Protect the Grid: Act on Facility Ratings Today

One of the fundamental inputs to achieve accurate planning and operations of the Bulk Power System (BPS) is Facility Ratings. Facility ratings are essential in the determination of System Operating Limits. Incorrect ratings can pose a risk to the reliability and security of the BPS in multiple ways. Ratings that exceed equipment capability could result in equipment damage or sagging beyond what is anticipated. This could result in unplanned outages and/or fires. Alternatively, ratings that are too low could result in unnecessary load shed or generation re-dispatch despite the equipment being capable of safely handling the loading. Due to the growing importance of accurate Facility Ratings, the Electric Reliability Organization (ERO) has identified them as an Enterprise Risk Element area of focus in the annual Compliance Monitoring and Enforcement Program (CMEP) Implementation Plan since 2016. SERC has also actively engaged in identifying and working to mitigate challenges associated with ineffective Facility Ratings programs. Through compliance monitoring and enforcement activities, SERC and registered entities have identified discrepancies between documented Facility Ratings and actual field conditions. These violations account for 86% of all FAC-008 violations in SERC’s footprint. Through its work, SERC has identified three main causes to the challenges of Facility Ratings programs.

These broader themes have been identified as:

• lack of awareness
• inadequate asset data management
• inadequate change management.

lack of awareness

 The first challenge observed pertaining to Facility Ratings is lack of awareness. This occurs when an entity lacks accurate physical accounting or understanding of the current carrying equipment within its electrical system, the effectiveness of its Facility Ratings program and/or fails to proactively develop, enhance or implement a sustainable Facility Ratings Program. This lack of awareness has been shown to allow Facility Rating discrepancies to go unnoticed for considerable amounts of time. This issue can be attributed to not having included steps to perform equipment field verification and validation but however, relies on ratings provided by the equipment manufacturer, nameplate ratings and/or one-line diagrams that may be out of date with what is in the field. This can give the entity a false sense of security that accurate ratings are being utilized. In addition, if the Facility Rating program does not adequately include any in-field verification and validation, the inaccuracies are even less likely to be detected after a field change is made. Some of the reasons behind this lack of awareness include but are not limited to a lack of management involvement or prioritization in program commitment. Other causes include a lack of engagement with an entity’s regions and a lack of training or experienced workforce. An entity’s “tone at the top” can be one of the key factors combatting and preventing lack of awareness. Senior management must set a positive “tone at the top” by creating an environment that prioritizes Facility Ratings as a program instead of a function of work. Another method to improve lack of awareness is to implement periodic walk-downs of facilities to validate and verify that the Facility Ratings accurately reflect what is in the field. After walk-downs are completed, quality assurance review personnel should compare equipment inventory and equipment rating. In addition to these methods among others, a corrective action program can reduce lack of awareness of existing or potential deficiencies in Facility Ratings. A corrective action program should be a continuous improvement process to support sustained safe and reliable performance.

INADEQUATE ASSET DATA MANAGEMENT

Regarding Facility Ratings, asset management is the identification, management and tracking of physical Facility Ratings assets. Data management is the collecting, validating and storing of all data associated with Facility Ratings. The success of an entity’s Facility Ratings program relies on effective and efficient asset and data management. Often, there are various locations that contain some form of equipment or Facility Ratings data. This data is then shared across multiple business groups to be placed in some type of ratings database, repository or one-line diagrams. Due to all these possible points of failure, this can be very challenging. This also reinforces the importance of maintaining accurate and efficient Facility Ratings programs. One common failure in asset management is when a program does not account for all the necessary pieces of equipment in the field when determining a Facility Rating. SERC has observed that programs most frequently miss accounting for equipment such as wave traps, jumpers, connectors, and bus work. These types of failures can often be attributed to equipment being consolidated in the database instead of listing equipment individually. One of the most effective controls utilized in identifying and inventorying every piece of equipment in the field is walking down facilities. In doing so entities can ensure proper inclusion and ratings of every piece of equipment in the field. Walk-downs should always be followed by a quality assurance review to ensure correct equipment ratings have been captured. Another measure that can be taken is to establish a single official Facility Ratings database. The location of this database or repository should be communicated to all relevant personnel. The process to obtain information and enter data into the official database should be well documented. Training should be documented and provided to reinforce the process on an annual basis. Write access to the official database should be restricted to a small number of users. The users with write access should be properly trained prior to receiving access.

INADEQUATE CHANGE MANAGEMENT

Change management, as it relates to Facility Ratings, are the management processes and controls that enable Facility and Equipment Rating changes to be captured, coordinated and implemented throughout an entity. This is often done across multiple models, departments and entities. Without a well-refined change management process, inaccuracies in Facility Ratings will most likely occur. This can often be seen when changes have been made in the field and there are no clear steps to record the changes through a written and recorded process. A strong change management process helps ensure that Facility Ratings are based on the equipment installed and energized. Clear roles and responsibilities should be assigned for a strong change management process to be effective. A Strong change management process should also include a quality review process for each change. Quality assurance personnel should be well trained and knowledgeable in the entity’s Facility Rating Methodology. There should be a clearly documented process with measurable expectations where any work is being performed. As with the prior mentioned themes, frequent walk-downs are recommended as equipment can be changed or modified over the years for various reasons. Another practice for entities to consider is bringing in outside experts to perform walk-downs as a form of peer review.

Facility Ratings programs can be difficult to design, implement and maintain, however, there are multiple best practices that can alleviate the challenge. One of the most effective is periodic walk-downs of entity’s facilities to ensure that all equipment in the field is accurately recorded and modeled in an official database. A well-documented process to track changes to equipment in the field is essential to maintain accurate Facility Ratings. Proper training and quality assurance will also help maintain accuracy of Facility Ratings and further ensure the reliability of the BPS.

Reference: SERC Report: Facilities Ratings Themes and Lessons Learned

For question or comments, reach out to GDS.

Justin Monk or Chris White