case study

Program Overhaul and Support

Initial Engagement

In 2021, NST supported the transition of a low impact generation plant to the status of medium impact. After an Independent System Operator (ISO) identified the facility as critical to the derivation of an Interconnection Reliability Operating Limit (IROL), the entity needed to:

  • Evaluate their current program;
  • Prepare for the necessary infrastructural and programmatic changes; and
  • Implement a full program in compliance with the NERC CIP standards for medium impact systems.  

NST completed a Gap Analysis and produced a detailed 24-month roadmap to lead the entity through the development process. Additionally, NST tracked each change and its associated costs for the sake of securing appropriate reimbursement from ISO.  

Additional Engagements

NST led the design and implementation of all necessary processes, documentation, and tools to support the transition. NST collaborated with site personnel, technology vendors, and regulators at various points throughout the program development process. In particular, NST took a hands-on approach to the redesign of OT systems and networks to account for segmentation between BES Cyber Systems and non-BES Cyber Systems. This included the retirement of systems that posed a challenge to ongoing compliance, as well as the transition of systems subject to compliance. NST worked closely with the client to identify vendor solutions to vexing compliance problems like system baselining, and to support the implementation of those solutions at the site.  

Following the implementation of necessary technological changes, NST worked with the client to develop the compliance program itself, beginning with process and documentation design. NST provided feedback on every element of evidence management, including collection, storage, retention, and security. Along the way, NST took a “teach a man to fish” (“teach a SME to CIP”) approach to program implementation to ensure the full capability of client SMEs to both understand and take ownership of CIP compliance processes.  

Ongoing Partnership

With the implementation of the CIP compliance program, NST continues to provide regular and routine assistance to support its upkeep. The client contracted NST to conduct Mock Audits/Gap Analyses, and to lead a full CIP-008 and CIP-009 tabletop exercise consisting of scenario development, serving as “Master of Ceremonies” and documenting formal “lessons learned”. NST also performed the annual CIP-010 Paper VA.

NST continues to supplement the CIP compliance team with periodic regular support.

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