ERCOT generation and transmission winterization rules proposed for publication

Generation and transmission entities in the Electric Reliability Council of Texas would have to complete by Dec. 1 "all actions necessary to prevent a reoccurrence of any cold weather critical component failure" that occurred in the winter of 2020-21 under weatherization rules proposed for publication and filed by Texas regulatory staff Aug. 25.

The staff of the Public Utility Commission of Texas on Aug. 25 filed its proposal for publication specifically addressing winter preparation by generation and transmission operators. A second phase of weatherization rules will be submitted later addressing weatherization for the summer.

The PUC is scheduled to discuss the proposal for publication of these rules during its Aug. 26 meeting.

The proposed rules would require generation and transmission entities to "complete ... all preparations necessary" for cold weather systems such as preparation of chemicals, auxiliary fuels, other materials and personnel.

For generation entities, the proposed rules would require:

• Installation of wind brakes and enclosures for cold-weather susceptible components
• Inspection of thermal insulation
• Confirmation of instrument air moisture prevention system operability
• Maintenance and testing of freeze protection components
• Installation of monitoring systems for cold weather critical devices
• Training operations personnel on winter weather preparation
• Calculation of minimum design and operating temperatures and other limitations based on weather factors such as humidity

Also, generation or transmission entities that have "repeated or major weather-related forced interruptions of service" would have to hire a qualified external engineer to assess such entities' weather preparation measures and report on those measures to the PUC and ERCOT.

Transmission-specific rules

Transmission service providers would have to confirm that breakers, meters and other electrical equipment has sulfur hexafluoride gas, an insulation material, at the correct pressure "to operate safely during extreme cold weather."

TSPs would also have to verify power transformers' readiness to operate in extreme cold temperatures.

Generation and transmission entities would have to submit a form by Dec. 1 to ERCOT describing efforts to complete these tasks, a notarized document signed by each entity's highest-ranking representative attesting to the completion of these tasks.

ERCOT would have to submit to the PUC by Dec. 10 a summary of these winter weather readiness reports.

If a generation or transmission entity fails to complete these tasks, that entity must seek a "good cause exception" detailing that entity's inability to comply with a specific requirement, what that entity has done to try to comply, how and when that entity plans to achieve compliance, and a notarized attestation by that generation entity's highest-ranking representative asserting that the submission is accurate.

The proposed rules would also require ERCOT to conduct generation and transmission inspections for the 2021-22 winter season and submit a report about them.

Interested parties have until Sept. 20 to file comments on the proposed rules.