Guidance for Extreme Weather Risk

By Tyler Espino, O&P Compliance Analyst & William Braun, Senior Risk Assessment Engineer

The 2024 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP IP) updated the weather response Risk Element from Cold Weather Response to Extreme Weather Response, which includes extreme cold weather, hot weather, storms, and geomagnetic disturbance events. The Standards falling under this Risk Element are EOP-011-2, EOP-012-1 (when it becomes effective), and TPL-007-4 (added in 2024). Between these three Standards, nearly all registered functions have at least one applicable requirement. Consequently, any Balancing Authority (BA), Transmission Operator (TOP), Generator Owner (GO), and Generator Operator (GOP) on the 2024 audit/spot check schedule will likely see at least one of these Standards in scope.

It is important to develop and implement preventative and detective controls, as well as corrective actions, to reduce reliability risks. With that in mind, Texas RE has developed guidance on these Reliability Standards that entities could consider implementing for applicable EOP requirements.

EOP-011-2 R7 requires each GO to implement and maintain one or more cold weather preparedness plan(s) for its generating units. Entities should consider implementing internal controls involving the following: 

• Consider what controls are in place to ensure personnel know how the cold weather preparedness plans are related to other processes and procedures, specifically the IRO-010-4 and TOP-003-5 data specification requirements that require the same data documented in the cold weather preparedness plan(s) to be provided to the Reliability Coordinator (RC)/BA/TOP. The Cold Weather Preparedness FAQ addresses the data specifications in Q17, stating that capability and availability should correlate to the data specifications and this is not a one-time submission.[1]
  
  
• Consider what controls are in place to determine when cold weather data and data for the geographic location should be re-evaluated and updated.

EOP-011-2 R8 requires each GO in conjunction with its GOP to identify the entity responsible for providing generating unit-specific training, and that identified entity shall provide the training to its maintenance or operations personnel responsible for implementing cold weather preparedness plan(s) developed pursuant to Requirement R7.  Entities should consider implementing internal controls involving the following: 

• Identify the roles of the GO and the GOP by addressing their responsibilities for providing generating unit-specific training. Having a clear understanding of the roles and responsibilities will set clear expectations for each entity, which will boost operational efficiency, transparency, and accountability. Both GOs and GOPs should document the agreement it has with the other entity and periodically verify that the roles and responsibilities have not changed.
  
  
• Once the entity responsible for providing the training has been identified, the entity should identify the operations and maintenance personnel responsible for implementing the cold weather preparedness plan(s), including third-party contractors.
  
  
• For new entities, ensure that all operations and maintenance personnel responsible for implementing the cold weather preparedness plan(s) are trained prior to the entity’s date of registration.
  
  
• For new operations and maintenance personnel responsible for implementing the cold weather preparedness plan(s), ensure that training is provided within a reasonable time and prior to completing activities related to implementing the cold weather preparedness plan(s). 
  
  
• If the cold weather preparedness plan(s) are revised, ensure that the operations and maintenance personnel responsible for implementing the cold weather preparedness plan(s) are provided updated training within a reasonable time and prior to completing activities related to implementing the cold weather preparedness plan(s).
  
  
• Ensure that records demonstrating the completion of training include, at minimum, the name of personnel being trained, date on which the training took place, and the training materials provided.
  
  
• Consider an internal control to determine if the plans are producing the results expected when they are used. This may impact other standards (such as IRO-010-4) by verifying that data from the cold weather preparedness plan(s) is provided as required in the RC/BA/TOP data specifications, for example.
  
  
• Ensure that all operations and maintenance personnel responsible for implementing the cold weather preparedness plan are provided generating unit-specific training pursuant to Requirement R7, and as written in the cold weather preparedness plan(s).

This requirement includes cold weather conditions, in addition to extreme weather conditions, for TOPs with EOP-011-2 R1 in scope. TOPs should consider how they will define when weather is, or is expected to be, extreme verses normal or bad weather as appropriate for the area in which the TOP operates. Consider how and when the grid conditions resulting from extreme weather would meet the definition of an operating Emergency (see the NERC Glossary of Terms). TOPs should also consider controls around how the actions used to prepare for and mitigate Emergencies are documented. Lastly, TOPs could implement a periodic detective control to gather and evaluate the EOP processes during an Emergency. This would help identify areas that require corrective actions or plan revisions.

While the focus in Texas has been on cold weather over the last few years, extreme heat and other weather-related events can also impact reliability. Entities are encouraged to not just look at whether they are compliant with the related standards, but also review the related internal controls to see the relationship between different Reliability Standards to help improve reliability as a whole.

[1] The Technical Rational for EOP-012-2 echoes the Cold Weather Preparedness FAQ regarding this point when it states, “…a requirement for the GO to document this information within the cold weather preparedness plan ensures the information is readily available and documented when the GO responds to a data specification.”