Sunday, July 21, 2013

Another Dialog inspired by my post on "The Real Cost of CIP Version 4"

August 12: I just posted my analysis of what FERC's order today - extending the compliance date for CIP Version 4 - means.

8/1: I've posted yet another dialog from LinkedIn, inspired by the original "Real Cost" post, here. This is becoming a long-running franchise, like "Planet of the Apes."  I may be able to retire just by posting these dialogs.

In the NERC CIP Compliance group on LinkedIn, John Kontofela of the New York Power Authority made this comment about the previous post, "The Real Cost of CIP Verison 4"; my correspondent then replied to John's comment, through me so he retains his anonymity.  Below is the dialog.  I have broken John's comment into two parts, since my correspondent does that in answering John.

1. John writes, "Read through the provided email, and I can feel the pain. However, at the risk of opening up multiple cans of worms I question some of the approaches for '...building a world class version 5 program behind the diodes.'

Just to narrow it down to one - the enclosing the fiber optic data highway for the DCS in conduit. Opening up the PSP to include the portions of the plant where the fiber runs in trays would obviate the need for enclosing it in conduit. Where we have fiber in trays as long as they have covers or they are more than a certain number of feet off the ground we consider it in the extended PSP."

My correspondent writes, "Through several years of managing PSPs in control centers and data centers, we have found that increasing the square footage of PSPs can be very costly with regards to on-going O&M in the future. Electronic security can be automated to the point that the human element is kept to a minimum, but physical security retains more of the human element than most parts of CIP. Expanding PSPs to encompass tray areas in a Fossil plant is almost impossible due to the number of openings in the perimeters."

2. John writes, "For the electronic security there are several products out there that utilize either dark fibers in the cables or a separate fiber laid on top of the fiber cables that we use to generate an electronic alarm if the cables are disturbed. With an engineering analysis showing the difficulty of "tapping" fiber, and the documentation and testing I would not feel uncomfortable presenting this approach to auditors."

My correspondent writes "Your input is appreciated. We need to do some more benchmarking on this interpretation."

Thanks for both of you for your comments.

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