A question about Reliability Standard EOP-011-2 R7
The Emergency Preparedness and Operations (EOP-011-2) standard was approved by the Federal Energy Regulatory Commission (FERC) on August 24, 2021 and becomes effective on April 1, 2023.
Requirements R7 and R8 are new additions to the previous version of the standard (EOP-011-1). Requirement R7 states that each Generator Owner must implement and maintain one or more cold weather preparedness plan(s) for its generating units. Requirement R7 Part 7.2 requires cold weather preparedness plan(s) to include an annual inspection and maintenance of generating unit(s) freeze protection measures.
The Implementation Plan section “Initial Performance of Periodic Requirements” states:
“Responsible Entities shall develop, maintain, and implement the Operating Plan(s) required by Reliability Standard EOP-011-2 by the effective date of the Reliability Standard. For the cold weather preparedness plan(s) for generating unit(s) required under Requirement R7, the Responsible Entity shall perform annual inspection and maintenance of generating unit freeze protection measures under Requirement R7 Part 7.2 and conduct generating unit specific training for its maintenance and operations personnel under Requirement R8 by the effective date of the Reliability Standard.”
A registered entity in another region asked if a Generator Owner would need to have performed the annual inspection and maintenance of generating unit(s) freeze protection measures per Requirement R7 Part 7.2 by the EOP-011-2 standard effective date of April 1, 2023.
The Electric Reliability Organization (ERO) discussed the question and concluded that the language within the Implementation Plan makes it clear that the annual inspection and maintenance of generating unit(s) freeze protection measures per Requirement R7 Part 7.2 must be completed by April 1, 2023, by all Generator Owners.
If you have any questions, or feel you may need to potentially self-report, please reach out to [email protected].
– Sam Zewdie, MRO Principal Compliance Engineer, O&P