The temperature outside may not be an indication, but winter is on the mind for much of the power
generation industry after the North American Electric Reliability Corporation issued its Level 3 Cold Weather Alert in May, the first of its kind.

This alert serves as a reminder of the critical importance of preparedness and proactive action for power
plant operators to ensure reliable electricity supply during extreme weather events. Below, Kevin Salsbury, NERC Compliance Director for EthosEnergy, helps highlight the reasons behind the alert and discuss key actions required by plant operators to navigate the cold weather successfully.

Q. This is the first time NERC has issued a Level 3 Cold Weather Alert. What is it and why is it so important?

A. After the wake of the 2021 FERC/NERC Joint Inquiry Report, extreme weather events occurred again – winter storms Elliott (2022) and Uri (2021) – that showed the progression of cold weather prevention efforts were still lacking and data on current implementation efforts (i.e., EOP-012), not available. The NERC Level 3 Cold Weather Alert was issued in response to these issues and forecasted future weather conditions that may adversely impact power system reliability.

For example, cold weather can introduce unique challenges beyond just freezing conditions. Limited or reduced transportation, safety concerns from ice or snow, and increased energy demand for heating purposes can strain power generation infrastructure, leading to potential disruptions and service outages. Level 3 cites these concerns must be acknowledged and essential actions taken to ensure a secure and reliable power supply.

Q. None of the requirements of the NERC Alert will be enforceable until October 2024. Why is EthosEnergy advising operators to achieve completion of the actions by October 2023? 

A. While none of the requirements will be enforceable until October 2024, EthosEnergy is strongly advising operators to achieve completion of the six essential actions by October 6, 2023 to support the purpose of the alert and strive for early implementation to stay ahead of the various effective dates of the requirements.

Also, the responses to NERC Alerts are tracked and recorded. They act as an additional tool for regional organizations such as the Texas Reliability Entity and the Western Electricity Coordinating Council to use to further understand and plan for risks to the bulk power system (BPS) that could impact the footprint they operate within. We believe all in the industry should be trying to best support one another.

Q. Can you tell us some ways operators can start to more quickly comply with the NERC Alert?

A. First, get knowledgeable on current NERC tools for extreme cold weather temperature calculation. That is key. Operators should review their current freeze protection measure maintenance program activities and the equipment with which these activities are being completed to prevent cold weather impacts.

Also, understand how local plant personnel are evaluating operations through root cause analysis (RCA) and tracking remediation and mitigation activities at their facility, specifically during the Winter months (December – February). Finally, evaluate your current communication “profile” with your reliability coordinator, balancing authority, and/or transmission operator to determine how much or how little you talk with these entities during winter months or emergency events and adjust your communication strategy as needed.

Source: EthosEnergy.

Q. What are the risks to operators if they do not take heed of NERC’s cold weather warning?

A. As previously mentioned, the responses to this alert will be recorded and used by NERC and other regional power entities to better understand and proactively respond to potential risks facing the BPS. Not addressing the essential actions may also lead to increased scrutiny on a facility by regulators. 

Additionally, not being fully aware of your facility’s critical equipment capabilities for cold weather operations could result in: shortened lifespan of equipment due to lack of preventative maintenance, decreased scope awareness of equipment failure, and long outage and recovery times during Winter months.

Q. How is EthosEnergy helping operators prepare and respond to the alert?

A. There are three ways we are helping or counseling our customers to prepare and respond. One, we recommend that all owner/operators review the essential actions in detail and calculate their Extreme Cold Weather Temperature (ECWT). If a plant needs help with that, EthosEnergy can support them. Two, inventory all of your plant’s critical components. We have developed an audit method to assist. It cannot be said enough that it is vital to know how extreme cold weather can impact your facility as a whole including operations, equipment, instrumentation, communications, and safety. The audit results allow plants to take immediate action and comply where needed. Three, evaluate and learn from what happened during a previous weather event.

Establishing a process/mechanism for identifying, evaluating, and tracking cold weather reliability events, including extent of condition reviews of impacted critical components and knowing how you handled it in the past, can lead to potential improvements in your RCA process to generate adequate corrective action plan evidence.

Q. Anything else operators should consider when evaluating winterization solutions?

A. When evaluating winterization solutions, especially through the new EOP-012 standard and definitions, generator operators need to be more diligent in their evaluations of equipment and systems, and other areas of plant vulnerabilities that may experience freezing problems or other operational issues to determine applicability. This includes ensuring adequate justification for inclusion and/or exclusion of equipment from scope. Leverage existing NERC and regional entity guideline documentation (i.e., NERC Reliability Guideline – Generating Unit Weather Readiness) to further educate staff and leadership on what industry expects from generation plants. These documents provide lists of equipment types for consideration and evaluation steps. In the end, this is a critical defense strategy for your inventory of cold weather critical components and mapping of freeze protection measure maintenance activities.

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