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NERC CIP Standards and NRC, How FERC Order 706-B

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JC Culberson's picture
Manager of Operations, Certrec Corporation

A proven industry leader in energy system operations, planning, compliance, and wholesale energy market structure, I have developed NERC compliance programs for entities ranging from ISO/RTO...

  • Member since 2020
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  • Nov 6, 2020

I've noticed more and more Regional Entities are scheduling nuclear generating plants for CIP audits. Pursuant to FERC Order 706-B, generating facilities that are regulated by the Nuclear Regulatory Commission are exempt from the CIP standards. We have helped some entities remove themselves from their respective Regional Entities' CIP audit list, but we still see this trend occurring with the posting of the Regional Entities' 2021 audit schedules.

Long story short, if a nuclear generating station is registered with NERC as a Genrator Owner (GO) or Generator Operator (GOP), it is subject to compliance with the OPs & Planning standards (see FERC Order 693) applicable to its functional registration(s); however, if it is under the regulatory authority of the NRC, the CIP standards are not applicable. If you have any questions about this, or if you see that your NERC registered nuclear Facility is on the CIP audit list, I'll be happy to answer your questions.

Matt Chester's picture
Matt Chester on Nov 6, 2020

Do the people running these facilities tend to understand this difference, or when you talk to them are they surprised to find out that they can be removed from the list like you suggest? 

JC Culberson's picture
JC Culberson on Nov 6, 2020

Most of the nuclear compliance staff have an understanding of the exemption, and the Regional Entities understand as well. I'm not completely sure why the nuclear GOs and GOPs are beginning to show up on the CIP audit lists, but it has been happening. It's not a very big problem, as it only takes the right kind of communication with the appropriate NERC or RE staff to resolve the issue. To answer the second part of your question, I believe the compliance personnel at the Facilities are more surprised that they are actually on the lists in the first place.

Jim Stack's picture
Jim Stack on Nov 9, 2020

What is the purpose of FERC706-B and why are some of these Nuclear plants exempt?

JC Culberson's picture
JC Culberson on Nov 10, 2020

There was a Memorandum of Agreement between the NRC, FERC, and NERC that dictated the CIP standards would not apply to nuclear plants under the regulatory purview of the NRC, due to their stringent security measures in place for NRC compliance. FERC Order 706-B solidified that MOA.

Bob Meinetz's picture
Bob Meinetz on Nov 13, 2020

In other words: nuclear professionals, unlike those in other energy disciplines, have always taken responsibility for ensuring any facilities that qualify as "critical infrastructure" are adequately protected.

It goes with the territory.

JC Culberson's picture
Thank JC for the Post!
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