effort and staffing requirements to maintain data tracking and compliance systems. OMS staff also worked collaboratively with utility staff to not only address staffing gaps, but identified process breakdowns, efficiency improvements, and process optimizations. OMS staff assessment included evaluations of process ownership, roles, and responsibilities, and overlap in responsibility. OMS staff collaborated with utility SME’s and process owners to update utility standards, operating procedures, and training documents to reflect the clarifications and identified improvements.



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