On October 1, 2024, the current Cold Weather Preparedness Requirements found in EOP-011-2 will move to enforcement through EOP-012-1.
EOP-012-1 is currently approved and subject to future enforcement. EOP-012-2 is currently filed with FERC and pending approval. The expectation is for EOP-012-2 to supersede EOP-012-1 before October 1, 2024 and EOP-012-1 will never go into effect. With this expectation, we recommend that entities should plan to transition directly to EOP-012-2.
With the implementation and enforcement of EOP-012-2, there are additional requirements for the GO and GOP. Please see below for a summary of the transition from EOP-011-2 to EOP-012-2:
- Requirement 1, 2, 3, and 4 – Cold Weather Preparedness Plans. Each site must have a Cold Weather Preparedness Plan that includes the calculation of the Extreme Cold Weather Temperature (ECWT). Every entity should have implemented a Cold Weather Preparedness Plan as required in EOP-011-2, Requirement 7. EOP-012-2 adds the requirement of calculating the ECWT.
- Requirement 5 – Cold Weather Plan Training. Each site must complete annual training of the established Cold Weather Plan and its implementation. This should have been implemented as part of EOP-011-2, Requirement 8. (EOP-012-2 makes training an annual requirement).
- Requirement 6 – Corrective Action Plans for Generators operating below the ECWT of 32 Degrees. Any site with an ECWT below 32 Degrees must develop a Corrective Action Plan whenever a Cold Weather Reliability Event occurs. This is a new requirement that must be implemented by October 1, 2024.
- Requirement 7 – Tracking Corrective Action Plans. All Corrective Action Plans must be tracked, timed, and implemented with the specific timetables in Requirement 7. This is a new requirement that must be implemented by October 1, 2024.
- Requirement 8 – Tracking Cold Weather Constraint Declarations. If a Generator has declared any Cold Weather Constraint, they must be reviewed and updated every 5 years. This is a new requirement that must be implemented by October 1, 2024.
If you need any assistance in developing your Cold Weather Preparedness Plans, as well as implementing these new requirements, MPC may be able to assist you. Please email Nancy Walters and we can schedule a call to discuss the needs of your entity.
