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Southern Energy Watch

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Eo reporter Cai Yixuan

Editor Chen Yifang

Review Jiang Li

In mid-February, 2024, a super cold wave hit East Asia and North America. The cold wave not only affected the power generation process, but also the production and transportation of natural gas. Due to the low temperature, the load of heating and other items will increase, and the spare capacity will also decrease. The power supply shortage caused by the cold wave exacerbates the power grid operators' challenges in ensuring supply.

On February 14, 2024, the Federal Energy Regulatory Commission (FERC) approved two new North American Electric Reliability Corporation (NERC) Reliability Standards for winter weather operations and preparedness: EOP-011-4 (Emergency Operations) and TOP-002-5 (Operating Planning). The new requirements on generators and grid operators to ensure power during winter events follow recommendations from a NERC investigation into the causes of the 2021 Texas power outages. The actions taken in the wake of the winter storm to hit North America could provide other regions with lessons learned on how to assess winter readiness and prepare for winter weather emergencies, such as how to assess winter readiness and winterize equipment.

Since 2022, NERC has formulated a new batch of extreme cold weather power reliability standards in two phases. Currently, 4 standards have been approved by FERC. The focus of the reliability standard is to summarize experience in dealing with severe weather, ensure that there are enough generator sets in cold weather, ensure reliable operation of the power system, and prevent similar incidents. The recently approved EOP-011-4 and TOP-002-5 are the results of the second phase of NERC.

EOP-011-4 pertains to emergency operations. FERC said the standard will improve the way grid operators coordinate manual load shedding and automatic load shedding in emergency operating plans, with a view toward minimizing the need for manual load shedding. Normally, in the course of normal system operation, if the system is in a coordinated operating state, relevant parameters can be automatically adjusted to adapt to changes in load. However, in the event of an accident, sudden changes in operating conditions or inconsistencies between parameters may cause the system to exit coordinated operation, and auxiliary equipment may switch from automatic control to manual operation. At this time, general experience is unlikely to be able to guide operational adjustments under complex operating conditions, and manual load shedding operations are prone to error, increasing the risk of operational errors leading to an expansion of the accident.

The TOP-002-5 standard covers preparation and operations for extreme cold weather. The standard requires power generators to develop anti-freezing measures and cold-weather response plans, conduct annual training, review failed units and develop a Corrective Action Plan (CAP) to address freezing problems. In addition, FERC requires power generators to provide cold-weather operating parameters to system operators and Balancing Authorities (BA) for analysis and planning.

Today, natural gas generation is dominant in many regions of North America, and the shortage of natural gas supply is one of the significant reasons for the blackout in Texas during the 2021 winter storm. Therefore, protecting critical natural gas infrastructure for gas-fired power plants by treating natural gas facilities as critical loads is an essential consideration for NERC in developing reliability standards.

EOP-011-4 requires that market operators shall ensure the supply of electricity for natural gas infrastructures in cases of emergency, with the market operators and balancing responsible parties implementing emergency management plans, and the regional reliability coordination organization coordinating the implementation.

NERC proposes, first, that utilities and transmission operators participating in Under-Frequency Load Shedding (UFLS) be designated as responsible entities under Reliability Standard EOP-011-4. Second, EOP-011-4 would require utilities to prioritize certain natural gas infrastructure in their load-shedding plans to avoid those facilities from experiencing power outages. The balancing authorities would have to exclude certain critical natural gas infrastructure from interruptible, curtailable, and demand response programs during cold weather events.

Standard TOP-002-5 requires the balancing responsible entity to develop an operating procedure for cold weather that includes methods for identifying extreme cold events, methods for forecasting reserve capacity during extreme cold events (which considers generator limitations), and methods for forecasting the expected hourly operation of each unit over a five day horizon that considers all factors relevant to the operation.

FERC said ensuring that natural gas infrastructure performs during cold weather will help ensure that gas-fired generation is available to reliably operate the electric grid. Under the plan, utilities would have 30 months to develop the plans, but some of the mitigation measures would not need to be implemented for three years.

Prior to the approval of these two reliability standards, NERC had also issued reliability standards EOP-011-3 and EOP-012-1, which were approved by FERC in February 2023.

EOP-011-3 is intended to ensure that a TSO is adequately prepared for an emergency and mitigates the risks associated with load shedding. Emergency events to be considered include a complete substation blackout, inter-area electricity import limits, extreme load, wind and solar generation sensitivity analysis, and gas pipeline failures. Similar to EOP-011-4, it requires system operators to consider the combined manual and automatic load shedding in their emergency operating plans, minimizing manual control actions to shed load.

EOP-012-1 is a prequel to TOP-002-5, which is a standard designed to ensure Transmission Owners develop and implement plans to mitigate the reliability impacts to their generator fleet during extreme cold events. This standard contains seven requirements, the four most notable are described below.

The third provision requires electricity market operators to take precautions to prevent the freezing of all applicable equipment based on each equipment’s applicable temperatures and to ensure the equipment will operate under extreme cold temperatures. The fourth provision requires operators to develop cold weather preparedness plans and conduct annual training. The fifth provision requires the operator to review every five years the extreme cold weather temperature calculations, cold weather preparedness plans, and freeze protection measures to determine the need for modification or updating.

The last requirement requires generating units that have experienced forced power outages, start-up failures, or forced power outages due to freezing to develop a corrective action plan (CAP). The corrective action plan must include the cause of the unit failure, a review of similar unit equipment, and a cold weather response plan. If the generator unit fails to implement the corrective action plan, the generator must