By Richard Schlottmann, Project Manager, NERC Services

We have learned some things about EOP-012-2 the closer we get to the implementation date. First, there are currently three SARS out concerning various aspects of the standard. Also, the concerns of ECWT and the 32 degrees F and what constitutes a cold weather event and finally, critical components and weather, or not HVAC systems need to be included in your CCL. Also, please be sure that training is completed before the start of program implementation and especially before the start of the plant winter season as identified in EOP-011-2.

With ECWT, the areas of concern are that while the temperature theoretically states you can run to that temperature, the zone of concern is that band between 32 degrees F and that temperature. That zone will be the area of concern with respect to critical components and cold weather event declaration. If a component causes an issue meeting the definition of cold weather when in that band between ECWT and 32 degrees F, it will need to be added to the Critical Components List and have a corrective action plan. Make sure your data sets capture back to 1/1/2000, using data closet to the pant location is vital. If the data set is pulled too far away from the plant, it could lead in errors to the value of the ECWT. Make sure you follow the directions in the NOAA guide, if you don’t copy and paste to a clean workbook each time, even though you filtered the data, it will carry that data forwards unless it is a new workbook, leading to errors.

The Critical Components List needs to be thorough and should start with the equipment that is directly tied to unit protection schemes first. It is important to note the freeze protection methods used or if it needs freeze protection, methods expected to be used. Also note if there are freezing moisture considerations (icing, sleet, snow, wind chill) that could exacerbate the potential loss of the component. Something else that needs to be considered, the addition of building/package HVAC units. These units are designed to keep the areas they are used in at a constant temperature or range of temperatures. Monitoring can be via DCS or rounds and if monitoring happens, the HVAC systems can be excluded. The worry is that if it fails and freezing of components happens, the critical components will need to be added to the list with individual CAPS. It might be good to add the HVAC systems to the list, citing they are the first layer of defense against freezing and undergo maintenance on an annual basis or as needed. It is good to have a list even if it is not complete, you can add or subtract components as needed to arrive at the complete list, just make sure the revision history matches the changes made.

Training must be addressed; the program can’t be a carryover from EOP-11-2 or EOP-012-1. Parts of that training is relevant, but the training must be tailored to EOP-012-2. Make sure training is completed prior to the start of the plants’ winter season, not done in April. Makre sure it meets the requirements of the standards. Provide examples in the training of work orders, check lists (hooches used, equipment checked, heat trace rounds, etc.).Remember, these are living documents and can be edited, and the need arises. In doing so you will make your program as robust as possible and stay in compliance with the Standard.