New Cold Weather Standard: Generator Preparedness in Extreme Cold Weather

The North American Electric Reliability Corporation (NERC) has filed a petition requesting the Federal Energy Regulatory Commission (FERC) to approve its proposed reliability standard EOP-012-1, which would add to reliability standard obligations of NERC-registered Generator Owners with respect to extreme cold weather preparedness, including freeze protection measures for both new and existing generating units, enhanced cold weather preparedness plans, and annual training. A bullet summary of key aspects of the proposal is below. Comments on this proposal must be filed with FERC no later than December 1, 2022.

Applicability. Subject to limited exemptions, proposed EOP-012-1 would be applicable to blackstart units and Bulk Electric System generating units that commit or are “obligated to serve a Balancing Authority load pursuant to a tariff obligation, state requirement as defined by the relevant electric regulatory authority, or other contractual arrangement, rule, or regulation, for a continuous run of four hours or more at or below a temperature of 32 degrees Fahrenheit (zero degrees Celsius).”

Extreme Cold Weather Temperature. Each applicable Generator Owner would be required to determine the Extreme Cold Weather Temperature for each of its applicable generating units, and to review and update that calculation every five years.

• Extreme Cold Weather Temperature means “the temperature equal to the lowest .2 percentile of the hourly temperatures measured in December, January, and February from 1/1/2000 through the date the temperature is calculated,” specific to the location of the generating unit. 

Freeze Protection for Existing Generating Units. Each Generator Owner with an existing generating unit would be required to add new or modify existing freeze protection measures to provide capability to operate for at least one hour at the Extreme Cold Weather Temperature. Where the generating unit is not capable of operating at the Extreme Cold Weather Temperature for at least one hour, the Generator Owner would be required to develop and implement a Corrective Action Plan for the identified issues.

Freeze Protection for New Generating Units. For generating units with a commercial operation date after the standard’s effective date, the Generator Owner would be required to “[i]mplement freeze protection measures that provide capability to operate for a period of not less than twelve (12) continuous hours at the Extreme Cold Weather Temperature for the unit(s), assuming a concurrent twenty (20) mph wind speed on any exposed Generator Cold Weather Critical Components,” or explain why it is not technically able to do so.

• Generator Cold Weather Critical Component is “[a]ny generating unit component or associated fixed fuel supply component, that is under the Generator Owner’s control, and is susceptible to freezing issues, the occurrence of which would likely lead to a Generator Cold Weather Reliability Event.”

Preparedness Plans and Training. Updating existing requirements in EOP-011-2 that will be moved to EOP-012-1, NERC proposes that a Generator Owner be required to:

• Implement and maintain cold weather preparedness plans documenting its Generator Cold Weather Critical Components and addressing freeze protection measures, annual inspection and maintenance for such measures, and identification of cold weather operating parameters, including fuel considerations and operating temperatures; and
• Provide training on such plans.

Generator Cold Weather Reliability Event. A Generator Owner that experiences a Generator Cold Weather Reliability Event would be required to develop a Corrective Action Plan to address the issues leading the event. Such events include:

• Forced derate of more than 10% of the total capacity of the unit and exceeding 20 MWs for longer than four hours in duration;
• Start-up failure where the unit fails to synchronize within a specified start-up time; and
• Forced Outage.

Implementation. As proposed, the standard would become effective approximately 18 months after FERC approval. Generator Owners would have additional 42 months from the effective date to comply with the new freeze protection measures requirements, and 60 months from the effective date to perform their first five-year update of the Extreme Cold Weather Temperature.

Generator Owners should consider whether these new requirements would be acceptable and, if not, consider filing comments in advance of the December 1 deadline.