Florida Power & Light Co. Noncompliant with FAC-008-5 R6 and is Assessed a Penalty of $120,000

Summary:

SERC determined that Florida Power & Light Co. (FPL) was noncompliant with FAC-008-5 R6. FPL failed to have Facility Ratings for its Facilities that are consistent with the associated Facility Ratings methodology (FRM). SERC determined that this noncompliance began under FAC-009-1 R1 and spanned to FAC-008-5 R6. On February 21, 2022, SERC sent FPL an audit notification letter for an onsite audit of FAC-008-5 R1, R2, R3, and R6. SERC conducted the on-site audit from June 20, 2022 through June 24, 2022. The audit team walked down four transmission substations and identified incorrect Facility Ratings at three of the four substations. The stations with incorrect Facility Ratings were 138 kV, 230 kV, and 500 kV. To determine an initial scope of the noncompliance, SERC identified and required FPL to walk-down eight Transmission Facilities and eight Generation Facilities and report the findings to SERC. Of the eight Transmission Facilities, FPL identified one incorrect rating on a 230 kV line that resulted in a 25% derate. Of the eight Generation Facilities, FPL identified incorrect Facility Ratings at one generation station and incorrect equipment ratings or missing equipment ratings at two additional generation stations, and one with an incomplete walk-down where an outage is required to field verify current transformers. For the complete extent of condition assessment, FPL completed a walk-down of all of its Transmission Facilities and Generation Facilities. For the Transmission Facilities, FPL identified that, out of 1822 Facilities, it had 153 incorrect Facility Ratings (8.4%) that did impact the Most Limiting Element (MLE) and Facility Rating. Specifically, for the 230kV class, it had 86 incorrect Facility Ratings with one exceedance (one time exceeded). The maximum exceedance was 67 MVA on a 568 MVA line with a 25% derate. For the 230kV class of incorrect Facility Ratings, there were 32 derates ranging from 0.41%-10%; 26 derates ranging from 10.92%-19%; 25 derates ranging from 20.84%-26%; 1 derate at 37%; 1 derate at 40%; and 1 derate at 45%. For the 138kV class, it had 37 incorrect Facility Ratings and there were no exceedances of the correct Facility Ratings. For the 138kV class of incorrect Facility Ratings, there were 16 derates ranging from 1%-9%, 11 derates ranging from 12%-20%, 9 derates ranging from 20.73%-25%, and 1 derate at 48% (jumper). For the 115kV class of incorrect Facility Ratings, there were 30 incorrect Facility Ratings and there were no exceedances of the correct Facility Rating. For the 115kV class of incorrect Facility Ratings, there were 12 derates ranging from 1%-10%; 7 derates ranging from 12%-20%; 3 derates ranging from 23%-28%; 3 derates ranging from 31%-36%; 4 derates ranging from 43%-46%; and 1 derate at 93% (line – jumper/metering PT/CT). FPL found that it did not have any incorrect ratings that did not impact the MLE or Facility Rating. For the Generation Facilities, FPL has completed the walk-down assessment of all of its 180 Generation Facilities. FPL identified that it had 12 Facility derates and 3 Facility uprates. The derates ranged from 0.4%-8.65%, and the uprates were 1.5%. FPL did not exceed the correct Facility Rating in any instance. This noncompliance started on June 18, 2007, when FAC-009-1 R1 was enforceable on FPL and FPL failed to rate its Facilities in accordance with the FRM, and is scheduled to end by April 30, 2025, when FPL completes its mitigating activities to revise all incorrect element ratings and Facility Ratings identified during the walk-down assessment.

Additional Discussion:

Cause

The causes of this noncompliance were ineffective controls to manage required training, ineffective validation control and ineffective controls to prevent failure to initiate the Management of Change (MOC) process. While FPL tracked its FAC-008 General Training through its Learning Management System, it did not track completion of the FAC-008 worksheet training and as a result, FPL did not train some of the individuals that should have taken the FAC-008 worksheet training. FPL’s post construction inspection review was not documented and resulted in failures to identify some differences in construction versus design. FPL personnel failed to initiate the MOC process due to a gap in understanding of when to apply for a like-for-like change.

Disposition

SERC considered FPL’s compliance history and determined there were no relevant instances of noncompliance.

SERC awarded penalty credit for settlement because FPL agreed to settle the Alleged Violation resolved by this Agreement thereby avoiding a hearing on this matter. A willingness to resolve cases without the need for a trial-type hearing reduces the amount of time and resources that SERC, NERC, and the Commission time would otherwise expend to resolve these Alleged Violations. Additionally, it is important to promote prompt resolution of enforcement actions so that FPL can focus on mitigation and reducing risks to reliability.

SERC also awarded penalty credit for admission. FPL recognized and affirmatively accepted responsibility for its conduct by admitting to the violations resolved by the Agreement. SERC is applying mitigating credit because there is independent value in FPL accepting responsibility for its violations. A penalty of $120,000 was assessed.