The ERO Enterprise continued its campaign against facility rating violations last week with the publication of a new report that builds on the work of NERC and the regional entities over the last several years.

The report, “ERO Enterprise Themes and Best Practices for Sustaining Accurate Facility Ratings,” aims to spread awareness among registered entities about the importance of maintaining accurate ratings of the equipment at their facilities. In the introduction, the authors note that “incorrect facility ratings can result in operating in an unknown state, uncontrolled widespread service outages and fires,” and can also make modeling the grid more difficult while hindering the planning of future expansions to the bulk power system.

Many recent penalties levied on utilities by their REs have involved violations of NERC’s reliability standards facility ratings. Just last month FERC approved a $105,000 penalty that the Texas Reliability Entity assessed against the Buffalo Gap Wind Farm because the rating for the facility did not match the utility’s documents. (See FERC Approves $105K Penalty for Texas Wind Facility Misratings.) So far this year, facility rating violations have accounted for $1.2 million in FERC-approved penalties.

4 Key Themes

NERC and the REs based their report on data that they have collected during their outreach and education efforts, as well as compliance monitoring and enforcement activities. They identified three common themes across the infringements involving inaccurate facility ratings.

First is an entity’s lack of awareness regarding the state of its equipment. This can include failure to adequately document or maintain an accurate equipment inventory, failure to understand the current carrying series equipment within its electrical system or an ineffective facility ratings validation program.

Lack of awareness can cause misratings to “go undetected for long durations, thereby potentially posing a greater risk to the reliability and security of the BPS.” The report said it may become a factor when an entity’s facility ratings program lacks internal controls for verifying and validating equipment in the field, instead relying on ratings provided by the manufacturer, or outdated diagrams and drawings. The authors recommended that entities “remain vigilant … and never assume that facility ratings issues do not exist on their systems.”

The second theme is inadequate asset and data management. In this context, asset management means the identification, management and tracking of physical facility ratings assets, while data management refers to the collection, validation and storage of data associated with ratings. Data may be spread across various locations or business groups within an entity, and moved back and forth as part of normal operations.

Failures related to data management include entities consolidating equipment in a database instead of listing it individually, or setting up programs that “do not identify and account for all necessary pieces of equipment or the equipment’s ownership in the field when determining a facility rating.”

In one instance, a transmission owner found two bundled transmission line conductors transitioned to a single conductor outside a station, wired to a switch using a single conductor because of physical constraints of the system. The utility “had situations where it failed to consider the switch configuration” and did not realize that the switch was the most limiting element of the facility.

The next identified theme is inadequate change management, involving failures by entities to document changes to equipment in the field or update their ratings documents to reflect newly installed or altered equipment. The ERO documented multiple instances of inadequate change management leading to inaccurate facility ratings, such as a generator and transmission owner replacing a transformer with a new piece of equipment with a higher rating, meaning the transformer is no longer the most limiting element, but not updating the facility’s rating.

According to the authors, failing to track, document and communicate all field changes creates “an increased risk of using inaccurate facility ratings.” To avoid this, utilities should implement strong change management processes that include:

• requirements for data entry verification by qualified personnel;
• a clear approval process prior to a change being implemented;
• notifications to update equipment inventory after a change is implemented;
• confirmation that the change was completed as planned;
• validation through periodic reviews; and
• checklists to verify that all necessary follow-up actions are taken after a change.

Finally, the fourth theme involves inconsistent development and application of facility ratings methodologies (FRM), referring to the methodology that each registered entity is required to have for determining facility ratings of its solely and jointly owned facilities.

An entity’s FRM can draw on many inputs, including manufacturer’s nameplates, engineering evaluations, testing or performance history, and physical or mechanical factors that might restrict a piece of equipment’s performance. However, the ERO said it has observed multiple issues in this regard, such as an entity considering only the electrical elements of a facility and failing to account for mechanical limitations. In addition, many entities fail to identify the next most limiting element in a facility, meaning that when the most limiting element is removed, they cannot quickly update the rating.

The report recommended that entities “strive to use a single consistent methodology and apply the same criteria when rating like components of a facility rather than using a mix of options.” While deviations from a single FRM may be inevitable, utilities should take care to minimize these events while ensuring that these deviations are “justified, consistently applied [and] well documented, and [that they minimize] inconsistent facility ratings.”

SERC Release Formed Report’s Basis

The ERO’s report is similar to a document released earlier this year by SERC Reliability, “Facility Ratings Themes and Lessons Learned,” which touched on similar points and even identified the same themes, with the exception of the fourth.

While the ERO-wide report does not explicitly mention SERC’s report, Tim Ponseti — the RE’s vice president of operations — said at the North American Generator Forum’s Annual Compliance Conference earlier this month that SERC had submitted its report to NERC to serve as the basis for a broader analysis. (See NAGF Attendees Discuss Facility Ratings Challenges.) He also credited the ERO with finding “a fourth theme that we missed” — likely referring to the inconsistencies in FRM methodologies.