Fuel Assurance and Fuel-Related Reliability Risk Analysis For The Bulk Power System

Reliability Guideline
Fuel Assurance and Fuel-Related Reliability Risk

Analysis for the Bulk Power System
March 2020
RELIABILITY | RESILIENCE | SECURITY
NERC | Report Title | Report Date

I
Table of Contents
Preface ........................................................................................................................................................................... iii
Preamble ........................................................................................................................................................................ iv
Introduction .................................................................................................................................................................... v
Background .............................................................................................................................................................. v
Chapter 1: Fuel Assurance .............................................................................................................................................. 1
Fuel Assurance Principles ............................................................................................................................................ 2
Markets .................................................................................................................................................................... 2
Generator Owners/Operators ................................................................................................................................. 2
Transmission Planners/Planning Coordinators........................................................................................................ 3
Chapter 2: Electric Generation Fuel Supply Primer ........................................................................................................ 4
Natural Gas .................................................................................................................................................................. 4
Oil ................................................................................................................................................................................ 6
Coal .............................................................................................................................................................................. 6
Nuclear ........................................................................................................................................................................ 7
Hydro ........................................................................................................................................................................... 7
Solar, Wind, and Other ................................................................................................................................................ 8
Chapter 3: Fuel Supply Risk Analysis Consideration ....................................................................................................... 9
Natural Gas .................................................................................................................................................................. 9
Oil .............................................................................................................................................................................. 10
Coal ............................................................................................................................................................................ 10
Nuclear ...................................................................................................................................................................... 11
Hydro ......................................................................................................................................................................... 11
Chapter 4: Fuel-Related Reliability Risk Analysis Framework ....................................................................................... 12
Step 1: Problem Statement and Study Prerequisites ................................................................................................ 13
Step 2: Data Gathering .............................................................................................................................................. 14
Step 3: Formulate Study Input Assumptions and Initial System Conditions ............................................................. 16
Step 4: Contingency Selection ................................................................................................................................... 20
Step 5: Selection of Tool(s) for Analysis .................................................................................................................... 22
Step 6: Perform Analysis and Assess Results............................................................................................................. 22
Step 7: Develop Solution Framework ........................................................................................................................ 22
Appendix A: Risk Analysis Framework Checklist ........................................................................................................... 23
Appendix B: Items to Include in a Fuel/Energy Survey ................................................................................................. 26
Contributors .................................................................................................................................................................. 31
NERC | Fuel Assurance and Fuel Related Risk Analysis for the Bulk Power System | March 2020
ii
Preface
Electricity is a key component of the fabric of modern society and the Electric Reliability Organization (ERO) Enterprise
serves to strengthen that fabric. The vision for the ERO Enterprise, which is comprised of the North American Electric
Reliability Corporation (NERC) and the six Regional Entities (REs), is a highly reliable and secure North American bulk
power system (BPS). Our mission is to assure the effective and efficient reduction of risks to the reliability and security
of the grid.
Reliability | Resilience | Security

Because nearly 400 million citizens in North America are counting on us
The North American BPS is divided into six RE boundaries as shown in the map and corresponding table below. The
multicolored area denotes overlap as some load-serving entities participate in one Region while associated
Transmission Owners/Operators participate in another.
MRO Midwest Reliability Organization

NPCC Northeast Power Coordinating Council
RF ReliabilityFirst
SERC SERC Reliability Corporation
Texas RE Texas Reliability Entity
WECC Western Electricity Coordinating Council
iii
Preamble
It is in the public interest for NERC to develop guidelines that are useful for maintaining or enhancing the reliability
of the Bulk Electric System (BES). The NERC technical committees—the Operating Committee, the Planning
Committee, and the Critical Infrastructure Protection Committee—are authorized by the NERC Board of Trustees to
develop reliability (Operating and Planning Committees) and security guidelines per their charters. 1 These guidelines
establish a voluntary code of practice on a particular topic for consideration and use by BES users, owners, and
operators. The technical committees coordinate these guidelines with the collective experience, expertise, and
judgment of the industry. The objective of this reliability guideline is to distribute key practices and information on
specific issues critical to maintaining the highest levels of BES reliability. Guidelines are not to be used to provide
binding norms or create parameters by which compliance to standards is monitored or enforced. While the
incorporation of guideline practices is strictly voluntary, reviewing, revising, or developing a program using these
practices is highly encouraged to promote and achieve the highest levels of reliability for the BES.
NERC, as the Federal Energy Regulatory Commission (FERC) certified ERO, 2 is responsible for the reliability of the BES
and has a suite of tools to accomplish this responsibility, including but not limited to the following:
• Lessons learned
• Reliability and security guidelines
• Assessments and reports
• The Event Analysis program
• The Compliance Monitoring and Enforcement program
• Mandatory Reliability Standards
Each entity, as registered in the NERC compliance registry, is responsible and accountable for maintaining reliability
and compliance with the mandatory standards to maintain the reliability of their portions of the BES. Entities should
review this guideline in detail and in conjunction with the periodic review of their internal processes and procedures
and make any needed changes to their procedures based on their system design, configuration, and business
practices.
1 http://www.nerc.com/comm/OC/Related%20Files%20DL/OC%20Charter%2020131011%20(Clean).pdf
http://www.nerc.com/comm/CIPC/Related%20Files%20DL/CIPC%20Charter%20(2)%20with%20BOT%20approval%20footer.pdf
http://www.nerc.com/comm/PC/Related%20Files%202013/PC%20Charter%20-%20Board%20Approved%20November%202013.pdf
2 http://www.ferc.gov/whats-new/comm-meet/072006/E-5.pdf
iv
Introduction
The 2019 ERO Risk Priorities Report highlights a wide array of pertinent risks to the reliable operation of the BPS that
merit attention and recommends actions that align with those risks. 3 Among the diverse risks identified in the report,
utilities, generators, and other suppliers are experiencing a number of factors that increase the likelihood of
fuel/energy supply challenges that exemplify the increased importance of thoroughly characterizing cross-sector
interdependencies.
The rapid advancement of renewable generation and increased use of natural gas have necessitated the need to re-
evaluate the methods that the industry has historically utilized to analyze and maintain BPS reliability. Increased
reliance on natural-gas-fired generation in various parts of North America will have increased by an estimated 55%
over the period 2010–2020. This document will provide entities guidance on how to evaluate such risk factors within
their own portfolios to address potential impacts on the BPS.
While this guideline addresses present concerns related to natural gas, it offers a broader perspective on the
definition of “fuel assurance” in Chapter 1 and takes a cursory look at all major fuel sources used to supply electric
generation in Chapter 2. As each fuel type possesses a variety of limiting factors that affect its reliable delivery
through its entire supply chain, Chapter 3 describes specifically what those limiting factors may be and provides
guidance to further equip planners with the requisite knowledge to assist in the development of credible fuel supply
risks to analyze.
There have been a number of relevant studies performed—especially by regional transmission organizations,
independent system operators (RTO/ISO), and other organizations 4 to analyze and assess generator fuel-related
concerns. This guideline combines the experience gained from these studies and outlines a framework in Chapter 4
that may be applied across all NERC Regions for effectively evaluating potential reliability risks to the BPS at all times
through the lens of fuel assurance. Applying this framework for a given area will uncover where credible risks to
reliability exist in terms of fuel delivery and will highlight those risks for further analysis and consideration.
Background
In November 2017, NERC published the Special Reliability Assessment: Potential Bulk Power System Impacts Due to
Severe Disruptions on the Natural Gas System (2017 NERC Special Assessment). 5 In that report, NERC made numerous
recommendations for assessing disruptions to natural gas infrastructure and related impacts to the reliable operation
of the BPS in planning studies, several of which were assigned to the NERC PC.
In July 2018, the PC convened a workshop to highlight ongoing “fuel assurance” discussions and studies and to
convene experts from across industries to develop a plan for action. Based on reactions from some workshop
attendees, it was clear that some entities desired guidance around establishing “contingency selection” and other
assumptions to be used for studying the impact on the BPS from fuel unavailability as well as fuel system disturbances.
Transmission Planners (TPs) also desired guidance in identifying potential transmission impacts and how to evaluate
the level of risk to the BPS, including the ability to serve load they should be willing to accept.
In November 2018, the NERC Board approved a set of recommendations developed by the PC to address concerns
from the 2017 NERC Special Assessment. One such recommendation was the development of this reliability guideline
that was assigned by the PC to the newly formed Electric Gas Working Group.
3
https://www.nerc.com/comm/RISC/Related%20Files%20DL/RISC%20ERO%20Priorities%20Report_Board_
Accpeted_November_5_2019.pdf
4 E.g., The Eastern Interconnection Planning Collaborative Gas-Electric Interface Study performed under the DOE grant and completed in June
2015
5 https://www.nerc.com/pa/RAPA/ra/Reliability%20Assessments%20DL/NERC_SPOD_11142017_Final.pdf
v
Introduction
In Appendix E of the 2017 NERC Special Assessment, NERC evaluated existing natural gas infrastructure disruption
studies conducted by the industry to gain an understanding of existing planning approaches and to highlight and
promote best practices. As a result of this assessment, NERC presented steps for Planning Coordinators to take when
performing future analysis (see below). This guideline is intended to expand upon methods to implement these
recommendations.
2017 NER C Special Assessm ent Appendix E Recommendations
Identify potential natural gas system contingencies and their likelihood of

occurrence
Assess the impacts for each of the identified contingencies in terms of

duration and amount of natural gas supply disrupted
Apply the contingency disruptions to the natural gas supply capabilities to

calculate the impact on total natural gas supplies and, more specifically, the
amount of natural gas available to electric generators
Determine the transmission systems ability to transport power to load

under these extreme conditions
Though this guideline discusses planning, commonalities in the assessment techniques, processes, and procedures
discussed are applicable to all time frames and may be adopted by more than just TPs and Planning Coordinators.
Terms like “planner,” “generator owner/operator,” and “fuel supplier” are not capitalized intentionally so that the
concepts presented may be considered and applied in the broadest sense as they pertain to the BES.
The processes identified within this guide may also be applied to those organizations whose resource mix includes
entitlement and bilateral transactions that have resource contingencies. Entities with such arrangements can also
benefit from recognizing when limitations may potentially impact their grid operations.
The Electric Gas Working Group will work with NERC to gauge the effectiveness of this reliability guideline and
support efforts for continued improvement and opportunities for education and information sharing.
NERC | Fuel Assurance and Fuel Reliability Risk Analysis for the Bulk Power System | March 2020
vi
Chapter 1: Fuel Assurance
Fuel assurance is a term that has been utilized in many forums to date but has yet to be given a formal definition. As
this guideline directly relates to the conversation taking place across the industry regarding concerns with the rapidly
transitioning BPS generation fleet, it is appropriate and timely for NERC to establish its definition for “fuel assurance.”
Defining this term will ensure consistency and alignment with statements within this guideline and also provide clarity
to the industry going forward on the most appropriate areas of focus related to fuel supply risks to generators
supporting the BPS.
For the purposes of this guideline, “fuel assurance” will be defined as follows:
Fuel Assurance: proactively taking steps to identify fuel arrangements or other alternatives that
would provide confidence such that fuel interruptions are minimized to maintain reliable BPS
performance during both normal operations and credible disruptive events
The criteria to establish the level of confidence referenced in the definition is unique to respective planning areas
and is established by planners and/or generator owners/operators based on internal assessments and understanding
of their asset characteristics. The role of the regional planner in addressing fuel assurance is related to but separate
from actions of individual generator owners to assure fuel assurance for their units. The regional planner’s focus is
to assess the vulnerabilities of the entire region to withstand fuel disruptions that could impact multiple generators
and impact reliable BPS performance. A lack of fuel assurance to a particular generator may affect that unit’s ability
to receive revenues from the market or otherwise meet their obligations to their customers but not necessarily
impact the provision of reliable service to the entire region. As the fuel mix of generation and wholesale electricity
market structures can vary greatly across reliability areas, this guideline does not and cannot prescribe a single
approach to the process.
NERC encourages planners to proactively model, evaluate and consider specific BPS impacts based on credible events
that could compromise the provision of reliable service to all or part of the region within the regional planner’s area
of responsibility and to develop strategies to mitigate credible risks. Regional planners may consider modeling
extreme fuel disruptions to better understand the impact of catastrophic events so that they may prepare for such
emergencies. Recognizing that there is no way to anticipate or measure all potential threats and catastrophic
scenarios, stakeholders and regional planners should focus on effective measures that will maintain reliable and fuel-
secure BPS operations during credible events. While the individual unit owners are ultimately responsible for
effectively managing the fuel assurance of particular units, the regional planners should understand the
consequences of losing critical generators and take steps to limit the impact of such a loss should a loss of fuel delivery
at a particular unit threaten reliability.
6 https://www.pjm.com/-/media/library/reports-notices/fuel-security/2018-fuel-security-analysis.ashx?la=en
NERC | Fuel Assurance and Fuel Related Reliability Risk Analysis for the Bulk Power System | March 2020
1
FUEL SECURITY ANALYSIS: A PJM RESILIENCE INITIATIVE 7
In 2018, PJM performed a fuel security analysis which was designed to stress-test the PJM grid and the
fuel delivery systems serving generation in PJM under a series of extreme but plausible future events
(using 2023/2024 as the study year). As in any stress test, the analysis was intended to discover the point
at which the PJM system begins to be impacted (i.e., when system operators initiate emergency actions)
and to identify key drivers of risk. In PJM’s phased approach to addressing the Fuel Assurance issue, Phase
1 involved the fuel security analysis. In Phase 2, which began in 2019, the analysis results are being used
to inform PJM’s stakeholder process, which will help to define fuel security attributes for PJM, location
and magnitude of how many fuel secure resources or megawatts are needed, as well as determine how
to value fuel secure resources. PJM may also use the results of the study to determine how best to
incorporate fuel security into other aspects of its operations, markets and planning. The final Phase 3 is a
cooperative effort between PJM and United States (U.S.) federal agencies to define and analyze further
scenarios based on classified information about credible risks to fuel security that could have impacts on
the power grid.
Fuel Assurance Principles

While each reliability area is unique, there are common principles for fuel assurance that may be applied more
broadly to assist planners in their assessments of fuel supply reliability. Below are some examples of actions that
various entities may perform to advance fuel assurance initiatives.
Markets
RTOs/ISOs that have not already done so could consider additional mechanisms for generators to meet their
obligations during reserve shortages—these could be market (e.g., capacity market reforms) or out-of-market
solutions while attempting to avoid out of market solutions where possible or only as a temporary measure while a
market-based approach is developed. Such market rules and mechanisms would incentivize generators to maintain
or enhance fuel delivery contracts. Additionally, adopting more detailed and timely procedures for communications
to members when near-term fuel shortages/reliability concerns arise (e.g., upcoming shortages, disruptive weather)
will allow time for generators to assess and react to fuel supply needs. RTOs/ISOs should also consider other
mechanisms that would facilitate greater certainty that generators have reliable fuel options regardless of market
structure (i.e., restructured or vertically integrated).
Generator Owners/Operators
Generator owners/operators should seek reliable delivery solutions from both a transportation and commodity
perspective. Monitor and evaluate risks associated with varying levels of transportation or delivery options associated
with the different types of transportation (e.g., interruptible transportation, firm transportation). Consider and
evaluate a diverse portfolio of products that can be utilized to deliver fuel both reliably and cost-effectively; examples
of these are as follows:
• Delivered bundled products
• Firm call options for periods of heightened fuel uncertainty
• Asset management arrangements
• Potential purchases from suppliers with firm capabilities
7 Id.
2
• Enhanced infrastructure considerations

• Storage capacity
• Liquefied natural gas (LNG) options
• Dual-fuel capability
• Interconnection with more than one pipeline
• On-site fuel reserves.
Generator owners/operators should consider credible fuel-related contingencies that impact their facilities and
provide fuel-related facility outage concerns as necessary to the reliability authority. Lastly, where fuel delivery
constraints are routinely evident, generator owners/operators should consider and investigate whether new options
for fuel deliveries to a specific facility or their fleet are available.
Transmission Planners/Planning Coordinators

Planners should consider using steps outlined in Chapter 4: of this guideline to develop credible fuel-related
contingencies that may be used in planning studies, including (but not limited to) Reliability Standard TPL-001
(Transmission System Planning Performance Requirements). 8 Any identified fuel-related contingencies should be
evaluated for reliability risks, and planners should determine what (if any) mitigation should be put in place. Planners
might consider conducting generator fuel-related surveys to determine potential risks to the fuel supply of the
generators. Using the survey data, planners may perform fuel-related reliability risk analyses as described in Chapter
4:. Planners should also seek and use experts familiar with regional markets and practices to help interpret and
analyze the survey data.
8See NERC Standard TPL-001-4 – Transmission Planning Performance Requirements, Table 1 –Steady State & Stability Performance Extreme
Events, 3.a.i.
3
Chapter 2: Electric Generation Fuel Supply Primer
This section describes the supply chain of each major generator fuel supply type at a high level. It describes illustrative
challenges that may be encountered between production and consumption as well as other viable considerations
specific to each fuel type. These considerations will assist planners in forming realistic assumptions when developing
their own fuel assurance and reliability risk analysis.
Natural Gas
The natural gas supply chain includes three major segments, listed below:
• Production and Processing
Natural gas is primarily found in reservoir pools and shale rock formations in the earth and brought to the
surface through production wells by processing plants that heavily rely on electric power to operate. A series
of flowlines and gathering lines then transport natural gas to processing plants. Natural gas is also a byproduct
of oil-focused production.
• Transmission and Storage
Large-diameter interstate and intrastate pipeline transmission systems transport processed natural gas to
end-use customers, such as large-volume customers (e.g., local distribution companies (LDCs), natural gas-
fired power generation, industrial users). Alternatively, the processed natural gas may be transported to
various storage facilities for future consumption.
• Distribution
Smaller-diameter local natural gas distribution pipelines deliver natural gas to residential, commercial, and
industrial customers as well as some natural-gas-fired power generators. These customers are often located
behind the city gate and are serviced by LDCs.
The FERC regulates interstate natural gas transportation and storage. The interstate pipeline industry is contract-
based, and pipeline and storage companies contract with customers under the terms of FERC-approved agreements
and tariffs. Customers select transportation and storage services (firm or interruptible) based on the level of certainty
and reliability desired. FERC regulations preclude interstate pipelines from undue discrimination. The pipeline
industry is required to honor all firm service contracts, provided force majeure conditions do not impact such service. 9
Therefore, the level of service and priority that a customer selects for delivery of natural gas is driven by the type of
contract that the customer has entered into. In addition to transportation service, customers also purchase the
physical commodity to receive natural gas at contracted points into the applicable transportation agreements and/or
at other points of points of delivery at their respective interconnection points or market center. Larger volume
customers (e.g., LDCs and electric generation facilities) may also purchase natural gas upstream at or near the point
of production and contract for pipeline service to transport the commodity to the point of delivery. In addition, based
on market conditions, these entities and other market participants may purchase natural gas at a market center and
contract for transportation from that point to a delivery point(s). Also, market participants may purchase a bundled
commodity and transportation package from marketers, who deliver the natural gas using the pipeline capacity for
which they have contracted through utilization of the established secondary bilateral market for capacity and
commodity. During periods of high usage and system constraints, pipelines may not be able to schedule interruptible
customers because capacity is being fully utilized by firm transportation customers. During force majeure events,
pipeline companies may also curtail firm customer pro-rata as needed to maintain system integrity.
Intrastate transportation, balancing, storage, and distribution of natural gas by LDCs is subject to state regulation.
LDCs are regulated by most states as local natural gas utilities that have an obligation to serve their firm core
customers–the customers for which the system is built to serve reliably (e.g., residential and commercial heating
9 See 18 C.F.R. § 284.7(a) (3).
4
customers). Similar to interstate pipeline operations, during periods of high usage and system constraints, LDCs may
call on interruptible customers to cease gas usage temporarily. State statutes and public utility regulations may allow
an LDC to curtail services to some industrial or non-core customers, possibly including power generators, during
emergencies to maintain the operational integrity of the system and/or maintain natural gas service to designated
high-priority customers. Historically, these state regulatory requirements give the highest priority to residential
(essential human need) and small commercial customers without short-term alternatives.
Natural gas pipelines (interstate, intrastate, and distribution) are subject to pipeline safety regulations that are
mandated by the Department of Transportation–Pipeline and Hazardous Materials Safety Administration (PHMSA)
and by the pipeline cyber-security authority of the Department of Homeland Security–Transportation Security
Administration.
The majority of natural gas infrastructure is automated, and pipeline operators, storage owners, and utilities alike
rely on industrial control systems for monitoring and/or remote control; however, the physical delivery systems are
mechanical by nature and can be run locally if necessary. Natural gas is moved by using pressure to control the
amount entering and leaving the system. Compressor stations are placed throughout the network to maintain
pressure at serviceable levels and are powered by the natural gas in the pipelines themselves in most cases. Some
stations may have both natural gas and electric or even diesel-driven compressors for contingency purposes; others
may rely solely on electric power. Mechanical regulators are also layered into the pipeline infrastructure to prevent
internal natural gas pressure from threatening pipeline integrity. Typically, limited supply and transportation
disruptions can be managed through substitution, transportation rerouting, and storage services (though such
infrastructure redundancy is much more limited in portions of North America). While the natural gas transmission
system may continue to operate even with the failure of as many as half of the compressors, the pressure may not
remain high enough for some power generators to continue to fully operate, depending on the specific pressure
requirements of each power generator and its location relative to the failed compressor. 10 Many modern natural gas
units have on-site boost compression built in to the unit that is capable of increasing the pressure of the pipeline
delivered natural gas to the combustion inlet pressure required by the unit even with a severe deviation in pipeline
pressure. In addition, the natural gas distribution network can operate largely unattended and without electric
power.
Certain characteristics of the natural gas system contribute to its reliability and resilience. The natural gas
transportation network is composed of an extensive network of interconnected pipelines that offer multiple
pathways for rerouting deliveries in the unlikely event of a physical disruption. Each customer’s ability to use such
alternate pathways and capacity to maintain natural gas delivery will depend upon the rights specified in the
customer’s transportation contract. 11 In addition, pipeline capacity is often increased by installing two or more
parallel pipelines in the same right-of-way (called pipeline loops), making it possible to shut off one loop while keeping
the other in service. 12 In the event of one or more compressor
failures, natural gas pipelines can usually continue to operate Line pack is the volume of natural gas
at pressures necessary to maintain deliveries to pipeline contained within the pipeline network at any
customers (at least outside the affected segment) subject to given time. It allows natural gas received in
the constraints that some power generators may experience one area of a pipeline system to be delivered
due to location and pressure requirements as noted above. 13 simultaneously elsewhere on the system.
“Line pack” in the pipelines is routinely used as necessary to
provide some additional operational flexibility. 14 It can facilitate non-ratable flows and support pipeline reliability as
10 Massachusetts Institute of Technology, Lincoln Laboratory, “Interdependence of the Electricity Generation System and the Natural Gas
System and Implications for Energy Security,” May 15, 2013.
11 NGC, Natural Gas Systems: Reliable & Resilient at p. 10 (July 2017).
12 Id.
13 Id.
14 Id.
5
a temporary buffer for imbalances. However, line pack must be kept reasonably stable throughout the system to
preserve delivery pressure and system capacity. Thus, line pack neither creates incremental capacity nor is it a
substitute for appropriate transportation contracts, however, it can support sustained operation in the short term
following a disruption.
Further, the existence of geographically dispersed production and storage and their locations on different parts of
the pipeline and distribution system also provide flexibility to maintain service in the event of a disruption on parts
of the transportation and distribution system. 15
Similarly, producers use various methods to help ensure operational continuity. Because producers have an economic
incentive and operational need to continue to flow natural gas out of the producing field at a constant rate, many
techniques are in place to help ensure that operations continue or that any disruption is minimized when a problem
arises. In the unlikely event of an unavoidable disruption of supply at a well or in a field, producers have many other
options to balance their supply commitments, including increasing production in other areas or using supplies of
natural gas in storage. 16
A disruption to the delivery or supply of natural gas may occur. For example, as NERC has previously reported in the
2017 Special Assessment, disruptions to the fuel delivery may result from adverse events, such as line breaks,
compressor station fires, well freeze‐offs, or storage facility outages. 17 Similarly, the pipeline system can be impacted
by events that occur on the electric system (e.g., loss of electric motor driven compressors). 18
Additionally, there are two distinct reliability risks associated with natural gas supply: interruption and curtailment
risk. Operational concerns provide a more typical reason for interruption while a force majeure event would reflect
a more extreme curtailment. Curtailment of firm service could occur when an event impacts the scheduled flow of
natural gas for various reasons. As stated in Chapter 1 the risks associated with levels of firm or interruptible service
should be monitored.
Oil
Fuel oil is obtained from the petroleum distillation process as either a distillate or a residual and is then distributed
to regional terminals for distribution to end users. Transportation to generation sites is typically by pipeline, barge,
truck, or a combination of the three methods where it is off-loaded into on-site fuel tanks. Each power plant site with
storage tanks will have unloading facilities that frequently limit the ability to replenish the on-site storage tanks. Each
generator with oil as either the primary or back-up fuel must decide the maximum capacity of the on-site storage
tanks as well as the amount of fuel oil that will be kept in inventory. Key factors in how much fuel oil to have on site
are the proximity of the regional terminal, the regional terminal capacity, expected run-time, availability of transport
tankers (maritime or over-the-road), pipelines, and expected transportation constraints (e.g., roads impassable due
to weather conditions or rivers impassable due to ice conditions).
Coal
Four major types of coal are used to produce electric power, each of which varies in heat content and chemical
composition:
• Anthracite: The highest rank of coal. It is a hard, brittle, and shiny black coal (often referred to as hard coal).
It contains a high percentage of fixed carbon and a low percentage of volatile matter.
15 Id.
16 Id.
17 2017 NERC Special Assessment at page 7
18 Id.
6
• Bituminous: Bituminous coal is a middle rank coal between subbituminous and anthracite. Bituminous
usually has a high heating (Btu) value and is the most common type of coal used in electricity generation in
the United States.
• Subbituminous: Subbituminous coal is black and dull (not shiny) and has a higher heating value than lignite.
• Lignite: Lignite coal, aka brown coal, is the lowest grade coal with the least concentration of carbon.
Coal is extracted from surface and underground mines in various regions around the United States and the world. It
is then crushed and washed in preparation for transport to power plants. Transportation is typically by rail, barge, or
truck. Coal may be delivered directly to a power plant or to a nearby unloading terminal from which it proceeds to
the power plant by truck or a conveyance system. At the plant, coal is stored on-site in piles to be used as needed for
generation, typically in an amount sufficient for several weeks to several months of operation. Coal can be
transported by rail using tariff rates shipment-by-shipment or under customer-specific short- or long-term rail
contracts. Contracts may provide discounts when compared to the tariff rates but require volume commitments over
a specified period of time.
Nuclear
Nuclear plants are refueled every 18–24 months. Required outages cannot normally be delayed. Nuclear plants need
to maintain certain reactivity levels in nuclear fuel. At times, this reactivity requirement has led to units derating in
shoulder months in order to conserve fuel and be available to operate 100% during peak months.
Four major processing steps must occur to make usable nuclear fuel: mining and milling, conversion, enrichment, and
fuel fabrication. The uranium used in power plants comes from Kazakhstan, Canada, Australia, and several western states
in the United States. Major commercial fuel enrichment facilities are in the United States, France, Germany, the
Netherlands, the United Kingdom, and Russia.19
Fuel is stored on site at nuclear plants that are built to withstand significant physical events, including weather, seismic,
and other types of natural disaster. Licensees must abide by robust security measures (e.g., armed security officers),
physical barriers, and intrusion detection and surveillance systems.20
The Nuclear Regulatory Commission regulates nuclear facilities in the United States. Nuclear power plants must show
that they can defend against a set of adversary characteristics called the Design Basis Threat (DBT). DBT imposes security
requirements on nuclear power plants based on analyses of various factors, such as the potential for a terrorist threat.
The Nuclear Regulatory Commission regularly evaluates the DBT for updates and alignment with the threat environment.
Nuclear facilities use digital and analog systems to monitor, operate, control, and protect their plants. Digital assets
critical to plant systems for performing safety and security functions are isolated from the external networks,
including the internet. This separation provides protection from many cyber threats.
Hydro
An integrated hydro-electric system, like those found in the Pacific Northwest, is more frequently energy limited than
capacity limited from its mix of storage and run-of-river projects. The storage projects fill and draft annually and tend
to have a steady discharge. Fluctuations in discharge (generation) are usually driven by flood control and downstream
water temperature objectives. The run-of-river projects more closely follow demand as the projects fill and draft
daily. However, run of river projects have limited storage to meet demand because the water needs to be in the right
place(s) at the right time(s). Hydro-electric generation also has many non-power objectives that can limit hydro-
19
https://www.nei.org/fundamentals/nuclear-fuel
20https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/security-enhancements.html and
https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/cyber-security-bg.html
7
electric power production (e.g., lake level management, recreational use). Information sharing, communication, and
coordination is critical across different hydro projects, utilities, states, and countries.
Solar, Wind, and Other

Technologies like BPS-connected solar photovoltaic and wind generation have grown rapidly and will likely remain a
part of the resource mix of the future. These resources are asynchronously connected to the grid and only interface
with the BPS through power inverters. This rapid adoption of inverter-based resources has presented new
opportunities in terms of grid control and response to abnormal grid conditions and has necessitated the
standardization of performance characteristics for inverter-based resources. NERC produced a reliability guideline
for this purpose in late 2018. 21 The "fuel" for wind and solar generation are the wind and sunlight that are effectively
limitless but are only available as weather permits.
Other technologies (e.g., battery storage) are still in early stages of development, and deployment of these
technologies will require further evaluation and consideration as they mature.
21https://www.nerc.com/comm/OC_Reliability_Guidelines_DL/Inverter-Based_Resource_Performance_Guideline.pdf
8
Chapter 3: Fuel Supply Risk Analysis Consideration
At a high level, this chapter describes the supply chain considerations of each generator fuel supply type that will
help planners form realistic assumptions when developing their own fuel-related reliability risk analyses.
Natural Gas
While the natural gas industry does not have a history of being susceptible to failure in general or to wide-spread
failure from a single point of disruption because of the dispersion of production and storage, 22 redundancies due to
the integrated pipeline and distribution network, and its low vulnerability to weather-related events, a temporary
outage of a section of a single pipeline or a delivery point is a credible scenario to examine. When considering such a
natural gas supply disruption within a given area, the examination would not just be limited to the loss of the natural
gas supply but also the associated loss of electric generation and any ancillary needs, such as the loss of electric
natural gas compression.
Planners should fully examine the credible reliability risks associated with the natural gas supplied to generators
within the reliability footprint of the planner. Further, planners should view the system through an “all-hazards” lens
and evaluate additional considerations, including weather, regional policies, and cyber-related risks. The following
paragraphs outline the information that planners should seek to understand as a precursor to a more rigorous fuel
assurance and reliability risk analysis.
To begin, planners should seek to understand the strategies employed regarding natural gas supply to each generator
within their reliability footprint and any applicable regulatory requirements. This could include regular and
emergency transportation/service agreements, call options, or other marketing arrangements being employed by
the generator owners/operators to meet its resources capacity obligations. This examination could also include
reviewing access to on-site fuel storage (e.g., fuel oil, propane, LNG, compressed natural gas), access to off-site
storage, 23 access and availability of an alternate pipeline connection, and the availability of non-firm natural gas
services and supply. Planners may also consider the alternative fuel capability of the generator, how any such
alternatives are contracted and managed, and any environmental and regulatory requirements that may limit the
use of the alternative fuel.
The PJM study “Fuel Security Analysis: 24 A PJM Resilience Initiative” investigated the two
following natural gas “disruption” scenarios with different recovery expectations:
“Line Hit,” such as an excavating crew accident “Other,” such as corrosion

This type of disruption is easily identified, isolated to a This could take longer as investigations are
smaller area requiring repairs, and would only cause needed over a larger area and will likely be
about a five-day disruption. a more “sustained” type of outage.
Planners should examine each generator and its potential physical access to supply (including access to pipeline,
distribution, and storage facilities), the amount of capacity subscribed and available at each supply facility, and the
ability of the facility to meet daily and seasonal demand swings. In addition, planners should review potential
curtailments to key supply points on their respective transportation agreements (e.g., LDCs needing to redirect supply
to “essential human needs” if a severe supply disruption occurs). These details are important in order to formulate
22
Although it is noted that prior to shale natural gas, hurricanes in the Gulf of Mexico caused large amounts of supply to be shut-in.
23 Storage facilities are different in the various regions of
the United States; therefore, understanding the configuration, operation, and services
available in the different regions is recommended.
24
https://www.pjm.com/-/media/library/reports-notices/fuel-security/2018-fuel-security-analysis.ashx?la=en
9
supply alternatives to consider when examining a possible supply shortage or failure. While physically severing an
interstate pipeline is very uncommon, it can occur in situations like third-party damage. Furthermore, a facility may
need to be taken out of service for maintenance. Other considerations include specific pipeline resilience, geography,
and potential state or federal restrictions on pipeline expansion, competition for supply with heating and industrial
demands, and upstream demand that may impact the region. 25 Environmental permits, such as those that allow
streambed alteration, may be required and will vary by repair required and specific location. Quick agreement on any
environmental mitigation measures will speed obtaining those permits. As noted previously, the planner’s role is to
have specific knowledge of the fuel assurance of individual generators in order to be able to assess, over the planning
area, whether any fuel assurance problems at a particular unit can impact the maintenance of reliability to the area
as opposed to just impacting the deliverability of that particular unit. Planners need to recognize this distinction so
as to avoid taking on management responsibilities that more appropriately lie with the individual unit owner.
In order to assess the forgoing, data can be obtained from certain public sources. FERC regulations and the business
practice standards of the Wholesale Gas Quadrant of the North American Energy Standards Board applicable to
natural gas pipelines, which are incorporated by reference into FERC regulations, include various posting
requirements for regulated pipelines. These standards require the posting of information related to pipeline capacity,
natural gas quality, operational notices, customer indices, tariff provisions, and other items. The U.S. Energy
Information Administration also publishes detailed information on U.S. natural gas pipelines and underground
storage. 26 FERC also requires that interstate pipelines and certain intrastate and Hinshaw 27 facilities file various forms
and operational reports. 28 In addition to the forgoing, the various states also require LDCs to file certain information
with the state commissions and/or publicly post certain information. The aforementioned information and data from
the applicable generators should also be used to evaluate fuel risk.
Oil
The main risks associated with fuel oil are typically regional depot capacity and transportation (e.g., pipeline, barge,
or truck) from the depot to the plant site. Since the fuel oil is stored in tanks, the capacity of the regional depot(s)
limits the amount of fuel oil that can be purchased when a need arises. Even in cases where depot levels are adequate
to meet the plant needs, the ability to move the fuel oil from the depot to the plant may be challenging due to
inclement weather that affects the ability of trucks to move the fuel oil safely. There may also be emissions limitations
or other environmental constraints that may limit the amounts or location for liquid fuel storage and/or prevent full
utilization of fuel oil in certain areas during portions of the year. For example, oil-fired generation cannot run between
May and September in ozone nonattainment locations unless the state governor declares an emergency.
Coal
Risks associated with coal supply are primarily in the transportation of coal from the mine to the power plant. The
rail network is comprised of an extensive grid of intersecting and interconnected tracks that offer multiple pathways
for rerouting deliveries in the event of a physical disruption, but temporary slow-downs or disruptions to supply can
occur in the rail system due to weather (e.g., floods or snow), derailments, or track repairs. Barge transport can be
temporarily impaired by icy, low-level, or flooded conditions on river systems. Generators rely on their on-site coal
supply for operation until deliveries can be restored. However, conditions like frozen or wet coal could impact on-
site coal supply. Coal commodity and rail transportation contracts may contain ratability language that states
shipments must be taken consistently even though there may be some month-to-month flexibility. This ratability
causes a natural rise and fall of the on-site stockpile based on periods of high and low demand. Any disruptions during
the periods of high demand may exacerbate low inventories. Additionally, coal plants are typically optimized to run
25 Such analyses are very similar to what many lenders offering non-recourse finance obtained from an Independent Fuel Consultant.
26 Energy Information Administration, Natural Gas Storage Report, and Wholesale Electricity and Natural Gas Market Data:
https://www.eia.gov/naturalgas/.
27 Hinshaw Pipelines are local distribution pipelines or companies served by interstate pipelines that are not subject to FERC jurisdiction by
reason of section 1(c) of the Natural Gas Act.

28 See FERC Forms: https://www.ferc.gov/docs-filing/forms.asp.
10
using only one of the four types of coal, potentially limiting generation capability if that coal becomes unavailable
due to long-term supply or transportation disruptions.
Nuclear
As described in Chapter 2 nuclear facilities store fuel on-site in a highly controlled and secure environment. There are
many layers of safety at nuclear sites to protect from physical and cyber risks.
Hydro
All hydroelectric projects are dependent on upstream sources for fuel supply water. Those sources can be snowpack,
other hydro projects, free flowing rivers, lakes, streams, or a combination. Ultimately, the source is a function of
precipitation. History has shown quite a diversity in the volume of water available for hydropower generation. The
total volume can run between 50–150% of the expected average. In some areas, much of the precipitation falls in the
form of snow and becomes useable water during the spring thaw. The rate of the melt or “run-off” is almost as
important as the volume. Slow melts are best as fast melts can lead to spilling water past fully loaded turbines or loss
of water as a fuel due to lack of storage. Deeply cold winters can also result in frozen rivers and streams, cutting off
fuel to downstream projects during times of elevated power demand. Temperature and precipitation are critical
factors in the availability of water for hydropower production.
11
Chapter 4: Fuel-Related Reliability Risk Analysis Framework
The BES, for the most part, is similar enough from area to area that a specified baseline set of criteria can be defined
and followed, resulting in similar and comparable results from transmission planning studies. TPL-001 defines and
prescribes these planning studies very well; criteria have been developed over many years, resulting in multiple
revisions to the standard. Even though TPL-001 references a fuel contingency analysis in Table 1 Steady State &
Stability Performance Extreme Events as a possible study contingency, the (default) contingency results in the loss of
only two generating stations and may not represent a significant pipeline segment, compressor station, storage
facility, barge transport, or other fuel supply disruption for many systems. This chapter provides details regarding the
scope of fuel-related generator outages beyond the minimum requirements for TPL-001 transmission system
planning assessments.
The framework presented below does not identify a single methodology but rather
outlines an approach to assist planners in determining what factors may be considered
to conduct a meaningful fuel-related reliability risk analysis for the BPS. The actions
described are intended to be flexible enough to account for all fuel types, broad enough
to support the unique circumstances in each region, and performable out of order (or in
some cases not at all). This framework does not provide specific solutions or next steps
that could be taken after assessing the results of any particular study.
Appendix A
The methodology described in this section may be applied narrowly or across a broad outlines this
range of credible assumptions as determined by the planner performing the study. The framework in
selected assumptions should ensure that the study is both relevant and meaningful. It checklist format
may be prudent to subject the BPS system under study to a range of high-probability,
low-impact (HPLI) contingencies as well as some high-impact, low-probability (HILP) contingencies. Studying HPLI
contingencies may shed light on operational needs during such instances and inform changes to processes and
procedures to preserve reliability (e.g., improvements in the ability of generators to schedule or contract for natural
gas). Even if they are not the primary motivation for the analysis, studying HILP contingencies that stress test the
system will bookend the study set and may inform regulators or other interested parties of the reliability impact of
such extreme conditions and may inform emergency preparedness efforts. Examples of HILP scenarios include severe
reduction of non-firm natural gas supply, prolonged pipeline repair, extreme prolonged weather events that affect
both supply of and demand for natural gas, or unanticipated low production from variable energy resources (VERs).
The examples used throughout this chapter are intended to be illustrative and
do not imply or prescribe mandatory actions
Based on the unique risks in different regions, the fuel-related reliability risk analysis outlined in this chapter
(although not required) is recommended as a best-practice approach for supporting existing studies (e.g., TPL-001
extreme events analysis) or for conducting a stand-alone analysis. In either case, documentation of each step of the
process is critical. Documenting the rationale behind the methodology and assumptions will better inform those
reviewing the study both presently and in the future and may also inform subsequent studies.
12
Step 1: Problem Statement and Study Prerequisites

To perform a valid fuel-related reliability risk analysis, there are numerous considerations that should be taken into
account that will help shape the direction and results of the analysis. Prior to beginning any analysis, the planner
must determine the purpose or goal of the study and, just as importantly, what the study will not do. It is at this point
that the criteria, concerns, scenarios and required data will become more evident. Determining which elements of
fuel supply risk are to be examined in a single study can be challenging as different combinations of risks can lead to
an unmanageable number of model runs.
Consider the following to help define the study:

• Have a clearly defined goal for the study. Set the criteria of the study and
define the criteria for system performance. A study that crosses the Deriving a
threshold of meeting certain criteria will do so when fuel is in short solution
supply, generators are no longer able to run, or there is a Use the study
Defining the results to set
supply/demand imbalance. The imbalance can be system-wide or, problem criteria for a
equally as important, a local area imbalance that results in the potential Gather supporting solution
data and study framework to be
exceedance of a NERC Reliability Standard defined System Operating reviewed with
materials for
Limit (SOL) or Interconnection Reliability Operating Limit (IROL) of the stakeholders to stakeholders
BPS. This philosophy can help determine contingencies that may not be review and concur
prior to
obviously catastrophic, but still highlight issues that may need commencing study
mitigation.
• Communicate the goals of the study with stakeholders and gain
agreement on principal concepts.
• Decide the analysis timeline prior to commencing work. If the problem definition and the solution are going
to be two separate phases of a study, set that expectation early in the process. Often, the deriving solution
means following the directives of governing entities (NERC, FERC, governmental agencies, state public utility
commissions, etc.). If this is the case, that is the goal of the study.
For example: “The purpose of this study is to determine the minimum required
resources to be retained in a capacity auction while accounting for system-wide
fuel supply constraints.”
• Clearly state the boundaries of the study. If there are certain aspects that will not be addressed by the study,
make that distinction clear as early in the process as possible.
For example: “The study will be limited only to the generators that are currently
in the interconnection queue through 2030.” Or “The analysis being performed
will only consider credible single points of disruption in the gas and fuel oil
supply chains.”
13
Step 2: Data Gathering

Data is essential for a valid fuel-related reliability risk analysis. While the planners performing the study are very
familiar with the transmission system and the inputs needed to perform traditional studies, there are many
considerations outside the normal inputs that are needed for this analysis. Much of the data needed is likely not
directly accessible to the planner and will therefore require the assistance of others in their company (e.g., operations
personnel) or even fuel suppliers themselves. FERC has through its Order 787 authorized the sharing of confidential
information between jurisdictional pipelines and system operators in order to ensure reliability. Planners should
consider using that authority to obtain needed information from the pipelines on a cooperative basis. The following
is a list of data sources and methods for acquiring data that can be used by planners to collect the information that
they need to perform the study outlined in Step 1:
• Coordinate fuel assurance assumptions with generator owners/operators:
 This may be achieved with surveys that may include, but are not limited to,
primary fuel availability, details of fuel supply and transport agreements,
usable on-site storage capability, historic inventory levels, resupply and back-
up fuel availability and strategy, resource limitations on alternate fuels (MW
output, switching time and process details, changes in heat rate), emissions
concerns, and staffing concerns.
Appendix B
o It may be helpful to discuss the formation of such a survey with generator contains a detailed
owners/operators and other stakeholders to seek their guidance and list of potential
expertise on the level of data they may be able and willing to provide.
survey questions
 Validate/benchmark that the data received is consistent with the recent
operational experiences when possible
Suggestions to Establish and Maintain a Suitable Fuel Survey
Consider managing a survey of this type through an established stakeholder forum
• This will ensure that any changes to the survey are subject to stakeholder discussion and therefore more
thoroughly vetted
• Ensure that the information is reaching the target audience as there can be a disconnect between
generator owners/operators and the stakeholder representatives
Consider hosting additional engagements like a winter generator readiness seminar
• This offers the opportunity to discuss with a more targeted audience of generator owners/operators and
not just their representatives
Consider conducting fuel-constrained scenarios as part of your regular training cycle
• This offers an opportunity to solicit concerns and gather potential impacts of limited fuel supply on system
operations across a wide spectrum of electric and cross-sector stakeholders
• This exercise also has the potential to identify fuel disruption impacts that can be further addressed
directly with fuel suppliers to seek actions to mitigate these impacts
14
• Gather appropriate fuel supply contingencies (to be further analyzed and filtered in Step 4):
 Coordinate with fuel suppliers or fuel specialists within your company, member companies, and/or
collaborate with the experts who own and operate the fuel supply chains, including (but not limited to)
natural gas and fuel oil pipelines, fuel producers, fuel oil refineries, storage and trucking companies, rail
carriers, and ocean or river bound tanker ships/barges. Their input will aid in the assessment of the
potential for disruption or failure. It will also lend credence to the assumptions.
 Discuss the fuel supplier’s response plans if fuel supply disruptions were to happen. Rather than rely
solely on a hands-off type of study (which still has value), consider the possible mitigating actions of the
fuel supplier after the disruptions occur in order to incorporate the impact to the BPS into your analysis.
Also consider the time considerations between the disruption and when it will impact the power system.
Not all failures have immediate impact.
o Outreach may include a review of disruption scenarios with each of the fuel suppliers operating
within the studied region to assess the viability of both the assumed disruption scenarios as well as
the potential downstream impacts.
As an example, ask the pipeline companies what remaining capacity would be available if they lost a particular
pipeline segment. Depending on the pipeline configuration, the capacity serving the area’s generators may be
reduced by 10%, 50%, or not impacted at all. Each case would produce different input assumptions for the study.
Consider review of internal operational policies and procedures with the pipelines to better understand the impact
of those procedures during a fuel supply disruption scenario.
15
Step 3: Formulate Study Input Assumptions and Initial System Conditions

Assumptions and system conditions may be developed by using information obtained from data gathering efforts
outlined in Step 2 as well as regional historical experience to establish relevant scenarios for incorporation into the
analysis. These assumptions may be specific (e.g., specific generator outage rates determined from regional historical
averages) or expressed in terms of a range (e.g., low, medium, and high ranges of projected generator retirements
affecting future fuel mix). Steps to develop these assumptions and conditions for the analysis include (but are not
limited to) the following:
• Determine which fuel(s) to study. When doing so, consider
the interdependence of various fuel types and how a large
disruption to one fuel source may impact another fuel source.
One existing analysis modeled a 14-
• Develop fuel assumptions using the best available day cold weather duration based on
information: historical weather analysis. The
 Document fuel supply assumptions for plants where data study focused on cold weather
is not available or up to date to maintain visibility of areas events because historical risks to
where the study may have weaknesses. procurement of adequate fuel were
most prominent during the winter
 Consider fuel supply alternatives, such as dual fuel use
when the needs of commercial and
and service from alternate pipelines.
residential heating were competing
• Determine weather and load assumptions: with natural-gas-fired and dual-fuel
generators. The study considered
 Weather input to the study can be historical normal and
projected typical winter load
extreme weather applied to future scenarios or some
conditions as well as extreme
version of a weather or climate forecast that describes
winter load.
the study time frame.
 For a fuel risk analysis, the system under study is more
than just the BPS. There are going to be shared resources between different sub-systems that are
interdependent; for example, natural gas is used for both heating and power generation.
Understanding the relationship between those two classes of natural gas demand is
paramount when performing this study. Knowing what will happen when the natural gas
system is full due to colder temperatures will define what direction the study goes and, in
large-part, the results of the study. Fuel oil works in a similar fashion but with a different
mode of transportation. Although pipelines can carry fuel oil, it is typically via truck or barge. But the
fundamental concept is the same—when it gets cold and the demand for fuel is up, supply chains become
full and resulting supply options and priorities may be unexpected.
• Determine interchange assumptions and interface capability:
 This should include coordination with neighboring entities to ensure accuracy and
agreement of their interchange contribution. Consider whether the conditions selected
for the study will also impact an adjacent area’s interchange contribution.
 A study may assume interchange transaction quantities that reflect the economic
interaction between the studied systems and neighboring systems consistent with real-time operations.
Alternatively, a historical analysis may be performed to determine an upper and lower bound for capacity
and energy imports and exports.
Coordination with neighboring systems should also include potential impacts of a natural gas disruption
in one area on gas-fired generation in adjacent areas—affecting the amount of electric interchange
support available.
• Determine generator outage rates and reductions assumptions:
16
 Generator outage rates may be defined by using standard methods (e.g., EFORd) or using a simple
analysis of historical performance. Depending on the approach or assumptions, this may deviate from
the normally accepted methods.
EFORd – Equivalent Forced Outage Rate demand

the probability a generator will fail completely or in part when needed
 Take care not to double count outages. Understand that if a generator is out of service due to normal
outages, it cannot also be counted as a generator that is out of service due to fuel and vice-versa.
• Determine assumptions related to VERs

 These considerations will be critical in areas with high penetration of VERs where the output
range can vary significantly.
As of 2019, wind generation output ranged from 0.5 GW to 16

GW in SPP
• Consider the evolution of generation technology, changes in fuel mix, and the interdependency of future
resource installation:
 The current interconnection queue and integrated resource plans/resource adequacy plans may inform
planners of resources to be selected in longer-term analyses.
 Resource planning forecasts are performed on a regular basis. These studies evaluate the future needs
and technologies to meet those needs:
o These studies may reveal, for example, the likelihood of renewable energy additions that result in
early retirement of coal or fuel oil resources.
o State initiatives for additional dual-fuel resources, as another example, would likely introduce more
gas/fuel oil generators into the interconnection queue.
 It may be difficult to predict how the future resource mix will vary based on factors like governmental
policy initiatives. Include a range of assumptions for items that have uncertainty. 29
29
https://www.iso-ne.com/static-assets/documents/2018/01/20180117_operational_fuel-security_analysis.pdf
17
ISO-NE OPERATIONAL FUEL SECURITY ANALYSIS30
ISO New England’s Operational Fuel Security Analysis modeled a wide range of resource combinations that might be possible
several years into the future. The study examined varying resource retirements, LNG availability, oil inventory, interchange,
and renewable resources. In addition to a reference case which incorporated the likely levels of each variable, these input
assumptions were varied individually to characterize the sensitivity between unfavorable to favorable boundary cases. Several
combination scenarios, examining how multiple related changes would affect the outcome, were also examined which adjusted
more than one of the key variables to represent future resource portfolios that could develop and their effects on fuel security.
• Determine performance criteria. For example:

 If the study being performed contemplates a HILP contingency, perhaps the performance criteria would
be that 90% of firm load is maintained for a short period of time. However, when HILP is studied, it should
be done for emergency preparedness and not for measuring the reliability of specific system resources.
Another consideration in this scenario would be acceptable system ratings and limits. If the study being
performed contemplates a HPLI contingency, perhaps the performance criteria would be set to a base
case, or up to unavailability of interruptible load.
• Determine the study frequency, outlook, and duration according to the risks identified through data
gathering. Depending on the assumptions, electric system, or fuel supply chains that may have changed, the
planner should use engineering judgement and historical information. See the three-column graphic on the
next page for additional information.
30
Id.
18
Frequency Outlook Duration

For choosing a study frequency (i.e., For choosing a study outlook (i.e., For choosing a study duration (i.e.,
how often the study is performed), when does the studied time horizon what is length of the study window),
consider the following: begin) consider the following: consider the following:
• Operational time frame studies • Short-term operations planning • The duration could be anywhere
could be performed on a weekly, study outlooks (e.g., one-week from a snapshot of the current
or monthly basis, or other near- out, one-month out, six-months system to a few days out or even
term periodicity. For example, out, other-less than a year out) to multiple years, depending on
one existing analysis involves a could be used. what is appropriate for the
winter weekly or non-winter assumptions or objectives of the
• Alternatively, near-term (1–5
biweekly energy study that is study. For example, one existing
years), long-term (6–10 years)
used on an ongoing basis for analysis involves a 14-day study
transmission planning time
operations planning. window to model a plausible 14-
horizons, or even greater study
day extreme cold weather
• Seasonal studies could be outlooks could be used if
scenario based on historical
performed periodically in the appropriate for the objectives
weather analysis.
prewinter or presummer time of the study. For example, one
frames in anticipation of the existing analysis was based on a • Consider varying durations of
peak load seasons. five-year look-ahead study to fuel disruptions to determine
assess system resilience under how reliability conditions may
• Longer-term studies could be
future resource portfolios. change over time given a
performed annually, every few
particular fuel disruption.
years, or on a longer-term
periodicity as necessary.
• Ad-hoc (one-time) studies could
also be performed to assess a
unique set of conditions and to
achieve specific objectives, and
may be more limited in scope.
ISO-NE performs a 21-day look ahead energy assessment based on the

lead time it takes to schedule an LNG and fuel oil truck delivery within
the associated region.
• Include any special or additional scenarios or assumptions, such as the following:

 Heavy seasonal directional power transfers
 Changes in generation mix
 Drought or flooding conditions
 Changes in fuel supply situation (e.g., closure of refineries or LNG storage facilities, new provisions that
limit or prevent local gas and fuel oil transport)
 System-wide blackout scenario (e.g., scenario studying fuel-related reliability risks to blackstart units and
potential impact on system restoration following a blackout)
• Document the rationale behind study assumptions and initial system conditions
19
Step 4: Contingency Selection

The data gathered at this point will help to form the basis for contingencies to the fuel supply of
the studied system. Some aspects will be known, and some will be assumed. It is possible that not
all contingencies will be included in the final study once the probability and credibility of the
various scenarios are better established. It may be prudent to establish a priority level for
different contingencies based on the planner’s experiences. There are many factors to consider
in filtering and selecting the appropriate contingencies to study; this may include, but is not
limited to, the following:
• The cause of the fuel disruption (which helps with developing proper mitigation) 31
• The frequency with which the disruption has occurred in the past in this or other locations
• The probability or likelihood that the disruption will occur in the future
• The expected duration of the disruption based on historical data or reasonable assumptions that
acknowledge system improvements over historical data:
 Fuel disruption duration can be seasonally dependent. For example, a failed fuel delivery system during
the high-demand winter months will likely be shorter in duration than a disruption during low-demand
periods.
• The amount of fuel supply interrupted (This is a line to be drawn based on relevance to the scenario being
studied.)
The loss of a single natural gas compressor engine at a station is more likely than the loss of an entire compressor
station. Many fuel supply systems contain redundancies and safeguards, making a full outage of service less likely
than a partial outage.
• The location of the disruption, even outside of your footprint as fuel delivery is a worldwide operation
 Interdependence of global markets on local systems should not be overlooked (e.g., LNG imports
in Japan surged following the 2011 Fukushima nuclear power shutdown.)
• The generating units that may be affected by the disruption (Be sure to account for remaining
generating capability if any.)
o Consider alternatives available to impacted generating units, such as dual fuel use and service from
alternate pipelines 32
• The extent or scope of the interruption as to whether it impacts other companies, industries, or other
subsystems, such as the following:
31 NERC Generator Availability Data System data collection was updated for 2020 reporting and going forward cause coding for “lack of fuel”
reporting will be much improved.

32 Eastern Interconnection Planning Collaborative (EIPC), 2015 Gas-Electric System Interface Study, Section 10 on Natural Gas and Electric
System Contingency Analysis, https://eipconline.com/phase-ii-documents.
20
 If flooding has washed out the railways in a particular

area, rerouting coal delivery around that area will
PJM FUEL SECURITY ANALYSIS
likely be more difficult due to all rail traffic trying to
reroute to meet guaranteed delivery dates.
PJM introduced four different gas pipeline
 Consider the likelihood of mutual assistance contingencies that represented disruption of
between suppliers. It is within the realm of possibility supply in a segment for four different natural gas
that a pipeline or fuel oil transporter could suffer a pipelines within the PJM region. Each contingency
resulted in reduced capacity on the affected
loss of capability and receive assistance from an
segment of the interstate pipeline, thereby
interconnected pipeline or associated supplier.
impacting the ability to deliver natural gas to
 Consider whether electric load shedding to resolve generating units downstream of the disruption.
BPS problems will impact fuel availability or For each contingency, PJM simulated partial
subsequent plant operations. disruptions (medium impact event resulting in loss
of a one out of multiple parallel lines in a pipeline
 Consider the impact of electric contingencies on the segment) and full disruptions (high impact event
natural gas system or recovery from a natural gas resulting in loss of all parallel lines in a pipeline
disruption (e.g., loss of power to electric driven segment). Each of these contingencies modeled
natural gas compressor stations or transmission took into consideration the design of the affected
contingencies that may restrict the redispatch of pipeline segment to determine the reduced
non-natural-gas-fired generators). capacity of the pipeline and impact to downstream
generator availability. The methodology for
• The influence of governmental agencies may also factor layering in the disruption scenarios and the
into the studied response to contingencies: assumptions for the duration of the disruptions
were based on observed conditions during recent
 Consider historical reactions by governing agencies. pipeline disruption events as well as consultations
 Consider guidance from governmental agencies, with the Natural Gas Council and major interstate
pipeline companies serving the PJM region.
such as the potential for cyber and/or man-made
threats to fuel delivery systems.
 Consider working with relevant governmental agencies to share the analysis, develop and gain any
needed approval for mitigation measures.
• Nontraditional solutions may be available when directed by emergency management or similar agencies.
Conversely, fuel supply could be made unavailable due to decisions made at the governmental level. For
example, a port necessary for the delivery of LNG or fuel oil may be shut down following worldwide events
that result in a state of heightened security. Another example may be the limited usage of fuel oil unless a
special (environmental) waiver is granted by state or federal officials.
Following a pipeline disruption event impacting one of the looped lines in a pipeline segment, PHMSA has
historically required a mandatory capacity reduction (typically about 20% firm capacity reduction) in the
adjacent non-impacted lines within the same pipeline right-of-way until initial investigation of the incident is
complete. PHMSA has also historically restricted access to an affected pipeline segment following an event for
safety reasons, delaying immediate restoration efforts by pipeline operators. Both the capacity reduction and
delayed restoration due to PHMSA’s response should be considered when studying the natural gas pipeline
contingency impact and duration.
• Document the rationale for each contingency selected.
21
Step 5: Selection of Tool(s) for Analysis

Because of individual system conditions and goals, no single type of transmission system
analysis will meet the need of every planner. Therefore, each planner should consider the
information gathered in the steps above and choose analysis tools that can provide
information that will allow for a thorough assessment of their supply and transmission
systems. This analysis may be power flow, stability or dynamic simulation, production cost
modeling, market simulation, fuel oil and natural gas
pipeline hydraulic flow modeling, deterministic Power flow
versus probabilistic modeling, in-house tools, or any combination of these
tools and others. Stability simulation
Production cost modeling
Regardless of the tool(s) chosen, the rationale for the selection should be
documented and reviewed periodically to ensure that the appropriate tools Market simulation
continue to be utilized and provide continuity from the end of the analysis Pipeline flow model
to what was defined in the goals.
Deterministic vs.
probabilistic model
Step 6: Perform Analysis and Assess Results
Based on the information from Steps 1–5, system analysis will be performed In-house tools
and assessed. The assessment will evaluate system performance based on
the criteria defined in Step 3 to determine if system deficiencies exist and,
if so, what actions might be considered to improve the observed deficiencies. Every step of the process was defined,
including the criteria for system performance. At this point of the analysis, the state of the system is known. If the
assessment determines that the system does not meet the prescribed criteria for reliable operation of the power
system, and corrective actions are needed, this step is where that would happen.
When delivering the results of the study, consider the audience. Consider their level of knowledge
of the system being studied and speak to the audience at a level they will understand. Use
commonly understood terminology, processes, and procedures so that the audience will more
likely comprehend the results as intended.
Step 7: Develop Solution Framework

As noted in Step 3, fuel assurance studies should be completed on an ongoing basis. Regular analysis will help planners
and other stakeholders better understand emerging risks as the power grid undergoes rapid transformation. Planners
are encouraged to develop a solution framework to ensure fuel assurance in advance of any potential credible
reliability issues. It is at this point that the planner should consider engaging governmental agencies that may be able
to assist with developing a framework of potential solutions. One example might be contacting state environmental
departments to discuss power plant air and water permits should a HILP contingency occur. At a larger regional level,
planners are encouraged to consider developing a response and mitigation plan for grid, generator, and natural gas
operators to guide their response to fuel assurance contingencies as identified in Step 4. Further, the development
of a communications protocol for grid, generator, and natural gas operators could benefit the regional response to
and mitigation of contingencies as identified in the risk analysis framework. These proactive actions will ensure
preparedness and improved situational awareness to handle these potential risks in the future.
22
Appendix A: Risk Analysis Framework Checklist
This checklist outlines the actions recommended in Chapter 4 into a list that entities may use as a reference when
performing their own analysis. As mentioned at the beginning of Chapter 4, the listed steps are intended to be flexible
enough to account for all fuel types, broad enough to support the unique circumstances in each region, and may be
performed out of order (or in some cases not at all).
Step 1: Problem Statement and Study Prerequisites

Define the study goal (i.e., problem statement)
Set the criteria for system performance
Communicate the goals of the study with all stakeholders (electric and fuel suppliers)
Gain agreement on principal concepts
Determine the timeline prior to commencing work
Set the boundaries of the study
Document agreed upon goals, time line, boundaries, etc.
Step 2: Data Gathering

Coordinate fuel assurance assumptions with generator owners/operators
Survey stakeholders (see Appendix B)
Identify relevant fuel supply contingency events
Maintain documentation for future use
Step 3: Formulate Study Input Assumptions and Initial System Conditions

Determine fuel(s) to be studied
Determine the interdependence of various fuel types
Determine how a large disruption to one fuel source may impact another fuel
If needed, develop fuel assumptions in the absence of actual information
Determine weather and load assumptions
Determine interchange and interface capability
Determine generator outage and reductions rate assumptions (e.g., EFORd)
Determine assumptions related to variable energy resources
Determine expected changes in regulatory policy, generation technology, and fuel mix, including the
interdependency of resource installation
Determine performance criteria using stakeholder input (e.g., is load loss acceptable? If so, for how long?)
Determine study frequency, outlook, and duration
Include any special or additional assumptions or system conditions, the following are examples:
Heavy seasonal energy transfers
23
Appendix A:Risk Analysis Framework Checklist
Changes in generation mix

Droughts
Flooding
System-wide blackout scenario
Document rationale for assumptions and system conditions selected
Step 4: Contingency Selection

Filter down identified contingencies. Consider CEII ramifications. Consider factors like the following:
Cause of the fuel disruption
Frequency with which the disruption has occurred in the past in this or other locations
Probability or likelihood that the disruption will occur in the future
Expected duration of the disruption based on historical data or reasonable assumptions
Amount of the fuel supply interrupted
Location of the disruption
Generating units affected by the disruption and remaining generating capability (if any)
Extent or scope of the interruption (does it impact other companies, industries, etc.)
Influence of governmental agencies on the response to contingencies
Document rationale for contingency selection
Step 5: Selection of Tool(s) for Analysis

Select analysis tools appropriate for the study, such as follows:
Power flow
Stability simulation
Production cost modeling
Market simulation
Pipeline hydraulic flow modeling
Deterministic vs. Probabilistic modeling
In-house tools
Document rationale for selection
Step 6: Perform Analysis and Assess Results

Perform analysis
Document and assess results
Consider CEII ramifications
NERC |Fuel Assurance and Fuel Related Reliability Risk Analysis for the Bulk Power System |March 2020
24
Appendix A:Risk Analysis Framework Checklist
Step 7: Develop Solution Framework

Identify potential risks
Develop solution framework as needed and in concert with stakeholders, regulators, etc.
Update existing plans and procedures
25
Appendix B: Items to Include in a Fuel/Energy Survey
This list is indicative but not all encompassing of the questions that planners may ask of its generator
owners/operators depending on the regional study goals and the possibility of regional fuel type generation
considerations.
When drafting a survey, consider whether certain questions should be made mandatory. Also consider how to format
answer selections; should some be limited to multiple choice, is free form text more appropriate, etc. It will also be
important to seek consistency in units of measurement. Make an effort to clarify what units are desired (MW, MWh,
MMBtu/day, etc.) so that compiling and analyzing responses is straightforward.
General Information
• Resource information
 Name
 Contact
 Unit identifier
 Type
• Square footage of fence footprint and what percentage of that space is empty
• Is there a “bump-up” compressor on-site? How often is it used?
• Net max and min sustainable rating
• Design and/or current operational max/min ambient temperature
• Unit maximum Summer heat rate
• Unit maximum Winter heat rate
• Dual Fuel Unit heat rate on different fuels
• Primary fuel source
• Alternate fuel source
 Fuel switching requirements, or other considerations
• Date of last MW disruption (or not received) on primary fuel (within the last 5 years)
• Amount of MWs disrupted (or not received)
 Reason for disruption (or not received)
• Have any fuel supply procurement processes been compromised?
 For example, limited trucking capability, navigation issues, lack of refinement capability from supplier
 How often?
 Any seasonal issues?
• Planned retirement date
• Is staffing required to start the unit?
• Is staffing required to switch fuels?
26
Appendix B:Items to Include in a Fuel/Energy Survey
• Is unit black-start capable or on ISO/RTO system restoration Plan?

• Consumable item most limiting unit operations (e.g., limestone, chemicals, demineralized water trailers, air
or water emission credits)
• Does the unit/station have existing on-site natural gas compression
• Availability of on-site boost compression
• Is there backup power on-site?
• Are there state restrictions on future use of this unit?
• What is the impact and duration of maintenance shutdowns?
• What is the risk of third-party damage to plant, inventory or transportation types to the plant?
Natural Gas Pipeline Information

• Companies providing physical natural gas pipeline connections
• Critical compressor facilities
 Identify whether natural gas or electric compressors connected to or required by the unit (if known)
 Identify if spare compression is available at each compressor site
• Required minimum pressure for full, half, and minimum output
• Required minimum pressure for unit operation (<full output)
• Peak burn rate
• Transportation contract
 No-notice service, firm, enhanced Firm, secondary firm, interruptible, etc.
 Transportation contract options available for natural-gas-fired generators
• Commodity
 Type of service—firm or interruptible, Other?
o Number of available suppliers
 Number of pipelines
 Storage access
 Asset Management Arrangements (e.g., firm delivery expressed in MMBtu/day)
• Seasonal operations considerations
 Identify any force majeure events called by the pipeline in the last 10 years
 Identify any critical generators connected to the pipeline that could affect your deliveries
 What is the nature of the balancing flexibility the pipeline offers you and provide a link to the tariff
summary
• Seasonal maintenance considerations
Oil Information
• Limitations on oil burn, number of hours, emissions limitations, seasonality limits
27
• Number of hours of operation at max/min output on oil

• Maximum fuel storage capability
• Type(s) of oil (e.g., residual fuel oil, fuel oil #2, etc.)
 Available usable fuel in storage (typical annual-average value)
• Plans to increase available usable fuel amount
• Assurance level for additional deliveries
• Can fuel be replenished faster than it is used?
• Alternate fuel contracts
• Number of alternate fuel suppliers
• Fuel primary and alternate transportation type (pipeline, barge, rail, truck, etc.)
• Fuel resupply limitations
 Notice time and delivery time
 Deliveries expected over given period of time (e.g., how many per day)
 Proximity of supplier(s)
 Available offloading facilities
• Does unit need natural gas to start?
 If so, is the fuel stored on site?
• Do other units share oil inventory?
• If so, number of hours of operation at max output on shared oil
Coal Information
• Maximum storage capacity
• Current inventory amount
• Inventory resupply plans
• Alternative suppliers
• Maximum output that can be sustained indefinitely
• Fuel primary transportation type (barge, rail, truck, etc.)
• Secondary transportation
• Fuel delivery time
• Is delivery on a schedule?
• Scheduled time between replenishments
• Maximum amount delivered in a single shipment
28
• Typical coal level for replenishment order

• Units that share coal inventory
• Max runtime for unit with shared fuel inventory
• Does unit need oil or natural gas to start?
 If so, what fuel(s) is stored on site?
• What is the unit’s history of freezing coal inventory/piles and are any measures in place to mitigate freezing?
Alternate Fuel Information

• Alternate fuel source(s)
• Additional staffing requirements to start the unit on alternate fuel
• Number of hours of operation at max on alternate fuel
• Maximum fuel storage capability
• Available usable fuel in storage
• Plans to increase available usable alternate fuel amount
• Alternative suppliers
• Fuel primary transportation type (barge, rail, truck, etc.)
• Secondary transportation
• Alternate fuel resupply time
• Unit net MW max capability on alternate fuel
• Does the unit have to be taken off-line to switch to the alternate fuel?
 If not, what is the MW output level needed to perform switching?
• Time to transition to alternate fuel
• Date alternate fuel capability was last tested
• Amount of net MW output achieved while on alternate fuel
• Does unit need natural gas to start?
 If so, is the fuel stored on site?
• Max number of starts per day on alternate fuel
• Number of starts per week on alternate fuel
• Can generator operate on both fuels simultaneously?
Environmental/Emissions
• Unit environmental/emissions limitations
• Pollutant responsible for most limiting emissions limit
29
• Limit periodicity of pollutant responsible for most limiting emissions limit

• Pollutant responsible for most second most limiting emissions limit
• Limit periodicity of pollutant responsible for most second most limiting emissions limit
• Other environmental/emissions concerns
30
Contributors
Contributor Company
Matthew Agen American Gas Association
Randall Van Aartsen Jacksonville Electric Authority
Nancy Bagot Electric Power Supply Association
Jordan Bakke MISO Energy
Eric Baran Western Interstate Energy Board
Karie Barczak DTE Energy
Scott Barfield-McGinnis North American Electric Reliability Corporation
Marcus Beasley SERC Reliability Corporation
Olivier Beaufils Wood Mackenzie
Richard Becker SERC Reliability Corporation
Matthew Beilfuss WE Energies
Bashir Bhana Independent Electricity System Operator
Katrina Blackley North American Electric Reliability Corporation
Jeffery Bloczynski Americas Power
Michelle Bloodworth Americas Power
Jonathan Booe North American Energy Standards Board
Mike Boughner Xcel Energy
Peter T. Brandien Independent System Operator - New England
John Brewer National Energy Technology Laboratory
Dick Brooks Reliable Energy Analytics LLC.
David Brown NextEra Energy Resources, LLC
Layne Brown Western Electricity Coordinating Council
Keith Burrell New York Independent System Operator
Masuncha Bussey Duke Energy
Rob Cashell Colorado Springs Utilities
Augustine Caven PJM Interconnection
Thomas Coleman North American Electric Reliability Corporation
Jeffery Dagle Pacific Northwest National Laboratory
Enoch Davies Western Electricity Coordinating Council
Lewis De La Rosa Texas Reliability Entity
Leeth DePriest Southern Company
Jay Dibble Calpine
William Donahue Puget Sound Energy
Katie Ege Great River Energy
Omar Elabbady Xcel Energy
Christine Ericson Illinois State Government
Ed Ernst North American Transmission Forum
Lynna Estep North American Transmission Forum
Brian Evans-Mongeon Utility Services, Inc.
Eric Eyberg Wood Mackenzie
Patrick Farace Federal Energy Regulatory Commission
Daniel Farmer Entergy
Philip Fedora Northeast Power Coordinating Council
Mike Ferguson Indeck Energy Services, Inc.
Jennifer Flandermeyer Evergy
31
Contributors
Contributor Company
Stephen Folga Argonne National Laboratory
Michael Fortini DTE Energy
Tim Fryfogle ReliabilityFirst
Dennis Gee Pacific Gas and Electric Company
Bill Graham North American Electric Reliability Corporation
Venona Greaff Occidental Petroleum Corporation (OXY)
Wayne Guttormson Sask Power
Maria Hanley Federal Energy Regulatory Commission
Katherine Harsanyi United States Department of Energy
Christina Hayes Berkshire Hathaway Energy Company
Daniel Head Consolidated Edison Company
Lynn Hecker MISO Energy
Bradley Heisey Tenaska, Inc.
Mark Henry Texas Reliability Entity
Michael Herman PJM Interconnection
Jo Hsiung Federal Energy Regulatory Commission
Michael Isper Interstate Natural Gas Association of America
Patricia Jagtiani Natural Gas Supply Association
Marilyn Jayachandran PJM Interconnection
Leah Kaffine ABB
Anuj Kapadia Federal Energy Regulatory Commission
James Kavicky Argonne National Laboratory
Tom Knowland Independent System Operator - New England
Andrea Koch Edison Electric Institute
William Lamanna North American Electric Reliability Corporation
Russell Laursen WEC Energy Group
Suzanne Lemieux American Petroleum Institute
Michael Lombardi Northeast Power Coordinating Council
Connie Lowe Dominion Energy
Glen Lyons Exxon Mobil
Eli Massey MISO Energy
David McConkey Canadian Gas Association
William Meyer NextEra Energy Resources, LLC
Leah Michalopulos Canadian Electricity Association
Sharon Midgley Exelon
Reene Miranda Xcel Energy
Roger Moraitis NextEra Energy
Mehmet Aydemir Nehrozoglu Consolidated Edison Company
Brent Oberlin Independent System Operator - New England
Brian O'Boyle Consolidated Edison Company
Mark Olson North American Electric Reliability Corporation
Raymond Orocco-John Federal Energy Regulatory Commission
C. J. Osmano Interstate Natural Gas Association of America
Darrell Pace Southern Company
Jason Pan Wood Mackenzie
Martin Paszek Consolidated Edison Company
Jaimin Patel Sask Power
32
Contributors
Contributor Company
Margaret Pate North American Electric Reliability Corporation
Levetra Pitts North American Electric Reliability Corporation
Thomas Popik Resilient Societies
Michael Powell Canadian Electricity Association
Donna Pratt North American Electric Reliability Corporation
Theresa Pugh Theresa Pugh Consulting
Ryan Ramcharan Consolidated Edison Company
Raborn Reader Enterprise Products Partners, LP
Laura Ritter Duke Energy
Sammy Roberts Duke Energy
Cathy Rourke Tellurian, Inc.
Stephen Rourke Independent System Operator - New England
John Rudiak Avangrid
Allen Schriver Florida Power and Light
Phillip Shafeei Colorado Springs Utilities
Jared Shaw Entergy
Wayne Sipperly North American Generator Forum
Aiden Smith Oneok, Inc.
Todd Snitchler (Vice Chair) Electric Power Supply Association
Stephen Stafford Georgia Transmission Corporation
Bob Staton Xcel Energy
John Stevenson New York Independent System Operator
David Swiech DTE Energy
Albert Taylor Wabash Valley Power Alliance
Michelle Thiry (Chair) Entergy
Chad Thompson Electric Reliability Council of Texas
Justin Thompson Arizona Public Service
Devon Tremont Taunton Municipal Lighting Plant
Kyle VanderHelm Tenaska, Inc.
Juan Villarreal Villarreal Energy, LLC
Nick Voris Kansas City Power and Light
Yajun Wang Dominion Energy
Douglas Webb Evergy
Steve Wenke Avista Corporation
Matt Whitenett Fortress Information Security
Patrick Wilkey Argonne National Laboratory
Noman Williams Grid Alliance
Wes Williams Bryan Texas Utilities
Cyndy Wilson United States Department of Energy
Scott Winner Bonneville Power Administration
Brad Woods Texas Reliability Entity
Craig Wrisley Xcel Energy
Ping Yan Electric Reliability Council of Texas
Charles Yeung Southwest Power Pool, Inc.
Joel Yu Consolidated Edison Company
33

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Reliability Guideline

Fuel Assurance and Fuel-Related Reliability Risk

RELIABILITY | RESILIENCE | SECURITY

NERC | Report Title | Report Date

Reliability | Resilience | Security

MRO Midwest Reliability Organization

2017 NER C Special Assessm ent Appendix E Recommendations

Identify potential natural gas system contingencies and their likelihood of

Assess the impacts for each of the identified contingencies in terms of

Apply the contingency disruptions to the natural gas supply capabilities to

Determine the transmission systems ability to transport power to load

FUEL SECURITY ANALYSIS: A PJM RESILIENCE INITIATIVE 7

Fuel Assurance Principles

• Enhanced infrastructure considerations

Transmission Planners/Planning Coordinators

9 See 18 C.F.R. § 284.7(a) (3).

Solar, Wind, and Other

“Line Hit,” such as an excavating crew accident “Other,” such as corrosion

reason of section 1(c) of the Natural Gas Act.

Step 1: Problem Statement and Study Prerequisites

Consider the following to help define the study:

Step 2: Data Gathering

Suggestions to Establish and Maintain a Suitable Fuel Survey

Consider managing a survey of this type through an established stakeholder forum

Consider hosting additional engagements like a winter generator readiness seminar

Consider conducting fuel-constrained scenarios as part of your regular training cycle

Step 3: Formulate Study Input Assumptions and Initial System Conditions

EFORd – Equivalent Forced Outage Rate demand

• Determine assumptions related to VERs

As of 2019, wind generation output ranged from 0.5 GW to 16

ISO-NE OPERATIONAL FUEL SECURITY ANALYSIS30

• Determine performance criteria. For example:

Frequency Outlook Duration

ISO-NE performs a 21-day look ahead energy assessment based on the

• Include any special or additional scenarios or assumptions, such as the following:

Step 4: Contingency Selection

reporting will be much improved.

System Contingency Analysis, https://eipconline.com/phase-ii-documents.

 If flooding has washed out the railways in a particular

• Document the rationale for each contingency selected.

Step 5: Selection of Tool(s) for Analysis

Step 7: Develop Solution Framework

Step 1: Problem Statement and Study Prerequisites

Step 2: Data Gathering

Step 3: Formulate Study Input Assumptions and Initial System Conditions

Changes in generation mix

Step 4: Contingency Selection

Step 5: Selection of Tool(s) for Analysis

Step 6: Perform Analysis and Assess Results

Step 7: Develop Solution Framework

• Is unit black-start capable or on ISO/RTO system restoration Plan?

Natural Gas Pipeline Information

• Number of hours of operation at max/min output on oil

• Typical coal level for replenishment order

Alternate Fuel Information

• Limit periodicity of pollutant responsible for most limiting emissions limit

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