Establishing accurate facility ratings is a significant challenge both in Texas and across the ERO Enterprise, according to participants in a webinar hosted by the Texas Reliability Entity on Thursday.

The webinar, part of the regional entity’s regular Talk with Texas RE series, was focused on the FAC-008 series of reliability standards, the most recent of which, FAC-008-5 (Facility ratings), took effect last October. Violations of the FAC-008 family are frequent both across the ERO Enterprise and in Texas RE; for example, last year the RE assessed a $192,000 penalty against Oncor for infringing the standard. (See FERC Approves $536K in Penalties from WECC, Texas RE.)

“It’s a pretty significant opportunity, [and] a pretty significant risk in this interconnection, to get the proper ratings out there for ERCOT to make the right decisions [and] for you to make the right decisions, and so we need to have reliable operations,” said Curtis Crews, Texas RE’s director of operations and procedures compliance and risk assessment.

A major focus of the webinar was FAC-008-5’s requirement that registered entities establish a “documented methodology for determining facility ratings” of relevant equipment, or facility ratings methodology (FRM). The lack of an adequate FRM is a common cause of FAC-008 violations; utilities may also face penalties for having a methodology but not following it, as in the case of a settlement between WECC and Arizona’s Salt River Project approved by FERC last month. (See NERC Hits SPP, SRP for $406K in Penalties.)

Crews also emphasized that even with a suitable FRM, it is not enough for utilities to rate their facilities once. He said registered entities should review their equipment regularly because repairs and upgrades can introduce new equipment that changes the overall rating for the facility. He warned that utilities “don’t want to wait for me to do that.”

“Texas RE shouldn’t be the one that provides you that periodic review … because if we find something, we’d have to report it, and there have been quite a few facility ratings non-compliances over the last several years,” Crews said.

To help attendees understand how Texas RE assesses a utility’s approach to ratings, Crews shared a list of evidence that auditors look for during their reviews. In addition to a detailed FRM, the RE aims to verify the results against the utility’s facility ratings database using manufacturer specifications and nameplate photos, one-lines and elevation drawings, and any other information that may help to independently establish the rating.

The presentation also contained a list of issues commonly identified during audits, including change-management process gaps — that is, failure to make sure that changes to field equipment are reflected in the ratings database — or omitting an element from the FRM. Crews acknowledged the latter error “doesn’t happen too often, but it has happened across the ERO Enterprise.”

Other issues include failure to maintain the one-line and elevation drawings, or inconsistencies between different records containing the same drawings; failure to account for jointly owned facilities; insufficient processes for keeping track of series elements; and lack of clarity in documentation.

In addition to technical evidence, auditors may look for indications of lax culture at the entity. These could be lifting language directly from the standard to use in the FRM with no modification for the case at hand, or not being able to demonstrate consistent application of the FRM in practice. Another sign that an entity has not done a thorough job is the use of the same ratings for normal and emergency situations.

Crews emphasized that while REs sometimes must penalize utilities as a result of compliance audits, their goal is to help build a reliable grid, rather than to punish wrongdoers.

“That is part of our role, to help ensure reliable operations through effective compliance monitoring, and I think that’s the heart” of what Texas RE does, Crews said. “I used to be at a registered entity, so I understand the ramifications of an audit, and I understand the implications of trying to operate in a reliable situation, given the complex issues like facility ratings.”