Program and Policy Development
A large gas and electric utility in Texas RE, who’s been with NST since 2003, has used NST for a diverse set of projects to improve their security, reliability, and compliance with both NERC CIP and the TSA Pipeline Security Directive.
The Beginning
NST began work in 2003 to help this utility understand their compliance obligations and their needs for a backup control center. Soon after, NST conducted a Gap Analysis in response to concerns stemming from the diversity of technology at the utility’s 400+ substations. NST performed an infrastructure review of the SCADA connectivity between their control center and substations to identify potential vulnerabilities. NST then conducted a Gap Analysis to measure and provide feedback on the utility’s compliance posture.
Following the Gap Analysis, NST constructed an action plan detailing steps to improve the processes for implementation of physical network components – such as cabling, color coding, and equipment access – as well as the electronic network components – IP address subnetting, password management, and firewall rulesets.
Next Steps
In 2012, the utility commissioned NST to support the development of a cyber security policy and network cyber security architecture for a new Advanced Distribution Management System (ADMS). NST first identified the scope of applicability for the new policies, including both the inventory of network devices and the individual SMEs who would be responsible for program execution. NST developed a program design and specified security monitoring and management protocol in addition to topology schematics for both physical and logical systems, as well as routing plans. As a result the utility adopted NST’s complete cyber security policy and document set describing the network security architecture and NST facilitated the handoff to utility SMEs for ongoing program maintenance.
In 2015 NST supported the development and implementation of updated program material with the introduction of NERC CIP v5. NST performed a Gap Analysis on the utility’s current compliance program, provided recommendations for remediation, and then facilitated the rollout of cyber security controls and associated documentation updates based on those recommendations.
A New Regulatory Framework
In late 2021, the utility requested NST to support the development of their Transportation Security Administration (TSA) Pipeline Security Directives compliance program. The TSA Security Directives evolved over several iterations for which NST provided support. For the first iteration, NST assisted with scope development and response to the TSA “questionnaire”. After the release of subsequent TSA Security Directive versions, NST examined current policies and procedures, and recorded the current compliance posture including gaps that were present. NST collaborated with the utility to develop new documentation to cover the new requirements. Finally, NST trained utility SMEs on the processes and documentation for the TSA Pipeline compliance program to ensure successful “handoff”.
With the release of TSA Security Directive “02C”, NST was tasked to support the development of the Cybersecurity Implementation Plan. With the acceptance of that Plan by the TSA, NST assisted in the development of the utility’s Cybersecurity Assessment Program.
Transmission Substation Upgrades
In 2023 the utility requested support from NST in a large-scale “digitization” project for their Transmission Substations with medium impact BES Cyber Systems. As a result of this infrastructure upgrade, the utility would be introducing the CIP Standards and Requirements for medium impact BES Cyber Systems with External Routable Connectivity (ERC). NST was contracted to perform a Gap Assessment of the program between current documentation, controls, and tools and the changes which would be necessary upon deployment of the digital communications under consideration. The project is ongoing, and upon completion of the Gap Assessment, NST will be collaborating to update the program prior to its implementation.
On-going Support
NST continues to support the utility with security, reliability and compliance challenges as the updated TSA Security Directives are released. One on-going task is to review performance records, offering either changes to the records or reviewing an annotated version to enable easy understanding of the relevance and sufficiency of the materials. Another area is reviewing progress in closing gaps identified in the Cybersecurity Implementation Plan and validating that performance records continue to be generated and retained.
