In October 2023, the Federal Energy Regulatory Commission (FERC), North American Energy Reliability Corporation (NERC), and Regional Entity staff jointly released a report regarding Bulk Power Systems (BPS) operations during Winter Storm Elliott in December 2022. The report presented recommendations to improve electric generation and natural gas infrastructure for extreme cold weather reliability, grid emergency operations, and seasonal preparedness. Among these, it is recommended entities responsible for the development of system restoration plans and selection of Black Start Resources (BSR) should consider reviewing internal processes to ensure the selection of BSRs include the consideration of NERC Reliability Standard EOP-012-3 as it pertains to BSRs and extreme cold weather preparedness. The joint study team observed that entities’ BSR design, selection or qualification processes could be strengthened by evaluating cold weather capabilities as outlined in NERC EOP-012-3. Entities responsible for BSRs should ensure Black Start operations include extreme cold weather preparedness to help operators successfully perform under extreme cold weather conditions. BSRs should evaluate their restoration plans to ensure that restoration plans consider and manage fuel availability risks under extreme cold weather conditions. BSRs with dual-fuel capabilities will establish/strengthen their requirements for a minimum amount of on-site or readily available backup fuel to successfully implement the restoration plan.
The joint study found that entities’ emissions were regulated by federal and state environmental agencies. This could restrict emissions that use distillate oil as an alternate fuel source to include byproduct limits for opacity, particulates, nitrogen oxides, sulfur dioxide, volatile organic compounds and other air pollutants. During the study it was found that approximately half of all BSRs have dual-fuel capabilities with approximately one-third using distillate oil as their alternate fuel source. To ensure they will work during a system blackout when called upon, entities should evaluate emission/environmental regulation waiver request processes. If a system emergency occurred that resulted in an emission exceedance, some Generator Operators were able to apply for emission waivers. Procedures can also be coordinated to set up emission waivers prior to grid emergencies to release environmental constraint obligations.
The study reaffirms the necessity to assess the impact of a blackout on the natural gas supply chain focusing on natural gas availability to BSRs and next-start resources. The joint study team recommends subject matter experts (SME) from both electric and natural gas industries evaluate the impact of a wide-area electric blackout on the natural gas system. The SMEs should also develop restoration plans that include distinguishing between critical customer loads and system restoration critical loads which include natural gas supply, processing storage and delivery facilities. It also requires Transmission Owners/Operators with natural gas BSRs work jointly with natural gas transmission and delivery facility owners identify necessary routes to support their natural gas BSRs.
The study found that across the Easter and Western Interconnections, there is no consistent or uniform requirements that exist for the amount of on-site alternate fuel that must be maintained to support the implementation of a restoration plan. As many as 42% of the entities that responded indicated that they did not have firm fuel supply and/or transportation contracts. The study showed that current natural gas regulatory framework, business practices and operational procedures do not permit flexibility to prioritize natural gas services to BSRs during system restoration. Across the study, it was observed there was no consistent mitigation strategy to fuel availability risk. While securing firm natural gas supply will continue to be a mitigation strategy to reduce fuel availability risk, prioritizing critical natural gas infrastructure will further strengthen system resilience and reliability to support fuel availability during electric system restoration.
The study emphasized that BSRs that utilize dual-fuel sources should identify, mitigate and communicate risks with their primary and alternate fuel supply availability and deliverability during blackout scenarios. The joint study reaffirms that each entity proactively collaborates based on their regional electric system restoration assessments. The study recommends BSR owners to evaluate primary and backup communications with fuel suppliers and delivery entities. It is recommended that SMEs should help develop restoration plans that include solutions to resolve identified constraints. This includes distinguishing between critical customer loads and system restoration critical loads such as natural gas supply, processing, storage and delivery facilities. Also included would be identifying natural gas and transmission facilities necessary for natural gas supply routes.
To maintain grid resilience and effective and timely restoration from a major blackout, maintaining robust maintenance programs is essential. Entities responsible for developing and implementing system restoration plans should consider implementing a periodic startup test utilizing their alternative fuel source for dual-fuel BSRs to ensure startup capability using alternate fuel sources. These entities should consider implementing fuel switching BSR testing to confirm the capability and time required to switch between primary and alternate fuels sources for an extreme cold weather black start event. The joint study team also recommends enhancements to existing simulator-based training to focus on system restoration during extreme cold weather events to strengthen the effectiveness of system restoration. To ensure continued functionality, it is crucial to periodically test and verify all design capabilities including startup on primary and alternate fuel as well as fuel switching.
The conclusion of the study emphasizes the importance of BSR readiness and availability during extreme cold weather events given the interdependence between electric and natural gas systems. The report highlights the importance of enhancing fuel assurance for BSRs. Extreme cold weather preparedness and operational readiness for BSRs must be strengthened to ensure the reliability of the BPS. Ensuring restoration plans incorporate resource selection processes accounting for cold weather-related risks will further assist in the operational readiness of BSRs. It is recommended that communication capabilities with fuel suppliers be improved. Finally, cold weather specific restoration training will be a necessary component to improve the preparedness in the future. The study reaffirms the value of cross-industry collaboration to address vulnerabilities and help develop coordinated restoration strategies.
Reach out to the GDS Energy Reliability & Security Team and let us know how we can assist you with Cold Weather or Blackstart preparation.
Blackstart Resource Availability and Readiness in the Eastern and Western Interconnections
Justin Monk
Project Lead - Energy, Reliability and Security
GDS Associates