By Michael Tate, NERC Reliability Specialist
EAs with every generating station comes a great deal of responsibility. On the day to day basis, you are tasked with a large list of NERC compliance items. Everything from voltage schedule matching verification to protection system operations can end up keeping you awake at night. However, many do not know that one of the easiest Standards to maintain is also one of the most violated in the industry. In fact, FAC-008 has seen an uptick in violations across the entire Bulk Electric System (BES) in the past 3 years.
FAC-008 tends to be one of those standards we forget about once it is complete, but the Regional Enforcement Entities have noticed the memory lapse. In fact, since its conception in 2007, there have been 198 Violations found resulting in approximately $4.1 Million in penalties, majority of which were completely preventable given that FAC-008 is solely based in Static Facility Analysis. Pair this with NERC observing that, “Change management weaknesses have also led to significant violations related to Facility Ratings and maintenance of Protection System devices.” (NERC CMEP 2020, Pg12) and you get reliability entities with a heightened sense of awareness to the standard. So much so, that every Reliability Regional Entity has included FAC-008 within is 2020 CMEP, ensuring that most Generator Owner NERC Audits have this standard in scope.
The reason that Facility Ratings are so important lays in its importance in a Regional Transmission Operator’s (RTO)the calculation of Interconnection Reliability Operation Limits (IROL). In this case, IROL is defined as” A System Operating Limit that, if violated, could lead to instability, uncontrolled separation, or Cascading outages that adversely impact the reliability of the Bulk Electric System.”(NERC Glossary of Terms, Pg16) In other words, where Generating and Transmission facilities have Limiting Equipment, RTO transmission entities have calculated IROL that they must not exceed based on those GO and TO Limits. FAC-008 ensures that all facilities have an equivalent method, from generation to transmission, in how limits are calculated. So, one missed calculation or misaligned equipment nameplate could result in devastating impacts to the BES.
Not to worry, because these is a cheap and easy way to ensure you do not have a violation in your Facility ratings. Take a stroll around your plant. Part of your compliance program should include plans to review FAC-008 and the facility ratings of the plant on an annual basis. In order to successfully conduct a proper analysis, walk around your facility with your most recent One-Line diagram in hand, and verify each piece of equipment in the design to its corresponding nameplate. After the tour is over, not only will you have a deeper knowledge of your facility, but you should have double verified evidence that your facility Ratings are correct. The annual tour can also allow you to practice for an on-site inspection from a Regional Entity (RE) in the future. Remember, nothing is more impressive to an auditor than personnel that knows their facility without hesitation.
The better you understand how your Facility Ratings impact your own operation as well as those facilities around you will make you all the better NERC example for the BES. With annual verification through Nameplate Walkabouts and One Line Diagram analysis, you can gain the confidence knowing that your facility is good to go inside of its own limitations as well as your transmission limitations too. However, this is just step one of making sure your FAC-008 compliance withstands the test of time.
Tune in next time for Step Two, in which we will address proper change management, ratings methodology, universal usage of MVA units and frequently asked questions.