security
JACK MOYER, COLUMN COORDINATOR
and preparedness
BY GLENN MYRES
Myres
Critical Operations Power Systems
A
s a part of the effort to make the
United States’ critical infrastructure
more impervious to both natural and
intentional disasters, the Department
of Homeland Security (DHS) in conjunction
with the National Fire Protection Association, recently recognized the importance of
hardening the electrical systems of critical
infrastructure. To that end, the 2008 National
Electrical Code (NEC) includes a landmark
article—Article 708, Critical Operations
Power Systems—that addresses new or significantly upgraded electrical systems for all critical infrastructure—including water and wastewater facilities. (The NEC is not retroactive.
Therefore, Article 708 only applies to new or
significantly renovated critical infrastructure.)
The federal government defines critical
infrastructure as: “systems and assets, whether
physical or virtual, so vital to the United States
that the incapacity or destruction of such
systems and assets would have a debilitating
impact on security, national economic security,
national public health or safety, or any combination of those matters”(CRS, 2004).
Water and wastewater systems are included
in the list of the nation’s critical infrastructures. In fact, when DHS produced The
National Infrastructure Protection Plan in June
2006, one of the 17 identified Critical Infra-
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SEPTEMBER 2009 | JOURNAL AWWA
structure and Key Resources Sectors was the
water sector, with an entire Water Sector Specific Plan (Water SSP) devoted to the protection of water and wastewater infrastructure.
Article 708 covers a broad spectrum of
applications, there is little specific direction
about how to implement its requirements at
water and wastewater facilities, especially with
regard to renovation projects at existing facilities. Thus the challenge for owners, operators,
and engineers is to design facilities that meet
code without overdesigning, and unnecessarily
wasting capital dollars.
In order to understand the breadth and
impact of Article 708, it is important to be
familiar with two key definitions:
• Critical Operations Power System
(COPS)—power systems for facilities or parts
of facilities that require continuous operation
for the reasons of public safety, emergency
management, national security, or business
continuity;
• Designated Critical Operations Area
(DCOA)—an area within a facility or site designated as requiring COP.
Although water and wastewater facilities
are considered critical infrastructure, not all
areas of a facility may be DCOAs. However,
those areas designated as a DCOA must be
powered by a COPS. Significantly, neither the
2009 © American Water Works Association
security
and preparedness
Water SSP nor Article 708 specifies
which systems or areas of a facility
should be designated as a DCOA.
This determination is left up to the
owner/operator (DHS, 2007).
Once a facility or a portion of
a facility is classified as a DCOA,
Article 708 sets forth specific
requirements the facility must meet.
(1) A risk assessment must be
performed on each DCOA, and mitigation strategies must be developed
to address defined risks. The Water
SSP (section 3) contains guidance to
perform this risk assessment.
(2) Locations that house COPS
electrical feeder distribution equipment (substations, motor control
centers, panelboards) must be
2-hour fire-rated and must be above
the 100-year flood plain. Thus if
new COPS electrical distribution
equipment is installed at an existing
facility, the fire rating of the location
of the new electrical equipment may
have to be upgraded.
(3) Access to COPS equipment
must be limited to qualified personnel only. A “qualified person”
is defined in NEC Article 100 as:
“One who has skills and knowledge
related to the construction and
operation of the electrical equipment and installations and has
received safety training to recognize
and avoid the hazards involved.”
This may require that COPS electrical equipment be housed in
separate rooms, whereas historically, electrical equipment has often
been located on the process floor.
Additionally, operators who have
had ready access to (and frequently
operate) motor control centers,
switchboards, circuit-breaker panel
boards, and other electrical equipment may have to receive additional
training to meet this requirement.
(4) COPS and non-COPS systems
must be kept physically separate,
including separate transfer switches
and separate conduit systems. If it is
determined that parts of the water
or wastewater treatment facility are
critical (whereas others are not),
separate electrical systems must be
installed for COPS, and non-COPS,
starting from the utility service all
the way to the loads.
(5) A second onsite source of
power for the DCOAs must be
capable of operating the DCOAs
for three days (72 hours). Article
708 lists four acceptable onsite
power sources:
• storage batteries,
• a generator set,
• an uninterruptible supply
of power, or
• a fuel cell system.
A second utility source is not
included as an acceptable alternative. For most water and wastewater facilities, a generator is the only
practical alternative. Therefore, in
most cases, onsite power generation will be required rather than
simply relying on two electrical
utility sources as has been acceptable in the past.
(6) Article 708 requires an onsite
fuel supply. Where a generator is
used as the second electrical source,
the unit cannot use natural gas as
its only fuel source. Dual fuel (diesel/natural gas) is acceptable; however duel-fuel units are frequently
more costly. For planning purposes,
it is useful to know that 72 hours
of fuel for a 1,500-kW diesel generator is approximately 7,600 gal.
(7) The wiring of COPS systems must be physically protected.
With some minor exceptions,
wiring must be installed in metal
conduit or in concrete-encased
nonmetallic conduit.
(8) COPS electrical feeders must
be a minimum of 1-hour fire-rated,
or embedded in a minimum of 2
2009 © American Water Works Association
in. of concrete. Because normal
building wire is not fire-rated, Type
MI (mineral insulated) or other
fire-rated cable or cable assembly is
required unless the conduits can be
concrete-encased.
(9) COPS electrical feeders must
be separate from non-COPS wiring. This may require additional
conduit systems to separate nonCOPS wiring.
(10) Control, monitoring, and
power wiring for HVAC systems
must be 2-hour fire-resistive cable
or a listed 2-hour electrical circuit
protective system.
(11) Only fiber optic cables
can be used for HVAC, fire alarm,
security, and emergency communications and signaling systems
between buildings.
The NEC has also gone further than ever before in requiring
initial and ongoing testing and
record keeping. A few of the newly
required items include the following:
• A Commissioning Testing Plan
must be developed to not only demonstrate that the COPS operates
properly under maximum anticipated loads, but that the testing
results also establish the baseline
for all future testing results. Article
708 requires that the authority having jurisdiction (AHJ)—usually the
electrical inspector—witness the
initial baseline testing.
• The COPS system must be
tested periodically while being witnessed by the AHJ.
• A documented preventive maintenance program must
be developed, and maintenance
records must be kept.
When does Article 708 apply?
If the 2008 NEC is in effect in the
specific jurisdiction when design
plans and specifications are submitted for the building permit, then
Article 708 applies. Interested parJOURNAL AWWA | SEPTEMBER 2009
35
security
and preparedness
permit can be issued and the facility can pass inspection. As an
example, the inspector may forgo
the requirement for the aeration
system generator if a plan is submitted to install a standby generation system for the entire facility
within a certain number of years.
Although Article 708 is still
being fine-tuned, changes will certainly be made in future revisions
of the National Electrical Code.
For now, utilities, design engineers,
and contractors should all be
aware of these new requirements
because they could affect nearly
every new water or wastewater
facility project that falls under the
2008 NEC.
ties can go to www.nema.org/stds/
fieldreps/NECadoption/implement.
cfm to determine whether the 2008
NEC is in effect in a specific location and, if not, when it is anticipated to be adopted.
It may be challenging to sort out
how to implement the requirements
of Article 708 when a facility
undergoes a partial upgrade. For
instance, if an aeration system is
being upgraded at a wastewater
treatment plant and the upstream
and downstream processes do not
have a backup generator, it makes
little sense to install one on the aeration system alone. In this case an
acceptable agreement may need to
be worked out so that the building
—Glenn Myres is an electrical
engineer with Malcolm Pirnie and is
responsible’s for the company’s Central US electrical engineering design.
He has more than 40 years’ experience, more than 11 of which are in
water and wastewater engineering.
Myres can be contacted at gmyres@
pirnie.com or (614) 430-2656.
REFERENCES
CRS (Congressional Research Service),
2004. Critical Infrastructure and Key
Assets: Definition and Identification.
Library of Congress, Washington.
DHS (Department of Homeland Security),
2007. Water Sector-Specific Plan as
Input to the National Infrastructure
Protection Plan. DHS, Washington.
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