Proven Compliance Solutions Inc. (PCS) monitors and tracks FERC, NERC and Regional activities on a daily basis, including violations and industry discussions. Along with this, we also observe and take note of auditor activities when assisting our clients with their compliance audits. One of the NERC Reliability Standards that continues to be a focus of audits is FAC-008-3 – Facility Ratings. NERC violation tracking shows us that the number of FAC-008 violations has trended downward in recent years; however, because Facility Ratings are fundamental inputs to accurate planning and reliable operations, and because violations are still occurring, NERC continues to closely audit FAC-008-3 requirements.
During recent years, NERC has increased their scrutiny of Facility Ratings to better verify Registered Entities are accurately identifying and rating their BES elements. As a part of audit activities, NERC and/or Regional auditors across North America are now routinely including a physical walkdown of selected facilities (substations and generators) in their on-site audit processes.
What are auditors looking to verify? The auditors are trying to verify that every single element in series in the Facility or Circuit is documented accurately in the Registered Entities’ Facility Rating processes. That includes every line, jumper, bus, breaker, transformer, disconnect or other element. What are auditors finding? Typical findings are connectors that may not be listed or jumpers, busses or lines that may be listed incorrectly.
How can a Registered Entity be better prepared and ensure their Facility Ratings are accurately documented? PCS offers the following suggestions to help accomplish this:
Develop a good Change Management process that includes Facility Ratings reviews and communications for Facility maintenance activities.
Review select Facility Ratings on a periodic basis.
Conduct spot walkdowns of Facilities with trained personnel.
When conducting Mock Audits or Compliance Assessments (internally or with a third party), include a Facility walkdown as a part of the FAC-008-3 assessment activities.
In addition to potential Facility walkdowns, NERC and the Regions are asking questions to better ensure Facility Ratings are consistent for jointly-owned Facilities. As a Registered Entity, you may believe your responsibility for Facility Ratings end at the Point of Interconnection with the neighboring Registered Entity. However, NERC defines Facility as, “A set of electrical equipment that operates as a single Bulk Electric System Element.” If Entity A owns a breaker on one end of a line and Entity B owns the line and breaker on the other end of the line, NERC may consider both breakers and the line to be a jointly-owned Facility. In that situation, both Entities need to coordinate ratings to ensure consistency, and be able to demonstrate consistent ratings in an audit.
The PCS team has extensive experience in assessing and developing Facility Rating programs, conducting compliance audits and reviews, developing Controls, and providing site walkdowns, and providing feedback for improvements. If you have questions or would like to discuss how to strengthen your Facility Rating program, please contact our Marketing Director, Dale Zahn, at dzahn@provencompliance.com or at 262.436.4116.
