FERC has accepted settlements totaling $175,000 between SERC and Ameren, along with Ameren Missouri, for violations of NERC’s FAC-009-1 and FAC-008-3 reliability standards for establishing and communicating facility ratings (NP20-19).

SERC reported the settlements in a spreadsheet Notice of Penalty on June 30. The commission indicated in a notice on Thursday that it would not review the penalties, leaving the penalties ($90,000 for Ameren and $85,000 for Ameren Missouri) intact.

Both settlements arose from a 2017 compliance audit by SERC that involved facility “walk-downs” at Ameren’s Big River and Spencer Creek facilities and Ameren Missouri’s Peno Creek and Pinckneyville facilities. During the visits, SERC’s audit team found discrepancies between the facility ratings methodology (FRM) and the established element ratings at all four facilities.

In the case of the Big River and Spencer Creek facilities, the inconsistencies did not affect the facility rating, but SERC requested additional information to get a better idea of the scope of the discrepancies. In the resulting system walk-down, Ameren found that 2,816 out of 27,330 elements at 56 of 297 transmission facilities had incorrect ratings. Five of the affected facilities were found to have experienced exceedances of the correct ratings, totaling 62 over a one-year period.

Similarly, the Peno Creek and Pinckneyville discrepancies led to a system walk-down in all of Ameren Missouri’s 63 generating facilities to check the physical components against the current system ratings. The utility found that 18 of its facilities had ratings that did not match its FRM, 10 of which had experienced exceedances in a single year — 762 exceedances in all.

SERC determined that the misratings had been in place since before June 18, 2007, when FAC-009-1 became effective. By the time the issues were discovered, the relevant standard was FAC-008-3, meaning that the discrepancies were assessed as a violation of both standards. Both Ameren and Ameren Missouri corrected their ratings, with the two companies finishing their corrections and returning to compliance in December 2018.

In both cases, the violations were determined to have posed a moderate risk and no harm was known to have occurred. Ameren and Ameren Missouri each implemented a number of mitigating measures. Ameren’s changes included the following:

• Developing and implementing a change management process to capture any element and overall facility rating changes during planned and unplanned outages;
• Hiring independent consulting firms to complete the transmission facility walk-downs;
• Communicating the results of the walk-downs to SERC on a quarterly basis in 2018; and
• Reverifying the walk-down results.

Ameren Missouri followed a more extensive mitigation that included the following steps:

• Hiring consultants to perform walk-downs at 100% of its generating facilities to verify component ratings;
• Revising its FAC-008 procedure to add a verification process for facility ratings by both the utility and an independent reviewer;
• Establishing a weekly report of all maintenance jobs involving components that might affect FAC-008-3 compliance for review;
• Establishing a point-of-reporting responsibility for all generating units, to be documented in the FAC-008 program documents;
• Committing to conduct sample audits at three randomly selected energy centers every three years to ensure FAC-008-3 compliance; and
• Completing an additional walk-down of all 63 generation facilities in the first quarter of 2020.

SERC awarded mitigating credit to Ameren and Ameren Missouri for their cooperation and settlement of the enforcement action and determined that there were no previous incidents of noncompliance to warrant increasing the penalty.