NERC FFT Reports: Reliability Standard FAC-009-1 | White & Case LLP International Law Firm, Global Law Practice
NERC FFT Reports: Reliability Standard FAC-009-1

NERC FFT Reports: Reliability Standard FAC-009-1

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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.

American Transmission Co. LLC ("ATC"), FERC Docket No. RC13-2-000 (November 30, 2012)

Reliability Standard: FAC-009-1

Requirement: 1

Region: RFC

Issue: ATC, as a TO, self-reported an issue with R1 in connection with a project to remedy congestion issues at its Butler Substation in southeastern Wisconsin (Project). Upon completion, ATC planned to establish a rating of 1688 amps for its Granville-Butler 138 kV transmission line (Line 3453), in accordance with its FRM. On September 9, 2011, ATC found a clearance to underbuild discrepancy on Line 3453 that necessitated the establishment a more restrictive Facility Rating. ATC approved an interim rating of 1420 amps consistent with its Methodology and authorized the rating to stay in effect until May 1, 2012, allowing time to make any needed corrections on the field line. However upon completion of the Project, ATC erred in recording the rating as 1688 amps. ATC authorized the 1688 amp rating for Line 3453, uploaded it into the EMS and reported it to the RC on October 12, 2011. During a review of the Project three weeks later, ATC realized the improper 1688 amp rating for Line 3453, which should have been rated as 1420 amps due to the field condition. In response to the discovery, ATC revised its Facility Rating for Line 3453 to 1420 amps. ATC lowered the underbuild in question on March 28, 2012, remediating the issue.

Finding: RFC found the issue posed a minimal risk to the reliability of the BPS because the maximum loading of Line 3453 during period in question was 770 amps, thereby mitigating the risk. Also, ATC implemented their documented Methodology to determine both Facility Ratings associated with Line 3453; the issue did not indicate systemic problems with ATC's Methodology or application.

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

Reliability Standard: FAC-009-1

Requirement: 1

Region: ReliabilityFirst

Issue: As a result of a compliance audit conducted January 23, 2012 to February 3, 2012, ReliabilityFirst determined that CCC violated FAC-009-1 R1 for failing to establish a Facility Ratings for its protective relay equipment based on its Facility Ratings Methodology. CCC’s Methodology requires it to include Facility Ratings for its protective relay equipment consistent with “manufacturer’s published ratings, or…based upon industry rating practices such as manufacturer’s warranty, IEEE, ANSI or other applicable standards.” Inconsistent with this Methodology, the settings CCC used for its protective relay equipment were not based on ratings published by the manufacturer or derived from industry rating practice.

Finding: ReliabilityFirst determined this issue posed only a minimal risk to the reliability of the BPS for two reasons. First, CCC included protective relay settings that were more restrictive parameters than the manufacturer’s ratings in its Facility Ratings Methodology. Second, because the most limiting components at the CCC generating facility are the turbine gearbox and generator, CCC’s generator would trip off line because of exceeding the maximum capability of the turbine’s gearbox before CCC would have exceeded either the protective relay settings or the manufacturer’s ratings for protective relays. As such, CCC’s use of relay settings instead of the manufacturer’s ratings did not limit the CCC’s generation output during the duration of the issue.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: RFC

Issue: During a compliance audit, RFC found that Camp Grove Wind Farm, LLC (“Camp Grove”) had not developed Facility Ratings for its nine miles of 138 kV transmission conductors between its substation and the Commonwealth Edison Company switchyard.

Finding: NPCC found that this issue, which lasted for only four days in 2008, constituted only a minimal risk to the BPS. Camp Grove designed the wind turbine to be its most limiting element, so when Camp Grove amended its Facility Ratings to include the transmission conductors it did not have to revise the most limiting element. In addition, the total load on the conductors was known, making it less likely that the conductors would be overloaded.

City of Springfield, IL – CWLP (CWLP), FERC Docket No. FERC Docket No. FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: FAC-009-1

Requirement: 1

Region: SERC

Issue: CWLP, as a TO, self-reported a violation of R1 of FAC-009-1 to SERC on March 29, 2012, when it found a transportation error in the winter emergency rating in its Facility Rating for a transmission conductor. Winter emergency ratings on nine branches on the CWLP 138 kV transmission system were affected due to the transportation error, with the emergency rating reading as 1,373 Amps in lieu of the correct rating of 1,337 Amps, with the difference between the two being 36 Amps, or 2.62%. SERC examined the CWLP Facility Rating Methodology (FRM) and ratings summary spreadsheets prior to and later than March 29, 2012. SERC found that in the rating summary spreadsheets, the summary table showed manually recorded rating (1,373) as opposed to the calculated rating (1,337). SERC also examined CWLP data sheets and discovered that the transportation errors only affected the winter emergency ratings for nine facilities while it had a normal distribution of summer, emergency summer, winter, and emergency winter ratings totaling 240 for 50 facilities. SERC decided that CWLP did not provide nine out of 240 ratings (3.75%) per the provisions of its FRM. SERC also decided that the issue did not apply to CWLP, as a GO.

Finding: SERC found that the issue posed a minimal risk to the reliability of the bulk power system since CWLP uses a supervisory control and data acquisition (SCADA) system that alarms the system operator in case of the facility loading reaching 90% of its normal summer and winter ratings, which gives CWLP enough time to act to prevent the load from reaching emergency limits. Also, the 9 facilities were never listed in MISO Interconnection Reliability Operating Limit, Transmission Operator congested flow gates, or Critical Facilities List, or found to be critical facilities according to CWLP vulnerability and risk assessment. Finally, the capacity ratings of the nine facilities went down by 2.62% once CWLP corrected the errors.

Colorado Springs Utilities (CSU), Docket No. RC12-12 (May 30, 2012)

Reliability Standard: FAC-009-1

Requirement: R1

Region: WECC

Issue: CSU, in its role as a TO and GO, submitted a self-certification addressing an issue with FAC-009-1 R1.2 based on its discovery that its backup over current relays and current transformers (CTs) located on its Bulk Electric System (BES) transformers were not considered when it determined its facility ratings on June 18, 2007, and in accordance with its Facility Ratings Methodology.

Finding: The issue was found to pose minimal risk to BPS reliability because the CT and PT devices are the most limiting factor and CSU notified its TOP of the de-ratings the day the problem was discovered.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: RFC

Issue: Eagle Point, as a GO, self-reported to RFC that it had an issue with FAC-009-1 R1 because it did not have Facility Ratings for 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 and found that the steam turbine generator has been and continues to be the most limiting element of the Facility.

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

Reliability Standard: FAC-009-1

Requirement: R1, R2

Region: SPP

Issue: During a compliance audit conducted during June 2010, SPP found that Eastman had two violations of the FAC-009-1 Standard. Regarding R1, Eastman had no capacity rating established for its generating facility through the use of a Facility Rating Methodology (Method) meeting the requirements of FAC-008-1. Rather, Eastman’s practice was to use a computer model to determine its generating capacity, and when asked for evidence of a Facility Rating, Eastman could only provide a forecasted energy output, and the data did not have all of the elements making up the generating facility. Eastman could not show that its generating Facility Rating was based on the most limiting element making up the generating facility in violation of FAC-009-1 R1. That violation of R1 led to a violation of R2 as Eastman could not show that the Facility Ratings it provided to its RC, TOP, Transmission Planner and Planning Authority were produced through the use of a compliant Method, as required by FAC-009-1 R2.

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.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: FRCC

Issue: FFT Entity self-reported that it had not applied its Facility Ratings Methodology to determine its Facility Ratings.

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-009-1

Requirement: R1

Region: RFC

Issue: As the result of a compliance audit, RFC determined FFT Entity violated R1 because it failed to provide evidence that it developed Facility Ratings for generator current transformers consistent with its Facility Ratings Methodology.

Finding: RFC 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 correctly identified the most limiting element in its Facility Ratings.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: SPP

Issue: During an audit, SPP found that FFT Entity did not identify the most limiting element in its Facility Ratings.

Finding: SPP found that this issue constituted only a minimal risk to BPS reliability since FFT Entity’s Facility Ratings were based on the design ratings of the facility. In addition, even when the most limiting element was added, it did not impact FFT Entity’s Facility Ratings.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: FRCC

Issue: During a compliance audit, FRCC determined that FFT Entity, for 29 months, did not incorporate its relay protective devices in its Facility Ratings Methodology as required.

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 were not the limiting factor.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: FRCC

Issue: FFT Entity self-reported that, for 4 years, it did not incorporate the ratings for its transmission conductors into its Facility Ratings Methodology.

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. The transmission conductors are also not a limiting element. 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-009-1

Requirement: R1

Region: FRCC

Issue: FFT Entity did not consider 225 feet of 230 kV radial line connecting FFT Entity to its BA’s substation when it established Facility Ratings consistent with the associated Facility Ratings Methodology.

Finding: The issue posed a minimal risk and did not pose a serious or substantial risk to the reliability of the BPS because FFT Entity was operating its equipment within manufacturer and design specifications. Furthermore, FFT Entity is located at one power plant site with a single radial 230 kV line connecting it to its BA.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: TRE

Issue: FFT Entity was unable to provide evidence of a documented Facility Ratings Methodology prior to April 30, 2009 or documentation of any calculations of Facility Ratings (based on any documented or undocumented Facility Ratings Methodology) that were performed prior to April 30, 2009.

Finding: TRE found the issue did not pose a serious or substantial risk and posed a minimal potential and actual risk to the bulk power system because FFT Entity had already developed and had been submitting its Facility Ratings to ERCOT ISO.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: Texas RE

Issue: FFT Entity self-reported that its facility ratings failed to include an equipment rating for its generation interconnection line. Generation interconnection lines ought to be considered—among other equipment—when establishing such a facility’s rating. It discovered this issue while reviewing the NERC Alert “Considerations of Actual Field Conditions in Determination of Facility Ratings.” The line failed to be included in the FFT Entity’s Facility Rating Methodology and also tied the plant to the transmission substation of another Entity.

Finding: Texas RE found that this issue constituted an unsubstantial risk to BPS reliability. There were other elements of the facility included in FFT Entity’s Facility Rating Methodology implementation that were more limiting than the generator interconnection transmission. After reviewing the Interconnection Agreement, FFT Entity coordinated appropriately with the other Entity; then, relay settings were found to need no modification. Finally, during the period of non-compliance, ERCOT was also informed of the line’s status and rating—and no transmission line disturbances occurred.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: Texas RE

Issue: FFT Entity self-reported that its facility ratings failed to include an equipment rating for its generation interconnection line. Generation interconnection lines ought to be considered—among other equipment—when establishing such a facility’s rating. It discovered this issue while reviewing the NERC Alert “Considerations of Actual Field Conditions in Determination of Facility Ratings.” The line failed to be included in the FFT Entity’s Facility Rating Methodology and also tied the plant to the transmission substation of another Entity.

Finding: Texas RE found that this issue constituted an unsubstantial risk to BPS reliability. There were other elements of the facility included in FFT Entity’s Facility Rating Methodology implementation that were more limiting than the generator interconnection transmission. After reviewing the Interconnection Agreement, FFT Entity coordinated appropriately with the other Entity; then, relay settings were found to need no modification. Finally, during the period of non-compliance, ERCOT ISO was also informed of the line’s status and rating—and no transmission line disturbances occurred.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: ReliabilityFirst

Issue: During a compliance audit, FFT Entity was found to be in violation of the Standard because, since it did not state which rating method was in use while rating facilities in its Facility Ratings Methodology document, it did not establish Facility Ratings consistent with the related Facility Ratings Methodology.

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, FERC Docket No. RC12-8 (February 29, 2012)

Reliability Standard: FAC-009-1

Requirement: R1

Region: RFC

Issue: FFT Entity self-reported that it did not timely establish a Facility Ratings Methodology, and therefore it did not have Facility Ratings that were consistent with 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.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: TRE

Issue: During an audit, TRE determined that FFT Entity did not have Facility Ratings that were consistent with its Facility Ratings Methodology.

Finding: TRE found that this issue constituted only a minimal risk to the BPS since this was primarily a documentation issue. FFT Entity was relying on regional requirements in calculating its Facility Ratings and was notifying its regional reliability entity of its Facility Ratings.

ITC Transmission (ITCT), Docket No. RC12-16-000 (September 28, 2012)

Reliability Standard: FAC-009-1

Requirement: 1

Region: ReliabilityFirst

Issue: ReliabilityFirst conducted a compliance audit of ITCT and its affiliate entity, METC, between August 15 and August 23, 2011, and found that both companies violated FAC-009-1 R1 because they each failed to revise the Facility Ratings for three transformers as required in their Facility Ratings Methodology. Specifically, one of ITCT's 345/120 kV transformers and two of METC's 345/138 kV transformers had Facility Ratings higher than those required by the Facility Rating Methodology in effect March 16, 2010. These transformers were consistent with the Facility Ratings Methodology effective prior to March 16, 2010, but both entities failed to revise their transformers' ratings after their revised Facility Ratings Methodology went into effect.

Finding: ReliabilityFirst determined both of these issues posed only a minimal risk to the reliability of the BPS for five reasons. First, all the transformers were equipped with a remote monitoring system that captures real-time values and alarms allowing ITCT and METC personnel to monitor and evaluate the critical parameters of hot spot, top oil temperatures and fault gasses to ensure the transformers were operating safely. Second, the transformer constituted less than 3% of ITCT's and METC's solely and jointly owned facilities. Third, during the time the incorrect Facility Ratings were in use, the transformer loading did not surpass the correct Facility Rating for any of the transformers, though METC was required to revise the Facility Rating for one transformer as a conservative measure to prolong the life of the transformer. Fourth, under the proper Facility Rating Methodology, the transformers' normal summer and winter ratings were decreased by only 1.25% and 2.3%, respectively. Fifth, for both the METC and ITCT transformers, both companies, in applying the revised Facility Ratings Methodology, decreased the Normal Facility Rating and increased the Emergency Rating, highlighting that the previous Facility Ratings were not endangering the operability of the transformers.

Lea Power Partners, LLC (LEAPP), FERC Docket No. RC13-3-000 (December 31, 2012)

Reliability Standard: FAC-009-1

Requirement: 1

Region: SPP

Issue: LEAPP, as a GO, self-reported a violation of R1 of FAC-009-1 to SPP on January 17, 2012, citing the lack of facility rating for its Hobbs Generating Station, mandated by its Facility Ratings Methodology (FRM). LEAPP's FRM held that the Hobbs Generating Station Facility Rating consider each rating of the equipment that makes up the station, surrounding conditions, operating limitations, and other factors. LEAPP violated R1 of FAC-009-1 because the facility rating of the Hobbs Generating Station is not determined by LEAPP's Power Purchase Agreement (PPA), which had labeled the most limiting element of the Hobbs facility as the combustion turbine generators, though PPA does not determine that facility rating of the Hobbs generating station and the most limiting elements of the facility are the step-up transformers and steam turbine generators.

Finding: SPP found that the issue posed a minimal risk to the reliability of the bulk power system for the following reasons: (1) despite the failure to establish the facility rating for the Hobbs Generating Station Facility based on its FRM, LEAPP did operate Hobbs units at the maximum capacity in accordance with the operating limitations and surrounding conditions; (2) the maximum capacity rating used by LEAPP was more limiting than the nameplate rating, which meant that the operating capacity was made aware to its TO, BA, and RC; (3) when LEAPP applied its FRM, the rating of the Hobbs facility showed little change.

LG&E and KU Services Company as agent for Louisville Gas and Electric Company and Kentucky Utilities Company (LG&E-KU), Docket No. RC13-1 (October 31, 2012)

Reliability Standard: FAC-009-1

Requirement: 1

Region: SERC

Issue: LG&E-KU, as a TO, submitted a self-report explaining it found a Facility Rating that was not in accordance with its Facility Ratings Methodology (FRM).

Finding: SERC found the issue posed minimal risk to BPS reliability because the relevant line was modeled and operated at its designed rating and therefore operating the line at 283°F would not have damaged the line; and the use of the designed rating meant that the Ghent-Fairview line was not the most limiting element. This is a repeat violation for LG&E-KU; however, the previous violation was in 2010 and had different facts and circumstances and so NERC determined FFT treatment was appropriate in this instance

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

Reliability Standard: FAC-009-1

Requirement: R1

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 it had not established Facility Ratings consistent with its Facility Ratings Methodology.

Finding: RFC determined that the issues posed a minimal risk to the reliability of the BPS because although the GO’s most limiting applicable equipment rating changed as a result of updating its Facility Ratings Methodology, that equipment component was included in the original Facility Ratings.

Michigan South Central Power Agency (MSCPA), Docket No. RC13-9, May 30, 2013

Reliability Standard: FAC-009-1

Requirement: 2

Region: RFC

Issue: Further to a Compliance Audit, RFC found that MSCPA, as a GO, had failed to use a common unit of measure on its facilities ratings sheet and therefore had an issue with FAC-009-1, R1. In the context of establishing Facility Ratings, this issue prevented a proper comparison of equipment elements to identify the most limiting element affecting generator output.

Finding: RFC determined that the issue posed a minimal risk to the BPS because despite the documentation issue, the GO had correctly determined the total output of its generating unit and had determined that the output would not force any individual piece of equipment to exceed its rating. The GO was also a relatively small contributor to the BPS.

Nashville Electric Service (NES), Docket No. RC12-13 (June 29, 2012)

Reliability Standard: FAC-009-1

Requirement: R1

Region: SERC

Issue: NES submitted a self-report in April. 2012 outlining violations of FAC-009-1 R1 upon its realization that the 2010 Facility Ratings involving secondary devices connected to bushing current transformers (BCTs) had not been established pursuant to its Facility Ratings Methodology (FRM). In particular, the emergency conductor ratings and the normal bus conductor ratings were miscalculated. NES has 32 161 kV transmission lines and ten transformers. NES provided SERC staff the 2010 Facility Ratings and reported that seven transmission lines were affected; however, NES further reported that the overall Normal Ratings of its Facilities were not impacted by the mistake. Upon review, SERC found that NES failed to use the proper operating temperature to calculate the emergency conductor ratings (100º Celsius (C) versus 140º C) and the normal bus conductor ratings (100º C versus 90º C) and, once fixed, the ratings were found not to be the Limiting Element. None of the mistakes affected the finding of the Limiting Element; however, the Facility Ratings for the 32 transmission lines were not consistent with the FRM.

Finding: The violation was deemed to pose minimal risk to BPS reliability because the failure to correctly use the FRM could lead to equipment damage, inaccurate modeling, and system outages. SERC staff discovered no evidence that the errors affected the determination of the Limiting Element.

NRG Rockford LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: FAC-009-1

Requirement: R1

Region: RFC

Issue: During a compliance audit, RFC found that NRG Rockford LLC (NRG Rockford), as a GO, had not properly established and listed the Facility Ratings for its transmission line, breaker disconnect switch, and protective relay coils.

Finding: RFC found that this issue constituted only a minimal risk to the BPS. As NRG Rockford had designed all of the elements to have a higher rating than the maximum output capability of the respective generating units, the most limiting element of NRG Rockford’s facility is its generators and the loadability of the terminal equipment is limited by the generator capacity.

NRG Rockford II LLC, FERC Docket No. RC12-11 (April 30, 2012)

Reliability Standard: FAC-009-1

Requirement: R1

Region: RFC

Issue: During a compliance audit, RFC found that NRG Rockford II LLC (NRG Rockford II), as a GO, had not properly established and listed the Facility Ratings for its transmission line, breaker disconnect switch, and protective relay coils.

Finding: RFC found that this issue constituted only a minimal risk to the BPS. As NRG Rockford II had designed all of the elements to have a higher rating than the maximum output capability of the respective generating units, the most limiting element of NRG Rockford II’s facility is its generators and the loadability of the terminal equipment is limited by the generator capacity.

Oncor Electric Delivery Company LLC (Oncor), Docket No. RC13-9, May 30, 2013

Reliability Standard: FAC-009-1

Requirement: 1

Region: TRE

Issue: Oncor, as a TO, self-certified an issue with FAC-009-1 R1 to TRE when the TO found that it had not established facility ratings consistent with its facility ratings methodology (FRM), leading to inaccurate 15-minute ratings for 20 autotransformers. Additionally, faulty cooling equipment on six of its autotransformers led to inaccurate normal ratings. These two issues led to inaccurate ratings under the TO’s FRM.

Finding: TRE found that the issue posed a minimal risk to the BPS as the 15-minute ratings were not used during the pendency of the issue and as a load levels for the autotransformers with faulty cooling equipment were well below the new normal ratings. While the inaccurate ratings posed a possible risk to the protection of the autotransformers, they posed minimal risk to the BPS.

Orlando Utilities Commission (OUC), Docket No. RC13-10, June 27, 2013

Reliability Standard: FAC-009-1

Requirement: R1

Region: FRCC

Issue: Further to a Compliance Audit, FRCC found that OUC, as a GO, had an issue with FAC-009-1 R1 because OUC did not have enough evidence to show that it had established Facility Ratings for its solely and jointly owned Facilities that are consistent with the associated Facility Ratings methodology.

Finding: FRCC determined that the issue posed a minimal risk to the reliability of the BPS for numerous reasons, including: OUC operated to manufacturer’s ratings, OUC had proven operational history with no actual impact based on the established ratings, and once the complete ratings were established there was no change in the most limiting piece of equipment.

Pinellas County Resource Recovery (PCR), Docket No. RC13-8, April 30, 2013

Reliability Standard: FAC-009-1

Requirement: 1

Region: FRCC

Issue: While conducting a Compliance Audit, FRCC found that PCR, a GO, had not included two items found in its switchyard (aluminum bus and aluminum jumper) on its Facility Ratings Worksheet when calculating its Facility Rating and as required by its Facility Rating Methodology.

Finding: The violation was deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because neither item was the most limiting element. In addition, PCR is a small facility, 75 MW, and connected to the BPS through a single radial 230 kV line. PCR provides less than 1% of regional generation.

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

Reliability Standard: FAC-009-1

Requirement: 1

Region: SPP RE

Issue: PowerSmith submitted a self-report in July 2011 alerting SPP RE to a compliance issue with FAC-009-1 in that PowerSmith, a registered GO, had no Facility Ratings for its generation facility consistent with a formal Facility Ratings Methodology (FRM) for the time period April 22, 2011 (the date of its NERC registration) until December 16, 2011.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk because although PowerSmith did not have Facility Ratings established pursuant to a formal FRM, 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.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: SPP

Issue: RHWP submitted a self-report explaining that the Facility Ratings in place had not been established through use of a documented Facility Rating Methodology (FRM). The violation duration was from February 26, 2009 through September 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 Ratings by using the manufacturer’s ratings, engineering studies and results from testing the equipment. Upon creating an FRM and using the method therein, no changes were made to the Facility Rating.

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

Reliability Standard: FAC-009-1

Requirement: R1

Region: TRE

Issue: SMEC, in its role as a GO, submitted a self-report of an issue with FAC-009-1 R1 due to the fact that SMEC failed to establish Facility Ratings consistent with its Facility Ratings Methodology (FRM). In particular, the FRM in effect at the time of the violation stated “SMEC does not establish emergency ratings for the generator”, which would be interpreted to mean that normal ratings are the same as emergency ratings. However, the Resource Asset Registration Form (RARF) and Planning Model generator data provided by SMEC included ratings that were higher than the normal ratings provided, which implies that an emergency rating different than the normal ratings was established and was assigned different value. Upon discovery that the narrative in the FRM did not match the ratings data in the RARF and Planning Model, SMEC adjusted the higher ratings to match the FRM narrative. By doing so, SMEC in effect declared that it has no different emergency rating, which does not comply with the requirements of the Standard. The period of non-compliance was from September 3, 2008 until January 31, 2012, when SMEC modified its emergency ratings.

Finding: The issue was found to pose minimal risk to BPS reliability because the original emergency rating which was provided to ERCOT in the RARF reflected the facility’s capability. The emergency rating was established in order to set a higher rating during periods in which SMEC’s adjacent lignite mine was out of service and the load was included as an auxiliary load for the generating plant. But, the generator gross MW capacity remained the same so the rating represented the actual capabilities of SMEC’s facility.

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

Reliability Standard: FAC-009-1

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 established Facility Ratings consistent with the related Facility Ratings Methodology (FRM), per R1. Sweetwater 5 failed to comply with the Standard until November 19, when Facility Ratings were established.

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 formally implemented the FRM and determined the Facility Ratings pursuant to 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-009-1

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 not determined Facility Ratings pursuant to a recorded Facility Ratings Methodology (FRM), as required by FAC-009-1 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.

Triton Power Michigan, LLC (Triton), Docket No. RC13-6-000 (February 28, 2013)

Reliability Standard: FAC-009-1

Requirement: 1

Region: RFC

Issue: While conducting a compliance audit, RFC found that Triton, a GO, had not determined the ratings for all devices pursuant to its Facility Ratings Methodology.

Finding: The issue was deemed to pose minimal risk to BPS reliability and not serious or substantial risk. The risk to BPS operations was mitigated because Triton's system is designed so that no generator can exceed the limitations of its associated electrical equipment, and Triton's electrical equipment has adequate capacity to accommodate the maximum output.

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

Reliability Standard: FAC-009-1

Requirement: 1

Region: SERC

Issue: On June 30, 2008, USACE-Charleston, in its role as a GO, self-certified a violation of FAC-009-1 R1 because it did not document its Facility Ratings Methodology (FRM) and, consequently, could not confirm that its Facility Ratings were consistent with its FRM.

Finding:SERC determined this issue posed only a minimal risk to the reliability of the BPS because USACE-Charleston established and published Facility Ratings consistent with the design criteria, and the Facilities were being operated within those criteria.

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

Reliability Standard: FAC-009-1

Requirement: 1

Region: SERC Reliability Corporation (SERC)

Issue: On June 19, 2008, USACE-Mobile, in its position as a GO, self-certified a violation of FAC-009-1 R1 because it did not document its Facility Ratings Methodology (FRM) and, consequently, could not confirm that its Facility Ratings were consistent with its FRM.

Finding: SERC determined this issue posed only a minimal risk to the reliability of the BPS because USACE-Mobile established and published Facility Ratings consistent with the station output as it was operated at the time of the issue.

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

Reliability Standard: FAC-009-1

Requirement: 1

Region: SERC

Issue: On July 7, 2008, USACE-Savannah, a GO, self-certified a violation of FAC-009-1 R1 because it did not document its Facility Ratings Methodology (FRM) and, consequently, could not confirm that its Facility Ratings were consistent with its FRM.

Finding: SERC determined this issue posed only a minimal risk to the reliability of the BPS because USACE-Savannah established and published Facility Ratings consistent with the 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-009-1

Requirement: 1

Region: SERC Reliability Corporation (SERC)

Issue: On July 14, 2008, USACE-Wilmington, a GO, self-certified a violation of FAC-009-1 R1 because it did not document its Facility Ratings Methodology (FRM) and, consequently, could not confirm that its Facility Ratings were consistent with its FRM.

Finding: SERC determined this issue posed only a minimal risk to the reliability of the BPS because USACE-Wilmington established and published Facility Ratings consistent with the station output as it was operated at the time of the issue.

Virginia Electric and Power Company, (VEPCO), Docket No. RC13-8, April 30, 2013

Reliability Standard: FAC-009-1

Requirement: 1

Region: SERC

Issue: In preparation for an upcoming Compliance Audit, VEPCO filed a self-report in December 2012 explaining that it had not determined, for one facility, Facility Ratings in accordance with is Facility Ratings Methodology (FRM). In particular, prior to September 2011, VEPCO failed to include load dump ratings in its FRM. Subsequent review found that the Facility Rating for one line did not show the correct most limiting element. But, the other normal and emergency calculations remained unaffected.

Finding: The violation was deemed to pose minimal risk to BPS reliability but not serious or substantial risk which was mitigated because actual flow was shown to never have been close to exceeding the rating limits.