Updated: Jul 18
As an electrical engineer with more than 50 years of experience designing and operating electric power systems, I’ve observed the development and implementation of NERC’s Reliability Standards. In this new series, I use my expertise and experience to outline concerns with and improvements to NERC Reliability Standards.
This article focuses on FAC-008-5 – Facility Ratings. First, I’ll list my concerns with the standard; then I’ll outline recommended actions to improve its effectiveness.
NERC FAC-008-5 Stated Purpose
The stated purpose of NERC FAC-008-5 is:
“To ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on technically sound principles. A Facility Rating is essential for the determination of System Operating Limits.”
Concerns with FAC-008-5
FAC-008-5 lists Requirements and Measures, Compliance, Violation Severity Levels, etc. in a manner that makes barristers proud. However, if a reliability standard is to be effective, it must be written in the jargon of the user, in this case, electrical engineers.
Electrical engineers focus on circuits, schematics, volts, amps, and ohms rather than on documents that are composed in legalese. Electrical engineers often begin with a schematic drawn on scrap paper, add squiggly lines, dots, numbers, and names. Then, they share their ideas with others and develop wiring drawings, connection diagrams, cable lists, and everything else needed to build a transmission line, a substation, or an energy production facility.
Because of the disconnect between the legalese style used in NERC’s reliability standards and the way that engineers work, reliability standards are not always implemented effectively. Let’s take a closer look at two main concerns with FAC-008-5 and NERC’s Reliability Standards in general.
Concern 1: Silo Mentality
Facilities are designed and operated by teams that work in silos:
Substation engineers design substations.
Transmission engineers design transmission lines.
Mechanical engineers design power plants.
System operators monitor electric power grids.
Each group has their own thought process and definition of success. They have limited knowledge of other group’s work practices, and often feel that they alone are subject matter experts.
Concern 2: Lack of Input from Varied Subject Matter Experts
A variety of different specialists and subject matter experts, besides electrical engineers, should make essential contributions to the performance of electric facilities. These include metallurgists, material scientists, and meteorologists. Unfortunately, these experts are rarely consulted, and were not included in the development of FAC-008-5.
An example of a lack of essential input to electric utility regulations occurred in the 1990s, when OSHA developed requirements for personal protective equipment (PPE) for switchmen. The new regulations, published in the Code of Federal Regulations (CFR), required that electric utilities provide PPE to minimize danger to switchmen when an arc flash occurs during a switching operation.
As electric utilities opposed the development of these regulations, energy release was calculated in scientific values (calories) rather than in electric nomenclature (watt-seconds). Measuring energy deposit in calories is effective but is not quite right for a standard relating to electric utility workers.
Improvements to NERC FAC-008-5
The following actions will substantially improve the effectiveness of FAC-008-5.
1. Add the requirement that current be monitored in each phase of each circuit breaker.
Impedances in switchyards are calculated in micro-ohms. Increased contact resistance, as little as 20 micro-ohms, in disconnect switches and circuit breakers can cause unequal current splits that are not detected when only facility current is monitored. This can be an issue in substations with double breaker – double bus, as illustrated in Figure 1, or double bus – breaker and one half switchyards, shown in Figure 2.
Figure 1 is a single line drawing of a double breaker – double bus switchyard.
Figure 2 is a single line drawing of a double bus, breaker and one-half switchyard.
2. Add the requirement that transmission system owners must prepare sketches that show each current carrying component in each switchyard that is part of a facility.
As the old saying goes, a picture is worth a thousand words. In Figure 1, does Facility TL1 include AB1 and AB4? A sketch would easily answer this question.
3. Add the requirement that every current carrying component in every switchyard be included as part of a designated facility.
No components can be orphaned, that is, not part of a designated facility. High voltage buses, shunt capacitors, shunt reactors, and static var compensators need to be designated as facilities with established current ratings.
Struts that are used to connect high buses to low buses are a frequently overlooked component. Another overlooked component is future facilities. For example, in Figure 3, are AB6 and AB7 installed and being used as a connector until the future facility is installed? Requiring every component be part of a designated facility would answer this question.
Figure 3 is a single line drawing of a ring bus switchyard.
4. Add the requirement that multiple parties contribute to the process of developing reliability standards.
Industry groups, such as IEEE, require that standards are developed with input from a wide range of experts. Other industries recognize the need for input from multiple parties when creating regulations.
When electric utilities develop reliability standards for themselves, potential issues are overlooked or ignored. Other important participants in the development process include equipment manufacturers, engineering firms, and researchers at universities. These groups should be invited to assist in the development of NERC reliability standards.
Including “outsiders” with a next generation mindset in the development of NERC reliability standards will increase effectiveness. FAC-008-5 requires that electric utilities determine facility ratings and submit the ratings to transmission system operators. A next generation mindset would, for example, mandate the development of visual aids that assure that every subcomponent is included, and every flow path is considered.
Experience Shows: Collaboration Leads to Improvement
Throughout my 50+ years in the electric utility industry, I’ve had quite a few opportunities to clean up messes and repair damage. I’ve experienced the benefits of working across industry lines while working in the nuclear power industry, and from working with material scientists and metallurgists on cross-industry projects.
It’s time that FERC, NERC, and electric utilities implement a mindset of collaboration, and use this mindset to update NERC Reliability Standard FAC-008-5. It is vital that these entities understand that wide area blackouts will occur until root cause issues are addressed.
A better purpose statement for this standard would be:
“To ensure that Facility Ratings used in the reliable planning and operation of the Bulk Electric System (BES) are determined based on technically sound principles that include facility boundaries. A Facility Rating is essential for the determination of System Operating Limits.”
In our next article in this series, concerns and improvements to NERC Reliability Standard CIP-014, Physical Security will be presented.