EOP-012 Update

EOP-012 Extreme Cold Weather Preparedness and Operations requires each Generator Owner to develop and implement plans to mitigate the reliability impacts of extreme cold weather on its applicable generating units. Extreme weather response was the most engaged (including audits, self-certifications, and spot checks) risk element in 2024 at Texas RE.

Recently, there’s been some discussion on the topic of Generator Cold Weather Critical Components (GCWCCs) as it relates to Extreme Cold Weather Temperatures (ECWTs). A GCWCC is a component:

• That is under the Generator Owner’s control and is susceptible to freezing issues; and
• Could have freezing issues that lead to a Generator Cold Weather Reliability Event (GCWRE) long before an ECWT

Let’s say a SF6 breaker was identified as a GCWCC (meaning the component is susceptible to freezing issues at 32°F and below) regardless of the ECWT. Identification of a GCWCC is independent of the ECWT. During audits, Texas RE looks for a list of GCWCCs that meet both parts of the definition to ensure freeze protection measures are in place for these components to operate at the ECWT.

The effective date for EOP-012-3 was October 1, 2025. EOP-012-3 expands on the following topics:

• Compliance abeyance period
• Adjustments when calculating the ECWT
• Corrective Action Plans (CAPs) as detailed in Requirements R6, R7, R8, and R9
• Includes nine requirements

Moving forward, entities could see Requirement R3 included in upcoming engagements. R3 states that applicable Generator Owners shall implement freeze protection measures to protect GCWCCs (which is typically captured in an engagement through R4), but if the Generator Owner cannot demonstrate implementation, then the Generator Owner shall develop a CAP to add new (or modify existing) freeze protection measures. The latest Standard revisions are available here.

The North American Electric Reliability Corporation (NERC) filed its work plan in February of 2024, which focused on analyzing data collected through Section 1600 cold weather generator data request. After follow-up from NERC, 98 percent of Generator Owners reported their cold weather data. Some of the highlights include:

• 99 percent of generating units can operate at their ECWT
• Four percent of the total winter capacity reported an ECWT greater than 32°F
• Generator Cold Weather Constraints (GCWC) represented four percent of the total winter capacity
• One percent of the total winter capacity will be under a CAP at the start of this winter

For more information, refer to Cold Weather Generator Data Request.

With the approval of EOP-012-3 and the results from the NERC 1600 data collection, there will be an increase in Periodic Data Submittals (PDSs). EOP-012-3 Requirements R6 and R7 will require a PDS if a CAP extension is needed. EOP-012-3 R8 will require a PDS if a Generator Cold Weather Constraint (GCWC) exists. See Appendix D: EOP-012-3 CAP Extension and Generator Cold Weather Constraint Request Review Process in the ERO Enterprise Periodic Data Submittal Schedule for more details.

As EOP-012 adapts to an evolving grid, Texas RE will continue to keep entities up to date and informed.