FERC, NERC and Regional Entities Technical Conference: Improving Winter-readiness of Generating Units

11:30 a.m.

Opening Remarks and Introductions

Chairman Glick and Commissioners

11:45 a.m.

Panel 1:  Cold Weather Preparedness Plans (150 mins.)

Extreme cold weather has resulted in four major system events in the last ten years that jeopardized the reliable operation of the bulk-power system.  During each of the events, unplanned generating unit outages contributed to the energy emergencies, and in three of the four events, triggered the need for firm load shed.  During the February 2021 Cold Weather Event (2021 Event), large numbers of generating units experienced outages, derates, or failures to start, resulting in energy and transmission emergencies affecting millions of electricity customers throughout the Midwest and South central states.  The top two major causes were the freezing of generator components and fuel issues (primarily natural gas fuel issues).  By April 1, 2023, Generator Owners (GOs) will be required to have cold weather preparedness plans to improve bulk-power system reliability.  Many GOs already have cold weather preparedness plans.  Panelists will discuss GO and Generator Operator (GOP) best practices for cold weather preparedness plans. 

1. What are the characteristics of cold weather preparedness plans of GOs/GOPs that successfully performed throughout the 2021 Event?  For example, why did some GOs/GOPs of certain types of generating facilities fare better than other GOs/GOPs of similar facilities during the 2021 Event in the Electric Reliability Council of Texas (ERCOT)? 
2. Discuss the elements of effective cold weather preparedness plans including:
   1. Freeze protection measures based on geographical location and plant configuration,
   2. Inspection and maintenance of freeze protection measures, and
   3. Planning for adequate fuel supply throughout the winter and contingency plans to alleviate potential operating limitations during extreme cold events.[1]
3. Describe how you consider the effects of precipitation in your cold weather preparedness plan.  Are there specific methods or measures that help to ensure performance during winter precipitation for certain generation types?  For example:
   1. For each generation type (e.g., combustion turbine, combined cycle, steam turbine, boiler-turbine), or by fuel type of generation (e.g., natural gas, coal, fuel oil, etc.) – what processes, plans, or techniques are used to minimize precipitation impacts on the ability of the resources to produce electricity?
   2. For wind and solar generation – what processes, plans, or techniques are used to minimize precipitation impacts on the ability of the resources to produce electricity?
4. Describe how you consider the accelerated cooling effect of wind in your cold weather preparedness plan.  Are there specific methods or measures to mitigate the accelerated cooling effect of wind for certain generation types and locations (e.g., open-frame generating units found in warmer climate zones)?
   1. What processes, plans, or techniques are used to minimize the accelerated cooling effect of wind on the ability of the resources to produce electricity?
5. How do you use staffing or personnel to effectively operate (including conducting inspection and maintenance of freeze protection measures) as part of cold weather preparedness?  Does this include provisions for personnel to stay on site or for clearing/de-icing roads to maintain access to facilitate maintenance at multiple sites?
6. Describe the steps taken to ensure supplies (e.g., portable heating or other cold weather protection equipment and materials), and spare parts are available as part of your cold weather preparedness plan.
7. What role do checklists play in ensuring effective implementation of cold weather preparedness plans?
   1. Do you maintain winter preparedness checklists to ensure lessons learned from previous years are captured, problem areas are addressed, and all equipment is properly protected?  Please discuss.
   2.  What are the elements of a good winter preparedness checklist?
8. Discuss considerations when developing winterization techniques/plans.
   1. How long before the winter period are winterization plans finalized?
   2. After winterization plans are developed, how often and on what basis are they reviewed or modified?
   3. What factors are considered when developing or updating winterization plans (e.g., costs, timing of implementation for winterization techniques, short-term vs. long-term requirements)?
   4. What challenges are present when developing or updating winterization plans (e.g., cost considerations, staffing availability, safety concerns)?

Panelists:

1. Roger Morgan, Vice President of Operations, NRG Energy Inc.  | Presentation
2. Demitrius Davis, Vice President, Power Generation Operations Support, Entergy LLC 
3. Charlie Gates, Executive Vice President, Power Operations, Calpine Corporation  | Presentation
4. Thomas J. Kent, President and CEO, Nebraska Public Power District  | Presentation
5. Garry Waggoner, Senior Director of Engineering Services for Luminant Fossil and Renewables Generation  | Presentation
6. David Lemmons, Chair, Cold Weather Preparedness Working Group, North American Generator Forum  | Presentation
7. Travis Fisher, President and CEO, Electricity Consumers Resource Council 

2:15 p.m.

Break

2:45 p.m.

Panel 2:  Planning, Engineering, and Technologies for Cold Weather Preparedness (150 mins.)

In preparing for cold weather, engineering analysis is necessary to determine a generating unit’s operating parameters and limitations, including ambient temperature limitations, and to determine and maintain appropriate cold weather protection measures to be applied to components and systems for reliable operations.  These could include upgrades and modifications to facilities that can be made to improve generator performance during cold weather events, particularly for generators in warmer weather regions.  This panel, comprised of GOs/GOPs, equipment manufacturers, and vendors, will explore technologies that could improve cold weather preparedness of existing plants or in planning of future generation projects.

1. What is your definition or criteria for “cold weather” for your cold weather preparedness plan?  Has your region or operating area discussed such criteria?  
2. What are the challenges of implementing cold weather protection measures for generating units that were built to operate in warmer climates, and how can those challenges be met?
3. What do you consider when planning and engineering generating unit installations for cold weather operations and/or for advising GOs/GOPs about application of cold weather protection measures?
   1. With respect to ambient design temperature, how do you consider historic ambient temperatures at which the unit has operated, and historic ambient temperatures for the generating unit’s location?
   2. How do GOs determine the ambient temperature and other conditions (wind, precipitation) to use for purposes of implementing cold weather protection measures?
   3. How have engineering analysis and unit modifications helped your generating units in warmer regions remain online during extreme cold weather?  What re-design options may be feasible for GOs to prepare to operate at a temperature that is lower than the original plant design temperature?
4. In planning and engineering for cold weather conditions, how and when (e.g., in conjunction with equipment modifications) do you identify the components and systems requiring freeze protection?
5. Describe the various types of cold weather protection measures available and/or applied to generating units.  Are there types of protection measures that cannot be added after original equipment manufacture and installation?
6. Discuss any specific considerations of engineering, designing, and implementing cold weather protection measures for each generation type (e.g., combustion turbine, combined cycle, steam turbine, boiler turbine), or by fuel type of generation (e.g., natural gas, coal, fuel oil, etc.), including dual fuel. 
7. Discuss any recently-developed technologies related to cold weather preparedness or freeze prevention that you have implemented, or that you plan to implement in the future.
8. Describe the steps for testing, maintaining, and/or monitoring the status of cold weather protection measures, including any new technologies that aid in maintaining and/or monitoring the performance of cold weather protection measures.

Panelists:

1. J Kyle Olson, Director of Power Generation and Asset Management, El Paso Electric Company | Presentation
2. Steve Metcalf, Vice President, Power Production and Delivery, Arkansas Electric Cooperative Corporation  | Presentation
3. Amanda Frazier, Senior Vice President of Regulatory Policy, Vistra Corp.
4. Mark Spencer, Sr. Director, Analytics and Market Policy, LS Power Development  | Presentation
5. Allan Schurr, Chief Commercial Officer, Enchanted Rock Energy  | Presentation
6. Mark Dittus, Project Manager, Black & Veatch  | Presentation

5:15 p.m.

Closing Remarks

Day Two

11:30 a.m.

Opening Remarks

11:45 a.m.

Panel 3:  Implementing Cold Weather Preparedness Plans for Reliable Operations (150 mins)

Panelists will discuss ongoing measures for winter preparedness and operations to ensure reliability.  GOs/GOPs may implement elements of their cold weather preparedness plans ahead of winter as well as just before a forecasted cold weather event, e.g., checking insulation for gaps or checking that heat tracing is operational.  Also, more accurate weather forecasts can improve GOs/GOPs’ ability to plan and prepare for extreme cold weather events.  Transmission Operators (TOPs), Balancing Authorities (BAs), and Reliability Coordinators (RCs) may perform assessments ahead of the winter season to assess the availability and capability of generating units to be prepared for peak cold weather demands.  TOPs, BAs, and RCs also consider fuel availability for generating units as a cold weather event draws near, recognizing the proportion of natural gas-fired generation in certain regions.[1]

1. Excluding already installed or implemented cold weather protection measures (e.g., insulation, indoor construction), what seasonal measures do GOs/GOPs take to prepare just ahead of winter?  What nearer-term measures are taken, for example, given a few days’ notice of an oncoming storm?  What measures are taken during a winter event?  Are there other measures that could be implemented?
2. Discuss how GOs/GOPs incorporate weather forecasts into their preparations and how this incorporation has improved their operations.
   1. Discuss the sources of weather forecasts used and how these sources have improved your operations.
   2. What communications procedures (with fuel suppliers, pipelines, TOPs, BAs, and RCs) are implemented based on the forecasted temperatures?
3. Describe your practices for testing dual fuel units:  
4. How do you verify dual fuel operating capabilities under certain cold temperatures and weather conditions?
5. What operational capabilities are tested/verified during testing?
6. What are the timing requirements with respect to the proximity of the tests to the (winter) operating period, if any?
7. Are there barriers to testing dual fuel capabilities?  If yes, what are these barriers from GOs’/GOPs’ perspective and from TOPs’/BAs’/RCs’ perspective?

4. What steps do you take to verify that blackstart resources are operational prior to extreme cold weather events?

1. Does this include verification of operator availability and training?
2. How are you made aware of ambient operating temperature limitations of blackstart resources?
3. How do GOPs and GOs ensure that their blackstart resources are tested and able to start during cold weather?  

5. Describe how GOs/GOPs use technologies that assist in optimizing maintenance intervals, such as computerized maintenance management systems (CMMS), to support implementation of your cold weather preparedness plan?
6. Describe how BAs manage planned outages and maintenance of generation facilities during winter, make the decision to postpone planned outages in anticipation of forecast cold weather events, and consider peak load and GO/GOP fuel supply and inventory concerns when scheduling generation outages?
7. Discuss the ways (other than limiting generation outages) in which TOPs/BAs/RCs take fuel supply and inventory concerns into account when planning for winter peak or an extreme cold weather event?
8. How do GOs/GOPs take fuel supply and inventory concerns (including any upstream fuel supply concerns) into account (including for blackstart units) and what steps can be taken proactively to ensure they are able to meet capacity commitments for upcoming winter peak conditions and forecasted extreme cold weather events?
9. How can the NERC Guideline[2] related to fuel-related risks be improved and made more useful to generators, TOPs/BAs/RCs, and fuel suppliers?

Panelists:

1. Tom Vinson, Vice President of Policy and Regulatory Affairs, American Clean Power Association  | Presentation
2. Mike Knowland, Manager of Operations Forecast and Scheduling, ISO-NE  | Presentation | Statement
3. Andrew Valencia, Senior Vice President of Generation, Lower Colorado River Authority  | Presentation
4. Michael E. Bryson, Senior Vice President – Operations, PJM Interconnection  | Presentation | Statement
5. Aaron Markham, Vice President, Operations, NYISO  | Presentation
6. C.J. Brown, Director System Operations, Southwest Power Pool  | Presentation

2:15 p.m.

Break

2:45 p.m.

Panel 4: Communications, Coordination, Training, and Education for Cold Weather Operations (150 mins.)

Communication and coordination are critical in advance of and during extreme cold weather events.  Communication between GOs/GOPs and BAs/RCs regarding generating unit cold weather availability and capability is necessary to support a reliable grid.  This includes understanding when and how GO/GOPs and BAs/RCs communicate fuel supply and inventory concerns and the impact on generation availability as heating load increases.  Proper training of BA/RC and GO/GOP personnel is critical to ensure they will be prepared to take necessary actions before and during extreme cold weather events.  Finally, GOs/GOPs should take advantage of sources of best practices such as NERC Guidelines and joint FERC-NERC inquiry report recommendations (2011, 2018 and 2021). 

1. Discuss communication and coordination protocols between GOs/GOPs and BAs/RCs, in advance of and during cold weather conditions, on topics including generator readiness and availability/capability for winter peak operations (including any fuel supply risk).
2. How do GOs/GOPs communicate and coordinate with pipeline owner/operators and Local Distribution Companies (LDCs) in advance of and during cold weather conditions to assess anticipated fuel supply and address inventory concerns?
3. Discuss how GOs/GOPs and BAs/RCs incorporate the communications discussed in responses to (a) and (b) above into their operating procedures and describe how you train operations staff on the procedures. 
4. How do GOs/GOPs and BAs/RCs achieve situational awareness (e.g., of potential reductions in gas or gas pressure) and coordinate when multiple natural gas generating units receive their gas supplies from a common source (e.g., where a single point of failure could result in loss of multiple units)?  At what level (e.g., pipeline, pipeline section, or compressor station) of common source/single point of failure are the GOs/GOPs and BAs/RCs able to identify an outage or potential outage through communication from natural gas suppliers or natural gas infrastructure entities? 
5. How do GOs/GOPs become aware of, and communicate fuel supply and inventory concerns (including any upstream fuel supply concerns) with fuel providers, internally within the organization between marketers/fuel purchasers and operations, and with BAs/TOPs?  Describe the types of exercises and coordination with fuel suppliers/marketers that you perform to prepare for the winter season.
   1. For gas suppliers/marketers:  would you be better able to accommodate changes after the timely nomination cycle if you had access to more information from generators or do you already provide maximum flexibility to generators?
   2. In advance of extreme cold, how do pipeline owner/operators, gas suppliers/marketers, and LDCs communicate with GOs/GOPs about the pending conditions, their operational and commercial preparations, and any potential service adjustments that might be required?
   3. For gas generators:  is there any additional information that gas suppliers/marketers could provide to improve your decision-making and performance? 
   4. What coordination and communication practices between gas suppliers/marketers and generators exist now and what protocols could be established to improve situational awareness?  Are there designated individuals within GOs/GOPs responsible for communication with fuel suppliers?
   5. For dual fuel units: what plans and processes are in place to ensure alternate fuel availability (including contracts for replenishments) and coordination and communication with BAs, RCs, and TOPs?
6. What are the GOs’/GOPs’ processes for providing cold-weather-related operating limitations and fuel supply and inventory concerns to BAs?  How frequently is the information updated to maintain accuracy?
7. Commission Order No. 787[1] allows the sharing of nonpublic information between electric utilities and natural gas pipelines for the purpose of promoting reliable service.  Has this resulted in better communication and situational awareness and improved reliable operations?  Are there other barriers to effective communication between GOs/GOPs with natural gas pipelines before and during cold weather events that can be removed?
8. Describe how BAs/RCs coordinate during cold weather conditions with state and federal regulators and governmental entities (e.g., DOE, DHS fusion centers, and state-level emergency centers), as applicable, particularly as an extreme weather event is forecasted and develops.
9. How do GO/GOPs use available recommendations and sharing of best practices to improve performance during cold weather such as those from NERC guidelines,[2] lessoned learned documents from NERC and industry, and from industry forum and trade associations? Do you have documented processes for how those recommendations are incorporated into procedures?  
10. How do GOs/GOPs implement FERC/NERC joint inquiry report recommendations from prior winter weather events (2011, 2018, 2021)?  Do GOs/GOPs have documented processes for reviewing, evaluating, and implementing these recommendations?  What criteria are used to decide whether to implement a recommendation?

Panelists:

1. Jessica Lucas, Senior Director, Reliability Coordination, Midcontinent Independent System Operator, Inc.  | Presentation
2. Charles Hall, Vice President of Power Generation, Entergy LLC 
3. Scott Aclin, Manager of Balancing Authority Administration, Southwest Power Pool
4. Chris Davis, Director of Field Operations, Southern Star Pipeline  | Presentation
5. Frank Rozmus, Vice President, Gas Control and Facility Planning, Northern Natural Gas  | Presentation
6. Keith Marsh, Engineer Analyst, Southern Company
7. Todd Staples, President, Texas Oil and Gas Association   | Presentation

5:15 p.m.

Closing Remarks