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Culler, Megan Jordan [Idaho National Laboratory (INL), Idaho Falls, ID (United States)] (ORCID:0000000331297823)

Publications and source records attributed to Culler, Megan Jordan [Idaho National Laboratory (INL), Idaho Falls, ID (United States)] (ORCID:0000000331297823).

Equipment Assessment Guide: A Technical Inspection and Hardening Guide for Devices in Power Grid Operations

This Equipment Assessment Guide, developed by Idaho National Laboratory (INL), provides a comprehensive framework designed to enhance the security of operational technology (OT) devices within power grid operations. The guide outlines essential steps for asset owners to conduct technical inspections and harden vulnerable hardware and firmware components commonly found in embedded systems. It focuses on components frequently targeted by cyber threats, offering valuable identification techniques for locating and recognizing critical components on devices. Additionally, the guide presents recommended secure configurations aimed at minimizing exposure and reinforcing defenses, along with impact analysis that highlights the potential consequences for grid operations if components are compromised. By implementing the recommendations outlined in this guide, asset owners can significantly enhance their cybersecurity posture, reduce the attack surface of field-deployed devices, and improve the resilience of grid services against emerging cyber threats.

42 - ENGINEERING

Virtual Power Plant Architecture and Resilient Design

Virtual Power Plants (VPPs) represent a fundamental shift in electric grid operations, aggregating distributed energy resources (DERs) such as solar panels and battery storage to deliver utility-scale grid services traditionally provided by centralized power plants. This report examines the unique architectural, operational, and digital assurance considerations that distinguish VPPs from conventional utility infrastructure as they scale from pilot projects to mainstream deployment across the United States. While VPPs offer significant opportunities for grid modernization and enhanced flexibility, their distributed, multi-stakeholder architecture introduces distinct security challenges that differ fundamentally from traditional generation facilities. The analysis identifies risks in VPP operations, including device-level security gaps, platform vulnerabilities, and communication protocol weaknesses that create expanded attack surfaces compared to centralized power plants. Through examination of real-world incidents and emerging threat patterns, the report demonstrates how some VPPs' reliance on consumer-owned devices, public internet infrastructure, and complex vendor ecosystems require new approaches to digital assurance and operational security. The findings provide practical guidance for utilities, regulators, and aggregators to implement robust security frameworks and operational best practices essential for maintaining grid reliability as VPP deployment accelerates under the Federal Energy Regulatory Commission (FERC) Order 2222 and related regulatory initiatives.

24 - POWER TRANSMISSION AND DISTRIBUTION

Data Center Cybersecurity, Supply Chain Risk Management, and Emerging Regulation Cohort Summary: Takeaways and Action Plans

This report summarizes the outcomes of the Data Center Cohort under the Department of Energy’s Technical Assistance for Digital Assurance (TADA) initiative, aimed at enhancing grid resilience through cybersecurity, supply chain risk management (SCRM), and Cyber-Informed Engineering (CIE). The cohort engaged 17 organizations across utilities, data center operators, vendors, and technology providers in three sessions combining presentations, discussions, and exercises. Key topics included AI-driven load behavior, cybersecurity vulnerabilities in UPS/BESS and cooling systems, governance gaps at utility–data center boundaries, and supply chain integrity. Five cross-cutting themes emerged: interconnection architecture vulnerabilities, fragmented governance, AI-driven stability risks, lack of regulatory frameworks, and long-term supply chain concerns. Actionable recommendations were developed, including implementing DMZ segmentation, formalizing vendor access agreements, designing AI workload limits, and advancing standards through NERC and state-level programs. These strategies aim to strengthen resilience, clarify responsibilities, and ensure secure integration of data centers into the grid.

24 - POWER TRANSMISSION AND DISTRIBUTION

Navigating United States Standards and Regulation for Digital Energy Systems

This report provides an analysis of the U.S. standards and regulatory landscape for digital energy systems, focusing on cybersecurity, safety, and reliability requirements. It examines the interplay between federal mandates, state regulations, voluntary industry standards, and utility-specific policies, highlighting critical gaps between compliance and real-world risk mitigation. While NERC CIP standards enforce cybersecurity for Bulk Electric System assets, distribution-level infrastructure and emerging technologies often fall outside mandatory oversight, creating vulnerabilities. The report identifies systemic challenges such as reliance on self-attestation, uneven state adoption of safety codes, and lagging standards for advanced technologies like battery energy storage and inverter-based resources. Through a detailed gap analysis, it underscores the urgency of proactive risk-based approaches, independent verification, and strategic engagement with state and federal entities. Recommendations include adopting tiered security frameworks, strengthening procurement practices, and addressing emerging technology risks to ensure resilient and secure digital energy infrastructure. This guidance is intended for utilities, regulators, and stakeholders navigating compliance obligations and seeking to enhance cybersecurity and safety beyond minimum standards.

24 - POWER TRANSMISSION AND DISTRIBUTION

Digital Assurance for Grid Reliability in the Era of Large Load Growth

The rapid expansion of large electric loads is reshaping the operational and regulatory landscape of the U.S. electric grid. These facilities are reaching new scales of expansion, now exceeding a gigawatt per site, and their highly sensitive, digitally driven behaviors introduce new reliability risks. Recent grid events, including large load losses following routine transmission disturbances, highlight the consequences of limited ride-through capability, inconsistent protection settings, inadequate modeling, and lack of behind-the-meter visibility. Parallels to earlier integration challenges of new grid technologies suggest that the grid’s existing processes, standards, and interconnection frameworks are no longer adequate for emerging large loads. This brief synthesizes lessons from the evolution of inverter-based resource regulation and applies them to large-load integration. It identifies critical gaps in modeling accuracy, interconnection processes, performance standards, and compliance mechanisms. Technical recommendations emphasize advanced monitoring, improved modeling, coordinated communication protocols, modernized substations, and structured behind-the-meter control schemes. Collectively, these measures provide a roadmap to maintain bulk power system reliability while enabling the continued growth of large, electrified digital infrastructure.

24 - POWER TRANSMISSION AND DISTRIBUTION

Advanced Transmission Technologies (ATTs) Supplier Cohort Workshops Cohort Summary [Slides]

This Summary slide deck summarizes the key outcomes of the Advanced Transmission Technologies (ATTs) supplier cohort, part of Idaho National Laboratory’s (INL) Technical Assistance for Digital Assurance (TADA) program. The program aimed to strengthen grid resilience through cybersecurity controls, supply-chain security, and Cyber-Informed Engineering (CIE) for advanced transmission technologies. The cohort brought together vendors representing the full range of Grid-Enhancing Technologies (GETs), including providers of Dynamic Line Ratings (DLR), Advanced Power Flow Control (APFC), Transmission Topology Optimization (TTO), and High-Performance Conductors (HPCs). Discussions focused on institutional, integration, and operational barriers limiting GET adoption; cybersecurity risks at EMS/SCADA, cloud, and network integration points; and supply-chain transparency issues such as semiconductor dependence and SBOM/HBOM expectations. Participants also addressed operator trust, human-in-the-loop requirements, and challenges with utility adoption, while exploring how CIE can support secure deployment of GETs. This deck represents a consolidated summary of challenges and risks identified by vendors, cross-cutting themes and technology-specific insights from three cohort workshops, and actionable mitigations to guide utilities, vendors, and the Department of Energy in advancing secure, trusted deployment of GETs.

24 - POWER TRANSMISSION AND DISTRIBUTION

Threat Hunt Guide for BESS Environments

The rapid digitalization of the electric grid - driven by the integration of inverter-based resources (IBRs), battery energy storage systems (BESS), and advanced grid control platforms - has significantly enhanced grid efficiency, visibility, and flexibility. However, this evolution also introduces new cybersecurity risks, particularly through supply chain dependencies and operational blind spots at the grid edge. To address these challenges, Idaho National Laboratory (INL), through the Department of Energy (DOE) Office of Cybersecurity, Energy Security, and Emergency Response (CESER) Rapid Risk initiative, conducted a series of rapid risk assessment engagements with energy organizations across the United States. Drawing on lessons learned from these engagements, INL developed the following threat hunting guide for asset owners and operators (AOOs) to enhance their cybersecurity visibility within BESS and IBR systems. The guide demonstrates how to use passive network monitoring to baseline device behavior, detect adversarial activity, and investigate anomalies without disrupting operations. By implementing these practices, energy sector stakeholders can improve coordination between cybersecurity and operations teams and strengthen the resilience of distributed energy resources (DERs) within the modern power grid. Prior to implementing any network monitoring, packet capture, or threat hunting activity described in this guide, AOOs are strongly advised to review applicable governance frameworks, legal requirements, and organizational policies. This guide is intended for informational and educational purposes only. It does not replace compliance with any federal, state, or local cybersecurity mandates or industry standards. Implementation of described configurations, technologies, or analytic workflows is performed at the discretion and responsibility of the asset owner and operator.

25 - ENERGY STORAGE

Bridging the Gap for Powering Data Centers

The rapid expansion of data centers, primarily driven by artificial intelligence, is outpacing the adaptability of the U.S. electric grid. This report, developed by Idaho National Laboratory (INL) , presents a gap analysis of some of the infrastructure challenges associated with large-scale data center deployment. Drawing from a national workshop hosted by INL in October of 2025, the report synthesizes stakeholder insights, survey data, and technical discussions to identify critical barriers and research needs. Key findings highlight the growing preference for behind-the-meter generation, the perceived inadequacy of legacy interconnection processes, and the urgent need for improved coordination between utilities, regulators, and data center developers. Environmental concerns such as water use and noise pollution, as well as economic constraints like equipment lead times and cost allocation, are also explored. The report outlines national lab capabilities in modeling, simulation, and technical assistance, and proposes targeted R&D priorities to support resilient, scalable, and efficient integration of data centers into the grid.

22 - GENERAL STUDIES OF NUCLEAR REACTORS

Cyber-Informed Engineering (CIE) Guide for States

The Cyber-Informed Engineering (CIE) Guide for States provides state energy offices, public utility commissions, and partner organizations with a structured framework for integrating cyber-resilient engineering practices into energy planning, grantmaking, interconnection processes, and workforce development. As grid digitalization and the adoption of distributed energy resources accelerate, states face expanding cyber-physical risks that traditional cybersecurity measures alone cannot fully address. CIE offers a proactive, consequence-focused engineering methodology that emphasizes eliminating or mitigating high-impact failure modes through design, physical controls, and operational safeguards. The guide outlines the 12 core CIE principles, demonstrates their application through state-focused use cases—including grant evaluation rubrics, interconnection reviews, allow-list development, and training programs—and provides practical tools such as scoring frameworks, impact assessment methods, and implementation checklists. It also highlights pathways for state–utility collaboration and opportunities for technical assistance from national laboratories. By adopting CIE, states can enhance grid reliability, reduce lifecycle costs, strengthen supply-chain assurance, and foster a security-aware engineering culture that aligns with broader resilience and modernization goals. November 2025

29 ENERGY PLANNING, POLICY, AND ECONOMY

Securing the Modern Grid: Federal Investments, Digitization, and Supply Chain Strategy

Across the United States (U.S.) grid expansion and modernization is underway, paving the way for accelerated load growth and intelligent resource management. Digitization of the grid is supported by several state and federal programs, providing support for utilities installing advanced metering infrastructure (AMI), AI-powered analytics systems, battery energy storage systems (BESS), and distributed energy resource management systems (DERMS) to transform the grid from a one-way power delivery system into an intelligent, responsive network that will enable faster load growth and power expansion of data centers for advanced artificial intelligence (AI) applications. The digital transformation of America's grid presents opportunity for increased efficiency and resiliency but also introduces new digital risks that require careful management. Digital equipment often contains several vulnerabilities such as unencrypted communication protocols, and persistent remote access capabilities that could be exploited to manipulate device settings, coordinate service disruptions, or inject false data into grid operations. These digital risks become particularly important as the grid must rapidly scale to support AI-driven data centers, which the administration has identified as essential for maintaining U.S. technological leadership and economic competitiveness. These vulnerabilities are compounded by supply chain realities: Chinese manufacturers currently produce 70-90% of essential grid components including inverters, batteries, and control systems, with the U.S. lacking domestic manufacturing capacity for critical assets like extra-high voltage transformers. Recent federal legislation has established Foreign Entity of Concern (FEOC) restrictions to address these risks, requiring projects to achieve escalating thresholds of non-FEOC content to receive tax credits while utilities work to expand sourcing channels for their supply chains and strengthen security measures. These restrictions arrive precisely when utilities face unprecedented electricity demand growth driven by the rapid growth in data centers, creating a considerable challenge: rapidly expanding infrastructure while navigating complex compliance requirements while lacking viable alternatives for many critical components. Idaho National Laboratory (INL) and its partners have developed practical approaches to help utilities navigate these intersecting challenges as they leverage federal investment to strengthen and grow the grid. These solutions include Cyber-Informed Engineering (CIE) principles that build resilience directly into systems, the Cirrus tool for secure cloud migration, and enhanced procurement guidance that embeds security requirements throughout equipment lifecycles. Federal initiatives, such as the Technical Assistance for Digital Assurance (TADA) project, provide direct support to utilities implementing these approaches while facilitating knowledge sharing across the industry. While these tools and frameworks cannot eliminate all risks inherent in foreign supply chain dependencies, they offer pragmatic pathways for strengthening security posture without sacrificing the deployment momentum essential to meeting surging electricity demand. Ultimately, securing America's digital energy infrastructure demands dedicated coordination across multiple fronts: building domestic supply chains, implementing robust digital assurance practices, and maintaining the aggressive modernization timeline necessary for reliability, resilience, and energy independence.

24 POWER TRANSMISSION AND DISTRIBUTION

MegaWatt Mayhem: Grid Operator Challenges Center Loads

This report provides a summary of the challenges faced by United States electricity grid operators in accommodating and anticipating the rapid deployment of large loads, particularly data centers, based on academic literature and industry working groups. The report highlights the unique requirements and operational characteristics of data centers, which differ significantly from traditional industrial loads. Key issues addressed utility planning considerations, with emphasis on the implications for grid operators, impacts to normal operations for grid operators, reliability considerations during periods of grid stress, and resilience considerations for the changing operational paradigms based on data centers. Real-world examples are used to highlight these challenges and the changes that grid operators must address. The findings underscore the necessity for coordinated efforts and innovative solutions from both grid operators and regulatory bodies to ensure the stable integration of large loads into the grid. This report is the first in a series that will explore the challenges of data center deployments based on several key power system perspectives.

24 - POWER TRANSMISSION AND DISTRIBUTION

Securing Grid Communications Infrastructure: Addressing Gaps Beyond NERC CIP Facility Perimeters

The North American electric grid relies on a complex communications infrastructure that extends beyond facility perimeters traditionally covered by NERC Critical Infrastructure Protection (CIP) standards. While CIP requirements have significantly strengthened cybersecurity within Electronic Security Perimeters, many operational communications—such as those between control centers, substations, and third-party networks—fall outside current regulatory scope. As grid modernization introduces new technologies and connectivity models, these external pathways present evolving security challenges. This brief explores the nature of these challenges, including emerging attack vectors and supply chain considerations, and highlights how ongoing grid transformation increases exposure to sophisticated threats. It outlines practical strategies and policy options to complement existing standards, such as expanding secure communications practices, enhancing supply chain transparency, and fostering collaboration among federal, state, and industry stakeholders. Near-term actions like encryption, authentication, and contractual safeguards can help reduce risk while longer-term frameworks are developed to ensure resilient and secure grid operations.

24 - POWER TRANSMISSION AND DISTRIBUTION

Adoption of AI in the Utility T&D Sector: Use Cases, Consequence, Assessment and Benefits

Digital transformation and utilization of artificial intelligence (AI) in the electric grid are fundamentally changing the industry’s approach to common problems and enabling a broader paradigm shift in grid planning and operations. The change in approach is circularly both enabling and driving modernization, with load growth and reliable management of data center and AI infrastructure shifting away from planning approaches with relatively predictable behaviors and toward a mix of consumer and industrial choices that surpass human cognitive abilities to process. This movement has potential to condition humans to not understand the system on which the AI depends, while requiring it for development of the necessary infrastructure. Approaches which would address most likely grid conditions and events, such as faults, aging of equipment, and weather, now must also account for large loads which shift not based upon weather or time of day, but the computational load. Quantifying computational load is independent of the traditional grid forecasting variables, where a data center’s aggregate load is determined by user and AI system behavior and decoupled from normal grid planning and operations. AI is both the cause and solution for these challenges, with new grid planning tools integrating massive amounts of decisions into frameworks.

24 POWER TRANSMISSION AND DISTRIBUTION

Cybersecurity Incident Response Guide for Wind

As wind energy systems become increasingly digitized and interconnected, they face a growing array of cyber threats that can disrupt operations, compromise safety, and trigger cascading impacts across the energy ecosystem. The Wind Incident Response Guide provides a structured, wind-specific framework for preparing for, detecting, responding to, and recovering from cyber incidents. Drawing on lessons from field demonstrations, cyber-physical testbeds, and stakeholder engagement across the wind sector, this guide integrates technical, operational, and regulatory considerations to support asset owners, operators, and responders. It outlines key roles and responsibilities, maps incident response phases to wind-specific scenarios, and highlights applicable laws, regulations, standards, and best practices. By tailoring general cybersecurity principles to the unique architectures and operational constraints of wind systems—including remote access, legacy components, and environmental interfaces—this guide aims to enhance resilience, reduce response time, and support coordinated action across public and private stakeholders. It is intended as a practical resource for utilities, developers, regulators, and emergency managers working to secure the future of wind energy.

17 - WIND ENERGY

Navigating Integration: Key Challenges for Data Centers, Nuclear Stakeholders, and Utility Operators

The rapid expansion of data centers, driven by the exponential growth in data-processing and storage needs, presents significant challenges and opportunities for various stakeholders, including data center developers, nuclear energy providers, and utility companies. Data centers are projected to consume 6.7–12% of United States (U.S.) electricity by 2028, driven by artificial intelligence (AI) and cloud-computing demands. Nuclear energy offers reliability and dispatchable baseload power, but data centers need power now while nuclear still needs time to address siting, fast power ramping, and regulatory hurdles. Utilities must keep pace with the unprecedented acceleration of large load interconnection requests and urgently adapt to high-density loads while maintaining grid stability, reliability, and accelerating interconnection timelines. This report dives into these challenges and proposes key collaboration strategies to streamline data center integration that aligns with recent federal initiatives like America’s AI Action Plan and related executive orders that emphasize the importance of data center growth, nuclear energy expansion, and maintaining a competitive edge in the global AI race.

21 - SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLAN

Utility-Scale Operational Consequences for Solar Grid Services

This report delves into the critical aspects of grid services provided by solar inverter-based resources (IBRs), with an emphasis on the evolving landscape of microgrids, virtual power plants (VPPs), aggregators, and distributed energy resource management systems (DERMS). As the energy sector undergoes a transformative shift towards more decentralized and resilient grid architectures, understanding the multifaceted risks associated with these technologies becomes paramount. The report categorizes these risks into organizational, technical, and procedural domains, providing a thorough risk assessment framework that stakeholders can utilize to anticipate and mitigate potential issues. In addressing the increasing complexity of grid interconnections, the report highlights the importance of Cyber-Informed Engineering (CIE). By embedding engineering controls and cybersecurity measures into the early stages of system design, this approach aims to fortify grid infrastructure against emerging cyber threats. The analysis includes an exploration of best practices and strategies for integrating CIE principles to enhance grid security and resilience. To provide practical insights, the report conducts a detailed consequence analysis of various grid services and cyber mitigations that can be applied through the interconnection process. This analysis evaluates the potential impacts of different failure modes and vulnerabilities, offering a clear understanding of the consequences that could arise from disruptions within the energy grid. The findings are further enriched by a series of case studies that illustrate real-world scenarios and lessons learned from past incidents. Through this comprehensive examination of grid services and their criticality, the report aims to prepare industry professionals with the knowledge and tools necessary to navigate the complexities of modern energy systems. By providing a comprehensive approach that includes risk assessment, cybersecurity, and consequence analysis, solar stakeholders can more effectively guarantee the reliability, efficiency, and security of the energy grid.

14 SOLAR ENERGY

Application of Cyber-Informed Engineering for Protecting BESS

This white paper synthesizes an array of crucial grid services provided by BESS technology, assesses its architecture and communications, and presents a case study for analysis against the principles introduced by Cyber-Informed Engineering (CIE). Furthermore, in walking through the analysis, this paper presents a framework to evaluate risks and solutions when considering BESS components. Asset owners and buyers could perform this analysis to assess their BESS product implementations, alternative inverter-based resources (IBR), and energy management systems (EMS). Battery systems fulfill various roles contingent on the unique market demands and the specific challenges presented by regional grid infrastructures. These roles also vary due to the differing utility models for ownership and operation, which are adapted to meet regional and local capabilities and requirements. Concerns have been raised regarding the potential for adversaries to exploit knowledge of battery operational patterns to orchestrate decisive attacks. However, the security of operational data for these systems may not be the primary vulnerability, as much of this information is already well-understood within the community. Applying a modest degree of subject matter expertise can often yield valuable predictions regarding how a battery will respond under certain conditions, such as grid emergencies, high or low-temperature days, Public Safety Power Shutoff (PSPS) events, and outages. The operational characteristics of batteries are well-documented, and their capabilities, including the risks associated with misoperation and the resulting consequences, are published and understood within the industry. CIE practices represent the next step in gaining functional assurance and providing an acceptable level of risk, regardless of whether a battery vendor can support a trusted and validated supply chain. While this issue has exacerbated supply chain challenges, it is not an isolated condition. This foreign supply route is the primary source of BESS for the U.S. market. Significant efforts are underway through the Bipartisan Infrastructure Law (BIL) to change that. Still, strategic short-term operational mitigations are needed to ensure the security of our operational technology (OT) systems, which are enhanced by instilling trust and are separate from vendors implementing CIE principles.

25 ENERGY STORAGE