FERC Division of Dam Safety & Inspections

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1 NHA/NWHA 2018 Walla Walla WA FERC Division of Dam Safety & Inspections Doug Johnson Regional Engineer

2 Outline Focused Spillway Inspections Owners Dam Safety Program Audits Questions from HPC members 2

3 Spillway Inspections The Oroville Incident triggered need to take a closer look at similar spillways A Letter was sent to Selected Licensees in the Portland Region as well as across the US Dams with Chute Spillways On Soil or Rock Dams with Unlined Principal or Emergency Spillways. 3

4 Spillway Inspections Perform a detailed review of all design, construction, inspection, foundation information. Close visual inspection of the entire spillway. Focused Potential Failure Mode Assessment We didn t know specific root cause of Oroville Spillway at that time. So, these inspections were to focus on all the common failure modes for spillways. 4

5 Results of Focused Spillway Inspections (as of 9/7/18) FERC Region Spillways Flagged for Inspection Spillways Inspections Completed Repairs Needed Atlanta Chicago New York Portland San Francisco Totals

6 Lessons Learned Inspections and Assessments are still ongoing, but a majority of the spillways inspected by FERC appear to be in satisfactory condition. However a small but still significant percentage of spillways have moderate to major issues which will require either major maintenance or remediation 6

7 Lessons Learned Oroville IFT findings reminded the entire industry of the importance of spillways and the fact they have been given inadequate attention during inspections and PFMAs. The FERC experience with our focused inspections confirmed that finding. As an industry, we all need to do a better job on inspecting and evaluating the condition of spillways. 7

8 Lessons Learned Detailed field inspections must be paired with comprehensive reviews of design, construction, and maintenance and Failure Modes. Just because it s been there for 50 years doesn t mean it s safe. Inspections by FERC have identified significant issues that need addressing. 8

9 Owners Dam Safety Program Audits FERC requirement of ODSP launched in One element was external audit every 5 years. We were getting audits submitted of ODSP document but not actual program and its effectiveness. 9

10 Owners Dam Safety Program Audits Developed new guidance for audits. Guidance and FAQ Posted on our website. opower/safety/initiatives/odsp.asp Focuses more on review of program than on document itself 10

11 Owners Dam Safety Program Audits Who should be hired to perform the ODSP audit? What experience and qualifications are needed by the auditor? For smaller licensees a single individual may be appropriate to perform the audit. For larger licensees with numerous dams and complex organizations, a two or more person audit or peer review team would likely be more appropriate. 11

12 Owners Dam Safety Program Audits Qualifications for auditor(s) would include: Engineer(s) experienced in dam safety design, operation, and maintenance of the types of dams being evaluated. A current/former CDSE who has worked in a different dam owning organization with a strong dam safety program. Someone with a regulatory dam safety background (e.g. current or former state or federal employee). Engineering Consultant with expertise in dam and hydro safety management, design, and/or dam safety engineering. 12

13 Owners Dam Safety Program Audits Do I need to submit the proposed auditor s resume to the FERC for acceptance?\ Yes, you should submit a statement of qualifications, including a resume, of the proposed auditor to the Regional Engineer for review and acceptance prior to performing the audit. 13

14 Owners Dam Safety Program Audits Can we just use our Part 12 Independent Consultant to conduct our audit? For smaller licensees with only a few dams and a simple organizational structure, Yes, provided their experience includes understanding of organizational management and leadership principles. For large licensees, we recommend that a auditor or team of auditors separate from the Part 12 consultant be utilized 14

15 Owners Dam Safety Program Audits Can we use the same auditor for every audit? In general, it is preferred that you use a different auditor for each external audit. Check with your Regional Office prior to proposing the same auditor twice. 15

16 Owners Dam Safety Program Audits Can the FERC provide us with some names of potential auditors? We do not maintain a list of individuals who are qualified to perform an audit. However, Professional Organizations such as the ASDSO, USSD, or (ASCE) may be able to help with finding qualified auditors or peer reviewers. 16

17 Questions from HPC members 17

18 Questions from HPC members 1. Can FERC provide information or suggestions on Penstock security & safety? We have an exposed penstock that is accessible to the public on foot just off a public road. We have no security items on it now, what would he suggest for increased security (motion detection, cameras, fences, vehicle license cameras)? We currently do regular visual inspections however what would FERC suggest for enhanced safety evaluations? 18

19 Questions from HPC members 2. For our reservoir we have a log boom set up and cameras but are curious about additional protection measures we could take to keep boaters away from the face of the dam, any suggestions? 19

20 Questions from HPC members 3. How can a licensee handle request for public access to the base of a very high risk dam? There have been request for the public to get vehicular access to the base of our dam on a very long, steep and unsafe single lane road. We use this access road for reaching our existing low level outlet valves, powerhouse intake butterfly valve and a mini hydro power generation structure. The public has also requested parking spaces and a turnaround area with in our immediate work zone. What types of approaches have been used at other locations to alleviate these requests or provide alternatives to the request? 20

21 Questions from HPC members 4. The current Drilling Program Plan guidelines are for embankment dams. Applying these guidelines to concrete dams is not straightforward. Is the FERC preparing an equivalent document for concrete dams? 21

22 Questions from HPC members 5. How should an owner plan for FERC reviews and approvals? For a multi-year project, an owner attempts to plan activities to develop a schedule baseline. Is there a suggested, realistic workflow for the FERC review processes that owners can use in baselining a schedule? One long activity entitled FERC Review is not sufficient. 22

23 Questions from HPC members 6. How does an owner decide who are the best people to audit a dam safety program? 23

24 Questions from HPC members 7. Is there any reason why audits wouldn t be well-served by using an ISO Asset Management Gap Assessment as has been completed for the California Department of Water Resources. 24

25 Questions from HPC members 8. What is FERC doing in response to the President s executive order (reduction of 2 for 1 added)? 25

26 Questions from HPC members 9. In the event that regulations cannot be eliminated, is FERC at least looking at interval reductions? For example, on a project that has shown no finding over the last 5 years of annual inspections, can the inspection interval be changed to every 2 years or 3 years instead of annually. For a project that shows no movement of the Dam, year after year, can the monument inspection be changed to once every 2 years instead of every year? Can the Independent Contractor inspection now done every 5 years be changed to 6 or 7 years? 26

27 Questions from HPC members 10. What efficiencies has FERC made or is planning to make to improve licensing efficiency and speed? 27

28 Questions from HPC members 11. Please provide an update to the status of the GAO investigation and the independent audit that FERC has requested. 28

29 Questions from HPC members 12. When and how do you expect Risk Informed Decision Making (RIDM) to become a more commonly used complement to traditional dam safety evaluation procedures? 29

30 Questions from HPC members 13. One of the take-aways or lessons learned from the Oroville incident is the risk of normalizing abnormal conditions or abnormal structure behavior. In the FERC s view, how common is that phenomena and how much is that a conscious behavior (intended to avoid spending money or changing practices)? 30

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