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FERC: Good, Better, Best?

  • October 6, 2022
man looks frustrated looking at laptop in an office

The expression “don’t let great get in the way of good” is a current catchphrase. It resonates with the college adage of “D’s get degrees” (or C’s depending on the university). I appreciate the sentiment that perfectionism can sometimes get in the way of the big picture goals and that getting little details tweaked to our personal flair really does nothing for the end product except cost more time, money, and precious patience. That being said, sometimes paying attention to the details pays off in dividends. Getting things right the first time will streamline your regulatory process, lower your labor costs, and prepare you for when things go awry at your hydropower project.

Knowing where to put your efforts in up front and where “good” truly is good enough is something a well-informed dam safety engineer can explain to you. We can guide you through the regulatory process, and help you develop a resilient, proactive dam safety program portfolio-wide.

5 places where the details matter

1. Public Safety Plans

It may be surprising that this is first on my list. But this part of the dam safety program can cost your organization millions of dollars if the public were to get hurt—or worse—on your project. Beyond the money is the emotional toll your employees will experience if their innocuous actions cause harm to someone downstream.

That being said, your Public Safety Plans need to be more robust than those of yesteryear. They should be actual plans complete with a project narrative, general maintenance schedule of your safety features (seasonal removal of buoys, signage), your outreach programs, an inventory of your safety features and the set of drawings that highlight where the features are (without any security information). Plans should have a dedicated section addressing the incidents on your project and the safety features that are in place to address those incidents. It might also be helpful for your team to have a catalog of all the incidents and have the plan act as a repository for all reportable incidents, likely in the appendix.

2. Security Plans

Regulators have spent significant resources in security, both physical and cyber, within the last 10 years. There is a reason for this. Security is essential to keeping your crew safe and the power on. Your Security Plans also need that upgrade. Like Public Safety Plans, it is no longer effective to have a generic Security Plan. Your plans should highlight what your organization will actually do based on the current threat level escalation, the phone numbers of the emergency responders your crew will call when there is an incident, and a depiction of where the security features are within any public safety information. Plans should have a dedicated section addressing the incidents on your project and can act as a repository for those incident reports. It should be a living document, open to continual updating.

3. Owner’s Dam Safety Program (ODSP) Documents

Every organization took its first stab at the ODSP circa 2012. Most got the familiar letters back asking for better resumes or more details in various sections. It has now been 10 years, and likely most organizations are in the second round of external audits. With this document in particular, the details matter. Stating you have a training program or that you are mindful of knowledge transfer is not enough information to highlight what your organization actually does. Include the details. What training programs do your engineers and operators attend upon hire, within the first year, and for annual maintenance? You should have a set program in place. What training does the board get? What information is mandatory for the annual “State of the Dams” address? Who exactly at the organization is responsible for what aspects of dam safety? What happens if that person is incapable of performing their duties—who is their backup? How does communication happen? Dig into the details. The better your plan, the better your program.

4. Construction Submittals

The Quality Control Inspection Plan (QCIP) and Temporary Construction Emergency Action Plan (TCEAP) are essential submittals for some construction projects. They are meant to ensure that your organization thinks through the details on how to get a quality product post-construction and amends the Emergency Action Plan (EAP) to allow for the construction activities. What typically happens is an organization has very robust quality control and emergency action processes that are not well-documented in the plans. Document what is being done, add the essential details, update those EAP flowcharts, and then look back and add more details if something is skipped. Having the details on paper will help your organization through any issue and through the approval process.

5. Part 12D Reports

These reports have gone through many updates over the years. What was once a few pages is now an encyclopedia. It is sometimes hard to understand what is going on during the regulatory approval process and even more daunting if the report is returned with a request for more information. Again, the details matter. See that your consultants show their work. What documents did they review, both before and after the inspection? This should be written into the report. What analysis did they proof? This should be documented. What did they see on their inspection? What was not seen? An inspector will either agree with the analysis of record or not—the reasoning for both needs to be included. Assume that the regulator was not there during the inspection document’s review and truly paint the picture of what happened. Why? Because while one or two inspectors may have been present for the inspection, not all the regulatory approvers were, and none of those regulators were present for your consultant’s deep dive into the details. Your consultant needs to show their work and back it up with their professional opinion on what is there.

At this point, you might be in detail overwhelm. We are here to help. As dam safety engineers, it’s part of our job to get the details right. It’s also our job to let you know when good is good enough. In this way, we hope to empower dam owners/operators with knowledge of the process they can use moving forward.

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