Cold Weather Considerations – Looking Ahead to the Highlights
This week the final ballot results were announced for the three standards being revised to enhance cold weather preparedness. All passed the Registered Ballot Body votes and will now go to the NERC Board for approval. The development of these standard revisions was put on a fast track given the dramatic consequences of the lack of preparedness last winter. A prime example of impeccable foresight if not efficiency of the process is the Standard Authorization Request to initiate these changes was filed in September of 2019 and was accepted by the Standards Committee in September 2020.
The three standards proposed for revision are:
EOP-011-2 – Emergency Preparedness
IRO-010-4 – Reliability Coordinator Data Specification and Collection
TOP-003-5 – Operational Reliability Data
Of particular interest to generators are the requirements R7 and R8 in EOP-011-2 that mandate “one or more cold weather preparedness plans.” For many generators, this is a non-issue they have had such plans for years. Insulation and heat tracing are inspected and repaired as necessary during annual maintenance outages. The plans also include securing roll up doors to minimize chilling winds, constructing temporary barriers around level sensing devices, and making sure portable heaters are assembled and ready to deploy. Ongoing monitoring of the heat tracing systems is also part of routine operator checks.
A tweak or two in the plans may be in order, especially around the documentation of minimum and historical operating temperatures and an engineering analysis of cold weather performance. Another tweak could be characterized in R8 that requires generator unit specific training to maintenance and operator personnel. This former operator’s experience was being handed a clipboard with checks for power and continuity at about twenty heat tracing panels around the boiler structure and sent on my way. Actually finding the panels was part of the education. Although arguably effective, this manner of training will not satisfy the new requirements. There are not an infinite number of freeze protection applications so we may find a general training overview of those types supplemented by site specific applications will be effective.
Another interesting feature of EOP-011-2 is Requirement 22.214.171.124 that ensures “fuel supply and inventory concerns” are included in the preparedness plans. Gas-fired generators in Texas will especially enjoy this one and they will likely include various versions of concern that will read something like, “Concerned that gas supply will stop.” They have no control over that but as we all know, auditors will check to make sure those concerns are included.
As with all reliability standards and requirements directed at Generator Owners and Generator Operators, there is little to no distinction (CIP standards excepted) between nuclear power plants, thermal plants, or renewables. This generalization has caused thousands of instances of confusion over the years, and it may be time to consider distinct standards for distinct technology types.