NERC FFT Reports: Reliability Standard FAC-008-1 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard FAC-008-1

NERC FFT Reports: Reliability Standard FAC-008-1

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This page contains the FFT (Find, Fix and Track) summaries. Click here to read the NOP (Notice of Penalty)/ACP (Administrative Citation of Penalty) summaries.

Cambria CoGen Company (CCC), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: ReliabilityFirst

Issue: As a result of a compliance audit conducted between January 23, 2012 and February 3, 2012, ReliabilityFirst determined that CCC violated FAC-008-1 R1 for failing to document a methodology to determine Facility Ratings for its 115 kV transmission line that interconnects CCC’s generator facility with Pennsylvania Electric Company’s (PENELEC’s) substation. CCC had an agreement to supply PENELEC with power until March 2011.

Finding: ReliabilityFirst determined that this issue posed only a minimal risk to the reliability of the BPS for two reasons. First, the risk to the BPS was mitigated because CCC’s 115 kV transmission line is not the most limiting component at the CCC generating facility. Instead, the facility’s most limiting component is its turbine gearbox and generator. As such, CCC’s generator would have tripped offline due to exceeding the maximum capacity of the turbine gearbox before exceeding the capability of its 115 kV line. Second, in the generator’s 21 years of operation, no records indicate that it has ever been limited by the 115 kV line or that it was forced to trip off line or separate from the BPS due to failure of the 115 kV line.

City of Columbia, MO (CWLD), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SERC

Issue: CWLD, a TO, self-reported that while conducting an internal audit in preparation for a scheduled SERC audit it found its Facility Rating Methodology (FRM) failed to address current transformers (CTs) integrated into circuit breakers in violation of FAC-008-1 R1. SERC confirmed the findings in the self-report, and upon further review of the FRM in effect during the period in question, SERC found the FRM also did not address shunt compensation devices.

Finding: The issue was found to pose a minimal risk to BPS reliability. First, CWLD does not own any shunt compensations devices and they would not have been a limiting device. Second, once the CTs were factored into the Facility Ratings, the lowered ratings did not warrant changes to transmission plans nor did they impact daily grid operations. Third, CWLD is a small system and is not involved with BPS networked energy transfers. SERC determined the violation warranted FFT treatment due to AER’s mitigation measures and the level of BPS risk involved.

City of Gardner (Gardner), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SPP

Issue: SPP conducted a Compliance Audit of Gardner in June 2011 and found that Gardner, as a TO, violated R1 of FAC-008-1, in that Gardner had no Facility Ratings Methodology (FRM) from 2007-2010 and in that Gardner's FRM from 2010-2011 had no ratings of its current transformers (CTs).

Finding: SPP found that this issue posed a minimal risk to the reliability of the bulk power system, for Gardner, with a peak load of 39.6 MW, 3.6 miles of 161 kV transmission line, two 161 kV interconnections with its TOP at Moonlight substation, and no Bulk Electric System generation, does not have much impact on flows through the Moonlight substation, and subsequently does not have much impact on the bulk power system in the vicinity. The TOP jointly owns the Moonlight Substation with Gardner and is informed of the Gardner facilities' ratings for future planning.

Eagle Point Power Generation, LLC (Eagle Point), Docket No. RC13-10, June 27, 2013

Reliability Standard: FAC-008-1

Requirement: R1; R2

Region: RFC

Issue: Eagle Point, as a GO, self-reported to RFC that it had issues with FAC-008-1 R1 and R2. Regarding R1, RFC found that Eagle Point lacked certain items in its Facility Ratings methodology, including: a statement that a Facility Rating will equal the most limiting applicable equipment rating of the equipment that comprises that facility; certain equipment required by the Standard (relay protective devices, terminal equipment, and series and shunt compensation devices); and the source of the Facility Ratings. Regarding R2, Eagle Point was unable to provide its TOP with a complete Facility Ratings methodology document upon request because it was still in the midst of determining whether its December 19, 2011 Facility Ratings methodology was accurate.

Finding: RFC determined that the issues posed a minimal risk to the reliability of the BPS. Regarding R1, RFC found that the steam turbine generator has been and continues to be the most limiting element of the Facility. In addition, to the best of Eagle Point’s knowledge, the R2 issue was an isolated incident as no other entity had previously requested its Facility Ratings Methodology, and when Eagle Point did eventually provide the TOP with the methodology document as requested, the TOP indicated it was no longer necessary. This reduces the chance that the issue would have had a reliability impact.

Eastman Cogeneration Limited Partnership, Docket No. RC12-10 (March 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SPP

Issue: During a compliance audit conducted during June 2010, SPP found that the Facility Rating Methodology (Method) in use by Eastman since May 2010 did not include the scope of equipment making up its generating facilities so that the most limiting element could be determined and to develop a Facility Rating. Also, the Method did not set forth how to determine ratings by using manufacturer ratings, design criteria and operation limitations. For the time period prior to May 2010, Eastman could not show that it had any Method in place.

Finding: SPP found the violation constituted a minimal risk to BPS reliability. SPP noted that even though the Method used by Eastman did not initially identify the most limiting element of its generation facility, the generating capacity of the cogeneration facility was determined through use of a computer model of the facility. Once Eastman revised its Method to comply with the Standard, no changes needed to be made to the existing computer model, which identified the facility generator as the most limiting element.

Electric Energy, Inc. (EEI), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SERC

Issue: In August, 2011, the SERC Audit Team found that EEI, in its role as a TO, failed to include series and shunt compensation devices within the scope of its Facility Ratings Methodology (FRM).

Finding: SERC deemed the issue to pose minimal risk to BPS reliability EEI considered series and shunt compensation devices even though it did not document the information; EEI developed and used a Facility Rating for the series reactor using its nameplate rating; and after documenting series and shunt compensation devices in its FRM, EEI's rating for the series reactor did not change and the most limiting device did not change.

Entergy Nuclear Palisades, LLC (ENP), Docket No. RC13-8, April 30, 2013

Reliability Standard: FAC-008-1

Requirement: 1; 1.2

Region: ReliabilityFirst Corporation (RFC)

Issue: While conducting a Compliance Audit in November 2011, RFC found that ENP, a GO, had two issues with its Facility Rating Methodology. First, it did not include the procedure used to determine its Facility Ratings for relay protective devices; and second, it did not include Normal and Emergency Ratings for relay protective devices.

Finding: The violation was deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because the relay protective devices were not the most limiting element of the facility. In addition, ENP could show that current and potential transformers used to calculate Facility Ratings were appropriately sized for the related device.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: FRCC

Issue: During a compliance audit, FRCC found that FFT Entity had not incorporated the complete scope of its equipment for relay protective devices, terminal equipment, and series and shunt compensation devices, ambient conditions, operating limitations and other required assumptions on the scope of equipment in its transmission Facility Ratings Methodology.

Finding: FRCC found that this issue constituted only a minimal risk to BPS reliability since FFT Entity was operating its equipment according to the manufacturer’s specifications. In addition, even after FFT Entity updated its Facility Ratings Methodology, its Facility Ratings did not change.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SERC

Issue: During a compliance audit SERCaudit,rmined FFT Entity violated R1 because it did not address series and shunt compensation devices in its FRM.

Finding: SERC found that this issue constituted only a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because FFT Entity’s FRM was designed to reflect the most limiting element, and FRM never owned series and shunt compensation devices.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SPP

Issue: During an audit, SPP found that FFT Entity did not incorporate its protective relays, relay protective devices and instrument transformers in its Facility Ratings Methodology.

Finding: SPP found that this issue constituted only a minimal risk to BPS reliability since FFT Entity’s relay protective devices and instrument transformers were not the limiting element in the design of the generation facility and did not have an impact on the capacity rating of FFT Entity’s generation facility.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: TRE

Issue: During an audit, TRE found that FFT Entity did not possess a Facility Ratings Methodology for the entire time the Reliability Standards have been in effect.

Finding: TRE found that this issue constituted only a minimal risk to BPS reliability since FFT Entity used the regional requirements to determine its Facility Ratings and was providing those ratings to its Reliability Coordinator.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1/1.2/1.3

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity did not have sufficient documentation for its Facility Ratings Methodology showing that its scope of equipment included protective devices and terminal equipment, as well as normal and emergency ratings for the relay protective devices. FFT Entity also did not have proper documentation covering the equipment manufacturers for the relay protective devices and terminal equipment, ambient conditions, operating limitations, and other required assumptions for generators, transmission conductors, transformers, relay protective devices, and terminal equipment.

Finding: FRCC found that this issue constituted only a minimal risk to BPS reliability since FFT Entity’s Facility Ratings were established when the facility was being designed. FFT Entity was also operating its equipment according to the manufacturer’s specifications and, even since the Facility Ratings Methodology was updated, the Facility Ratings have not changed.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1.3

Region: FRCC

Issue: FFT Entity self-reported that it did not have sufficient documentation to show that it had included ambient conditions for relay protective devices and terminal equipment, operating conditions for transmission conductors, terminal equipment and protective relay devices, and other required assumptions for transmission conductors, terminal equipment and protective relay devices in its Facility Ratings Methodology.

Finding: FRCC found that this issue constituted only a minimal risk to BPS reliability since FFT Entity was operating its equipment according to the manufacturer’s specifications.

Find, Fix and Track Entity, Docket No. RC11-6 (September 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R2

Region: SERC

Issue: Following a self-report, SERC determined FFT Entity failed to make its Facility Ratings Methodology available for inspection and technical review by the TP within 15 business days of receipt of a request as a required.

Finding: SERC found that this issue constituted only a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because FFT Entity had a Facility Ratings Methodology that was provided to the TP 6 days after the 15-day deadline.

Find, Fix and Track Entity, FERC Docket No. RC12-1 (October 31, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity, for 17 months, did not properly incorporate into its Facility Ratings Methodology the design criteria, ambient conditions, operating limitations, and other required assumptions for its transformers, protective relay devices, breakers and switches.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity was operating its equipment according to the manufacturer and design specifications. In addition, the relay devices, breakers and switches were not the limiting factor.

Find, Fix and Track Entity, FERC Docket No. RC12-1 (October 31, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: FRCC

Issue: FFT Entity self-reported that, for 29 months, it did not incorporate into its Facility Ratings Methodology, as required, a statement about the most limiting factor, the manufacturer’s ratings, the ambient conditions, the operating limitations, and other required assumptions.

Finding: FRCC found that the issue constituted only a minimal risk to BPS reliability since FFT Entity was operating its equipment according to the manufacturer and design specifications. In addition, FFT Entity is a waste-to-energy facility that has less than 75 MW of capacity and is only connected to the BPS at 138 kV.

Find, Fix, Track and Report, Docket No. RC12-2 (November 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SERC

Issue: FFT Entity self-reported that it did not have a documented Facility Ratings Methodology (FRM) from its date of registration, until approximately one month later.

Finding: SERC staff determined that the issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the bulk power system because: FFT Entity identified the generator as the most limiting element prior to documenting its FRM, Normal and Emergency ratings were included for some of the equipment, and FFT Entity does not own series or shunt compensation devices.

Find, Fix and Track Entity, Docket No. RC12-6 (December 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SERC

Issue: During an audit, it was discovered that the Facility Rating Methodology (FRM) used by FFT Entity did not address series and shunt compensation devices. The FRM in place states that FFT Entity has an agreement with the utility to use that utility’s procedure, which SERC found to be compliant with FAC-008-1. SERC stated that upon the effectiveness of that document, FFT Entity was in compliance with the Standard. The auditors further discovered that the previous FRM in use by FFT Entity only addressed the generator, which is the limiting element, leaving the scope of equipment or normal and emergency ratings unaddressed causing a lapse in compliance for FAC-008.

Finding: SERC staff found the issue constituted a minimal risk to BPS reliability because both FRMs were created to show the most limiting element, the generator. Further, FFT Entity has no transmission lines of its own nor does it own series or shunt compensation devices.

Find, Fix and Track Entity, Docket No. RC12-6 (December 30, 2011)

Reliability Standard: FAC-008-1

Requirement: R1/1.2/1.2.2

Region: ReliabilityFirst

Issue: During a compliance audit, FFT Entity was found to be in violation of the Standard because its Facility Ratings document is also its Facility Ratings Methodology document, which includes the available methods used when rating equipment; but, FFT Entity did not to designate which rating method was in use when rating its Facilities, which is required by FAC-008-1 R1.2. Also, FFT Entity did not address Emergency Ratings as required by FAC-008-1 R1.2.2.

Finding: ReliabilityFirst found the issue constituted a minimal risk to BPS reliability because FFT Entity developed Facility Ratings for its BPS facilities and included the available methods for coming to such Ratings. FFT Entity’s Facility Ratings Methodology included the following: “the scope of Ratings addressed shall include, as a minimum, Normal and Emergency Ratings, where applicable,” but it did not specifically state that Normal and Emergency Ratings are the same. In addition, FFT Entity’s Facility Ratings did not change when it revised its Facility Ratings Methodology.

Find, Fix and Track Entity, Docket No. RC12-7-000 (January 31, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: ReliabilityFirst

Issue: During a compliance audit, ReliabilityFirst discovered that FFT Entity’s Facility Ratings Methodology failed to include all relevant technology.

Finding: This issue posed only a minimal risk to the reliability of the BPS because FFT Entity’s failure to include a Facility Rating for relay protective devices did not limit the generation output of FFT Entity’s system. Wind generating facilities are designed so that the wind turbine generators constitute the most limiting element. As such, although FFT Entity failed to include a Facility Rating for its relay protective devices, the device that would limit the amount of generation remained the same. The relay protective devices on the wind turbine generators were designed to safely withstand the amount of generation the system is capable of producing.

Find, Fix and Track Entity, Docket No. RC12-7-000 (January 31, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: ReliabilityFirst

Issue: During a compliance audit of FFT Entity’s corporate affiliate, ReliabilityFirst discovered the corporate affiliate had an issue with FAC-008-1 R1 in that its Facility Ratings Methodology included only relay settings for relay protective devices. In light of this finding, other corporate affiliates, including the instant FFT Entity, conducted self-certifications to determine if they too were in violation of FAC-008-1 R1. FFT Entity self-certified to ReliabilityFirst that it was in violation of the Standard because it utilized its corporate affiliate’s incomplete Facility Ratings Methodology.

Finding: This issue posed only a minimal risk to the reliability of the BPS because FFT Entity’s failure to include a Facility Rating for relay protective devices did not limit the generation output of FFT Entity’s system. Wind generating facilities are designed so that the wind turbine generators constitute the most limiting element. As such, although FFT Entity, in adopting its corporate affiliate’s Facility Ratings Methodology, failed to include a Facility Rating for its relay protective devices, the device that would limit the amount of generation remained the same. The relay protective devices on the wind turbine generators were designed to safely withstand the amount of generation the system is capable of producing.

Find, Fix and Track Entity, Docket No. RC12-7-000 (January 31, 2012)

Reliability Standard: FAC-008-1

Requirement: R1; R1.2.1

Region: SPP RE

Issue: During a compliance audit, SPP RE determined that FFT Entity violated FAC-008-1 R1 because FFT Entity’s Facility Rating Methodology did not properly specify a method for rating the equipment comprising the facility. This equipment includes the generators, transmission conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices.

Finding: The issue posed only a minimal risk to the reliability of the BPS because FFT Entity determined the rating of its generation facilities by performing a capacity test in accordance with the procedures established by SPP RE’s Pool Criteria. Because FFT Entity’s capacity tests provided an accurate capacity rating, there is no material difference between the generation facility capacity determination before and after the remedy of this issue.

Find, Fix and Track Entity, FERC Docket No. RC12-8 (February 29, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: RFC

Issue: FFT Entity self-reported that while it identified its gas turbine generators as its most limiting equipment, it did not review its associated electrical system as required. FFT Entity also did not timely establish a documented Facility Ratings Methodology or initially include terminal equipment in its Facility Ratings Methodology.

Finding: RFC found that this issue constituted only a minimal risk to the BPS since FFT Entity had identified its gas turbines as the most limiting element at the facility and had developed its Facility Ratings accordingly. After FFT Entity had rated all of the relevant equipment in its facility, it found that it had correctly determined the gas turbines to be the most limiting element.

Fowler Ridge Wind Farm LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1/1.2.1

Region: RFC

Issue: During a compliance audit, RFC found that Fowler Ridge Wind Farm LLC (“Fowler Ridge”), as a GO, had not included its terminal equipment in its Facility Ratings Methodology as required.

Finding: RFC found that this issue constituted only a minimal risk to the BPS. Even after Fowler Ridge updated its Facility Ratings methodology, the most limiting element remained the same since none of the equipment in Fowler Ridge’s junction switchyard (such as the terminal equipment) was designed to be the most limiting element. In addition, Fowler Ridge has never de-rated a facility.

Fowler Ridge II Wind Farm LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1/1.2.1

Region: RFC

Issue: During a compliance audit, RFC found that Fowler Ridge II Wind Farm LLC (“Fowler Ridge II”), as a GO, had not included its terminal equipment in its Facility Ratings Methodology as required.

Finding: RFC found that this issue constituted only a minimal risk to the BPS. Even after Fowler Ridge II updated its Facility Ratings methodology, the most limiting element remained the same since none of the equipment in Fowler Ridge II’s junction switchyard (such as the terminal equipment) was designed to be the most limiting element. In addition, Fowler Ridge II has never de-rated a facility.

Fowler Ridge III Wind Farm LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1/1.2.1

Region: RFC

Issue: During a compliance audit, RFC found that Fowler Ridge III Wind Farm LLC (“Fowler Ridge II”), as a GO, had not included its terminal equipment in its Facility Ratings Methodology as required.

Finding: RFC found that this issue constituted only a minimal risk to the BPS. Even after Fowler Ridge III updated its Facility Ratings methodology, the most limiting element remained the same since none of the equipment in Fowler Ridge III’s junction switchyard (such as the terminal equipment) was designed to be the most limiting element. In addition, Fowler Ridge III has never de-rated a facility.

Independence Power & Light (Independence, Missouri) (INDN), Docket No. RC12-14 (July 30, 2012)

Reliability Standard: FAC-008-1

Requirement: 1/1.2.1

Region: SPP RE

Issue: While conducting a Compliance Audit in March 2010, SPP RE audit staff found that the Facility Ratings Methodology (FRM) used by INDN, a GO, did not identify all of INDN’s generation facility equipment.

Finding: The issue was deemed by SPP RE to pose minimal risk to BPS reliability because the FRM used by INDN was complete with respect to its transmission components, but the requirements for generator Ratings were lacking. SPP RE found that capacity testing to determine capacity ratings give a better rating than ratings established using other considerations. In addition, SPP RE considered that INDN is only a 315 MW facility which lessened any risk that the issue posed and also had a transmission compliant FRM.

Lafayette Utilities System (LUS), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SPP

Issue: After submitting a self-report and undergoing a compliance audit, it was determined that LUS, in its roles as GO and TO, had not included relay protective devices in its Facility Ratings Methodology (FRM) for its generator and transmission facilities. The Audit Team also found that LUS' FRM for establishing the Facility Rating for its generating facilities did not specifically reference the spreadsheet by which LAFA determines generator Ratings; did not clearly identify the methodology by which bus Ratings were determined; did not include Normal and Emergency Ratings; and did not clearly identify the method for determining Normal and Emergency Ratings.

Finding: SPP found the issue posed minimal risk to BPS reliability. Even though LAFA did not properly record its FRM and include protective relays in its FRM analysis, the Facility Ratings established by LAFA for its transmission and generation facilities were consistent with the actual Ratings of the facilities and no new limiting elements were identified. As such, the changes made to LAFA's FRM in response to this instance of noncompliance did not result in any changes to the Ratings of LAFA's transmission and generating facilities. The Emergency Ratings for LAFA's generating facilities are the same as its Normal Rating of the facilities, further lessening the risk to the BPS.

Lee County Resource Recovery (LCR), Docket No. RC13-8, April 30, 2013

Reliability Standard: FAC-008-1

Requirement: 1/1.2.1

Region: FRCC

Issue: While conducting a Compliance Audit, FRCC found that LCR, a GO, could not show that all terminal equipment, specifically a 52-L2 circuit breaker, had been included on its Facility Ratings Methodology used to calculate its Facility Rating.

Finding: The violation was deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because the missing item was not the most limiting element. In addition, LCR is a small facility, 48 MW on a 138kV radial line, and was operating according to manufacturer’s specifications.

Louisiana Generating, LLC (LaGen), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SERC

Issue: The SERC audit team found that LaGen, as a GO, did not have an established Facility Ratings Methodology (FRM) for generation facilities for the period June 18, 2007 and December 31, 2008. In particular, early versions of LaGen’s FRM did not address series and shunt compensation devices for the generation facilities. SERC’s review of LaGen’s role as a TO found no issues of non-compliance.

Finding: The issue was found to pose a minimal risk to BPS reliability because LaGen’s 2009 FRM was compliant but for the missing information on series and shunt compensation devices. And, LaGen owns none of the relevant devices. Early versions of the FRM identified the generator as the most limiting element. LaGen had provided all generation and transmission bus data to its transmission providers in 2007 for use in models and studies.

LSP University Park, LLC (LSP University Park), Docket No. RC13-10, June 27, 2013

Reliability Standard: FAC-008-1

Requirement: R1; R1.2

Region: RFC

Issue: LSP University Park, as a GO, self-reported to RFC that it had an issue with FAC-008-1 R1 after finding that due to an administrative oversight, LSP had not included all required elements, as well as Normal and Emergency ratings, in its Facility Ratings Methodology, specifically, LSP had not included its transmission conductors, transformers, relay protective devices, terminal equipment, and series and shunt compensation devices.

Finding: RFC determined that the issues posed a minimal risk to the reliability of the BPS because none of the GO’s generators could exceed the limitations of the most limiting element, which is the generator step-up transformer, and because peak generation for the facility is below the limits established by both the original and revised ratings. In addition, the GO’s Facility Ratings Methodology considers Normal and Emergency ratings to be equal.

Northampton Generating Company ("Northampton"), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: FAC-008-1

Requirement: 1; 1.2

Region: RFC

Issue: During an audit, RFCt discovered that, as a GO, Northampton's documented Facility Ratings Methodology did not contain a specific method for rating current sensing devices, or current transformers (per R1). The documented methodology stated that the ratings for current transformers (CTs) would meet or exceed full load current. In August of 2010, Northampton switched operating companies to NAES Corporation, and, as a result, Northampton modified its NERC-related programs, including the Facility Ratings Methodology.

Finding: RFC found the issue posed a minimal risk to the reliability of the BPS because Northampton provided commissioning test data for CTs, which demonstrated ratings for the CTs as issue existed and mitigated the risk. Furthermore, the ratings were consistent with the Facility Ratings Methodology, and Northampton implemented their Facility Ratings Methodology for the duration of the period in question, even though the documentation lacked specificity. In addition, Northampton's generators were designed so that the CTs would not limit the rating of the related element or facility.

Northern Indiana Public Service Company (NIPSCO), Docket No. RC12-16-000 (September 28, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: ReliabilityFirst

Issue: Between December 6 and December 13, 2011, ReliabilityFirst conducted a compliance audit of NIPSCO finding that the company, operating as a GO, violated FAC-008-1 R1 because it did not document the methodology it used to determine the Facility Ratings for current transformers (CTs), a relay protective device, on its Baily Generating Unit #7. Specifically, ReliabilityFirst determined NIPSCO did not have a single document describing the methodologies used to determine ratings for its generators; instead, NIPSCO relied on separate documents for determining the Facility Ratings for each generator. The document pertaining to Bailey Generating Unit #7, however, failed to state a facility rating methodology.

Finding: ReliabilityFirst determined this issue posed only a minimal risk to the reliability of the BPS because it is an isolated documentation error. NIPSCO did have a Facility Rating for its CTs at Unit #7 during the duration of the issue, but failed to document the process it used to determine that rating. Further, NIPSCO based the Facility Ratings for all generating units, including Unit #7, on manufacturer's recommendations and nameplate ratings.

PowerSmith Cogeneration Project, LP (PowerSmith), Docket No. RC13-7-000 (March 27, 2013)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SPP RE

Issue: PowerSmith submitted a self-report in July 2011 alerting SPP RE to a compliance issue with FAC-008-1 in that PowerSmith, a registered GO, had no documented system used to establish Facility Ratings for its generation facility.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk because even though PowerSmith did not have the required documentation, capacity tests had been performed pursuant to SPP standards and the results provided to its TOP. Also, the compliance issue was found to be only eight months, and net output of the facility is only 120 MW.

PPL - Lower Mount Bethel Energy, LLC (LMBE), Docket No. RC12-16-000 (September 28, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: ReliabilityFirst

Issue: Between September 12 and September 30, 2011, ReliabilityFirst conducted a compliance audit of LMBE and its affiliate entity, PPL Holtwood, L.L.C, and determined both entities, operating as GOs, violated FAC-008-1 R1 because both failed to include the method by which they determined the Facility Rating for transmission conductors in their Facility Ratings Methodology. Regarding LMBE, the company has three generating units interconnecting with PPL EU at 230 kV through a GSU. Pursuant to an Interconnection Agreement under FAC-008-1, LMBE ownership of the transmission conductors transfers from LMBE to PPL EU where the transmission conductors enter the 230 kV switchyard. Consequently, LMBE owns less than one mile of transmission line from the GSU to the interconnection point. Similarly, PPL Holtwood's ten generating units interconnect at two points with PPL EU at 60kV through three GSUs. Pursuant to their own interconnection agreement, ownership of the interconnection transfers from PPL Holtwood to PPL EU at the disconnect switch on the high voltage side of the EU. As such, PPL Holtwood owns the conductors between the GSU and the high voltage disconnect switch, a distance of approximately ten to twenty-five feet. Both LMBE and PPL Holtwood failed to account for these portions of the transmission conductors in their Facility Ratings Methodology.

Finding: ReliabilityFirst determined that these issues posed only a minimal risk to the reliability of the BPS for two reasons. First, the TO had a facility Rating for each transmission conductor and operated its side of the transmission conductors within that Facility Rating. Second, because both LMBE's and PPL Holtwood's generating stations were designed so that the generators are the most limiting element, these short spans of interconnecting conductors are less likely to limit the generating station's capacity.

Red Hills Wind Project, LLC (RHWP), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SPP

Issue: RHWP submitted a self-report explaining it had not documented Facility Rating Methodology (FRM) for the development of its Facility Ratings. The violation duration was from February 26, 2009 through July 29, 2011.

Finding: The violation was deemed by SPP to pose minimal risk to BPS reliability because even though no FRM was in use, the facility had been designed and constructed with the generators as the most limiting element. RHWP had developed its Facility Rating by using the manufacturer’s ratings, engineering studies and results from testing the equipment. Upon creating an FRM and using the methods therein, no changes were made to the Facility Rating.

San Miguel Electric Cooperative (SMEC), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1.1

Region: TRE

Issue: SMEC, in its role as a GO, submitted a self-report discussing an issue with FAC-008-1 R1 because the Facility Ratings Methodology (FRM) in use by SMEC did not have the required statement that a Facility Rating shall equal the most limiting applicable equipment rating of the individual equipment that compromises that Facility. SMEC’s rating did reflect the most limiting equipment rating. SMEC subsequently updated its FRM to include the missing terminology. The duration of the violation was from September 3, 2008, when SMEC adopted its FRM, through September 13, 2011, when SMEC updated its FRM.

Finding: The issue was found to pose minimal risk to BPS reliability because even though the FRM did not contain the required statement, the rating given to ERCOT was correct as it reflected and considered the most limiting rating. The addition of “limiting equipment” language in the FRM provided clarity to the reader that “limiting equipment” also includes transmission conductors, terminal equipment, series and shunt compensation devices, ambient conditions, operating limitations and other assumptions.

Sweetwater Wind 5 LLC (Sweetwater 5), Docket No. RC12-16 (September 28, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: Texas RE

Issue: During an audit, Texas RE found that Sweetwater 5, as a GO and wind generator in the ERCOT service region, did not have a documented Facility Ratings Methodology (FRM) of its solely and jointly owned Facilities (per R1). Sweetwater 5 failed to comply with the Standard until November 19, when an FRM was applied.

Finding: Texas RE found the issue posed a minimal risk to the reliability of the BPS because Sweetwater 5 was fully aware of the actual rating of the facility. The ratings did not change after Sweetwater 5 developed and formally implemented the FRM. Furthermore, the sum of the Sweetwater 5's wind generator's nameplate capacities was an understood limiting element, and the remediated issue lasted 18 days.

Tatanka Wind Power, LLC (TWP), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: MRO

Issue: TWP registered with MRO as a GO in April 2008; however, it wasn’t until June 2011 that TWP realized it had no recorded Facility Ratings Methodology (FRM) to develop Facility Ratings as required by FAC-008-1 R1. In October 2011, TWP self-certified to MRO that it had violated the Standard. The issue came to light when TWP’s parent company was replacing its current version of its Facility Rating procedure with an updated FMR. TWP developed an FRM in July 2011.

Finding: The violation was deemed to pose minimal risk to BPS reliability. The risk was mitigated by the fact that TWP did have Facility Ratings, but the procedure used to determine the ratings was not documented. In addition, the TWP facility is non-dispatchable and interruptible, as it is 120 1.5 MW wind turbine generators interconnected to the grid by a 230 kV transmission line. The facility exports the entire capability of the 120 wind turbine generators and runs lower than the normal rating of the equipment. Also, no misoperations were reported. When TWP rated the equipment per its FRM, the revised Facility Ratings were negligible.

USACE - Charleston District (USACE-Charleston), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SERC

Issue: On June 30, 2008, USACE-Charleston, in its position as a GO, self-certified a violation of FAC-008-1 R1 because it did not document its historical method of determining Facility Ratings.

Finding: SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE-Charleston determined its Facility Ratings based on design parameters, nameplate ratings, and good engineering practice. Additionally, USACE-Charleston proved its Facility Ratings were credible by establishing and publishing Facility Ratings consistent with station output.

USACE - Mobile District (USACE Mobile), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SERC

Issue: On June 19, 2008, USACE-Mobile, in its position as a GO, self-certified a violation of FAC-008-1 R1 because it did not document its historical method of determining facility ratings.

Finding: SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE-Mobile determined its Facility Ratings based on design parameters, nameplate ratings, and good engineering practice. Additionally, USACE-Mobile proved its Facility Ratings were credible by establishing and publishing Facility Ratings consistent with station output.

USACE - Savannah District (USACE - Savannah), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SERC

Issue: On July 7, 2008, USACE-Savannah, a GO, self-certified a violation of FAC-008-1 R1 because it did not document its historical method of determining facility ratings.

Finding: SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE-Savannah determined its Facility Ratings based on design parameters, nameplate ratings, and good engineering practice. Additionally, USACE-Savannah proved its Facility Ratings were credible by establishing and publishing Facility Ratings consistent with station output as it was operated at the time of the issue.

USACE - Wilmington District (USACE-Wilmington), Docket No. RC12-15 (August 31, 2012)

Reliability Standard: FAC-008-1

Requirement: 1

Region: SERC

Issue: On July 14, 2008, USACE-Wilmington, a GO, self-certified a violation of FAC-008-1 R1 because it did not document its historical method of determining facility ratings.

Finding: SERC determined that this issue posed only a minimal risk to the reliability of the BPS because USACE-Wilmington determined its Facility Ratings based on design parameters, nameplate ratings, and good engineering practice. Additionally, USACE-Wilmington proved its Facility Ratings were credible by establishing and publishing Facility Ratings consistent with station output as it was operated at the time of the issue.

Virginia Electric and Power Company, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: FAC-008-1

Requirement: R1

Region: SERC

Issue: Virginia Electric and Power Company (VEPCO) self-reported that it did not include its circuit switchers and series compensation devices in its Facility Ratings Methodology as required.

Finding: SERC found that this issue constituted only a minimal risk to the BPS. VEPCO’s circuit switchers are not the most limiting component in its Facility Ratings and the circuit switchers were only installed in 9 of VEPCO’s substations (out of 200). Also, VEPCO did not use series compensation devices, so their exclusion from the Facility Ratings Methodology did not have an impact on VEPCO’s Facility Ratings.

Western Farmers Electric Cooperative (WFEC), Docket No. RC13-7-000 (March 27, 2013)

Reliability Standard: FAC-008-1

Requirement: 1.2.1

Region: SPP RE

Issue: While conducting a compliance audit in November 2012, SPP RE found WFEC, a registered GOP, to be non-compliant with FAC-008-1 in that, due to a documentation mistake, WFEC had not included relay protective devices in its equipment inventory used to determine Facility Ratings in its current generation Facility Ratings Methodology, Rev. 3, dated August 20, 2012. The period of non-compliance was June 22, 2010 to November 8, 2012.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk because it was documentation related, and WFEC had included the relay protective devices when determining its generation Facilities' Ratings. An earlier version of WFEC's FRM, Ver. 1, dated June 22, 2010, did include the relay protective devices.