Regional entities and utilities have a lot to gain by taking a collaborative rather than an adversarial approach to compliance with NERC’s new extreme winter weather standards, participants in a ReliabilityFirst webinar said on Monday.
The webinar was part of the RE’s regular “Technical Talk with RF” series. RF’s Brian Thiry said in his introduction that RF staff had jokingly dubbed the event “Christmas in July” because of its focus on “all things cold weather,” particularly the new standards that began to take effect earlier this year.
Topics included NERC’s first Level 3 alert, issued earlier this year after the ERO’s Board of Trustees approved it at its meeting in May. (See “ERO to Issue First Level 3 Alert May 15,” NERC Board of Trustees/MRC Briefs: May 10-11, 2023.) The alert requires registered entities to provide NERC an extensive set of information by Oct. 6, including their total net winter capacity and how they have prepared their systems for cold weather. It also identified eight essential actions for entities to take to prepare for cold weather, although implementing them is voluntary.
Darrell Moore, NERC’s director of situation awareness, emphasized the importance of abiding by the Level 3 alert in his presentation, stressing that “it has become increasingly important to understand how entities have taken steps to prepare for extreme weather conditions” in light of the storms that caused widespread power outages in the last two winters.
RF representatives also talked up their organization’s cold weather winterization (CWW) program, which is intended to help registered entities with their winter preparations by having RF consultants visit generating plants to check their weatherization measures personally.
Staff emphasized that despite the CWW program’s reliance on site visits and audits, it is not part of the RE’s compliance monitoring and enforcement program; nor is it intended to formally certify a generating facility’s preparedness for winter operations. Rather, the aim of the program is to inform and educate generator owners and operators in what RF’s Senior Reliability Consultant Joseph Jagodnik called “a more relaxed, constructive and forward-looking atmosphere.”
This year’s program will focus on plants commissioned in 2023, along with existing generation that has experienced a cold weather-related outage. The RE will send out a survey in late summer or early fall to identify site candidates, with visits to follow from late October through mid-December. Visits are expected to last a day with two to four RF staff members on site.
Nicholas Poluch, senior manager of NERC relations at Talen Energy, joined the webinar to describe a visit last year by CWW staff to the utility’s Lower Mount Bethel plant in Pennsylvania. He credited the RF team with helping Talen reorganize its winterization operations and consolidate its compliance program.
“I think overall, [there was] a lot of benefit, not only to this plant, but we took the ideas that RF gave us for this facility and rolled them out across the fleet, and I think it really upped our game,” Poluch said. “I think we as an organization [also] became more accountable [on] weatherization and more disciplined in implementing it. We were doing stuff [before], it just wasn’t to the same level as, say, our protective systems program.”
RF staff encouraged utilities to take advantage of the CWW program, describing it as a chance to put RF’s knowledge and experience to work for their benefit. Thiry said it fits into the RE’s goal of being a partner to the industry, rather than solely an enforcement mechanism.
“Our winterization program is … something we take a lot of pride in, and it’s something that we do want to continue to grow and expand upon,” Thiry said. “At the end of the day, what matters to ReliabilityFirst is that you are reliable, resilient and secure. So if there’s any consulting work that we can do with you before or after an audit engagement, we’d love to engage with you on that.”
