AICPA SOC Service Organizations - Certrec

FAC-008 Common Questions and Answers

FAC-008 Common Questions and Answers - opt - Certrec
At a high level, what does the FAC-008 standard consist of?

FAC-008 is a NERC standard that pertains to the determination of Facility Ratings for power system equipment within the bulk electric system. This standard intends to ensure that all equipment such as generators, transformers, breakers, switches, busbars, and other components of the power system are correctly rated for their thermal and mechanical capabilities and that these ratings are accurately reflected and documented. This includes every element from the generator out to the system’s point of interconnection, including distribution and transmission components. The Facility Ratings are critical as they ensure that system operation remains within equipment thermal ratings, which in turn helps prevent equipment failure, system instability, and potential blackouts.

Why is it challenging to comply with FAC-008?

Compliance with FAC-008 can be challenging because of the extensive amount of detail required. Every piece of equipment within the bulk electric system must be accounted for and its thermal rating properly documented. Often, smaller components like current transformers or connectors between breakers and switches are overlooked, even though they play a critical role in transmitting power and have specific thermal ratings. Gathering all this information, especially for large systems with thousands of components, can be a complex and time-consuming task. Furthermore, discrepancies may arise between listed equipment ratings and actual nameplate data, making compliance efforts more difficult.

What steps should registered entities take to ensure compliance with FAC-008?

Registered entities should start by reviewing their current facility rating documentation and comparing it to system diagrams and actual field equipment. All equipment components must be accounted for and their thermal ratings properly documented based on equipment rating sheets, IEEE standards, or ANSI standards. Following the paperwork review, entities should conduct physical inspections or “walk-downs” of the facilities to verify that the documented data matches the actual field equipment. This includes cross-checking listed equipment ratings with the nameplates on the actual equipment. If discrepancies are found, they should be corrected in the facility rating documentation. These steps should be a part of an ongoing process of configuration management that ensures all changes to the system are documented and ratings are kept up to date.

What is the recommended team size for conducting these compliance activities?

Ideally, a minimum of two individuals should be involved in the compliance process. This typically involves a “preparer,” who gathers and records all the neces- sary data, and a “reviewer,” who verifies the accuracy of the data. The number of preparers may vary based on the size of the system, with larger systems potentially requiring multiple preparers to manage the workload. Having a reviewer involved provides an additional level of quality assurance, ensuring that no components are overlooked, and all ratings are correctly documented.

How frequently should registered entities perform these compliance activities?

The frequency of compliance activities should be determined based on the specific circumstances of each registered entity. However, as a general guideline, a full walk-down and review should be performed whenever significant changes are made to the system, such as the installation of new equipment. In the absence of changes, a good practice is to conduct a spot check every year or two to ensure that the facility rating documentation remains accurate and up to date. Regular reviews help identify potential discrepancies early and ensure continued compliance with the FAC-008 standard.

What are the best practices for ensuring proper change management as per FAC-008?

To ensure proper change management as per FAC-008, entities should have a robust and systematic process in place. Some industries have developed effective change management processes over the years that could serve as models. These processes include systematic tracking and updating of changes in the power generation, distribution, and transmission systems. Also, auditors have begun focusing more on whether FAC-008 requirements are being met after changes in the system, which makes change management increasingly critical for entities.

Has there been a recent significant violation of the FAC-008 standard resulting in a substantial monetary fine?

Yes, there have been cases where entities faced hefty fines because of violations of the FAC-008 standard, with one primary issue being the method used to evaluate equipment. Entities are required to adhere to a specific methodology, such as following IEEE, ANSI, or other engineered-type analyses for evaluating their equipment. In one instance, an entity claimed to follow a particular methodology, but upon inspection, it was discovered that their practices did not align with the stated method. Such discrepancies can lead to significant violations and associated fines. For example, Virginia Electric and Power Company – Power Generation Penalized $130,000 for Violation of FAC-008-3 R6.

Does the methodology for compliance with FAC-008 vary between entities, or is there a general approach that is widely applicable?

For most generators, the approach is often the same – using equipment ratings given by the manufacturer. This is typically the most straightforward method, eliminating the need for a specialized engineering firm or the use of IEEE. For transmission lines, however, the approach can vary, with different entities using unique ways to calculate aspects like thermal sag for normal operation or emergency ratings. Hence, the methodology may differ depending on the specific circumstances and equipment involved.

What role does Certrec play in FAC-008 compliance, and how it can assist registered entities?

Certrec assists registered entities with FAC-008 compliance by developing the required methodology and equipment list. This involves examining the drawings, gathering equipment information, and formulating the rating and methodology. Certrec considers all the equipment from the generator onwards, ensuring all information is correctly collated and tracked. This comprehensive service helps entities to ensure they are in full compliance with the FAC-008 standard.