ATLANTA — Facility ratings, and the challenge of keeping them up to date, were a recurring theme on the second day of the North American Generator Forum’s Annual Compliance Conference, held at NERC’s headquarters, with multiple presentations on the subject from industry stakeholders.

NERC’s FAC-008-5 reliability standard, which governs facility ratings, was a frequent reference during the day’s discussions. Mike Gabriel, a co-founder of consulting firm Greybeard Compliance Services and NAGF board member who focuses on NERC compliance, walked attendees through the preparation process for an audit of the standard, reminding them that being upfront with any potential instances of noncompliance would be a major plus in the eyes of their regional entities.

“You’re trying to find what the auditors are going to find before they do it. You’ve got to beat them to the punch — give them nothing to mess with you about,” Gabriel said.

Acknowledging that performing a full walkdown of existing equipment can be daunting for even a moderately sized utility, much less a large one, Gabriel said that registered entities must nevertheless be prepared to take a critical look at their facilities and challenge all their assumptions.

“Your existing FAC-008 equipment list — you want to have that, and assume it’s not 100% accurate. If you follow what you already have, you’re not bringing any value to the table,” he said. “Do you have these nameplates already photographed or not? Do you have some other proof? Do you have design documents? Or is it just a reading on a one-line diagram somewhere?”

The reason for this level of detail is not because auditors are obtuse or rulebound, but because experience has taught industry participants — not just NERC — that design documents, no matter how detailed, quickly become irrelevant as parts are replaced through regular maintenance and repairs, Gabriel said. Improper facility ratings have become a frequent source of compliance issues across the ERO Enterprise, with penalties of over $200,000 levied against utilities in multiple regions over the last two years. (See SERC Urges Industry Effort on Facility Ratings.)

Gabriel added that entities should also be prepared to bring in outsiders to get a fresh perspective, warning that even the most conscientious internal review is vulnerable to overlooking crucial details of facilities with which they have spent years.

“Think about how the human mind works. When you drove to the airport to get here … how observant were you [of] all the details along the way, or were you on the phone listening to some music?” he said. “When you walk past your plant, it takes a lot of concentration to … really scrutinize [everything]. [If you have] that second set of eyes that you trust and you gave them free will to say anything … now you’re getting something.”

Along with Gabriel’s audit presentation, Tim Ponseti, SERC Reliability’s vice president of operations, updated attendees on the Facility Ratings Themes and Lessons Learned report that the RE released earlier this year. SERC used data from hundreds of FAC-008 violations since 2017 to identify three major themes associated with facility ratings problems, along with potential mitigation strategies for each issue.

Ponseti said that after the report’s publication in April, SERC offered it to NERC to serve as the basis for an ERO-wide analysis of facility ratings issues, to which the organization readily agreed. That broader report — which Ponseti said had “found a fourth theme that we missed” — is scheduled to be published next week.