NERC CIP Low Impact RequirementsThe July 1 effective date for High and Medium Impact Bulk Energy System (BES) Cyber Systems is rapidly approaching, causing Registered Entities and Regional Entities to now shift their focus toward meeting the Low Impact BES Cyber System (BCS) requirements.

This will be the first in a series of articles covering those requirements, what Burns & McDonnell has experienced in helping Registered Entities in their implementations, and information being provided by NERC and the Regional Entities as part of their outreach efforts.

What to Expect

Over the next few week, I’ll cover a variety of topics related to NERC CIP requirements, including:

  • Culture change due the implementation of the CIP Standards, especially for Entities new to the CIP Standards and how the current culture can impact implementation of the Standards
  • Defining what Policies, Plans and Procedures are, and what should they contain
  • Inventory of facilities with Low Impact BCS and methods of approach to demonstrate that they comply with several of the Standards requirements
  • Configuration information required for several of the Standards requirements and potential issues experienced during the collection process
  • What have other Entities done to implement these requirements while facing budget and resource constraints

Important Dates to Note

One of the initial items to understand about these requirements is the enforcement dates for Low Impact BCS summarized below:

July 1, 2016

  • CIP-002-5.1, R1 & R2 — BCS Impact Determination, Review and Approval
  • CIP-003-6, R3 & R4 — Identification of CIP Senior Manager and Delegations

July 15, 2016

  • Self-Certification for CIP-002-5.1

April 1, 2017

  • CIP-003-6, R1 Part 1.2 — Cyber Security Policies for Low Impact BCS
  • CIP-003-6, R2 Attachment 1, Section 1 — Cyber Security Awareness Plan
  • CIP-003-6, R2 Attachment 1, Section 4 — Cyber Security Incident Response Plan

September 1, 2018

  • CIP-003-6, R2 Attachment 1, Section 2 — Physical Security Controls Plan
  • CIP-003-6, R2 Attachment 1, Section 3 — Electronic Access Controls Plan

By now, Registered Entities should already have their CIP-005.1 BCS Impact Determination completed since the original enforcement date was April 1, 2016, which was moved to July 1 by FERC earlier this year.

One area which Burns & McDonnell has seen some client confusion is the identification of the CIP Senior Manager and Delegates and when that is to be enforced for Entities who only have Low Impact BCS, or never had a previous CIP Program implemented. As noted above it is July 1 and not the first Low Impact BCS date of April 1, 2017.

Additional Information to Keep in Mind

Over the next few months, I will try and provide industry references to Low Impact BCS, which start with the following:

  • The WECC will be conducting a CIP Low Impact Workshop May 25-26, 2016, in Salt Lake City, Utah.
  • Scott Mix from NERC has been presenting, “Auditing Low Impact BES Cyber Systems” at several Regional Workshops, with a link provided here for the ReliabilityFirst presentation on April 15, 2016.
  • Burns & McDonnell will have our second-annual Power Utility Security & Compliance Symposium August 9-10, 2016, which will cover several subjects related to Low Impact BCS.

Michael C. Johnson is a member of the Compliance & Information Protection Group at Burns & McDonnell. He provides cybersecurity and NERC CIP compliance consulting to generation, transmission and distribution entities.


How Power Plants Can Prepare for Overlapping EPA RegulationsLast fall, the United States Environmental Protection Agency (EPA) finalized a rule that sets the first federal limits on the levels of toxic metals in power plant effluents. The rule will likely affect about 12 percent of steam electric power plants that must reduce the levels of metals, nutrients and other pollutants by 1.4 billion pounds. The overlap of these new wastewater regulations and recently passed Coal Combustion Residual (CCR) regulations poses significant challenges for power plants.

The Cost of Implementation

The EPA estimates it will cost $480 million industrywide to come into compliance with effluent limitation guidelines (ELGs). But some — including representatives from the National Rural Electric Cooperative Association — believe that number is too low. A recent special report from Bloomberg BNA asserts high capital costs will place too high a burden on small- and medium-sized power plants to meet the EPA’s new regulations.

The issue of power plant wastewater goes back to the Clean Air Act Amendments of 1990, when technologies for scrubbing the pollutants out of exhaust gases led to an increase in those pollutants in wastewater. The new rule provides ELGs — national standards for how this wastewater must be managed or treated before it can be discharged to surface waters.

Overlapping ELG and CCR Regulations

Complicating the situation is the timing of an EPA regulation covering coal combustion residuals (CCR), which went into effect in October 2015. CCRs are fly and bottom ash, boiler slag or flue gas desulfurization (FGD) materials generated by coal-fired power plants. This rule change sets standards for where and how ponds and landfills are built, operating them, monitoring their performance and closing them when full. The regulation is expected to lead to the closure of a number of CCR ponds and landfills.

ELGs and CCRs are intimately connected. As coal-fired power plants take action to meet the ELG rule, they must also consider the CCR requirements. For example, if ash pond use is halted because of the ELG, then the pond must be closed under the CCR rule within a specific amount of time and must meet other CCR requirements. Burns & McDonnell can help you develop solutions for both ash handling and wastewater treatment, but these systems take time to plan and implement.

Developing a Long-Term Plan for Compliance

With the EPA tightening up in both areas, the idea that power plants will have to do nothing is unlikely. If not already in progress, operators should make it a priority to develop a compliance strategy that considers both the CCR and ELG. One step in that process is converting to dry handling of fly ash and bottom ash — a process we’ve helped operators across the country implement.

So, what’s next? Where do you use water? How are you going to handle a dry process? What does your water look like when your ash pond goes away? Answering these questions can provide a good foundation for compliance.

Understanding your plant’s water budget is the first step. If needed, our team has the equipment in house to design and conduct a flow metering program at your plant to document your flows. A valuable but sometimes overlooked tactic is the development of a strong water management program, cutting water use by doing everything from fixing leaky pumps to tightening up operational processes. A surprising amount of water can be lost through pump seals and small process leaks. The less water you use, the less you have to treat and discharge. Because water treatment costs are driven by the flow rate, tightening the water budget can pay off big in capital cost savings.

The next step is understanding what you need to do to comply. Are you only impacted by the ELG requirements, or do you also have local discharge requirements — such as water quality based effluent limits (WQBELs) — to contend with? Consultants with extensive permitting experience can be a significant asset in helping your plant reach compliance as cost effectively as possible.

A good water balance is vital. It’s a tool to predict the impact of changes in plant processes on water use and on effluent quality. If paired with monitoring data, the water balance can become a mass balance that will estimate the final concentration of regulated constituents in the plant effluent, following dry ash conversion and pond closure. This, in turn, will show whether wastewater treatment systems are needed for any of the “leftover” streams, and help to size any new equipment that is needed.

If treatment is needed, tactics to achieve compliance might include a mix of pond-based systems and tank-based systems, including flue gas desulfurization (FGD) wastewater treatment using both physical/chemical and biological systems. Some may choose to install evaporative treatment or eliminate all FGD wastewater by another method in order to qualify for extra time to meet the compliance deadline. It sounds complicated and it can be. The changes required by both recent EPA regulations are extensive.

We’re committed to helping our clients simplify the process by helping define treatment goals and outlining a plan for moving forward.

What do you think? Are these regulations too heavy a burden for small to midsize power plants? Share your thoughts in the comments.

Diane Martini, an associate environmental specialist at Burns & McDonnell, has more than 30 years of experience in water and wastewater design and operations. She’s focused on developing strategies for coal-fired power plants faced with the new Steam Electric Power Effluent Limitation Guidelines (ELGs), the Coal Combustion Residuals (CCR) rules and other new regulations.


Using ITS Technology for Transportation Safety

by Andrew Reid April 13, 2016

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The Core Plant Concept: A New Approach to Gas Processing Plant Design

by Karen Bray April 7, 2016

The midstream industry has experienced a phenomenal construction boom over the last several years. Speed-to-market was once the name of the game, but times have changed; margins are down and gas processors have new marching orders when it comes to capital projects: Cost is king. With management at midstream companies looking for a significant step […]

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Applying TOTEX to Electric Gas Transmission & Distribution Assets

by Mike Beehler April 4, 2016

With the pace of transformation in the transmission and distribution industry, there’s no shortage of relevant and interesting topics. Today’s growing demand for resilient, reliable and sustainable energy at an affordable price suggests that we may need to look for new ways to plan and analyze capital investments in power assets of the future. That’s […]

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