AICPA SOC Service Organizations - Certrec

NERC Sees Discrepancies Between Documented Equipment/Facility Ratings and Actual Field Conditions – What are FAC-008 Requirements?

NERC Sees Discrepancies Between Documented Equipment/Facility Ratings
What Are NERC Reliability Standards – FAC-008?

NERC Reliability Standards – FAC-008 establishes the reliability requirements for planning and operating the North American Bulk Power System. These requirements are developed using a results-based approach that focuses on performance, risk management, and entity capabilities.

NERC Reliability Standard FAC-008 ensures that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on technically sound principles. A Facility Rating is essential for the determination of System Operating Limits.

FAC-008 requires each Transmission Owner and each Generator Owner to provide documentation for determining the Facility Ratings of its solely and jointly owned Facilities. FAC-008 is an intensive NERC standard. NERC and FERC have revised the FAC-008 standard for Transmission and Generator Owner, in order to reduce the intricacies.

Discrepancies Between Documented Equipment/Facility Ratings and Actual Field Conditions

Recent years’ audit and enforcement activities, including field verification by the regions and entities, have identified multiple instances of discrepancies between documented Equipment and/or Facility Ratings and actual field conditions. This is an extremely important issue as incorrect Facility Ratings can pose significant risk to the Bulk Electric System.

The information suggests, in general, that registered entities with strong controls and change management procedures typically have better data, that results in more accurate ratings, as compared to those entities that have not taken meaningful steps to develop strong controls, change management focus, and validated field conditions with Facility Ratings databases.

Emanated from Federal Power Act’s Section 215, NERC, in accompaniment with its six regional entities, i.e., MRO, NPCC, RF, SERC, Texas RE, and WECC, serves as the ERO Enterprise to leverage its key resources for the North American Bulk Electric SystemERO’s mission is to assure the effective and efficient reduction of risks to the reliability and security of the grid. The data provided thus far includes some significant and widespread discrepancies across the ERO Enterprise.

NERC identified design and actual field condition discrepancies based on previous reports such as Odessa Disturbance Report 2021San Fernando Disturbance Report 2020, and Eastern Interconnection Oscillation Disturbance Report 2019.

These studies provide a number of key findings from disturbance analyses, which clearly state the inconsistencies between Facility Ratings and actual field conditions.

Some of them are:
  • Insufficient implementation of NERC Reliability Guidelines
    • Regional entities were well aware of the guidance material published by NERC, but they did not adopt the guidelines;
  • Lack of performance requirements
    • NERC Reliability Standards were documented by the REs, but were enforced ineffectively;
  • Lack of performance requirements
    • Inverter-based facilities highlighted gaps in the NERC Reliability Standards;
  • Poor Solar PV Data Resolution
    • Most of the solar PV facilities were unable to provide sufficient information to the analysis teams to recommend necessary actions; and
  • Inadequate analysis.

One of the registered entities was declared responsible for serious Facility Ratings violations. The entity was found to be inconsistent with its own Facility Rating Methodology.

It failed to be compliant with Reliability Standards, and it lacked uniformity with the National Electric Safety Code. However, NERC found that the registered entities with better data facilities, equipment, robust controls, and change management procedures demonstrated accurate ratings.

Large deratings were observed so often when Facility Ratings were not carefully weighed. In some instances, equipment damages were apparent, causing unintentional outages. When Facility Ratings are not determined correctly and applied consistently for all applicable Facilities.

This can result in equipment operating beyond its capability, causing equipment damage or line sagging beyond its design, resulting in unplanned outages. It is for this reason that Facility Ratings issues were noted as one of the contributing factors to the August 2003 blackout and continues to be an ERO Area of Focus.

NERC Sees Discrepancies Between Documented Equipment/Facility Ratings and Actual Field Conditions What are FAC 008 Requirements?
FAC-008 Requirements

FAC-008 requires the registered utilities to:

  • Regularly update Facility Ratings Methodology
  • Establish strong internal controls, asset management, and equipment configuration
  • Recognize ratings-based limiting components

FAC-008 calls for ongoing compliance from Transmission Owners and Generator Owners to prevent them from Enforcement Actions in the form of penalties. NERC meted out company fines of $10 million in 2019.

Access RegSource® as your source of regulatory compliance information.

We would love to hear from you. If you have any comments on this blog, please reply below.

Disclaimer: Any opinions expressed in the blog do not necessarily reflect the opinions of Certrec. The content of this blog is meant for informational purposes only.