It’s Time to Address Generator Frustrations with FAC-008
For anyone, especially Generator Owners, who has been involved in compliance with the NERC Reliability Standards in the past few years, the FAC-008 Facility Ratings standard has become a bit of a running joke. It has been one of the most violated Operations and Planning standards since the inception of mandatory standards, partially due to its questionable application to generators. The term “facility rating” has historically been a transmission term and is quite useful for static-type equipment with few moving parts. Generators, and most particularly thermal-powered generators, have hundreds of moving parts and are anything but static, making it difficult to meet the standard’s facility rating requirement.
However, documenting a series of individual component ratings, including electrical and mechanical limitations, and identifying the most limiting element as the facility rating is awkward at best. This exercise is marginally useful since on any given day, the facility may not be capable of the rated output. At some point, the standard evolved to only consider electrical components in the facility rating which, given other limitations, could cast the rating into the category of “questionable accuracy.”
Some have suggested MOD-025 R1 would be far more useful data, and we agree.
One of the suggested changes to FAC-008 from the Facility Ratings SAR Project 2021-08 is:
“Alter the language within FAC-008, R1 to explicitly allow the inclusion of non-electrical components in Generator Facility Ratings documentation.”
The term “allow” is a noble effort to permit the non-electrical components into the mix for most limiting elements. If that is what happens, and Generator Owners can tack on something like the nameplate power output of their steam turbine to their components, then great. If the option becomes an expectation by auditors that all Generator Owners need to account for potential limitations of non-electrical components, then there will be problems.
You can imagine the challenges of documenting the capability of any system that could prevent the facility from achieving full output. Examples that come readily to mind are turbine steam condensers, generator hydrogen cooling systems, fuel handling systems, ash handling systems, and electro-hydraulic control systems. There are many other examples, based on the facility type, that could make it hard for Generator Owners to account for all possible limitations.
Our hope is that the suggested and needed change to the requirement is concise and easily achievable. It should be. Generator Operators have enough challenges without the ongoing difficulties of FAC-008 compliance.