|By Robynn Andracsek, P.E., and R.J. Hope, CPP, ABCP, Burns & McDonnell|
Editor’s note: This is Part II of a three-part series on power plant security. Read Part I: Security in an Emergent Threat Environment: Motivating Factors.
The first article in this series (July 2014) touched on events that are driving change in the security posture of the energy industry, specifically substations assets. No sooner did the ink dry on writing that column, the industry experienced another event. On the morning of Wednesday, June 11th local police were notified that a fence was breeched and a small incendiary device was detonated at a substation in Nogales, Arizona. The bomb was placed at one of the 50,000 gallon diesel storage tanks at the site and ignited, causing a minor rupture and fuel leak. While obviously not to the scale of the April 2013 events in San Jose, this is another illustration of the developing threats to U.S. electricity generation and transmission assets. While members of the power industry are working to improve security, the threat model continues to evolve.
In light of the events in San Jose, the Federal Energy Regulatory Commission (FERC) directed the North American Electric Reliability Corporation (NERC) to submit reliability standards that require owners and operators of transmission stations and substations to take measures to protect against physical attacks and vulnerabilities. NERC’s newly proposed regulation, CIP-014, addresses these measures and lays out the guidelines for implementation. The process involves Risk Assessment, Threat Evaluation, Development of Security Plans and Third Party Verification. The purpose of CIP-014 is “to identify and protect Transmission stations and Transmission substations, and their associated primary control centers, that if rendered inoperable or damaged as a result of a physical attack could result in widespread instability, uncontrolled separation, or Cascading within an Interconnection.” While the screening criteria for substations will most likely not include those situated directly outside of generating facilities, some screening of those stations will take place to demonstrate that an evaluation has been conducted to establish that they were below the screening criteria.
In light of both the CIP-014 requirement and events in the industry, many utilities are taking early action to harden their assets. This includes evaluating substations based on the CIP-014 risk criteria to clearly identify applicable substations, conducting security risk assessments to better understand the risk exposure and implementing additional physical security measures to mitigate from those identified risks. The security approach can vary based on the security strategy of a given organization as well as the essential nature of the assets and the clients they serve. Those servicing critical functions such as state and federal governments and hospitals are taking aggressive steps at these key stations.
Entities across the country are evaluating the physical security of their sites on threats seldom seen inside the United States. These include vehicle-borne improvised explosive devices (car/truck bombs), man-portable improvised explosive devices (pipe bombs), assault teams and asset shootings (snipers). Considerations such as clear lines-of-sight (shooting lanes) and hostile vehicular approach paths are common abroad but are certainly new and require a unique skillset. These analyses can empower a utility to make wise budgetary decisions by accounting for event probability, target shifts, and attack characteristics.
Necessity is the mother of invention and this particular circumstance is no different. Protective measures such as ground-based radar, advanced camera analytics and high security fencing are proving to be promising solutions. These methods continue to build on the fundamentals of security which are to deter, detect, delay, deny and respond. It is understood that risk is not a zero sum game and this is especially true in an industry where operational tempo can affect the types of security measures that are implemented. The utility still has to operate, provide maintenance, and continue to service its customers.
As the industry works to implement risk mitigation options many topics need to be considered, such as permitting, clearance requirements, air flow to cool the equipment, and community relations. All these issues affect selection criteria and implementation. The important part of these types of mitigation plans is that they need to be compatible with current and planned security strategies. Without full integration into normal operations, these solutions can fall in disuse as the memory of the initiating events fade.
Akin to when Michael Corleone went to Vegas, it’s time to look beyond the sensationalistic headlines and maintain focus on the business of supplying electricity in a safe and secure manner.
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