Security Plan Example
Security Plan Example
Security Plan Example
Section 1
PURPOSE:
This Security Plan constitutes the "Standard Operating Procedures" relating to physical, cyber, and
procedural security for all (Utility) hydro projects. It contains a comprehensive overview of the
(Utility)'s security program, and in some sections, makes reference to other relevant plans and
procedures. Security personnel, operators, and selected hydro personnel shall be familiar with the
information and procedures associated with this Security Plan.
Distribution: A copy of this plan shall reside in each of the following locations:
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Section 2
SITE MAPS:
These site maps reveal the restricted areas of each hydro project, as well as the physical security
layouts that protect such areas. The measures listed below are incorporated into the security layouts,
and shall be utilized to control and enforce access to the restricted areas:
Guard posts (with barriers and "Tiger Teeth") - located at each access point
Placement of fencing, locked gates, barricades, and signage
Placement of signage and buoy lines - upstream and downstream of dam
Electronic Access - Identification/access badges issued to employees and approved
contractors. Doors and barrier arms can be activated by: 1) employee displaying access
badge, or 2) operated by on-site guard, or 3) operated remotely from Security Operations
Center.
"Hydro Access Request" - screening process for contractors and visitors
Security camera monitoring - 1) Security staff (Security Operations Center), 2) control room
operators, 3) Systems Operations Center personnel, 4) Regional dispatch center for
law enforcement and fire services, and 5) the State Patrol.
Intrusion alarm monitoring - 1) Alarm Central (contracted monitoring agency), 2) Security staff
(Security Operations Center)
Contracted guards -- inspection patrols
Law enforcement - observation patrols
Section 3
Dam (Structure)
Spill Gates/Controls
Intake Units
Transformers
Powerhouse
Generator Floor
Control Room
Switchyard
Transmission
Abutments
Fishway Structure
Penetrations
Irrigation Structure
Penetrations
Recreation Structure
Penetration
Visitor Center
Maintenance Galleries
Domestic Water
HazMat storage
CPME
CDP&R
Cyber Security
Security Plan
Security Assessment
Assessment (internal)
Assessment (external)
Response Time
Response
Delay
Detection
Physical Security
PROJECT
Critical
Physical Dam Related
Assets
External access
HYDRO
Section 4
SECURITY SYSTEMS:
The (Utility) utilizes a number of security systems designed to help fulfill its security
mission. These systems complement the policies, procedures, and measures that form
the (Utility)'s robust security program.
The (Utility)'s security systems include:
1. Fencing & Gates
Fencing is the first layer of security at all of our Hydro projects,
Transmission/Distribution points, and (Utility) facilities. The (Utility) has standardized
on 8-foot fencing, using tension wire in lieu of bars, placing fence barbs up, and
securing the bottom of the fencing below grade. Access points/gates are secured
through one of the following methods: Manually opened and secured with a heavy
duty (Utility) approved pad lock, electronically accessed with card credential, or
electronically accessed with remote gate fob. All perimeters and access points are
monitored 24/7 by CCTV or contracted security guards.
2. Exterior Lighting
Exterior lighting has been strategically placed throughout the (Utility) to emphasize
and highlight perimeters, gate and Guard Post access points, entry points into
buildings, and areas of interest. Lighting can be activated by motion or photo-cell.
Exterior lighting serves as a deterrent, as well as to aid in monitoring of the (Utility)'s
CCTV system.
3. CCTV
The (Utility) has deployed over 100 CCTV cameras throughout the county. These
cameras have Pan/Tilt/Zoom (PTZ) capabilities, and are strategically placed
throughout the projects. Via our unique Fiber Optic infrastructure, these camera
signals are sent back centrally to the (Utility)'s headquarters office where they are
recorded 24/7. From this central point, Security has the ability to monitor and control
all cameras. In addition, Security shares control and monitoring of these cameras
with the Hydro projects, System Operations (Dispatch), Engineering staff, as well as
three local law enforcement agencies and Regional Dispatch Center. This CCTV
system is monitored 24/7.
Provide 24/7 monitoring in remote locations where staff is not always present.
Installed in all CIP-designated spaces.
The alarm sensors include door/window contacts, motion detection, and glass break.
These Intrusion alarm systems are monitored 24/7.
6. Security Guards
The (Utility) contracts the services of a private security company. Guards are
stationed at the Hydro Projects. Additionally, "patrol" guards are assigned to conduct
security checks of the (Utility)'s properties -- including the hydro projects.
7. Law Enforcement Support
The (Utility) has developed strong partnerships with the local law enforcement
agencies. These agencies support the (Utility)'s security mission through
collaborative training & exercises, observation patrols, response to incidents, and
proactive meetings.
Section 5
MAINTENANCE & TESTING:
The (Utility)'s security systems and equipment shall be properly maintained and tested in order to
ensure its continuous and effective operation.
Whenever feasible, Maximo (computer program) is used to schedule and track routine
maintenance.
Routine maintenance is performed by a trained group of (Utility) employees who possess the
necessary levels of mechanical and technical competence. These individuals are substantially
assigned to one of the following work areas: Maintenance Department, Technician Shop,
Facilities Department, and Security Division.
The (Utility)'s Maintenance and Testing Program is consistent with FERC guidelines.
Section 6
The Facilities Department will cut and mark all keys after the Key Administrator has
made a key request.
All cores and hardware will be ordered or combined by the Facilities Department after a
request has been received from the Key Administrator. The use of all hardware
installed in (Utility) locks must be approved in writing by the Facilities Department.
All key core combinations will be determined by the Keystone 600 software and
maintained by the Key Administrator or Building Maintenance Foreman.
Contact Information
Security Department
Reference
Policy #704 - Employee, Contractor and Visitor Identification Badges
Policy #104 - Employee Separation Policy
Formerly: _____________ Administrative Instruction #31: Key Policy Manual
Section 7
2.
Any employee who forgets his/her badge should immediately advise his/her
supervisor and contact the nearest badge station to obtain a replacement Employee
Photo ID Badge. If the badge station attendant does not recognize the employee,
or a current picture is unavailable on the badging computer base, the employee's
supervisor or supervisor's designee must verify the employee's identification.
3.
Any employee who misplaces or loses his/her badge should immediately contact
his/her supervisor and the Security Department. After hours, contact the Security
Department through System Operations at Ext. 4000. A replacement Employee
Photo ID Badge will be issued.
4.
Any person, including employees, not wearing a badge in a Secured Area should
be questioned by other employees, security guards or other authorized personnel
to follow the provisions of this policy.
5.
When entering any access-controlled area by vehicle, each vehicle and each
occupant must stop to display the proper ID Badge.
6.
7.
8.
9.
All employees serving as Sponsors shall comply with the provisions for
contractor and visitor badges.
10.
Contractor Badges:
1. A Contractor is a vendor, supplier, professional service representative or consultant
("Contractors") who has business with the (Utility).
a) Contractors are required to sign in and receive an identification badge if they will
be accessing Secured Areas of the (Utility).
2. Contractors who will be on (Utility) facilities for only one day or less will be provided a
Visitor Badge.
a) Security guards, switchboard operators and receptionists will be trained to issue
Visitor Badges to Contractors entering (Utility) facilities.
b) Contractors should be instructed to wear their badges properly while in Secured
Areas of the (Utility).
c) The employee or project manager whom the Contractor wishes to see will
become the "Sponsor" of the Contractor.
d) Sponsors will be contacted to escort all Contractors into and from Secured
Areas.
3. At the request of a Sponsor, a Contractor who will be on (Utility) facilities for more
than one day, or who will not be escorted by a Sponsor, will be issued a Contractor
Photo ID or Access Badge.
a) Contractors should be instructed to wear their badge while in Secured Areas of
the (Utility).
b) The badges must be returned to the Sponsors or issuing personnel at the end of
each project.
4. Sponsors who authorize photo ID badges for Contractors will be required to make
arrangements prior to the work-start date. Pertinent information must be given to
designated security badge providers. Time must be allowed at the beginning of a
project for photos to be taken and badges to be created for each Contractor
representative. [Example: Having a contract crew install fish monitoring equipment
at a hydro project will require that the (Utility) engineer or Fish and Wildlife employee
be responsible for providing the necessary information, in advance, to the
designated badge provider.]
5. Contractors who misplace or lose their badges must immediately notify their
Sponsor or (Utility) Project Manager and the Security Department. After hours,
contact the Security Department through System Operations at Ext. 4000. A
replacement Contractor Photo ID Badge will be issued.
a) Any Contractor not wearing a badge in a Secured Area should be questioned by
employees, security guards or other authorized personnel to follow the provision
of this policy.
6. Questions regarding where to obtain a Photo Contractor ID Badge should be
directed to (Utility) Security.
Visitor Badges:
1. A Visitor is any individual who is conducting business with the (Utility) (other than
those customers in public reception areas to pay bills, etc.) or a family member or
guest visiting a (Utility) employee.
2. All visitors to the Headquarters Complex and hydro projects (other than customers
conducting business in public reception areas to pay bills, etc., visitors attending
open-access commission meetings in the auditorium) are required to sign in and
receive a visitor's badge if they will be accessing Secured Areas of these facilities.
Exception: Areas open to the general public at Rocky Reach during the season the
project is open to visitation by the Public.
3. Visitors who will be on (Utility) facilities for only one day or less will be provided a
dated Visitor Badge.
a) As a courtesy, Sponsors who have visitors arriving for scheduled meetings may
provide notice to the designated security badge providers in advance.
Formerly:
Effective Date:
Date of Amendments:
Section 8
(Utility) Security Measures:
Policy #708
Purpose
This policy addresses the responsibility of all employees to comply with (Utility) security
measures. Employees and contractors are prohibited from tampering with or
obstructing the view of (Utility) security cameras and/or security-related equipment.
This policy also addresses interfering with or disabling any other security-related
measures.
The (Utility) relies on comprehensive security systems and measures to ensure our
employees, contractors and visitors remain safe and our critical assets are protected.
Many of these security measures are required by federal law due to the nature of the
(Utility)'s facilities. All employees are expected to know and support the security
measures related to their jobs.
Security cameras strategically placed throughout the (Utility) have an integral role in
security. Unauthorized interference with these cameras can jeopardize people and
facilities. Therefore, no employee shall knowingly tamper with or obstruct the view of
any security camera or security-related equipment.
The (Utility) has carefully implemented a number of other integrated security measures,
including but not limited to: electronic access control, restricted access, intrusion
alarms, locked doors/gates/windows, fencing, and signage. No employee shall
knowingly disable, circumvent, bypass or compromise any of the (Utility)'s security
measures.
Any employee having knowledge of any tampering with, circumvention of or breach of
security or security measures shall notify either their supervisor or the Security Division
immediately.
Investigations of alleged violations of this policy will be conducted under the direction of
the Security director. If the director is unavailable, then the general counsel/chief
compliance officer will assume such responsibility. At the conclusion of the
investigation, any employees found to be in violation of this policy will be subject to
disciplinary action, up to and including termination of employment.
Contact Information
Director- Security Division
Formerly:
Effective Date:
Date of Amendments:
New
Section 9
Sabotage Recognition and Reporting:
1.0 PURPOSE
(Utility) facilities are considered critical infrastructure as defined in the National Infrastructure Protection Plan.
Attacks on critical infrastructure could disrupt the direct functioning of key business and government
activities, facilities and systems, and the bulk power system. Such attacks could have cascading effects
throughout the economy and society. The purpose of this procedure is to provide guidance to staff on
recognizing and reporting potential sabotage events.
SCOPE
What:
This document serves as guidance for employees in recognizing and reporting suspicious or
unusual activities that could potentially be considered sabotage.
Who:
Page 1 of 4
Sabotage attempts may be tied to disruptive events in the work place, such as possible threats to an
industry or region and labor unrest. Sabotage events can be cyber, physical and/or operational
and may include things like:
There are a number of suspicious activities that may indicate a potential or actual threat of
sabotage. Examples include:
It is often difficult to determine if any single activity is an act of sabotage. Employees are must report
any activity that appears suspicious in nature. Security personnel will investigate and make the
determination if further action is needed.
Page 2 of 4
(Utility) employees should report suspicious activity as soon as possible to the (Utility)
Security Division. This can be accomplished by initiating a telephone call directly to
Security at (telephone), or by submitting a Suspicious Activity/Incident Reporting Form
located on the Security Division's webpage.
(telephone)
(telephone)
(telephone)
(telephone)/ www.nicc@dhs.gov
(telephone)
http://www.esisac.com
Page 3 of 4
Revision History
Owner
Rev.
Date
Ver.
Assignment Change
Approved By
References:
NERC Standard CIP-001 System
Operating Instruction 16
Page 4 of 4
Section 10
THREAT ALERT
GUIDELINES
GREEN - BLUE - YELLOW
ORANGE - RED
Section 11
EMERGENCY RESPONSE:
Emergency response shall be in accordance with an "all-hazards" approach. Such incidents/events
may include:
Bomb Threats
Fires
Earthquakes
Hazardous Materials Release
Floods
Windstorms
Civil Disturbances
Pandemic Flu
Serious Accidents
Criminal Activity
The (Utility) shall implement the principles of the Incident Command System (ICS) when managing
significant incidents/events. Implementation may include:
Coordinate with internal and external stakeholders (i.e. law enforcement, fire services)
Emergency Action Plans (EAPs) - The (Utility) maintains EAPs for each of its Hydro projects.
These EAPs should be referenced during the course of any emergency. Information contained in
these EAPs includes:
Non-emergency
(telephone number)
Emergency
911
System Operations
(telephone number)
Control Rooms
Hydro Project A
(telephone number)
Hydro Project B
(telephone number)
Hydro Project C
(telephone number)
Excessive postage.
Handwritten or poorly typed addresses.
Incorrect titles for recipient.
Addressed to no particular person in (Utility).
Title, but no name.
Misspellings of common words.
Oily stains, discolorations.
Plain envelope with no return address.
Excessive weight.
Lopsided or uneven envelope, thick or lumpy package.
Ticking or buzzing sound, sloshing sound or unusual smell.
Protruding wires or aluminum foil.
Excessive security material such as masking tape, string, filament tape,
etc.
Marked with restrictive endorsements, such as "Personal" or
"Confidential", or alternatively, "Open This Envelope."
Call Security
o Notify Safety
Building Evacuation
Reasons to evacuate may include:
Fire
Bomb Threat
Power Outage
Earthquake
Water/Gas Leak
Hostage Situation
Methods of Notification
1. Intercom system
2. Alarm.
3. Direct or electronic from authorized emergency personnel.
Do Not
1. Use elevators.
2. Gather in lobbies.
3. Bring disabled individuals into stairwells without fire department approval.
4. Open a door without first checking for heat.
5. Run or panic.
6. Re-enter the building until authorized.
Disabled individuals or others who need assistance should:
1. Be assisted by Floor Wardens (Sweepers).
2. Be evacuated only under the direction of authorized emergency personnel
(i.e. Fire Department).
Course of Action:
Emergency recognized.
If the emergency is a fire, delegate another employee to try to extinguish it
with the nearest fire extinguisher.
Call 9+911 or 911.
Intercom announcement:
o "Attention, Attention, Attention.
o An emergency has been reported. o
Evacuate the building at once.
o Use the stairs.
o Avoid the elevators."
Preserve any and all evidence, if applicable, and remain accessible for
discussion with law enforcement personnel.
Do not touch any suspicious items or suspected bombs.
Employee Responsibilities:
1. Each employee is expected to know the location of the fire extinguishers,
emergency exits, and first aid supplies.
2. Extinguish the fire by using a portable fire extinguisher if safe to do so and
if you have been trained to use a fire extinguisher.
3. Evacuation Route-Preplan your escape route based on your familiarity
with the building. Always take the nearest stairwell. All stairwells are fire
corridor rated.
4. Do not re-enter the building.
5. Regular review of attached floor plans and evacuation plan maps is
recommended.
Floor Wardens (Sweepers):
1. Recognized as a designated authority in the event of an emergency.
2. Responsible for the evacuation in their designated area and will assist
other floor wardens as need.
3. Equipped with identifying apparel and a flashlight.
4. Responsible for complete evacuation.
5. Responsible for knowing the general identity and physical ability of
employees in the area.
6. Familiar with the location of emergency exits, emergency equipment, and
trained in emergency response procedures.
Section 12
GENERAL STATEMENT:
(Contracted Security Company) provides contracted services to the (UTILITY). This
manual addresses policies, procedures, and information associated with these
services.
This manual is intended to serve as a guide to (Contracted Security Company)
employees, so they may understand the expectations of conduct and performance.
This manual will assist them in making decisions and carrying out their duties in a
manner consistent with those expectations. It should be noted that this manual is not
intended to address every situation that may arise. (Contracted Security Company)
employees are expected to use good judgment in all situations.
TABLE OF CONTENTS
SECTION I:
Rules of Conduct
SECTION II:
Appearance Standards
SECTION III:
Post Operations
SECTION IV:
Use of Force
SECTION V:
Emergency Operations
SECTION VI:
Chain of Command
SECTION VII:
SECTION VIII:
SECTION IX:
3. Guards will wear black undershirts, black socks, and black footwear. Any exceptions
must be authorized by the Division Manager or Guard Supervisor.
4. Guards will wear a (Contracted Security Company) approved hat.
5. Guards shall keep their stations and vehicles clean and neat. Garbage containers shall
be emptied during the last shift, daily.
GATES/BARRIER ARMS
a. Post #2 and Post #5 have a designated "visitor"
entry lane, and a designated "employee" entry lane. The employee lane is
restricted to only employees. Employee badges are identified by a blue stripe
with the wording "EMPLOYEE". All other traffic must proceed through the
visitor's lane (including any employee not in possession of his/her badge).
b. Guards shall require all persons who enter through the visitor's lane to stop
and produce valid identification and/or issued badges. Guards shall
raise/lower barrier arms for each individual vehicle, and not allow more than
one vehicle at a time to pass through. These identification/access procedures
shall be followed each time an occupant attempts to enter the property - no
matter how many times that person has already entered and departed.
c. Some employees may arrive on bicycles and attempt to enter through the
"exit" lane. On these occasions, guards shall direct the bicyclist through the
"employee" lane, where the bicyclist must swipe his/her badge. (Note:
When a bicycle passes through, the barrier arm may not automatically close.
In these cases, it may be necessary for the guard to lower the barrier arm by
dragging an object, such as a chair or shovel, across the pavement cuts.)
d. Any mechanical problems with the barrier arms should be reported as soon as
possible.
2.
CAMERA MONITORING
a. Guards shall monitor the security cameras relative to their assignment.
Guards shall maintain a record of their monitoring and any activities they
observe.
b. Guards are authorized to move the security cameras only for security-related
reasons.
SECURITY ROUNDS
a. At the beginning of each round, Guards shall first notify Control. Then, they
shall announce their departure on the security channel and lock up their posts
before departing. While making their rounds, Guards shall take their keys,
portable radio, scanning wand, and appropriate PPE.
b. Guards shall report each location upon their arrival. They shall check all
doors and locks, making certain to scan all buttons with their wand.
c. When outside their security vehicle, Guards shall leave the vehicle running
and activate the emergency lights. Guards shall wear required PPE and
orange coat or reflective vest.
4.
PATROL SCHEDULE
a. Hydro A: November 1st through March 14th (Hydro A Park/Visitor
Center is closed to the public) - Guards shall conduct one round at the end of
their shift.
b. Hydro A: March 15th through October 31st (Hydro A Park/Visitor
Center is open to the public) - After the park/Visitor Center closes for the
evening, Guards shall sweep the property to ensure all visitors have departed.
Guards shall also lock the restrooms. ((UTILITY) staff will unlock the
restrooms
in the morning.) Guards shall report any discovery of graffiti or vandalism.
c. Hydro B: Guards shall conduct one round prior to ending their shift.
d. Guards at Hydro A and Hydro B shall not conduct their round
simultaneously.
5.
SAFETY EQUIPMENT
a. Guards shall wear their issued hard hats whenever they are outside of their
vehicle during the making of rounds.
b. Wherever designated, guards shall wear the required personal protective
equipment (PPE) hard hat, eye protection, ear protection, protective
footwear.
NOTIFICATIONS
a.
b.
Guards shall contact the Guard Supervisor for all other matters involving
general inquiries, suggestions, supply requests, etc.
c.
d.
2.
The Day/Night Watch acts under the authority of the Guard Supervisor,
and will occasionally provide direction to the guards.
2.
Guards are authorized to operate (UTILITY) vehicles only on (UTILITY)
property.
3.
Vehicles shall be kept locked when parked, unless Guards are in immediate
attendance.
4.
5.
Guards shall obey all laws, and drive in a careful and prudent manner at all
times.
6.
Guards shall transport any person in a (UTILITY) vehicle, except in the line of
duty or with supervisory approval.
7.
8.
Guards shall complete an inspection form at the beginning of each shift. Guards
shall record the checking of fluids, observations of damage, discovery of
defective equipment, etc. Any discovery of "new" damage shall be reported to
the Guard Supervisor immediately.
9.
Guards shall not change the pre-set radio frequencies in any (UTILITY)
vehicle.
3. BADGE VISUALS
4. VISITOR BADGES -- ISSUANCE
6. RETIREE BADGES
Whenever a retired (UTILITY) employee requests access, Guards shall:
Match the badge photo to the person.
Call the person the retiree intends to visit, and confirm permission to enter.
Allow entry. No visitor badge is necessary, provided the retiree has a
badge in his/her possession. If not, a visitor badge shall be issued. (Note:
a "Retiree " badge does not guarantee entry unless an active employee on
site agrees to the visit.)
Guards shall record the information on their DAL.
8. Patrol units shall announce their status whenever they are out of the vehicle.
Examples: Patrol out of the vehicle at North End restrooms at destination."
Patrol back in the vehicle, restrooms are secure".
Night Watch shall acknowledge by repeating the radio traffic.
9. Patrol units shall be specific in reporting their locations and activities. When
encountering persons in the park at night, Guards shall explain the hours of
closure and direct them to leave. Guards shall record all relevant information (i.e.
physical descriptions, vehicle license numbers) and advise over the radio.
Example: Patrol observed (#) subject(s)/vehicle(s) at destination, they were
advised to leave (if after hours)." If the subjects remain in the park, Guards
shall make the appropriate notification. Example: Patrol to Night Watch,
subject(s)/vehicle(s) are still in the area, preparing to call." Post #2 and Post
#5 will copy/receive and Night Watch will repeat. Example: "Night Watch
(copies or received) Patrol, preparing to call at destination at (time)."
10. Whenever a Guard is conducting a security sweep, or is out of the vehicle, the
Night/Day Watch (if on duty, otherwise, Post #2) will conduct "status checks"
every 2 minutes. These checks will continue until the Guard responds that he/she
is secure/clear. Example: "Night Watch to Patrol, status check".
Response: Patrol clear" (or state problem).
11. The calling of is the responsibility of the security officer in direct
contact of the situation, since he/she is in the best position to relate complete and
accurate information. This information must be passed on to the Night/Day
Watch as soon as possible.
12. The calling out of license plate numbers over the radio is at the Patrol's
discretion. License numbers having any relevance (to the Guards' security
duties) shall be recorded on the DAL.
Section 13
INFORMATION TECHNOLOGY/SCADA:
The (Utility) is committed to protecting its Critical Cyber Assets.
The SCADA network is physically isolated from other networks, with one
exception: One
specific host on SCADA is allowed to send certain data through a proxybased firewall to a
specific repository on the corporate network.
Table of Contents
OVERVIEW
Background
Purpose
Scope
LEADERSHIP RESPONSIBILITY
RESPONSIBILITIES
CRITICAL CYBER ASSET IDENTIFICATION
Critical Asset Identification
Critical Cyber Asset Identification
CCA Annual Review and Approval
PERSONNEL RISK ASSESSMENT AND ACCESS
AWARENESS AND TRAINING
INFORMATION PROTECTOIN AND CONTROL
ELECTRONIC SECURITY
Change Control
Electronic Security Perimeters
Cyber Vulnerability Assessment
Documentation Review and Maintenance
SYSTEMS SECURITY MANAGEMENT
Testing of New or Modified Cyber Assets
Ports and Services
Security Patches
Malicious Software Prevention
Account Management
Security Status Monitoring
Disposal and Redeployment
Cyber Vulnerability Assessment
Documentation Review and Maintenance
INCIDENT REPORTING AND RESPONSE
CRITICAL CYBER ASSET RECOVERY
PHYSICAL AND ENVIRONMENTAL SECURITY
Physical Security Plan
Access Controls
Access Monitoring
Maintenance, Testing and Documentation
EXCEPTIONS
EMERGENCY PROVISION
DOCUMENTATION
REPORTING OF ISSUES/CONCERNS
APPROVAL
GLOSSARY
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Overview
Background:
As technology has progressed, concern regarding the protection of Bulk Electric
System Critical Cyber Assets has grown as well. In 2003 the North American
Electric Reliability Corporation (NERC) Board of Trustees approved the
implementation of Urgent Action Cyber Security Standard 1200 (UA 1200),
which eventually evolved into the NERC Critical Infrastructure Protection (CIP)
standards. The stated purpose of the CIP standards is "to protect the Critical
Cyber Assets (hardware, software, data, and communications networks) essential
to the reliability of the bulk electric system." On January 17, 2008 the Federal
Energy Regulatory Commission (FERC) issued order 706 approving NERC CIP
standards and making them mandatory and enforceable pursuant FERC authority.
Purpose:
The purpose of this Policy is to clearly demonstrate the commitment of the
(Utility)'s management to the security and protection of cyber assets deemed
critical to the operation and reliability of the Bulk Electric System. Management
is dedicated to fostering a culture of compliance among all employees. The
information contained herein is intended to serve as a framework and provide
guidance to (Utility) staff in the management, access to and protection of Critical
Cyber Assets.
Scope:
This Policy applies to all (Utility) personnel, contractors, and vendors. This Policy
sets the direction, gives broad guidance, and defines the requirements for cyber
security related processes, programs, and actions across the (Utility). This Policy
should be considered in conjunction with administrative policies regarding
internal compliance.
Leadership Responsibility_________________________
The (Utility)'s Executive Manager-Operations Group (or an equivalent position of
responsibility and scope within the (Utility)'s senior management) shall serve as the
Senior Manager with overall responsibility and authority for leading and managing the
(Utility)'s implementation of and adherence to Standards CIP-002 through CIP-009. As
such, the Senior Manager's responsibilities include annual review and approval of the
(Utility)'s CIP Cyber Security Policy as well as approval of any exceptions to that Policy.
The Standards call for specific actions by the Senior Manager. As allowed by Standards
CIP-002-2 through CIP-009-2, the Senior Manager may delegate authority for specific
actions to a named delegate or delegates. These delegations shall be documented as
required under Standard CIP-003 and approved by the Senior Manager.
The Senior Manager is responsible for ensuring that adequate resources are dedicated to
cyber security and CIP related compliance activities. Day-to-day responsibilities for
cyber security and CIP compliance activities are delegated to others based on job function.
In accordance with CIP-003, R2 the contact information for the Senior Manager is
included herein:
Name:
Title:
Executive Manager - Operations Group
Date of Designation:
Responsibilities __________________________________
Cyber security is the responsibility of all (Utility) employees, contractors, and vendors.
The (Utility) is committed to consistent enforcement of this Policy and cyber security.
This Policy is a directive in compliance with federal reliability standards. All responsible
managers and supervisors are required to communicate this program to appropriate
employees and implement this Policy. Employees are responsible to know and
understand their roles and responsibilities.
The following (Utility) positions oversee and implement cyber security for all Critical
Cyber Assets owned by the (Utility). The references to specific position titles apply to
positions with equivalent responsibility and scope in the event there is a change in
personnel or titles:
Executive Managers: Provide additional leadership, guidance and oversight of
the cyber security programs and activities.
(Utility) Compliance Manager: The (Utility) Compliance Manager is responsible
for independent review of compliance policy, programs, and processes to verify
compliance with NERC CIP standards. The Compliance Manager is also
responsible for updates to this policy, and ensuring annual senior management
reviews and approvals.
Regulatory Compliance and Policy Development Manager: Ensures
compliance with NERC CIP standards through oversight of operational programs,
processes and procedures. Further responsibilities include: resource coordination,
regulatory reporting, tracking and monitoring of standards, communication of
requirements, and compliance documentation management.
Director - Security Division: Responsible for the development, implementation,
and enforcement of the (Utility)'s Physical Security Plan. The Director -Security
Division has additional responsibilities of managing and monitoring the day-to-
day activities related to physical security and ensuring CIP compliance goals and
deadlines are met. Other responsibilities include the implementation and
management of Physical Security Perimeter Access Control and Monitoring
systems, which facilitate the protection of Critical Cyber Assets.
Operations Reliability Manager: Responsible for recommending and managing
cyber security operational procedures and resources designed to protect the
(Utility)'s Critical Cyber Assets and ensure compliance with applicable NERC
Reliability Standards. The Operations Reliability Manager has additional
delegated responsibilities of managing and monitoring the day-to-day activities
related to cyber security and ensuring CIP compliance goals and deadlines are
met.
Control System Engineers/Analysts ("CSE Group"): Under the direction of
the Operations Reliability Manager, the Control System Engineers/Analysis (CSE
Group) are responsible for the development, deployment and maintenance of the
(Utility)'s Critical Cyber Assets, including control system networks. The CSE
group is responsible for identifying, implementing, and documenting the
hardware and software used to meet NERC CIP requirements.
Critical Asset Manager: (Utility) managers with oversight for critical Bulk
Electric System Assets as defined within the methodology developed pursuant to
NERC Standard CIP-002 are responsible for approving and revoking access to
Critical Cyber Assets and/or their associated information.
on applicable cyber security policies and procedures, physical and electronic access
controls, proper use and handling, and recovery action plans. Training will be customized
based on the need of the individual and will be conducted in accordance with the CIP
Cyber Security Training Program.
Electronic Security________________________________
The electronic security perimeter surrounding critical assets shall be identified, protected
and secured as directed in NERC standards CIP-002 through CIP-009.
Change Control
Careful control and implementation of changes made to critical systems is a key
component of the reliability of those systems. The CSE Group is responsible for
change control and configuration management for development, deployment,
modifying, replacing, or removal of critical cyber asset hardware or software. The
CSE Group develops, documents, and implements the processes which are used to
identify, and control most (Utility) or vendor related changes to hardware or
software components of (Utility) Critical Cyber Assets. Change control associated
with systems used in the access control and monitoring of the Physical Security
Perimeter is the responsibility of the Director - Security Division. Change control
associated with Intelligent Electronic Devices (IED) is the responsibility of the
CM Tech Shop Department Superintendent.
Security Patches
All work performed on (Utility) Critical Cyber Assets is performed by trained
(Utility) staff. This includes the installation of security software patches. Cyber
security related software patches are applied and administered by the CSE Group
in accordance with (Utility) CIP Security Patching Procedures.
Account Management
The Operations Reliability Manager or equivalent is responsible for establishing
appropriate procedural controls to implement and enforce access authentication.
The (Utility) carefully maintains account privileges for system administration,
network administration, CSE Group use, shared, generic and default accounts.
The (Utility) requires the removal, disabling, or renaming of shared and default
accounts where technically feasible to help maintain cyber security in accordance
with standard CIP-007 and (Utility) CIP Account Management Procedures.
Access Controls
It is the responsibility of the Director - Security Division to maintain strong
Physical Access Controls Systems (PACS) in order to properly maintain the
Physical Security Perimeters (PSP) protecting the Critical Cyber Assets.
Electronic card readers provide a computerized monitoring and logging record of
physical access through the physical security perimeter to Critical Cyber Assets.
Physical intrusion detection, which alarms the system control center when the
physical perimeter is accessed, affords additional protections. The Critical Asset
Manager who oversees the Critical Assets and the associated Critical Cyber
Assets is responsible for determining the operational parameters of these systems
and controls as well as granting and revoking physical access to (Utility) Critical
Assets.
The devices that authorize and/or log access to the PSP, exclusive of hardware at
the PSP access point such as electronic lock control mechanisms and badge
readers, shall be protected from unauthorized physical access. It is the
responsibility of the Director- Security Division to ensure that PACS are afforded
all of the protections detailed in CIP006 R2. Protection and maintenance will be
done in accordance with established procedures detailed in the (Utility)'s Physical
Security Plan.
It is the responsibility of the Director - Security Division, the Operations
Reliability Manager and the Critical Asset Manager to ensure Cyber Assets used in
the access control and/or monitoring of the Electronic Security Perimeters(s)
reside within an identified Physical Security Perimeter.
Access Monitoring
It is the policy of the (Utility) to continually monitor physical access through PSP
locations the protect Critical Cyber Assets. Unauthorized access attempts will be
reviewed, investigated and processed in accordance with the (Utility) Physical
Security Procedure PSP-6R1.3. Physical access records and records of PACS
shall be maintained for ninety (90) calendar days. Reportable incident logs shall
be maintained in accordance with CIP-008.
Exceptions
Any instance where the (Utility) is unable to conform to its CIP Cyber Security Policy
shall be documented as an exception and authorized by the Senior Manager. Authorized
exceptions to the CIP Cyber Security Policy shall be reviewed and approved annually by
the Senior Manager to ensure the ongoing validity of any exception.
Emergency Provision______________________________
An emergency is defined as an unforeseen event or occurrence that poses an imminent
threat to: the safety and health of persons, (Utility) facilities, or the reliability of the
(Utility)'s Bulk Electric System. In an emergency situation it may be necessary to
temporarily suspend the CIP Cyber Security Policy. The priorities in an emergency are
the safety and protection of persons first, and the protection and security of the (Utility)'s
physical and cyber assets second. In order to protect both persons and property it may be
necessary to temporarily disable access controls and other system protections.
If an emergency situation arises, (Utility) staff is directed to call the Security Division as
soon as it is safe to do so. The Security personnel who receive the call will alert the
General Manager or his designee. The General Manager or his designee will assess the
situation and make a determination regarding an emergency declaration. If an emergency
is declared, the General Manager or designee will notify system operations. System
operations personnel will document the emergency declaration (including start time) in the
log. When the (Utility) has returned to normal operations, the General Manager or
designee will again alert system operations who will record the emergency ending time in
the log. The CIP Cyber Security Policy will be suspended during the emergency
declaration period.
Documentation
Documentation will be maintained in accordance with existing (Utility) practices pursuant
to NERC standards CIP-002 through CIP-009 and related policies and procedures. Where
there are conflicts, retention periods outlined in NERC Reliability Standards will
supersede all other guidelines.
This Policy makes references to various (Utility) CIP programs and procedures that are
not included as links in the policy. For information regarding these documents, contact
the Regulatory Compliance and Policy Development Manager. Information is identified,
classified and protected in accordance with Administrative Policy and the CCA
Information Classification and Protection Program. Requests for information will be
processed accordingly.
12
Reporting of Issues/Concerns
Employees are encouraged to report concerns regarding compliance issues and situations.
Employees should feel free to report concerns to their supervisors, managers, directors, or
executive managers. Employees may also report concerns to the (Utility)'s General
Counsel/Chief Compliance Officer, General Manager, Compliance Manager or Internal
Auditor. Retaliation against an employee reporting concerns or issues in good faith will
not be tolerated.
Approval _______________________________________
This Policy is approved by the (Utility)'s General Manager and all Executive Managers.
This Policy will be implemented in accordance with the NERC Implementation Plan for
Cyber Security Standards.
Contact Information
Director - Security Division
Compliance Manager
Operations Reliability Manager
Regulatory Compliance and Policy Development Manager
References
NERC Reliability Standards CIP-002 through CIP-009
NERC Implementation Plan for Cyber Security Standards
Formerly:
Effective Date:
Date of Amendments:
New
13
Glossary
Critical Asset Manager - Specific (Utility) managers who oversee the operation of bulk
electric system assets, critical assets, and the associated Critical Cyber Assets. The
Critical Asset Manager is responsible for granting and revoking physical access to
(Utility) critical assets containing Critical Cyber Assets.
Critical Assets - Facilities, systems, and equipment which, if destroyed, degraded, or
otherwise rendered unavailable, would affect the reliability or operability of the Bulk
Electric System.
Cyber Assets - Programmable electronic devices and communication networks including
hardware, software, and data.
Critical Cyber Assets - Cyber Assets essential to the reliable operation of Critical
Assets.
Cyber Security Incident - Any malicious act or suspicious event that: Compromises, or
was an attempt to compromise, the Electronic Security Perimeter Physical Security
Perimeter of a Critical Cyber Asset, or, Disrupts, or was an attempt to disrupt,
Electronic Security Perimeter - The logical border surrounding a network to which
Critical Cyber Assets are connected and for which access is controlled.
Physical Security Perimeter - The physical, completely enclosed ("six-wall") borders
surrounding computer rooms, telecommunications rooms, operations centers, and other
locations in which Critical Cyber Assets are housed and for which access is controlled.
Six-wall Protection - Protection barrier surrounding an asset that includes above, below,
and all four sides.
14
Section 14
TEMPORARY PROJECT CLOSURES:
Procedures have been placed into effect which eliminates the occurrence of any "temporary project
closure".
Labor Disputes - In the case of a bargaining unit strike, the (Utility) retains the right to employ
a temporary workforce.
Emergency Situations - The (Utility) recognizes that certain incidents and events (i.e.
pandemic flu) may cause a reduction in the (Utility)'s workforce. Therefore, minimum staffing
levels and essential functions have been identified to ensure the continued operation of each
hydro project (ATTACHED).
Hydro Mgr
Ext:
Description
Prevent dam overtopping
and flooding
Maintain FERC head level
requirements and use flows
as efficiently as possible
Meet plant demand and
voltage schedules
Perform all above and keep
plant systems operating
Respond to equipment
failures and outages -restore
generation as quickly as
possible.
Maintain a 1.1' differential in
fishladder discharges
Respond to equipment
failures and outages restore fish passage criteria
as quickly as possible.
Continue basic maintenance
rounds and routines as
conditions allow.
Management duties: Assure
safety and health services,
payroll, CBA admin, site
supervisory decisions,
necessary communications
and continuation of basic
operational and business
requirements
Internal
Internal
Internal
Internal
Minimum Staffing Levels -- Provide the minimum number of staff required to maintain essential
services. (Please feel free to provide/attach an additional sheet if needed).
Essential Service (*see prior
question)
Protect plant integrity
Manage river flows
Generate electricity
Provide basic hydro plant
operations
Provide emergency or urgent
response to maintain electric
generation
Maintain fish passage
Provide emergency or urgent
response to maintain fish passage
Provide basic maintenance to
generating and fish passage
assets
Provide organizational and
supervisory support
Minimum# of Staff
to maintain
One operator in the
control room
Same
Same
Same
Type/Description of position
One Duty
Supervisor
Action Plans - Describe courses of action that will be taken to overcome the expected challenges.
These will substantially be the strategies used to maintain delivery of essential services. Note: Action
plans should directly support our objectives. (Please feel free to provide/attach an additional sheet
if needed).
1. Provide a common area (lounge area) with food and bedding for employees asked to perform
extended duty. Consider ways to support voluntary sequestration.
2. Supervision may support administrative tasks, (time entry, scheduling, etc)
3. Suspend large group meetings and non-essential meetings and limit/suspend (Utility) travel.
Encourage social distancing techniques during meetings or tailgates that must occur.
4. Provide sufficient and accessible infection control supplies (e.g. hand-hygiene products,
tissues and receptacles for their disposal) in all business locations. Step up surface cleaning in
common areas.
5. Re-prioritize and suspend work when resources dwindle. Implement contingency plans for
major projects or safely shut down major projects that cannot be supported.
6. Implement operational contingency plans if essential operations are threatened. Emergency
assignments may be made to non-typical job classifications.
Ext:
Description
Operate hydro and
diesel generators
Monitor operating
conditions
Tagging /equipment
operations
Operate/Monitor
operating conditions
Operate/Monitor/Adjust
Adult Fish Ladder
Maintenance in
progress
Is this Internal or
External?
Internal
Internal
Internal
Internal
Internal
Internal
Minimum Staffing Levels -- Provide the minimum number of staff required to maintain
essential services. (Please feel free to provide/attach an additional sheet if needed).
Essential Service (*see prior
question)
Operate/Monitor Hydro C
Powerplant
Monitor Hydro C Powerplant
Support Hydro C Modernization
Operate/Monitor/Adjust Hydro A
generation
Operate/Monitor/Adjust Adult Fish
Ladder
Complete C-7 Overhaul
Minimum* of
Staff to
maintain
1
Type/Description of position
Operator (5 days/week)
11
5 mechanics, 5 wiremen, 1
technician
Action Plans - Describe courses of action that will be taken to overcome the expected
challenges. These will substantially be the strategies used to maintain delivery of essential
services. Note: Action plans should directly support our objectives. (Please feel free to
provide/attach an additional sheet if needed).
1. Provide food and bedding for employees asked to perform extended duty
2. All administrative tasks to be performed by supervision (time entry, scheduling, etc)
3. Close visitor center and museum if support personnel become absent
4. Re-prioritize and suspend work when resources dwindle
5. Cancel all standard meetings and replace with daily attendance checks and tail gates
***PLEASE ROUTE THIS COMPLETED FORM TO:
CM Superintendent
Ext:
Central Maintenance
Description
Assist in maintaining
physical hydro plant
integrity - i.e. - spillway
Provide basic
transmission yard
maintenance and
emergency repair
Hydro plant fish ladder
emergency repair
Is this Internal or
External?
Internal
Internal
Internal
Internal
Emergency repair to
mitigate possible
hatchery fish loss
Internal
Minimum Staffing Levels - Provide the minimum number of staff required to maintain
essential services. (Please feel free to provide/attach an additional sheet if needed).
Essential Service (*see prior
question)
Protect hydro plant integrity
Maintain reliability of the
Minimum* of
Staff to
maintain
5 Mech. 4
Wiremen 2
Techs
4 Wiremen
Type/Description of position
All positions are maintenance
oriented positions
All positions are maintenance
4 Technicians
1 Station Engineer
2 Materials
Specialists
2 Wiremen
5 Mech.
2 Techs
2 Materials
Specialists
7 Techs
6 Wiremen
5 Mechanics
2 Materials
Specialists
1 Mech.
1 Wiremen
1 Tech
1 Materials
Specialists
oriented positions
Action Plans - Describe courses of action that will be taken to overcome the expected
challenges. These will substantially be the strategies used to maintain delivery of essential
services. Note: Action plans should directly support our objectives. (Please feel free to
provide/attach an additional sheet if needed).
1. Suspend performance of "non-essential" services.
2. Provide the minimum Supervisory presence for crew support and organization by location - 3
3. Practice social distancing practices with the crews - no large meetings, separate tailgates,
etc...
4. Leverage administrative support (high-priority tasks) from internal resources.
5. Maintain special function personnel levels: CM specialists - (station crane mechanic,dive
crew, mobile crane crew)
6. Provide overall minimum coverage for Mission Critical functions which would be:
MCF jobs where coverage is required 24/7 for emergency continuance of core operations
Hatchery response (1 Mech., 1 Wiremen, 1 Tech) Telecom, SCADA, Radio, Plant support
(2 Wiremen, 4 Tech, 4 Mechs) Transmission/Distribution: (4) CM Switchyard Crew, (2)
Technicians, (1) Station
Engineer
Materials Specialist (1 at each Hydro Warehouse)
Total CM Wiremen - (6)
Total CM Techs - (7)
Total CM Mechanics - (5)
Total CM Materials Specialists - (2)
Section 15
COMMUNICATIONS:
The (Utility) recognizes the value of maintaining an effective communications system.
Telephones:
Radios:
Radio users include hydro project employees, contracted security guards, and (UTILITY)
Security Division personnel.
Radios are programmed to afford interoperability throughout the (Utility). Additionally, these
radios provide interoperability with local First-Responder agencies.
Radios normally operate with "wide area" (throughout (Utility)) coverage. If there is computer
failure of the wide area coverage, then the individual project radios continue to operate with
local repeaters. If the local repeaters fail, then radios can still be used in "talk around" mode
(portable-to-portable, mobile-to-mobile, base station-to-base station). Base-station radios
have battery back-up, in case of AC failure.
Hydros A&B
Co.