Starting Oct. 1, 2024, numerous requirements and definitions within the Cold Weather and Preparedness (EOP-012-2) NERC Reliability Standard will become effective.

In May, in preparation for EOP-012-2, the ERO Enterprise hosted Cold Weather Preparedness Small Group Advisory Sessions, and on Sept. 3, NERC posted a Frequently Asked Questions (FAQ) document.

The FAQ includes stated definitions and responses to a total of 108 questions providing clarification across many new elements introduced in the EOP-012-2 standard. The FAQ also summarizes the additional clarification and revisions that are required by FERC by March 27, 2025.

The NERC standards drafting team is working on required modifications and the proposed project timeline is available here: Project 2024-03 Revisions to EOP-012-2 (nerc.com).

A few highlights from the FAQ document include the following:

• For larger entities, it’s permissible to have an overarching winterization plan, but for any fleet with multiple locations, this means each specific plant needs its own, site-specific plan for cold weather preparedness.
• EOP-012-2 requires entities to identify their Generator Cold Weather Critical Components. NERC defines these as “any generating unit component or system, or associated Fixed Fuel Supply Component, that is under the Generator Owner’s control, and is susceptible to freezing issues, the occurrence of which would likely lead to a Generator Cold Weather Reliability Event. This definition excludes any component or system or associated Fixed Fuel Supply Component located inside a permanent building with a heating source that regularly maintains the space at a temperature above 32 degrees Fahrenheit (0 degrees Celsius).”
• In addition to identifying critical components, entities must document the necessary freeze protection measures implemented or identified in Corrective Action Plans. Annual freeze protection measures are also required to be both inspected and maintained on an annual basis. All efforts around inspection, maintenance and Corrective Action Plan review/implementation should be well-documented and easy to understand under a third-party review.

RF encourages all entities to familiarize themselves with the full NERC FAQ document and develop a control to monitor the future changes based on the established FERC timeline. For additional information on EOP-012-2, RF discussed this standard on Tech Talk in December 2023, May 2024 and July 2024, as well as in an April 2024 newsletter article. Those resources are linked below.

• Tech Talk: RF EOP-011 and Future EOP-012 On-Site Walkdowns (Dec. 18, 2023)
• Tech Talk: GO and GOP O&P Standards (May 20, 2024)
• Tech Talk: RF Winter Recap of Conventional Unit Performance During the Winter of 2022-2023 (July 15, 2024)
• Newsletter: Continuous Improvement: Freeze protection requirements and winterization best practices (April 2024)

If you have any questions regarding the EOP-012-2 standard or implementation, or if you’re interested in a voluntary on-site Cold Weather Winterization visit outside of Compliance Monitoring engagements, please visit the RF Winterization webpage to request a visit.