What Happens When You Pull the Plug? What COPS Means to Your Facilities

1. What Happens When You Pull the Plug?What COPS Means to Your Facilities Presented by Vincent Plansky, PE, LEED BD+C August 11, 2010

2. NEC 2008 Article 708 Critical Operations Power Systems (COPS) 708.1 Scope - Applies to power systems, HVAC, fire alarm, security, communications, and signaling systems in facilities classified as “critical” by: Any governmental agency having jurisdiction Municipal, state, federal, or other codes Facility engineering documentation establishing the necessity

3. Homeland Security Strategy and Legislation • Presidential Directives • National Initiatives Federal Government • National Infrastructure Protection Plan (NIPP) Base Plan (2007) • Requires development Sector Specific Plan (SSP) by the various SSA’s • Grants Enforcement Power to US EPA Department of Homeland Security • Responsible for development of the process for risk-based prioritization of its assets in the Water Sector • Integrates federal protection efforts for Critical Infrastructures and Key Resources (CI/KR) into the Water Sector US EPA is the Water SSA • Primacy authority to oversee SDWA drinking water programs within its borders • Regulates wastewater programs under the CWA’s National Pollutant Discharge Elimination System (NPDES) program. State and Local Agencies Owner Regulatory Chain of Command

4. 2008 NEC Adoption by State ME WA ND MT M I VT MN NH NY MA OR WI CT RI ID SD M I WY PA NJ IA MD OH DE NB IN NV IL WV UT VA CO CA MO KS KY Expected January 2011 NC TN State Adopted SC S. Carolina Code Council adopted 2009 IRC with 2008 NEC 3/22/10 with implementation 1-1-11 AR AZ NM OK GA TX AL MS State Adopted Unincorporated Areas LA AK FL 2008 NEC – 34 States Basically 2002 NEC but some islands back to 1993 NEC 2005 NEC – 6 States Local Adoption – (10) Note: Some local adoption states have earlier than 2005 adoptions in some jurisdictions Revised October 30, 2009

5. May be applied to entire facilities or to designated areas within a facility 708.2 Definitions Critical Operations Power Systems (COPS) Power systems for facilities or parts of facilities that require continuous operation for public safety, emergency management, national security, or business continuity. Designated Critical Operations Areas (DCOA) Areas within a facility or site designated as requiring critical operations power.

6. Critical infrastructure is “critical” for a reason • Water and wastewater facilities can be classified as critical infrastructure because they: Protect public health and safety Expedite disaster recovery Safeguard the environment Allow businesses to function

7. The Reliability of the Water Sector Depends on a Complex Power Grid Pump Stations Water Plants Wastewater Plants Wholesale Suppliers Investor Owned Utility Generators Independent Power Generators Power Marketers Power Exchange (RTOs/ISOs) Transmission Retail Electricity Providers

8. The Electric Power Industry Before 2005 • 18 Reliability Coordinators • Managed reliability and operation of wholesale markets • Voluntary Membership • Competing interests • North American Electric Reliability Council (NERC) • Ten Regional Reliability Councils • 140 control areas • No Enforcement Powers • Voluntary Cooperation

9. 2003 – The Tipping Point • Trouble began at 12:15 PM • Inadequate situational awareness by FirstEnergy • Inadequate tree-trimming by FirstEnergy • 345kV Sammis–Star overload trip at 4:06 PM – essentially complete by 4:13 PM • High speed cascading lasted approximately 12 seconds • 263 power plants shut down (531 generating units) • Over 50 million people in the Northeast US and the Province of Ontario were out of power up to 3 days

10. The Energy Policy Act (EPAct) of 2005 • NERC’s mission: • To ensure the reliability of the bulk power system in North America. The Reorganization • NERC reorganized as the North American Electric Reliability Corporation • Granted powers to enforce its own reliability standards • Consolidation of Regional Entities • 131 Balancing Authorities (BAs)

11. EPAct and the Energy Markets • FERC: • Regulates the transmission and wholesale sales of electricity in interstate commerce. • State Public Utility Commissions: • Regulate retail electricity sales to consumers. RTOs and ISOs: • Serve roughly two-thirds of all US electricity customers • Operate organized wholesale electric markets • Provide transmission service • Interconnect new resources to the transmission grid • Financial interests must be kept at arms length from reliability interests

12. Generation Transmission Local Distribution Traditional Risks to Electrical Infrastructure Generation Failures Vegetation Equipment Failures Lightning Floods Storms

13. Emerging Risks to the Electrical Grid Risk Reliability Source: NERCs 2009 -2018 Long-Term Reliability Assessment

14. Shift toward renewable energy will affect grid reliability Variable Generation is the term for generation based on renewable fuel sources such as wind and solar. NERC’s 2009 Long-Term Reliability Assessment estimates that 229,000 MW of wind generation resources may be added by the year 2018. How variable generation affects the reliability of the bulk power system: Power output changes according to wind or weather These resources are not dispatchable to grid operators Renewable sources are less predictable than conventional generation.

15. The Smart Grid - Challenge or Opportunity? Section 215 of the Federal Power Act: §215(a)(8) “The term ‘cyber security incident ’ means a malicious act or suspicious event that disrupts, or was an attempt to disrupt, the operation of those programmable electronic devices and communication networks including hardware, software and data that are essential to the reliable operation of the bulk power system.” While the smart grid promises to bring greater efficiency and functionality to grid operators, it also poses a significant security challenge. NERC assessment - much of the grid is vulnerable to cyber attack. FERC examined AURORA compliance: Only 7 of 30 companies had mitigated the vulnerability Only 2 of 30 had a good cyber security posture.

16. Pulling the Plug on the Grid • Article 708 requires critical systems to operate indefinitely while completely cut off from the electric, gas, and water utility grids. Successful compliance requires: Planning and Assessment Engineering Beyond Traditional Approaches Rigorous Maintenance

17. Risk Assessment (708.4) • Planning • Engineering • Maintenance Conduct Risk Assessment per NFPA 1600 “Disaster/Emergency Management and Business Continuity Programs” Identification of natural and man made hazards Assess specific vulnerability of the electrical system Develop mitigation strategy

18. Physical Security (708.5) • Planning • Engineering • Maintenance Review Vulnerability Assessments Restrict Unauthorized Access Develop Security Plan

19. Emergency Operations Plan (708.64) • Planning • Engineering • Maintenance Documented emergency operations plan NFPA 1600, Section 5.7 Consider emergency response, recovery, and continuity of operations Identify internal and external roles and responsibilities

20. Power Sources (708.20) • Planning • Engineering • Maintenance Generator Set Fuel Cell UPS Storage Battery • A portable, temporary, or redundant alternate power source shall be available for use whenever the COPS power source is out of service for maintenance or repair.

21. Generator sets (708.20F) Onsite fuel supply independent of public utility gas system Cooling systems independent of municipal water supply Single generator requires a means to connect a backup portable generator Automatic starting and transfer on failure of the normal service

22. Fuel Cells Methane produced from anaerobic digester used as the fuel Ultra-low emissions Heat byproduct used to heat the sludge. Up to 80% CHP efficiency. Biogas is a renewable fuel eligible for incentive funding for projects in 28 states including the Central States 2.8 MW, 13.8 kV Fuel cell Courtesy of FuelCell Energy, Inc.

23. Capacity of Power Sources (708.22) • Planning • Engineering • Maintenance Capacity & rating for continuous operation all loads simultaneously Selective load pickup, load shedding, and peak load shaving allowed 72 Hr minimum duration of operation Ventilation required

24. Transfer Equipment (708.24) • Planning • Engineering • Maintenance Means of bypass and isolation Automatic transfer switches – listed, electrically operated, mechanically held Use only for COPS loads

25. COPS Distribution Equipment (708.11) • Planning • Engineering • Maintenance COPS branch circuit distribution equipment located within DCOA served Located in 2 Hr rated fire resistant spaces 100 year floodplain protected Surge protection devices at all voltage levels (708.20)

26. Feeder & Branch circuit wiring (708.10) • Planning • Engineering • Maintenance Identification of boxes, enclosures, receptacles used for COPS Separate raceways from non-COPS COPS branch and feeders circuits supplied by COPS shall be used only on COPS equipment.

27. COPS Feeder Circuit Wiring (708.10C) • Planning • Engineering • Maintenance Protect against physical damage RMC, IMC, MI cable PVC, EMT in 2” concrete 1 Hr rated fire protection or 2” concrete encasement Above 100 year floodplain or listed for wet location

28. HVAC, Fire Alarm, Security, Emergency Communications, and Signaling systems (708.14) • Planning • Engineering • Maintenance 2 Hr fire ratings Twisted shielded pairs Continuous shields Fiber optics between buildings 600v cables for signals 50v & up Secondary protectors

29. Overcurrent Protection (708.50) • Planning • Engineering • Maintenance Devices accessible to authorized persons only Ground fault protection on next level Ground fault testing Full selectivity 6 cycle minimum coordination between service and feeder

30. Commissioning (708.8) • Planning • Engineering • Maintenance Commissioning plan – NFPA 70B “Recommended Practice for Electrical Equipment Maintenance” Independent component & system tests Test results establish a baseline to measure future performance Annex F - Functional Performance Tests (FPTs)

31. Testing & Maintenance (708.6) • Planning • Engineering • Maintenance Witness test by AHJ Periodic testing thereafter - schedule acceptable to AHJ Documented preventative maintenance program per NFPA 70B required by AHJ Written records Testing under load – NFPA 110 Standby & Emergency Power Systems

32. Funding Opportunities FEMA Pre-Disaster Mitigation (PDM) Program PDM program funds plans and projects that reduce overall risks to the population Awarded on a competitive basis without reference to state allocations

33. CHP and biomass/biogas funding opportunities Energy Efficiency and Conservation Block Grant (EECBG) Stimulus Package – $37B for energy efficiency and clean energy U.S. Department of Energy (DOE) – $27.1B in proposed FY2010 budget State and Local – State Energy offices and local utilities host multiple programs for energy incentives and rebates

34. Supplemental Utility Gas Power Generation Gas Cleaning CH4 Gas Storage CH4 Landfill Gas Collection WWTP Digesters Emissions Fuel Cells are a Green Power Opportunity GHG Pollutants Fuel Cell

35. Open Discussion www.cdm.com World Headquarters Cambridge, MA