NERC Case Notes: Reliability Standard FAC-008-3 | White & Case LLP International Law Firm, Global Law Practice
NERC Case Notes: Reliability Standard FAC-008-3

NERC Case Notes: Reliability Standard FAC-008-3

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CCI Signal Hill LLC (CCI SH), FERC Docket No. NP15-29-000 (May 28, 2015)

Reliability Standard: FAC-008-3

Requirement: R1, R1.2

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: Texas RE

Issue: Texas RE, during a compliance audit, found that CCI SH's Facility Ratings documentation was not bifurcated up to the high side terminals of the main step up transformer. Additionally, CCI SH's Facility Ratings Methodology (FRM) used the gas turbines' firing temperature as the facility's most limiting equipment rating, which is an invalid Equipment Rating criterion.

Finding: Texas RE found that this issue, along with violations of FAC-008-1 R1, posed a moderate risk to BPS reliability because facility ratings affect system operating limits. Additionally, two of the plant's four units were Blackstart resources, and inaccurate facility ratings involving Blackstart units could delay restoration of firm load. However, during the violations period, CCI SH did not fail a Blackstart test, the plant's two other units had the ability to support the Blackstart, and CCI SH was contracted to supply only 3.4% of ERCOT's primary Blackstart capability. To mitigate the violation, CCI SH (1) created Equipment Ratings based on valid criteria, (2) created a Facility Rating based on characteristics that do not violate applicable Equipment Ratings, (3) hired a consultant to review CCI SH's internal compliance program, and (4) added an annual FRM review to its tracking and notification system.

Penalty: $50,000 (aggregate for 6 violations)

FERC Order: FERC approved the settlement on June 26th, 2015.

CCI Signal Hill LLC (CCI SH), FERC Docket No. NP15-29-000 (May 28, 2015)

Reliability Standard: FAC-008-3

Requirement: R2, 2.3

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: Texas RE

Issue: Texas RE, during a compliance audit, found that CCI SH did not have a "statement that a Facility Rating shall equal the most limiting applicable Equipment Rating of the individual equipment that comprises that Facility" in its Facility Ratings Methodology (FRM) document.

Finding: Texas RE found that this issue posed a moderate, but not a serious or substantial, risk to BPS reliability because facility ratings affect system operating limits. Additionally, two of the plant's four units were Blackstart resources, and inaccurate facility ratings involving Blackstart units could delay restoration of firm load. However, during the violations period, CCI SH did not fail a Blackstart test, the plant's two other units had the ability to support the Blackstart, and CCI SH was contracted to supply only 3.4% of ERCOT's primary Blackstart capability. To mitigate the violation, CCI SH (1) created Equipment Ratings based on valid criteria, (2) created a Facility Rating based on characteristics that do not violate applicable Equipment Ratings, (3) hired a consultant to review CCI SH's internal compliance program, and (4) added an annual FRM review to its tracking and notification system.

Penalty: $50,000 (aggregate for 6 violations)

FERC Order: FERC approved the settlement on June 26th, 2015.

CCI Signal Hill LLC (CCI SH), FERC Docket No. NP15-29-000 (May 28, 2015)

Reliability Standard: FAC-008-3

Requirement: R6

Violation Risk Factor: Medium

Violation Severity Level: Severe

Region: Texas RE

Issue: Texas RE, during a compliance audit, found CCI SH's facility ratings were inconsistent with its Facility Ratings Methodology (FRM). The FRM stated that gas turbines' firing temperature was the facility's most limiting equipment rating, but the FRM rated generators in MW and MVA. Also, CCI SH reported facility ratings to its Reliability Coordinator that were different than the ratings listed in the FRM.

Finding: Texas RE found that this issue, along with violations of FAC-009-1 R1, posed a moderate, but not a serious or substantial, risk to BPS reliability because facility ratings affect system operating limits. Additionally, two of the plant's four units were Blackstart resources, and inaccurate facility ratings involving Blackstart units could delay restoration of firm load. However, during the violations period, CCI SH did not fail a Blackstart test, the plant's two other units could have supported the Blackstart, and CCI SH was contracted to supply only 3.4% of ERCOT's primary Blackstart capability. To mitigate the violation, CCI SH (1) created Equipment Ratings based on valid criteria, (2) created a Facility Rating based on characteristics that do not violate applicable Equipment Ratings, (3) hired a consultant to review CCI SH's internal compliance program, and (4) added an annual FRM review to its tracking and notification system.

Penalty: $50,000 (aggregate for 6 violations)

FERC Order: FERC approved the settlement on June 26th, 2015.

Tampa Electric Company (TEC), FERC Docket No. NP15-29-000 (May 28, 2015)

Reliability Standard: FAC-008-3

Requirement: R8

Violation Risk Factor: Medium

Violation Severity Level: Lower

Region: FRCC

Issue: FRCC, during a compliance audit, found that in two instances TEC did not re-rate a facility or provide its Reliability Coordinator (RC) with proper notification through an inter-control center communications protocol.

Finding: FRCC found that this issue posed a moderate, but not a serious or substantial, risk to BPS reliability. Because the RC model had incorrect ratings data, the RC might not have operated appropriately. However, during the two instances maximum flow was 15% and 9% of the revised limits. These low percentages show the risk was not substantial. To mitigate the violation penalty, TEC (1) added a step to the process for planned switching requiring the energy system operator (ESO) to update ratings, (2) installed alarms which remind ESOs to check ratings when the possibility for de-rating arises, and (3) trained ESOs on the FAC-008-3 R8 requirement.

Penalty: $3,000 (aggregate for 2 violations)

FERC Order: FERC approved the settlement on June 26th, 2015.