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Chap16 Part 12D Program

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

ENGINEERING GUIDELINES FOR THE


EVALUATION OF HYDROPOWER PROJECTS

CHAPTER 16 – PART 12D PROGRAM

DECEMBER 16, 2021


Revised March 29, 2023

FEDERAL ENERGY REGULATORY COMMISSION


888 First Street NE
Washington, DC 20426
Document Accession #: 20230329-3010 Filed Date: 03/29/2023

Revision Log
No. Date Description
1 3/29/2023 Revisions in Appendices B, C, D, and E to address
public comments (correcting a compilation error during
final preparation of the original issuance)

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TABLE OF CONTENTS

Abbreviations.................................................................................................................16-vi
Definitions ................................................................................................................... 16-vii
Preface ……………………………………………………………………………...16-viii
Introduction .......................................................................................................16-1
Purpose ..........................................................................................................16-1
Applicability ..................................................................................................16-1
History of the Part 12D Independent Consultant Inspection Program .......... 16-1
Structure of this Guideline.............................................................................16-1
Overview of the Part 12D ...............................................................................................16-2
Independent ....................................................................................................................16-2
Overview of the Part 12D Program ..................................................................16-3
Part 12D Inspection Timeline ........................................................................16-3
Typical Inspection Cycle ........................................................................16-4
Potential Variations to Inspection Cycle ................................................ 16-4
Waivers from 10-Year CA Requirement ................................................ 16-4
Initial Coordination Call ................................................................................16-5
Part 12D Inspection Plan ...............................................................................16-5
Second Coordination Call..............................................................................16-5
IC Team’s Pre-Inspection Preparation Report .............................................. 16-5
Part 12D Inspections and Reports .................................................................16-6
Periodic Inspection .................................................................................16-6
Comprehensive Assessment ...................................................................16-6
Owner’s Dam Safety Program Reviews ................................................. 16-7
Roles and Responsibilities .............................................................................16-7
Licensees .................................................................................................16-7
Independent Consultant(s) ......................................................................16-7
Facilitators ..............................................................................................16-8
FERC Dam Safety Personnel..................................................................16-8
Independent Consultants, Independent Consultant Teams, and Part 12D
Inspection Plans ............................................................................................................16-11
Background ..................................................................................................16-11
Independent Consultant and Supporting Team Member Requirements ..... 16-11
Professional Licensure ..........................................................................16-11
Dam Design and Construction Experience ........................................... 16-11
Relationship with Licensee ...................................................................16-11
Part 12D Inspection Plans............................................................................16-14
Content of the Part 12D Inspection Plan .............................................. 16-15
IC Team Proposals ................................................................................16-15
Proposed Part 12D Schedule ................................................................ 16-21
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Time to Submit the Part 12D Inspection Plan ...................................... 16-21


FERC Review and Approval of Part 12D Inspection Plans ................. 16-21
Pre-Inspection Preparation Reports ................................................................ 16-30
Purpose ........................................................................................................16-30
Required Documentation in the PIPR ......................................................... 16-30
Additional Information Required from the Licensee .................................. 16-31
Periodic Inspections ........................................................................................16-32
General.........................................................................................................16-32
Review of Prior Reports ..............................................................................16-32
Observations and Evaluations of Performance............................................ 16-33
Physical Field Inspection ......................................................................16-33
Review of Instrumentation Data and Surveillance Reports.................. 16-35
Review and Evaluation of Dam and Public Safety Programs ..................... 16-37
Owner’s Dam Safety Program .............................................................. 16-37
Performance Monitoring Program (Surveillance and Monitoring) ...... 16-37
Hazard Potential Classification............................................................. 16-38
Emergency Action Plan ........................................................................16-39
Public Safety Plan .................................................................................16-39
Operations and Maintenance Programs ................................................ 16-40
Additional Information for the PIR ............................................................. 16-41
Summary of Findings............................................................................16-41
Recommendations .................................................................................16-41
Project Description ...............................................................................16-41
Changes Since the Previous Part 12D Report....................................... 16-42
Comprehensive Assessments ..........................................................................16-44
General.........................................................................................................16-44
Review of Prior Reports ..............................................................................16-44
Review and Evaluation of Design Basis and Construction ......................... 16-45
General ..................................................................................................16-45
Documenting the Review......................................................................16-46
Review and Evaluation of Previous Analyses ............................................. 16-47
General ..................................................................................................16-47
Evaluation Requirements ......................................................................16-47
Documenting the Review......................................................................16-50
Review of the STID and Digital Project Archive (DPA) ............................ 16-56
General ..................................................................................................16-56
Documenting the Review......................................................................16-56
Potential Failure Modes Analysis and Risk Analysis ................................. 16-57
General ..................................................................................................16-57
Potential Failure Modes Analysis ......................................................... 16-57
Risk Analysis ........................................................................................16-58
Requirements for Review and Evaluation ............................................ 16-58

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Observations and Evaluations of Performance............................................ 16-59


Physical Field Inspection ......................................................................16-60
Review of Instrumentation Data and Surveillance Reports.................. 16-63
Review and Evaluation of Dam and Public Safety Programs ..................... 16-64
Owner’s Dam Safety Program .............................................................. 16-64
Performance Monitoring Program (Surveillance and Monitoring) ...... 16-65
Hazard Potential Classification............................................................. 16-65
Emergency Action Plan ........................................................................16-66
Public Safety Plan .................................................................................16-67
Operations and Maintenance Programs ................................................ 16-67
Evaluation of Spillway Adequacy ............................................................... 16-68
General ..................................................................................................16-68
Conditions Affecting Spillway Capacity .............................................. 16-68
Consequences of Inadequate Capacity ................................................. 16-70
Documenting the Review......................................................................16-71
Additional Information for the CAR ........................................................... 16-71
Summary of Findings ...........................................................................16-71
Risk Analysis and Dam Safety Risk Classification (DSRC) ................ 16-71
Recommendations .................................................................................16-72
Project Description ...............................................................................16-73
Changes Since the Previous Part 12D Report....................................... 16-73
Follow-up and Corrective Measures ............................................................... 16-75
General.........................................................................................................16-75
No Action and Alternatives .........................................................................16-75
Emergency Corrective Measures .................................................................16-76
Periodic Updates ..........................................................................................16-76
Comprehensive Assessment Review Meeting............................................. 16-77
References .......................................................................................................16-79
Appendix 16-A Outline for the Part 12D Inspection Plan ........................................ 16-A-1
Appendix 16-B Outline for the Periodic Inspection Report .......................................16-B-1
Appendix 16-C Outline for the PI Pre-Inspection Preparation Report ...................... 16-C-1
Appendix 16-D Outline for the Comprehensive Assessment Report........................ 16-D-1
Appendix 16-E Outline for the CA Pre-Inspection Preparation Report..................... 16-E-1
Appendix 16-F Outline for the CA Review Meeting Presentation ............................ 16-F-1

LIST OF TABLES

Table 1: Sections of this Guideline Relevant to a PI or CA ........................................... 16-2


Table 2: Typical Timeline, Periodic Inspection ............................................................. 16-9
Table 3: Typical Timeline, Comprehensive Assessment ............................................. 16-10

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Table 4: IC and IC Team Member Requirements ........................................................ 16-11


Table 5: IC Team Composition for Part 12D Inspection Plan (EXAMPLE)............... 16-18
Table 6: Roles and Responsibilities of Key Part 12D Positions .................................. 16-19
Table 7: Technical Expertise Considerations (EXAMPLE) ........................................ 16-23
Table 8: Selected Technical Disciplines and Review Elements by Type of Project Feature
(EXAMPLES) ..............................................................................................................16-25
Table 9: Pre-Inspection Preparation Report Requirements .......................................... 16-31
Table 10: IC Team Composition for PIPR Transmittal Letter (EXAMPLE) .............. 16-31
Table 11: Analysis of Record Review Calculations (EXAMPLE) .............................. 16-50
Table 12: Suggested Format for Tracking IC Team Recommendations ...................... 16-76
Table 13: Typical Comprehensive Assessment Review Meeting Agenda................... 16-77

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ABBREVIATIONS
CA Comprehensive Assessment
CAR Comprehensive Assessment Report
CFR Code of Federal Regulations
Commission Federal Energy Regulatory Commission
D2SI Division of Dam Safety and Inspections
DSPMP Dam Safety Performance Monitoring Program
DSSMP Dam Safety Surveillance and Monitoring Plan
DSSMR Dam Safety Surveillance and Monitoring Report
EAP Emergency Action Plan
FAAP FERC After Action Panel
FERC Federal Energy Regulatory Commission
FERC-RO Regional Office (of the FERC, D2SI)
FERC-WO Washington Office (of the FERC, D2SI)
FPC Federal Power Commission
Guidelines FERC Engineering Guidelines for the Evaluation of Hydropower
Projects
IC Independent Consultant
IC Team Independent Consultant Team
IDF Inflow Design Flood
IFT Independent Forensic Team
Part 12D 18 CFR Part 12, Subpart D
PFM Potential Failure Mode
PFMA Potential Failure Modes Analysis
PI Periodic Inspection
PIR Periodic Inspection Report
PIPR Pre-Inspection Preparation Report
PMF Probable Maximum Flood
PMP Probable Maximum Precipitation
RA Risk Analysis
RAR Risk Analysis Report
STID Supporting Technical Information Document

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DEFINITIONS
Part 12D Inspection: an inspection performed to fulfill the requirements for an inspection
by an Independent Consultant, as defined in 18 CFR § 12.31(a). This term may refer to
either a Periodic Inspection (PI), Comprehensive Assessment (CA), or an inspection
conducted in accordance with the rules established by Federal Power Commission (FPC)
Order 315 or Federal Energy Regulatory Commission (FERC) Order 122. Whether the
term “Part 12D Inspection” refers to a PI, a CA, or inspection in accordance with the
rules established by FPC Order 315 or FERC Order 122 can be determined from the
context in which it is used.

Part 12D Report: the report on a Part 12D Inspection (i.e., a Comprehensive Assessment
Report, a Periodic Inspection Report, or a report on an inspection in accordance with the
rules established by FPC Order 315 or FERC Order 122).

Note: all references to "Licensee" in this chapter are also applicable to Exemptees.

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PREFACE
Prior to the issuance of this chapter of the Guidelines, FERC-issued guidance related to
the performance of Part 12D Inspections was limited in scope and detail. The majority of
the information was provided as an appendix to Chapter 14 and in the project-specific
Part 12D Inspection reminder letter from the D2SI-Regional Engineer to the licensee.
This chapter consolidates and expands on that information and incorporates several
findings and recommendations of the Oroville Independent Forensic Team (IFT) and
FERC After-Action Panel (FAAP).

The FERC strongly recommends that all parties involved in dam safety read the Oroville
IFT and FAAP Reports in their entirety and carefully consider their contents and lessons
learned. Both reports are available on the FERC website. Several passages from each
have been reproduced below (emphasis added) along with commentary on the D2SI
interpretation and application of these comments in enhancing the Part 12D Program.

Need for Comprehensive Reviews


Both the IFT and the FAAP identified issues regarding the general understanding of the
scope of a Part 12D Inspection:

Periodic comprehensive reviews of original design and construction and


subsequent performance are imperative. These reviews should be based on
complete records and need to be more in-depth than periodic general reviews,
such as the current FERC-mandated five-year reviews. 1

…the Part 12D regulations and other published guidance from FERC have
been somewhat ambiguous regarding whether the Part 12D reports were
intended to be ‘updates’ on changes since the prior five-year report, versus
relatively comprehensive reviews of the facilities which evaluated their design,
construction, condition, and performance history relative to current states of the
practice. 2

…certain aspects of [Oroville Part 12D] reviews were treated as merely


updates of existing information, rather than an independent checking of facts
and a thorough review of available information and analyses… 3

This chapter of the Guidelines clearly states that each Part 12D Inspection and Part 12D
Report is to be an independent assessment. It is not permitted to rely entirely on previous

1
IFT Report, page S-3.
2
IFT Report, page K2-5.
3
FAAP Report, page 30.
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interpretations; critical evaluation is required and must be thoroughly documented for


each Part 12D Inspection.

Importance of Reviewing Original Design and Construction Records, Analyses of


Record, Comparing to Current Practices, and Performing Independent Calculations
Both the IFT and FAAP identified several instances in which there was an apparent lack
of critical information due to a reliance on summaries of information – in the Supporting
Technical Information Document (STID), Potential Failure Modes Analysis (PFMA),
Part 12D Report, or elsewhere – that mischaracterized the original content, even by
something as simple as the omission of two introductory words. The deference to
summaries and lack of review of original documents contributed to an overestimation of
the resiliency of the Oroville spillway structure:

Although the poor foundation conditions at both spillways were well


documented in geology reports, these conditions were not properly addressed
in the original design and construction, and all subsequent reviews
mischaracterized the foundation as good quality rock. 4

Similarly, the FAAP noted the following with respect to the implementation of the Part
12D program with respect to Oroville Dam:

There was an overall lack of rigor in the performance of the Part 12 review
and their follow up. Too much emphasis seems to have been placed on the
process and not enough on detailed engineering reviews aimed at understanding
the performance of critical structures. 5

The FAAP provided examples of this, including: 6

• an “over reliance on previous analyses without reviewing whether such analyses


were appropriately representative and used tools and methods that would satisfy
current (at the time of evaluation) state of the art”
• and “the apparent contradiction between the poor geology actually mapped
along the spillway chute during construction, and the statements in the Part 12
and PFMA reports that the rock along the spillway chute was very
competent.”
Both the IFT and FAAP commented on the need to perform a comprehensive review of
the design and construction, with comparison to as-built conditions and current best
practices:

4
IFT Report, page S-2.
5
FAAP Report, page 41.
6
FAAP Report, page 41.
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The IFT believes that comprehensive and detailed reviews of older designs against
current best practices for design and construction are required. 7

FERC Engineering Guidelines for the Part 12 process specifically dictate that the
IC should review all available analyses and determine as to whether or not the
summary of those analyses contained in the STID are accurate and sufficient for
use by the owner during operation of the project. Apparently, no efforts were
made to review original design calculations and intent and compare them with
as built conditions, opting instead to accept past Part 12 descriptions and
summary of results as adequate. The FAAP notes that this was apparently also
the case at Wanapum Dam in Washington state a few years ago. 8

In the case of Wanapum Dam, a simple hand calculation, whether completed by the
licensee, IC, or the FERC, could have been able to identify the lift line stability issue and
allow it to be addressed before progressing to the point of permanent displacement.

The regulations incorporate these enhancements recommended by the IFT and FAAP.

Surveillance and Monitoring Data and Operations and Maintenance Programs


Both the IFT and the FAAP noted the high flows from Oroville spillway chute drains and
repeated repairs of herringbone cracks in the slab, and expressed concern that these
observations were never treated as indicative of adverse performance. Instead, conditions
that should have been considered as unexpected behavior became the accepted condition
due to repeated occurrence and lack of adverse consequence.

This concept has been referred to as the “normalization of deviance,” which the IFT
noted “was being perpetuated by blindly building on previous reports.” 9 The FAAP
Report noted that there was a “lack of urgency/concern about the very large outflows
from the spillway chute drains throughout its operational life.” 10

The following passage further illustrates this point:

…physical inspections are typically visual inspections from accessible locations


and do not directly provide insight into latent conditions which cannot be detected
by visual inspection. For the Oroville Dam service spillway, the observed slab
cracking and the drain flows had become accepted by DWR, DSOD, FERC, and
external consultants as “normal” conditions, and the slab details which increased
its vulnerability to failure went unnoticed. As long as the physical inspections

7
IFT Report, page F2-14.
8
FAAP Report, pages 30-31.
9
IFT Report, page F2-14
10
FAAP Report, page 41.
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revealed no detected change in the observed conditions, no concerns were


identified. 11

In addition, the IFT noted that the owner had performed repairs to the spillway chute
multiple times with varying degrees of success. In some cases, the repairs were not
coordinated with regulators in advance, so there was less of an opportunity to review the
underlying causes that necessitated the repairs.

The repairs which deteriorated in as little as a few years after completion posed
risks of increasing leakage into the foundations, increasing uplift pressures, and
possibly creating vertical projections into the flow at spalls… it was not
understood that development of deterioration of concrete in new areas, not just in
previously repaired areas, was an indication of… continued degradation of the
condition of the slab.

The chute repairs which DWR performed in 2009 and 2013 were viewed as
“routine maintenance” and not submitted to the regulators for review and
approval. 12

All parties involved in Part 12D Inspections must make a conscious effort to ensure they
are not perpetuating mistaken assumptions or incorrect interpretations of information.
Each inspection requires a detailed, independent review and evaluation of information.

Importance of Potential Failure Modes Analysis and Risk Analysis


The Oroville IFT noted that “shortcomings of the current [PFMA] processes in dealing
with complex systems must be recognized and addressed. A critical review of these
processes in dam safety is warranted.” 13 Similarly, the FAAP noted that:

A contributing factor was an apparent lack of recognition and appreciation of


the probability and consequences (i.e., risk) in the evaluation of the FCO
[flood control outlet] chute and ES [emergency spillway] failure modes and a
lack of rigor in reviewing existing project documents…the potential failure of
the FCO chute was dismissed due to an assumed low probability of
occurrence because it was founded ‘on solid rock’, although construction data,
including photographs, documented the presence of shear zones and erodible clay
material below the chute slab. Similarly, the potential for failure of the
Emergency Spillway and the impact of potential erosion was repeatedly
dismissed outright, based on the assumption that this structure would be used

11
IFT Report, page 75.
12
IFT Report, pages 52-53.
13
IFT Report, page S-2.
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only in the rarest of circumstances (i.e., very low probability) but not necessarily a
low risk event, as amply demonstrated. 14

The regulations formally incorporate a PFMA and Risk Analysis into the scope of a
Comprehensive Assessment (CA), and this chapter of the Guidelines provides details
with respect to the performance of those activities during a CA.

14
FAAP Report, pages 42-43.
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INTRODUCTION

Purpose
The purpose of this chapter of the Engineering Guidelines for the Evaluation of
Hydropower Projects is to establish the expectations associated with the performance of
Periodic Inspections (PIs) and Comprehensive Assessments (CAs), and the contents and
format of reports thereon. This Guideline assumes that the reader has an understanding of
the regulations that establish the Commission’s program for inspections by an
Independent Consultant (IC).

Applicability
The guidance in this chapter is applicable to any Periodic Inspection or Comprehensive
Assessment performed, and the report on it filed, to fulfill the requirements defined in
Title 18 Code of Federal Regulations (CFR) Part 12, Subpart D.

History of the Part 12D Independent Consultant Inspection Program


FPC Order 315
The Part 12D Independent Consultant inspection program began in 1965 after Federal
Power Commission (FPC) Order 315. The initial reports were relatively short and in
many cases reiterated the design basis. Subsequent reports mostly repeated or referenced
information contained in previous reports.

FERC Order 122


As part of the reorganization of the Department of Energy in 1977, the Federal Energy
Regulatory Commission was chartered and replaced the FPC. In 1981, FERC Order 122
superseded FPC Order 315 and revised the procedures related to Independent Consultant
inspections. Subsequent enhancements to the program included the addition of a Potential
Failure Modes Analysis (PFMA) and development of the Supporting Technical
Information Document (STID) in the early 2000s.

FERC Order 880


With respect to subpart D of the Commission’s part 12 regulations, FERC Order 880
superseded FERC Order 122 and established new requirements for Part 12D Inspections.
This chapter was developed to provide context and additional details regarding the Part
12D Program.

Structure of this Guideline


This Guideline has been structured so a person interested in the requirements for a PI
does not have to refer to sections related strictly to a CA (and vice versa). While this
resulted in some redundancy in the Guideline, since there is some overlap between the
two types of inspections, it was intentional for the purpose of usability. Table 1 indicates

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the portions of the Guideline that contain information relevant to each type of inspection
(PI or CA).

In addition, please note that Appendices 16-B, 16-C, 16-D, and 16-E are outlines for the
four major types of reports that must be submitted. The outlines contain brief reminders
of the information to be provided in each section. Detailed descriptions of the purpose
and contents of each report are provided in Sections 16-5 and 16-6; the IC Team should
refer to those sections while preparing a report to ensure they meet the intent.

Table 1: Sections of this Guideline Relevant to a PI or CA


Periodic Comprehensive
Section/Appendix Topic Inspection Assessment
Section 16-2 OVERVIEW OF THE PART
X X
12D Program
Section 16-3 Independent Consultants,
Independent Consultant Teams, X X
and Part 12D Inspection Plans
Section 16-4 Pre-Inspection Preparation
X X
Reports
Section 16-5 Periodic Inspections X
Section 16-6 Comprehensive Assessments X
Section 16-7 Follow-up and Corrective
X X
Measures
Outline for the Part 12D
Appendix 16-A X X
Inspection Plan
Appendix 16-B Outline for the Periodic Inspection
X
Report
Appendix 16-C Outline for the PI Pre-Inspection
X
Preparation Report
Appendix 16-D Outline for the Comprehensive
X
Assessment Report
Appendix 16-E Outline for the CA Pre-Inspection
X
Preparation Report
Appendix 16-F Outline for the CA Review
X
Meeting Presentation

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OVERVIEW OF THE PART 12D PROGRAM


This section provides a general overview of the FERC’s Part 12D Inspection Program.
Projects are subject to the requirements of 18 CFR Part 12, Subpart D based on the
applicability defined in §12.30, which includes any licensed project development that:

(a) Has a dam


(1) That is more than 32.8 feet (10 meters) in height above streambed, as defined
in §12.31(c); or
(2) With an impoundment gross storage capacity of more than 2,000 acre-feet (2.5
million cubic meters), as defined in §12.31(d);
(b) That has a project work (dam or water conveyance) or any portion thereof that has a
high hazard potential, as defined in §12.3(b)(13)(i); or
(c) Is determined by the Regional Engineer or other authorized Commission
representative to require inspection by an independent consultant under this subpart.

Provisions for exemption from these requirements are provided in 18 CFR § 12.33, and
require the licensee to submit a request and justification for an exemption to the Director,
D2SI, who may grant the exemption at their discretion. The Director also has the
authority to rescind previous exemptions and require additional work, such as a CA,
before considering a further request.

Part 12D Inspection Timeline


Table 2 and Table 3, which are included at the end of this section, show the typical
timelines for a PI and a CA, respectively. In each of the tables, the left column shows
tasks or submittals that are the licensee’s responsibility; the right column shows those
that are the Commission’s responsibility; and the middle shows the due date or
approximate timing.

For the purposes of this Guideline, the phrase “first IC Team activity” typically refers to a
PFMA, risk analysis, or site/field inspection, though there might be limited situations in
which another major activity requires the participation of the complete IC Team, licensee
staff, and FERC staff. The Second Coordination Call is not considered an “IC Team
activity.”

Note that the Part 12D Inspection Plan should be submitted to the FERC-WO
(Washington Office) and addressed to the Director of D2SI. All other items shown in the
tables should be submitted to the D2SI Regional Office, addressed to the Regional
Engineer.

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Typical Inspection Cycle


As described in 18 CFR § 12.40, a CA is typically due once every ten years. A PI is
typically due five years after a CA. This maintains the five-year interval for a Part 12D
inspection that existed prior to Commission Order 880.

The sequential numbering of Part 12D Inspections must be maintained – for example, a
project that had its Seventh Part 12D Inspection in 2017 would have its Eighth Part 12D
Inspection, either a PI or a CA, in 2022.

Potential Variations to Inspection Cycle


There may be cases where a project is subject to a Part 12D inspection more often or less
often than once per five years. Some situations that may result in variations to the typical
cycle include:

• During the initial implementation of the 2022 revisions to the Part 12D program;
• At the request of the licensee due to workload balance, major studies or
remediation designs subject to a Board of Consultants review, etc.; or
• During or following a major dam safety incident.
Any licensee requesting a variation to the typical cycle must submit a request to the D2SI
Regional Engineer. No variation may take effect without the written authorization of the
D2SI Regional Engineer.

Waivers from 10-Year CA Requirement


Depending on the facts and conditions associated with a project – including the hazard
potential, risk, and the reason it is subject to the Part 12D Program – the Regional
Engineer may grant a waiver from the requirement that a CA be performed once every
ten years. This will be evaluated on a case-by-case basis by the Regional Engineer, in
consultation with the Director, D2SI. Any requests by a licensee to obtain a blanket
waiver from performing a Comprehensive Assessment, without having performed
one previously to provide a full understanding of the project, will not be considered.
Any such request must be made in writing, provide clear and complete justification for
the waiver request, and include the proposed frequency for performing Comprehensive
Assessments in the future.

The FERC understands that some projects subject to the Part 12D Program based on dam
height or impoundment volume might have extremely low life safety consequences (i.e.,
are classified as having a Low or Significant hazard potential). For such projects,
performing CAs on a ten-year cycle may not be necessary; however, the FERC does not
intend to provide a waiver modifying the typical CA cycle without the full understanding
provided by the initial CA. For example, a remote project could have previously
unrecognized non-life safety consequences, such as the criticality of power generation to

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the local community, which could be revealed by the initial CA. However, a CA
frequency of once every 15 or 20 years may be justifiable for such a project.

Initial Coordination Call


After issuance of the Part 12D Inspection Reminder Letter, the D2SI-Regional Office
(D2SI-RO) will schedule the Initial Coordination Call with licensee staff. The purpose of
this call is to discuss general information about the Part 12D Inspection process,
including the scope of the inspection to be performed (PI or CA). Licensee staff will have
the opportunity to ask questions and clarifications that might help them scope contracting
documents (e.g., a Request for Proposal).

Part 12D Inspection Plan


As required by 18 CFR § 12.34(b), Licensees must submit a detailed Part 12D Inspection
Plan that describes the scope of the inspection, proposes an Independent Consultant
Team, and establishes the proposed schedule. Details regarding the Part 12D Inspection
Plan are provided in Section 16-3.

Independent Consultant Team (IC Team)


The Part 12D Inspection Plan must include the proposed Independent Consultants and
other roles required for the project and type of Part 12D Inspection being performed.
Collectively, the ICs and supporting team members are referred to as the IC Team.

Second Coordination Call


After D2SI-WO has responded to the Part 12D Inspection Plan, the D2SI-RO will initiate
the Second Coordination Call with the licensee, who should arrange for the IC Team’s
participation in the call. The purpose of the call is to ensure that all parties know their
roles and responsibilities for the scheduled IC Team activities. The call also serves as an
opportunity to discuss project-specific concerns that might help guide IC Team review of
supporting documents, planning for special access during the field inspection, etc.

IC Team’s Pre-Inspection Preparation Report


As required by 18 CFR § 12.42, the IC Team must prepare a Pre-Inspection Preparation
Report (PIPR) (also known as a preliminary report) to document their initial findings
from their review of project documentation (including the STID), instrumentation data,
and other information prior to the first IC Team activity (i.e., the field inspection, PFMA,
or risk analysis, as applicable). Details regarding the scope and content of the PIPR are
included in Section 16-4. The format of the PIPR generally follows that of the
corresponding Part 12D Inspection Report.

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Part 12D Inspections and Reports

Periodic Inspection
The PI is a performance-focused evaluation that includes, but is not limited to, the
following components:

• A review of relevant background material, including the STID, so the IC Team has
a full understanding of the project being inspected;
• A field inspection and review of instrumentation data and surveillance reports;
• Evaluation of project performance with respect to PFMs; and
• A review and evaluation of other dam safety program elements.
An outline is provided for the Periodic Inspection Report (PIR) and the Periodic
Inspection Pre-Inspection Preparation Report (PI-PIPR). Additional information
regarding the scope of a PI is provided in Section 16-5.

Comprehensive Assessment
The CA is an in-depth evaluation of a project, including (but not limited to) the following
components:

• A review of relevant background material so the IC Team has a full understanding


of the project being inspected;
• A detailed review and evaluation of the STID, reference documents, design basis,
construction, and analyses of record, which may require supporting independent
calculations;
• A field inspection and review of instrumentation data and surveillance reports;
• An evaluation of project performance with respect to PFMs;
• A review and evaluation of other dam safety program elements;
• A PFMA; and
• A Risk Analysis.
An outline is provided for the Comprehensive Assessment Report (CAR) and the
Comprehensive Assessment Pre-Inspection Preparation Report (CA-PIPR). Additional
information regarding the scope of a CA is provided in Section 16-6.

Comprehensive Assessment Review Meeting


Following submittal of a CAR, the IC Team should arrange a review meeting and
presentation for FERC and licensee staff, either in person or via teleconference/webinar.
The purpose of this meeting is for the IC Team to present the findings and

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recommendations contained in the CAR. Additional information about the scope of the
meeting and the required attendees is provided in Section 16-7.5.

Owner’s Dam Safety Program Reviews


Both a PI and CA include a review of the Owner’s Dam Safety Program (ODSP) and
discussion of its implementation with respect to the project being inspected. As discussed
later in this Guideline, the scope of the ODSP review during a PI or CA is not
intended to be equivalent to an independent external audit or peer review. Some
licensees, particularly those with a small number of projects, may determine that there are
benefits to incorporating an external audit or peer review in the scope of a Part 12D
Inspection. This is a permissible option but should be included in the Part 12D Inspection
Plan and accepted by the FERC. The external audit or peer review would have to be
performed and documented consistent with other guidance.

Roles and Responsibilities

Licensees
The licensee has the primary responsibility for scheduling and coordinating with the
FERC, the IC(s), and IC Team, including submitting the Part 12D Inspection Plan to the
FERC in a timely manner. The licensee must arrange for all relevant personnel to be
available for the field inspection, PFMA, risk analysis, and any other special inspections
and meetings that may be required. In addition, the licensee must provide adequate
meeting space for the PFMA and risk analysis and ensure that all necessary information
is available and accessible for all parties to review in advance.

While licensees contract with and retain the services of the IC Team for the work
associated with a Part 12D inspection, the IC Team must have sufficient freedom such
that they can complete an independent review and assessment. Licensees may freely
communicate and coordinate with their IC Team but must be careful not to attempt to
influence the conclusions or recommendations of the IC Team. The IC Team must
document any requests by licensee staff to modify or eliminate any conclusions or
recommendations prior to finalization of the Part 12D Report.

Independent Consultant(s)
One or more designated Independent Consultant(s) are responsible for signing and
sealing (stamping) the final PIR or CAR. They should take a lead role in the IC Team and
should contribute extensive dam-related experience. When an IC Team includes more
than one IC, it may be beneficial to designate one of them as a Lead IC for organizational
and communication purposes, though this is not required.

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Facilitators
A facilitator is required for a PFMA and risk analysis workshop and will fulfill the duties
of the role as described in Chapters 17 and 18 of the Guidelines, respectively. While a
facilitator(s) may or may not serve other roles as part of the IC Team, their role is
important to the successful execution of the PFMA and risk analysis. Therefore, the
FERC requires any facilitator(s) to be identified and approved in advance.

FERC Dam Safety Personnel


FERC dam safety personnel will provide guidance and clarification on the expectations
of the Part 12D process beginning with the reminder letter to the licensee, continuing
with the pre-inspection coordination calls, and during any PFMA and risk analysis
sessions. During the field inspection, FERC personnel will typically perform their dam
safety inspection alongside the IC Team and licensee personnel.

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Table 2: Typical Timeline, Periodic Inspection


Licensee Activity Approximate Time FERC Activity
FERC-RO Issues Part 12D
18 months before PIR due date
Reminder Letter
FERC-RO holds Initial
Participates in Initial Coordination Within 30 days after Reminder
Coordination Call with
Call Letter is issued
Licensee
Licensee develops the scope of work, identifies the required disciplines for the IC Team,
and identifies one or more people to serve as the IC(s)
Submit Part 12D Inspection Plan At least 6 months in advance of the
to FERC-WO first IC Team activity
Within ~30 days after submission FERC-WO responds to
of the Part 12D Inspection Plan Part 12D Inspection Plan
Within 6 weeks after Approval (or FERC-RO holds Second
Participates in Second
Conditional Approval) of the Coordination Call with
Coordination Call
Part 12D Inspection Plan Licensee and IC Team
IC Team performs their review of existing information,
prepares the PI-PIPR, and provides it to the Licensee
At least 30 days prior to the field
Submit PI-PIPR to FERC-RO
inspection
Within 2 weeks after submittal of FERC-RO Responds to the
the PI-PIPR PI-PIPR
Date(s) previously coordinated
Site Inspection Attends Site Inspection
with all parties in advance
IC Team prepares the PIR and provides it to the Licensee
Due Date as stated in the Part 12D
Submit PIR to FERC-RO
Reminder Letter
Submit Plan and Schedule to
Within 60 days after submitting the
address IC Recommendations to
PIR
FERC-RO
FERC reviews the PIR
FERC-RO responds to the
PIR
Bold text indicates an item that will be submitted to or issued by the FERC.
Italicized text indicates an in-person or teleconference activity.
Underlined text that spans across all three columns represents an activity, either by the Licensee, IC Team, or the
FERC, that does not require formal communication or coordination.

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Table 3: Typical Timeline, Comprehensive Assessment


Licensee Activity Approximate Time FERC Activity
FERC-RO Issues Part 12D
18 months before CAR due date
Reminder Letter
FERC-RO holds Initial
Participates in Initial Coordination Within 30 days after Reminder
Coordination Call with
Call Letter is issued
Licensee
Licensee develops the scope of work, identifies the required disciplines for the IC Team,
and identifies one or more people to serve as the IC(s) and facilitator(s), as needed
Submit Part 12D Inspection Plan At least 6 months in advance of the
to FERC-WO first IC Team activity
Within 30 days after submission of FERC-WO responds to
the Part 12D Inspection Plan Part 12D Inspection Plan
Within 6 weeks after Approval (or FERC-RO holds Second
Participates in Second
Conditional Approval) of the Part Coordination Call with
Coordination Call
12D Inspection Plan Licensee and IC Team
IC Team performs their review of existing information,
prepares the CA-PIPR, and provides it to the Licensee
At least 30 days prior to the first IC
Submit CA-PIPR to FERC-RO
Team activity
Within 2 weeks after submittal of FERC-RO Responds to the
the CA-PIPR CA-PIPR
Site Inspection Attends Site Inspection
Date(s) previously coordinated
PFMA Attends PFMA
with all parties in advance
Level 2 Risk Analysis Attends Level 2 Risk Analysis
IC Team prepares the CAR and provides it to the Licensee
Due Date as stated in the Part 12D
Submit CAR to FERC-RO
Reminder Letter
Submit CAR Review Meeting At least 7 days prior to the CAR
Presentation to FERC-RO Review Meeting
Within 60 days after submitting the
CAR Review Meeting Attends CAR Review Meeting
CAR
Submit Plan and Schedule to
Within 60 days after submitting the
address IC Recommendations to
CAR
FERC-RO
FERC reviews the CAR
FERC-RO responds to the
CAR
Bold text indicates an item that will be submitted to or issued by the FERC.
Italicized text indicates an in-person or teleconference activity.
Underlined text that spans across all three columns represents an activity, either by the Licensee, IC Team, or the
FERC, that does not require formal communication or coordination.

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INDEPENDENT CONSULTANTS, INDEPENDENT CONSULTANT


TEAMS, AND PART 12D INSPECTION PLANS

Background
The regulations establish specific requirements of an Independent Consultant (IC),
including professional licensure, a minimum of ten years of experience, and not being an
employee or agent of the licensee or its affiliates. This section elaborates on those
requirements, which are provided in 18 CFR § 12.31(a).

This section also discusses the requirements of the Part 12D Inspection Plan, which
includes the names and resumes of the IC(s); and the requirements of the IC Team, which
is defined in 18 CFR § 12.31(b).

Independent Consultant and Supporting Team Member Requirements


The basic requirements for an IC are set forth in 18 CFR § 12.31(a) and include three
general categories of requirements which are identified in Table 4 and described in more
detail below.

Table 4: IC and IC Team Member Requirements


Category CFR Reference Applicability
Professional Licensure 12.31(a)(1) IC(s) only
Minimum Experience 12.31(a)(2) IC(s) only
Relationship with Licensee 12.31(a)(3) through (5) All members of the IC Team

Professional Licensure
18 CFR § 12.31(a)(1) requires that the IC(s) who will sign and seal the report be a
licensed professional engineer(s). The IC(s) should be licensed in the state(s) in which the
project is located.

Note that the FERC does not stipulate the type of engineering license (e.g., civil,
mechanical, structural, etc.) required since state definitions and requirements vary and
persons from various backgrounds may be able to demonstrate the experience and
qualifications discussed in the next section.

Dam Design and Construction Experience


IC(s) must have a minimum of ten years of experience in dam design and construction,
and in the evaluation and assessment of the safety of existing dams. This experience must
be demonstrated in a detailed resume (discussed subsequently in this Guideline).

Relationship with Licensee


18 CFR § 12.31(a)(3) through § 12.31(a)(5) place three limiting conditions on who may
serve as an IC or supporting team member based on the current or previous working

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relationships between the proposed individual and the licensee or its affiliates. Two of
these conditions are self-explanatory:

• A current employee of the licensee or its affiliates cannot serve as an IC or


supporting team member; and
• A person who was an employee of the licensee or its affiliates within the previous
two years cannot serve as an IC or supporting team member. This period is
measured from the date of termination of employment to the date the proposed
individual will begin performing any work as part of the IC Team on behalf of the
licensee, including preparatory review for an inspection. If necessary, an IC Team
proposal should clearly identify the dates of termination of prior employment and
start of IC Team services.
The third limiting condition, provided in 18 CFR § 12.31(a)(5), requires review and
evaluation by the FERC on a case-by-case basis to determine the extent of the
relationship between the proposed individual and the licensee or its affiliates, and
whether any restrictions are warranted. The intent of this restriction is to prevent an IC
Team member from reviewing their own work. If there is a situation that could disqualify
an IC Team member under 18 CFR § 12.31(a)(5), it is the licensee’s responsibility to
demonstrate, in the Part 12D Inspection Plan, that any potential conflict of interest will be
avoided.

The following paragraphs provide some examples and how the FERC may consider
them.

Licensees with a contracted Chief Dam Safety Engineer (CDSE)


Some licensees choose to retain the services of a consultant or consulting firm to fill the
role of CDSE instead of having a CDSE on staff. In no case will a consultant serving as
CDSE for a project be approved as an IC or supporting team member for the same
project, nor will any other individual from the same consulting firm.

Licensees with a Chief Dam Safety Coordinator (CDSC)


Licensees who have a CDSC instead of a CDSE are required to retain the services of a
consultant or a consulting firm to provide dam safety engineering services. In no case
will a consultant or consulting firm providing such services for a project be
approved as an IC or supporting team member for the same project.

Consecutive Inspections
To help ensure that projects are inspected periodically by persons with a fresh perspective
and different professional experience:

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• No person will be approved as an IC, or as a supporting team member with the


same role/responsibility, for more than two consecutive Part 12D Inspections for a
given project.
• No person will be approved as an IC, or as a supporting team member with the
same role/responsibility, for consecutive CAs for a given project.
A person may be approved as an IC, or as a supporting team member with the same
role/responsibility, for consecutive PIs for a given project, provided that such approval
would not violate the first bullet (above).

The restrictions above may also be applied to consulting firms; it would be inappropriate
for Firm A to perform consecutive CAs or more than two consecutive Part 12D
Inspections for a given project.

PI Following a CA
A person who served as an IC or supporting team member for a CA will most likely be
eligible to serve as an IC or supporting team member for the subsequent PI (subject to the
limitation of not performing more than two consecutive Part 12D inspections). There
could be significant benefits to this, as the person would already be familiar with the
project from performance of the CA.

It is possible that, after a CA, the licensee will need to complete engineering studies or
analyses to evaluate PFMs or address IC Team recommendations contained in the CAR.
Licensees may be inclined to retain the IC, supporting team members, or their consulting
firm to perform those studies. If the licensee proposes those same people as the IC Team
for the subsequent PI, on first impression it would appear to be a violation of 18 CFR
§ 12.31(a)(5), as completing those engineering studies would make the IC “an agent
acting on behalf of the licensee or its affiliates.”

It is important to remember the intent of this limitation. The scope of a PI does not
include an in-depth review and evaluation of the analyses of record or other studies.
Thus, the work performed would most likely not represent a conflict of interest and
would not disqualify those individuals from serving as an IC or supporting team member.

CA Following a PI
Similar to the above, a person who served as an IC or supporting team member for a PI
will most likely be eligible to serve as an IC or supporting team member for the
subsequent CA (subject to the limitation of not performing more than two consecutive
Part 12D inspections). However, if that person was responsible for performing follow-on
work after the PI (such as a major revision of the DSSMP) that is to be reviewed and
evaluated in the CA, a different IC Team member would have to be identified to review
that work.

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Engineers-of-Record
A person who is the engineer-of-record for, or contributed substantially to, a particular
analysis or design effort should not be proposed as an IC or supporting team member
with responsibility for reviewing their previous work.

Consider a situation in which Person A was the engineer-of-record for a stability analysis
of the primary water-retaining features. If a licensee proposes Person A to serve as the IC
or supporting team member responsible for evaluating those stability analyses as part of a
CA, Person A will most likely be rejected. As with the previous example, Person A could
be eligible to serve for a PI.

First Part 12D Inspection for Newly Constructed Projects or After Major Remediation
The first Part 12D Inspection (likely a CA) for newly constructed projects, or projects
where a major dam safety remediation has recently been completed, may be done by the
design engineer or an engineer from the design engineer’s firm. While this may seem to
violate the principle discussed above (“prevent an IC Team member from reviewing their
own work”), it maintains an option for flexibility and efficiency that existed under the
rules established by FERC Order 122, and permits the design engineer/design
engineering firm to serve as IC Team members and document all of the analyses and
construction they completed in the format of a CA. The next report (either PI or CA)
must be completed by a different engineer not associated with either the design or
construction firm. Subsequent reports may be completed by an engineer associated with
the design, construction, or remediation work, subject to the additional restriction below.

Other Considerations Relating to Consulting Firms


Some of the examples discussed above refer to consulting firms. The FERC recognizes
that engineering consulting firms vary in size, geographic distribution, and organizational
structure, and that any given firm might have several offices that operate mostly
independently of each other.

There may be cases in which a person from Firm A is proposed as an IC or supporting


team member with responsibility for reviewing work completed by another group within
Firm A. In these situations, it is the licensee’s responsibility to demonstrate, in the Part
12D Inspection Plan, that the individuals proposed for the IC Team have sufficient
independence from those within Firm A who completed the work.

Part 12D Inspection Plans


18 CFR § 12.34(a) requires the licensee to obtain the written approval of the IC Team
from the Director of D2SI prior to performance of a Part 12D Inspection. The Part 12D
Inspection Plan is the submittal required to convey information related to the
qualifications of the IC Team.

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Content of the Part 12D Inspection Plan


The Part 12D Inspection Plan must include the following information:

• Project name, FERC number, and state(s) where the project is located;
• Type of Part 12D Inspection (CA or PI), and whether a risk analysis is included
for a CA (identify the date of a waiver if one was granted by the Regional
Engineer);
• A brief description of the project features that will be inspected;
o This section should also state whether any special access provisions will be
required to allow observation (e.g., confined space entry or rope access)
and/or whether features will be test operated (e.g., spillway gates) and how
many test operations will be performed;
• An IC Team Proposal, including the identification and assessment of technical
disciplines to be represented on the IC Team; the names and resumes for the IC(s);
a list of supporting team member roles and their intended areas of expertise; and
the names and resumes of facilitators for any PFMA and/or risk analysis as
needed; and
• A schedule for Part 12D Inspection-related activities.
If there are any potential conflicts of interest – for example, a member of the IC Team
performed a substantial fraction of the work on a critical study – those should be
described in the Part 12D Inspection Plan, along with how the IC Team will be structured
to avoid a conflict of interest.

Additional information regarding the Part 12D Inspection Plan is provided below; an
example outline is provided as Appendix 16-A.

IC Team Proposals
Selection of the Independent Consultant(s) is critical to the success of the project. The
IC(s) must possess the appropriate dam design and construction experience; understand
the requirements of an IC described in this Chapter of the Engineering Guidelines; be
able to lead the IC Team; and be able to communicate the findings and recommendations
of the reviews, assessments, and inspection.

Collectively, the IC Team must have “demonstrable experience and expertise in dam
design, construction, and in the evaluation and assessment of the safety of existing dams
and their appurtenances, commensurate with the scale, complexity, and relevant technical
disciplines of the project and type of review, inspection, and assessment being
performed…” [18 CFR § 12.31(b)(3)]. In order to fulfill this requirement, the IC Team
Proposal must:

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1. Identify the required technical disciplines for IC(s) and supporting team members;
2. Identify the Independent Consultant(s);
3. Demonstrate that the IC Team has the required experience; and
4. Identify the facilitators for the PFMA and/or risk analysis, if required.
As the scope of a CA is greater than the scope of a PI and involves an in-depth review of
analysis and construction records, the “demonstrable experience and expertise” threshold
is greater for a CA. Members of the IC Team for a CA will have to demonstrate greater
technical proficiency related to the design and/or analysis of the types of project features
under consideration. In addition, for the same project, the IC Team for a CA may require
more members than for a PI. Conversely, there may be some technically simple projects,
with sufficiently low risk, that a single IC may be able to perform a PI or even a CA
without any supporting team members.

Identification of the Required Technical Disciplines


In order to determine the composition of the IC Team, an assessment of the project
features and project setting must be performed. This assessment must include:

• A summary of project features, including all water-retaining and water-conveying


structures at the project and major components critical to project operation;
• An understanding of the project setting, such as site geology, the magnitude and
frequency of seismic loading, magnitude and frequency of hydrologic loading,
upstream and downstream consequences, etc.; and
• Any past or ongoing studies or dam safety incidents requiring specialized
experience.

This assessment must be included in the proposal and should be used to identify the
technical disciplines and levels of experience required of the IC Team to properly review,
inspect, evaluate, and assess the project features and associated studies.

For example, if a project does not include a type of feature, certain technical disciplines
may not be needed on the IC team (e.g., if a project has an uncontrolled overflow
spillway and no gates, there may not be a need for a mechanical or electrical engineer).
Similarly, a project located in a low seismic setting (e.g., northern Minnesota) will likely
not require an expert seismologist. A sample format for providing this information is
provided in Table 7, which is located at the end of this section. The information in that
table is provided only for illustrative purposes.

The FERC has not established criteria for the degree of expertise or technical proficiency
(e.g., novice, intermediate, advanced, expert, etc.) required for any particular type of
feature or situation. Each project is unique and the needed level of proficiency may be
influenced by the dam height, dam age or era of design, history of satisfactory or

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unsatisfactory performance, general uncertainty with conditions or design assumptions,


or many other factors.

As general guidance, Table 8 (located at the end of this section) presents some of the
technical disciplines that may be relevant to various project features, along with examples
of those elements that each discipline may be required to review and/or factors that affect
the overall complexity of the discipline’s review. The FERC will consider the relevant
review elements when evaluating the degree of technical proficiency required for a given
project. The information in Table 8 is not comprehensive and other factors will be
considered on a case-by-case basis. Do not use the information provided in Table 8
as criteria – it is general guidance.

Mechanical and electrical engineers, with formal training and years of specialized
experience, can provide valuable insight into the function and expected performance of
many project features. General civil engineers can gain a working knowledge of the
mechanical and electrical systems. Licensee operations staff can provide important, and
often insightful, background information about how the project operates. The IC Team
should consider including one or more members to represent the mechanical and
electrical disciplines to evaluate these components and ask questions that probe
operations and reliability. Mechanical and/or electrical engineers should be included for
projects that have:

• a large number of gates or a variety of gate types;


• limited discharge redundancy (e.g., a single spillway with one gate at an
embankment dam);
• power generation facilities which are required to remain operable to safely pass
flood flows; or
• a history of mechanical and/or electrical problems.

Identification of IC Team Members


The licensee must identify the role, technical discipline(s), and demonstrate the technical
proficiency for each member of the IC Team. Table 5 provides a suggested format for
providing this information to the FERC. To provide consulting firms flexibility in work
assignments between submittal of the IC Team Proposal and performance of the in-
person activities, the names of supporting team members do not have to be provided in
the Part 12D Inspection Plan.

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Table 5: IC Team Composition for Part 12D Inspection Plan (EXAMPLE)


Name Role Technical Discipline(s)
Mr. Douglas Clay Independent Consultant Geotechnical
Ms. Samantha Waters Independent Consultant Hydraulics and Hydrology
TBD Team Member Structural
TBD Team Member Mechanical/Electrical
TBD Team Member Geology
TBD Team Member Seismicity

If supporting team member names and resumes are provided in the Part 12D Inspection
Plan, the FERC response will evaluate the experience of every IC Team member and the
technical disciplines represented on the team.

If supporting team member names and resumes are not provided in the Part 12D
Inspection Plan:

• The FERC response to the Part 12D Inspection Plan will evaluate the experience
of the IC(s) and the proposed technical disciplines for supporting team members.
• The PIPR will be required to include the name(s) and resume(s) of any supporting
team members (refer to Section 16-4.3 for details on how to provide that
information in the PIPR).
• The FERC response to the PIPR will evaluate the experience of the supporting
team members.
For a CA, the name(s), qualifications, and resumes of the PFMA facilitator(s) and risk
analysis facilitator(s) must also be provided. Qualifications for PFMA and risk analysis
facilitators are discussed in Chapters 17 and 18 of the Guidelines, respectively.

Table 6 summarizes the roles and responsibilities of key Part 12D Inspection positions.
The licensee must carefully consider the responsibilities of the IC(s) relative to their
potential role in the PFMA and risk analysis for a CA. An IC could potentially serve
as a core team member (subject matter expert), facilitator (if qualified), or reviewer of the
PFMA and risk analysis. Selecting the appropriate role for the IC for the PFMA and risk
analysis depends on a number of factors, including:

• Availability of other qualified PFMA and risk analysis facilitators.


• The qualification and experience of the IC to serve as a facilitator.
• Using the IC as a participant to leverage their knowledge of the project gained
through the review of the project records.
• Adding the responsibility of facilitating the PFMA and risk analysis on top of the
already large workload and responsibility of the Part 12D review and inspection.

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These factors and others should be considered in selecting the role of the IC and the
facilitator(s) of the PFMA and risk analysis. Note that a licensee is not permitted to serve
as facilitator for either a PFMA or risk analysis for their own project. Additional details
regarding the roles, responsibilities, and qualifications of the IC and facilitators with
respect to the performance of a PFMA and risk analysis are described in Chapters 17 and
18 of the Guidelines, respectively.

Table 6: Roles and Responsibilities of Key Part 12D Positions

Responsibility
Role Qualifications Part 12D PFMA Risk Analysis
Reviews
project Participant Participant
documents or or
Independent Chapter 16,
Performs site Facilitator Facilitator
Consultant Section 16-3.2
inspection or or
Prepares Part Reviewer Reviewer
12D Report
Chapter 17, Participant
PFMA
Section 17- - Facilitator or
Facilitator
4.3.3 Facilitator
Participant
Chapter 18,
Risk Facilitator - or Facilitator
Section 18-5.3
Facilitator
Supporting Members of the Independent Consultant Team
Other members of the IC Team are not responsible for signing and sealing the report and
are not required to have at least ten years of experience. These supporting team members
still provide valuable technical expertise that ensures the IC Team is qualified to review,
inspect, and assess a given project. Members of the IC Team are expected to inspect
those physical features and review the portions of prior reports, as-built drawings,
instrumentation data, etc. that are within the purview of their technical expertise.

For example, an IC with a primarily geotechnical background would likely have to rely
on a structural engineer to inspect, review, and evaluate information related to a concrete
arch dam. That structural engineer would be required to attend all IC Team activities,
including the field inspection and, for a CA, the PFMA/risk analysis.

Resumes
The resumes provided with an IC Team Proposal (or included with the PIPR) must
clearly state the individual’s role in each project listed (e.g., a member of a design team,
QC/QA review, engineer of record, etc., along with the duration and scope of that role).

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A general list of projects, without context, is not acceptable and may result in rejection of
the Part 12D Inspection Plan. The FERC will evaluate the resume and compare it to the
stated technical discipline and proficiency; the resume must clearly document that the
individual possesses the relevant knowledge and skills at the proficiency level identified
in the submittal. Consider the following examples:

• Project A includes a 450-foot-high, double-curvature thin arch dam with thrust


blocks on either side and an uncontrolled overflow spillway in the center of the
crest. The dam is located in a high seismic area. The structural analyses of record
include three-dimensional dynamic finite element models evaluating the potential
for rock block displacement, continuity of the arch (opening/closing of monolith
joints) during the earthquake, and post-earthquake stability of thrust blocks on
either side.

The IC Team should include a structural engineer who can demonstrate experience
and understanding of tall, double-curvature thin arch dams; finite element
modeling and its limitations; gravity structure analysis; and seismic loading on
concrete structures; as well as an engineering geologist who can evaluate the
performance and three-dimensional stability of the abutments and foundation
subject to the same loading.
• Project B includes a 250-foot-high zoned embankment dam; a gated, concrete-
lined service spillway with two 16-foot-high by 20-foot-wide radial gates; a 200-
foot-wide uncontrolled emergency spillway with an earth and rock-lined chute;
and a low-level outlet works. The project is located in an area of relatively low
seismicity. Hydrologic analyses indicate the dam is overtopped at about 90-
percent of the PMF. Downstream consequences are moderate.

The IC Team should include a geotechnical engineer who can demonstrate


knowledge and experience in internal erosion and overtopping erosion of tall
embankment dams; a hydraulic structures engineer who can demonstrate
experience and understanding of concrete-lined and earthen-lined spillways and
low-level outlets; structural and electrical/mechanical engineers who can
demonstrate knowledge and understanding in the design, construction, and
operation of radial gates and low level outlets; and an engineering
geologist/geotechnical engineer who can demonstrate knowledge and
understanding of the erodibility (scour) of earth and rock-lined chutes and
channels. In addition, the team would likely need to include a
hydrologist/hydraulic engineer who can demonstrate knowledge and experience in
flood routings and scour analyses.
Note that in each of the above examples, the required personnel are discussed only with
respect to the specific project features listed. Under no circumstances should these

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brief examples be used as justification not to include any particular discipline as


part of an IC Team.

Proposed Part 12D Schedule


The Part 12D Inspection Plan must include a proposed schedule for major activities and
milestones. At a minimum, the following items must be listed with anticipated dates,
informed by the timing presented in Table 2 or Table 3, as applicable:

• Submittal of the Pre-Inspection Preparation Report;


• Field/Site Inspection;
• PFMA and risk analysis session(s), as applicable;
• Submittal of the PIR/CAR; and
• CAR Review Meeting, if applicable (CA only).
The schedules for the PFMA and risk analysis session(s) should include a brief
discussion of general logistics (e.g., expected duration of each process; whether they will
be performed in-person or as virtual/remote sessions; if there is a backup set of dates in
case the PFMA or risk analysis is not completed within the allotted time).

Time to Submit the Part 12D Inspection Plan


Licensees must submit the proposed IC Team and resumes far enough in advance that, in
the event one or more members are rejected or supplemental information is requested, the
schedule to complete the inspection or assessment is not affected. The Commission’s
regulations require that the resumes be submitted “at least 180 days prior to the
performance of the Periodic Inspection or Comprehensive Assessment.” This refers to the
date of the first in-person activity (e.g., field inspection, PFMA, etc.), not the date the
report is due.

The FERC strongly recommends, but does not require, that the licensee submit the Part
12D Inspection Plan at least one year in advance of the due date of the report, even if that
is greater than 180 days in advance of the first IC Team activity. Submitting the Part 12D
Inspection Plan earlier than required can provide the IC Team additional time to review
background information and prepare the PIPR.

FERC Review and Approval of Part 12D Inspection Plans


The licensee is required to submit the Part 12D Inspection Plan to the Director of D2SI.
Upon receipt, the FERC will review the information and provide a written response that
may fall into one of the following general categories:

• Approval of the Part 12D Inspection Plan and entire IC Team;

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• Conditional Approval of a portion of the Part 12D Inspection Plan or IC Team,


with a request for minor revisions to the Part 12D Inspection Plan and/or
supplemental information to describe the necessary expertise, demonstrate the
experience of one or more members of the IC Team (to include IC(s) and, if they
are identified by name in the Part 12D Inspection Plan, supporting team members),
and/or a request for additional members to provide a certain level of experience in
one or more technical disciplines; or
• Rejection of the Part 12D Inspection Plan and/or IC team with a requirement to
resubmit a new proposal.
Neither an IC nor an IC Team member is guaranteed approval for a particular Part 12D
inspection simply because they have previously been approved in that role for a similar
project in the past. The FERC may reject any proposed IC or IC Team member due to the
specific IC Team Proposal under consideration not demonstrating that the person has
sufficient relevant experience. In addition, the FERC may reject any person who has
shown a consistent pattern of poor performance with respect to Part 12D inspections and
the reports thereon, such that entrusting the performance of all or a portion of a Part 12D
inspection to that individual presents a clear risk that potential dam safety deficiencies
may be overlooked or inadequately considered.

Changes to the IC Team After Approval


As discussed previously, the Part 12D Inspection Plan is required to be submitted at least
180 days in advance of the first IC Team activity, and is requested to be submitted at least
one year in advance of the due date of the report. There may be situations in which key
members of the IC Team are no longer available to participate after receiving FERC
approval but before performance of the inspection or completion of the Part 12D report.

IC(s) and Facilitator(s)


If an IC or facilitator is no longer able to participate, a revised Part 12D Inspection Plan
must be submitted to D2SI-WO as soon as practicable. Critical activities such as the
inspection, PFMA, and risk analysis may not proceed without an approved IC Team.

Supporting Team Members


As discussed previously, the names and resumes of supporting members of the IC Team
are not required to be included in the Part 12D Inspection Plan; they can be provided in
the cover letter transmitting the PIPR (which is discussed in the subsequent section of this
Guideline). As such, the FERC does not anticipate many situations in which supporting
team members are changed on short notice.

In the event that a key supporting team member is unable to participate after their name
and resume have been submitted and approved as part of the IC Team, the licensee will
need to file the name and resume of a proposed replacement. If that is not done in time,

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then portions of the inspection, PFMA, or risk analysis may need to be redone by the
replacement with oversight by the IC(s) and possibly FERC dam safety staff.

Table 7: Technical Expertise Considerations (EXAMPLE)

BIG DAM PROJECT, FERC No. 98765


IC Team Technical Disciplines and Issues
Relevant Technical Identified Issues and/or
Project Feature Disciplines Technical Complexity
Hydraulically or semi-hydraulically placed
fill
Unfiltered seepage exit on downstream
Embankment
Geotechnical slope/toe
Dam
Inadequately designed embankment filters
High phreatic surface in embankment
Steep slopes
Overhangs at fill/structure contact
Lack of batter at fill/structure contact
Evidence of differential settlement at
Embankment
structure interfaces
Dam Foundation Geology
Karst foundation
and Abutments
Liquefiable foundation
Incompatible filter for foundation blanket
Evidence of seepage through abutments
Double-curvature thin arch dam with
Concrete Arch
Structural instrumentation data that suggests there
Dam
may be adverse performance.
River deposits remain in channel to a depth
100 feet below the base of the dam.
Arch Dam Abutments contain complex joint sets and
Foundation and Geology potentially releasable blocks critical to
Abutments dam stability. History of small rock slides.
Significant differences in rock mass
influences foundation rock modulus.

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BIG DAM PROJECT, FERC No. 98765


IC Team Technical Disciplines and Issues
Relevant Technical Identified Issues and/or
Project Feature Disciplines Technical Complexity
Gates are of modern design with no
Structural
problematic detailing.
Project has twelve radial gates with
multiple backup power sources, antiquated
hoist equipment, and complex SCADA
Radial Spillway
Mechanical/Electrical systems. History of failure to operate due
Gates
to mechanical issues.
Lack of personnel to operate gates in a
timely manner in an emergency situation
Gate configuration and inlet conditions are
Hydraulics
simple.
Project is located in a small basin;
Overall Project
Hydrology and hydrology is well-understood and is
Hydrology and
Hydraulics current. No concerns related to flood
Hydraulics
passage if project is fully operational.
High consequences – City of Damsville,
population 30,000 is located 2 miles
Downstream
Emergency Response downstream.
Hazard Potential
Limited or negative excess response time
in many locations.
Project is located in an extremely low
Overall Project seismicity area. Structures are very
Seismicity
Seismicity unlikely to sustain damage from an
earthquake.
Project is heavily instrumented; numerous
types of instruments on multiple types of
dam sections.
Overall Project Instrumentation and/or
Instrumentation is connected to an ADAS
Instrumentation Programming
with programmed alarms that consider
statistical correlation and seasonal
behavior.

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Table 8: Selected Technical Disciplines and Review Elements by Type of Project


Feature (EXAMPLES)

Project Feature
and/or Review Elements and Factors to
Consideration Technical Discipline Consider
Anchors
AAR
Height
Structural
Tailwater washout
Drains required for stability
Stability at lift joints
Concrete Gravity Weak planes below foundation
Dams and their contact
Foundations Erodible foundation material at toe
or along abutments that overtop
Geology during floods
Karst in foundation
Competency of foundation bedrock
(asperities, favorable bedding angle,
soundness of rock, etc)
Height, thickness, and type of arch
dam.
Structural
History of concerning
instrumentation data.
Arch Dams and their Abutments contain complex joint
Foundations sets and potentially releasable
blocks critical to dam stability.
Geology
Significant differences in rock mass
influences foundation rock
modulus.

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Project Feature
and/or Review Elements and Factors to
Consideration Technical Discipline Consider
Height of dam
Slopes
Unfiltered exits
Filter installed but not designed to
current standards
Geotechnical
Instrumentation documentation of
elevated phreatic surface
Embankment Dams Hydraulic or semi-hydraulic fill
and their Type of cutoff
Foundations Embankment materials
Karst foundation
Liquefiable foundation
Erodible foundation or abutment
Geology
materials
High foundation water pressures
Soft, weak layers in foundation
Lack of modern design and
construction
Unfiltered seepage
Inadequate freeboard
Inadequate control of inflow into
canal
Inadequate spillway capacity to
Geotechnical
control flood flows
Steep slopes
Canal Embankments Excess vegetation on slopes
and their Unfiltered penetrations through
Foundations embankment (old pipelines, old
structures, etc.)
Length of canal embankment
Liquefiable foundation or
embankment materials
Karst foundation
Geology
Erodible foundation materials
High foundation water pressures
Soft, weak layers in foundation

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Project Feature
and/or Review Elements and Factors to
Consideration Technical Discipline Consider
Era of construction (i.e., typical
detailing of joints and slab,
drainage, anchoring, etc.).
Flow velocities and potential for
Structural
cavitation and/or stagnation
pressure.
Criticality of spillway operability to
pass flows.
Lined Spillway Flow velocities and depths
Chutes Drainage, reinforcing, anchor, and
joint details
Susceptibility to stagnation
pressure/slab-jacking
Hydraulics
Erodibility of material potentially
exposed to spillway flow in the
event of chute failure
Available analyses of spillway
stability
Flow velocities and depths
Erodibility of material potentially
Unlined Spillway Hydraulics
exposed to spillway flow
Chutes Geology/Geotechnical
Available analyses of spillway
stability
Era of construction (riveted, bolted,
welded, material specifications)
Condition of penstock (e.g.,
Structural Total head
Geometry (e.g., horizontal and/or
vertical curves with critical thrust
blocks and/or saddles)
Penstocks Bearing capacity of foundation
Geotechnical
materials at supports.
History of or susceptibility to
Hydraulics
cavitation damage
History of load rejections/water
hammers due to valve issues
Mechanical
Criticality of penstock availability
for passing required flows

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Project Feature
and/or Review Elements and Factors to
Consideration Technical Discipline Consider
Structural capacity of gates with
respect to anticipated loading
conditions.
Number of types of gates and their
relative structural complexity.
Redundancy in number of gates and
Structural
overall complexity of
mechanical/electrical systems.
Sensitivity of flood routing with
respect to gate availability and
operations.
Binding due to AAR
Age of hoist
Spillway Gates
Moveable or fixed hoist
Multiple moveable hoists
Mechanical Redundancy in backup methods of
mechanical operation (e.g., crane
lift, electric drill, etc.)
Operational history
Redundancy of power supply
Locations of backup power sources
and routes of power supply
Electrical Remote operation
Hoist motor capacity with respect to
demand
Operational history
Considerations will vary depending
Other Water
Structural, Geology, on the type of water conveyance.
Conveyances (e.g.,
Hydraulics, possibly May require evaluation of rock
tunnels, flumes,
others block stability, tunnel linings,
siphons, etc.)
dewatering rates, etc.
Ability of the project to pass the
Overall Project PMF/IDF
Hydrology and/or
Hydrology and Complexity of PMP/PMF study
Hydraulics
Hydraulics (e.g., site-specific, new
methodologies, etc.)

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Project Feature
and/or Review Elements and Factors to
Consideration Technical Discipline Consider
Magnitude of seismic loading.
Uncertainty regarding seismic
Overall Project sources, methodologies, or ground
Seismology
Seismicity motions
Susceptibility of project structures
to seismic loading
Variety of instrument types installed
Variety of project features
instrumented
Overall Project Instrumentation and/or Level of automation in data
Instrumentation Programming acquisition, processing, and alarms
Criticality of instrumented
monitoring to ensuring project
safety

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PRE-INSPECTION PREPARATION REPORTS

Purpose
In the PIPR (also known as preliminary reports), which is required by 18 CFR § 12.42 for
both a PI and a CA, the IC Team is expected to document the findings of their review of
existing information. This provides a structure to record the IC Team’s preliminary
evaluation of dam and public safety programs, analyses of record, instrumentation data,
etc., which can help ensure that the IC Team is adequately prepared to perform the site
inspection and PFMA/risk analysis, as applicable.

Any information included in the PIPR will be considered preliminary. The FERC
does not expect the PIPR to include any final findings or conclusions. It is entirely
acceptable, and even expected, for the IC Team to acquire new information or a different
understanding of the project and its components between completion of the PIPR and the
final Part 12D Report. The FERC does not intend to compare the PIPR to the final Part
12D Report.

The FERC will review and evaluate the PIPR to determine whether the IC Team is
adequately prepared, and the determination will fall into one of the general categories
listed below:

• An Acceptable PIPR demonstrates that the IC Team is adequately prepared and


likely will not receive a response before the first IC Team activity, which will
continue as scheduled.
• A Generally Acceptable PIPR demonstrates that the IC Team is mostly prepared
but there might be one or more topics that require additional review before the first
IC Team activity. Within two weeks of the PIPR submittal, the FERC will issue a
response letter identifying these topics and requesting an updated PIPR by the date
of the first IC Team activity, which will continue as scheduled.
• An Unacceptable PIPR does not demonstrate adequate preparation by the IC
Team and raises significant concerns about the IC Team’s ability to perform the
first IC Team activity. Within two weeks of the PIPR submittal, the FERC will
issue a response letter detailing the deficiencies, requesting a conference call to
discuss the issues, and postponing the IC Team activities as described in 18 CFR §
12.42. Note that any such postponement will not affect the due date for the Part
12D Report.
If the FERC does not issue a response to the PIPR within two weeks of submittal, the first
IC Team activity will continue as scheduled and the PIPR will be considered Acceptable.

Required Documentation in the PIPR


Table 9 lists the information required for the PIPR; outlines for the PI-PIPR and
CA-PIPR are provided in Appendix 16-C and Appendix 16-E, respectively.

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Table 9: Pre-Inspection Preparation Report Requirements

Required Required
Documentation for for
CA-PIPR? PI-PIPR?
Potential deficiencies in the previous description and/or
Yes Yes
understanding of project works.
Potential design or construction-related issues. Yes No
Potential deficiencies (accuracy, relevance, current state-
Yes No
of-the-practice) in the analyses of record.
Project status, including a list of recent modifications to
project works, operations, and the status of previous Part Yes Yes
12D recommendations.
Review and interpretation of instrumentation data. Yes Yes

Additional Information Required from the Licensee


As noted in Section 16-3.3, the Part 12D Inspection Plan is not required to contain the
names or resumes of supporting team members. The letter transmitting the PIPR must
contain the final composition of the IC Team; Table 10 provides an example of how to
format this information. The letter should indicate which activities each member will
participate in (e.g., field inspection, PFMA, risk analysis, report preparation, etc.).
Resumes demonstrating the experience of the supporting team members must be attached
to the letter, if they were not already provided in the Part 12D Inspection Plan.

Table 10: IC Team Composition for PIPR Transmittal Letter (EXAMPLE)


Name Role Technical Discipline(s)
Mr. Douglas Clay Independent Consultant Geotechnical
Ms. Samantha Waters Independent Consultant Hydrology and Hydraulics
Ms. Carol Gates Team Member Structural
Mr. Max Power Team Member Mechanical/Electrical
Ms. Linda Stone Team Member Geology
Mr. Steve Shaker Team Member Seismicity

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PERIODIC INSPECTIONS

General
The scope of a Periodic Inspection is established in 18 CFR § 12.35 and comprises the
following:

• A thorough review of existing information to familiarize the IC Team with the


relevant background and historical information to allow proper evaluation of
project features;
• Review and evaluation of dam and public safety programs (e.g., Operations and
Maintenance Program, Public Safety Plan, Owner’s Dam Safety Program, etc.);
• Review and evaluation of instrumentation data and surveillance reports;
• A physical field inspection; and
• Preparation of the Periodic Inspection Report.
The Federal Guidelines for Dam Safety [Federal Emergency Management Agency
(1979)] recommends that an independent evaluation occur at least once every five years.
A PI, which typically occurs five years after a CA, fulfills this recommendation.

This section provides more detail on the scope of each component of the PI along with
discussion of the documentation requirements. It describes the minimum expected level
of effort for preparation and performance of the PI and completion of the PIR. An outline
of the PIR, which is included in Appendix 16-B, can be used as a template and rough
guide for the contents of each section.

Review of Prior Reports


The IC Team is required “to have, at the time of the inspection under [18 CFR Part 12,
subpart D], a full understanding of the design, construction, performance, condition,
downstream hazard, monitoring, operation, and potential failure modes of the project
works.” The IC Team must perform all necessary review, prior to the field inspection, to
meet this requirement, which is established in 18 CFR § 12.35(a). At a minimum, this
should include review of the two preceding Part 12D Inspection Reports, the most recent
PFMA report, and other relevant information in the STID.

A PI is not required to include a formal PFMA workshop. However, at the time of the
field inspection, IC Team members should have a full understanding of the loading
conditions, failure mechanisms, and conditions identifiable during a field inspection that
may indicate any PFM is active or developing. The IC Team members should know what
conditions they might observe during their inspection that would warrant closer attention,
require follow-up action, or could indicate that project features may be particularly
susceptible to failure modes under loading conditions not occurring at the time of their

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inspection (e.g., a gate misoperation during an inspection under normal conditions may
inform the expected reliability of a gate during flood conditions).

The FERC stresses the importance of advance review of prior reports. Remember that if
the IC Team is not adequately prepared, the FERC may require the field inspection
to be performed again, at a later date, following further review of project records by
the IC Team.

Observations and Evaluations of Performance


This section of the PIR has been structured to help ensure that findings are thoroughly
documented and evaluated for each project feature. Four headings, listed below, are
required for each project feature.

Field Inspection Observations


Review and Evaluation of Instrumentation Data and Surveillance Reports
Evaluation with Respect to Potential Failure Modes
Conclusion
The evaluation of potential failure modes for each feature must consider both the field
inspection findings and an independent interpretation of instrumentation data and
surveillance reports. It is not acceptable to rely entirely on previous interpretations,
nor is it acceptable to state that instrumentation data does not indicate a potential
issue simply because it is not changing over time.

The PIR must include a discussion of the field observations relative to each of the
identified potential failure modes as well as the Independent Consultant’s own
assessment of the significance of the identified potential failure modes; whether any other
(previously unidentified) potential failure modes may exist based on specific field
observations or instrumentation data; and conditions that have changed and may impact
previous conclusions regarding potential failure modes. The PIR must provide sufficient
documentation to support whatever the stated conclusion is with respect to each identified
PFM and the overall suitability of the feature for continued operation.

The overall conclusion for each project feature should be clear and based on the
discussion that precedes it. It is not necessary to reiterate information as long as the
rationale is apparent from the preceding discussion. The requirements of physical field
inspection and review of instrumentation data and surveillance reports are discussed
below.

Physical Field Inspection


The requirement for a physical field inspection is established in 18 CFR § 12.35(b). The
physical field inspection must include a detailed visual observation of all physically
accessible project features by one or more members of the IC Team. Each portion of the

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inspection should be observed by at least one IC, plus any members of the IC Team
qualified to evaluate that type of project feature (e.g., a structural engineer should not be
the primary inspector for an embankment dam). The Bureau of Reclamation Safety
Evaluation of Existing Dams (SEED) Manual [Bureau of Reclamation (1995)] may be
used as a reference for general procedures related to the inspection of dams and project
works.

Reservoir Rim
If there are any credible PFMs related to the reservoir rim, visual inspection of the
relevant portion is required. Otherwise, it may be sufficient to visually observe the
reservoir rim within the immediate vicinity of the project works (e.g., from the dam
crest).

Spillway Chutes
Spillway chutes, whether lined or unlined, should be inspected up close to the extent
possible. The FERC recognizes that some spillways are too steep to be inspected without
extensive preparation, and that in some cases a licensee or IC Team may choose to have
only a specially-trained (e.g., rope access) team perform the inspection for safety
considerations. In that case, it may be acceptable for the IC Team to review a recent
detailed inspection report (e.g., a focused spillway assessment report) prepared by
another qualified party. It is preferred, but not required, that one or more members of the
IC Team at least observe the special inspection.

If the IC Team reviews a detailed inspection report, it is important to ensure that the
report is timely and relevant; therefore, it is strongly preferred that the special inspection
occur within one year prior to the PI. It is acceptable for the IC Team to review an older
report as long as the special inspection occurred since the previous Part 12D inspection
and no events have occurred that would reasonably be expected to change the condition
of the spillway chute (e.g., high spill events, seismic loading, chute maintenance/repairs,
etc.). The Regional Engineer may provide additional requirements related to the spillway
chute inspection in the inspection reminder letter.

Gate Operations
If possible, the relevant members of the IC Team should observe full-height spillway gate
test operations. In many cases, this may require significant coordination (e.g., placement
of dewatering bulkheads, a low reservoir, preexisting high flows to limit downstream
effects, etc.). If circumstances do not permit the observation of full-height gate tests, the
IC Team still must observe test operations of a representative number of gates such that
they can evaluate the gate performance, licensee’s standard operating procedures, and
provide informed conclusions.

Every power source available for operation of gates should be tested and used to operate
a gate during the inspection. If there are multiple backup power sources – for example, a

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diesel-powered generator, a portable propane-powered generator, and a battery bank –


each should be used. If the licensee’s standard operating procedures include other
emergency methods for operating a gate – such as using a lifting beam and portable
crane, or attaching a hand crank – the IC Team should confirm that the required
equipment is available and that licensee staff are sufficiently familiar with the
procedures.

Some projects may have restrictions such as ramping rates, water availability, circuit
switching, etc. that will require advance coordination to ensure that the IC Team is able
to observe and evaluate gate and backup power operations. Any circumstances that would
prevent the IC Team from observing these operations must be clearly described in the
Part 12D Inspection Plan for review and evaluation by the FERC. If necessary, the
licensee must propose an alternate scope that accomplishes the same goal, and the FERC
reserves the option to deny the alternate scope and require that the IC Team observe the
procedures as described above.

Other Special Inspection Reports


The IC Team must review all reports on special inspections that have occurred since the
previous CA or within the preceding five years, whichever period is longer. Some
examples of special inspection reports are:

• Underwater inspections;
• Hands-on gate inspections;
• Focused spillway assessments (discussed previously);
• Special access inspections (confined space, rope access, etc.), including of
penstocks and tunnels;
• Camera scope inspections of drains, conduits, and other features;
• Aerial drone inspections; and
• Other inspections as applicable.

Review of Instrumentation Data and Surveillance Reports


The requirement to review surveillance and monitoring data is established in
18 CFR § 12.35(c). This is a critical component of the PI and is equally important as
the field inspection. Previous dam safety incidents may have been avoided, or the
urgency of response and remediation reduced, had the instrumentation data been
reviewed with more careful consideration.

The review of monitoring data must be a critical, thorough review of the data itself. It is
not acceptable for the IC Team to review only the instrumentation data plots prepared by
the licensee and included in the annual DSSMR submittal. The licensee must provide the

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IC Team with all available data, through the date of the field inspection, such that the IC
Team can identify, describe, and evaluate:

• Relationships between instrument readings and environmental factors such as


reservoir elevation, precipitation, air/water temperature, project operations, etc.;
• What constitutes expected behavior for each instrument (and, by extension, what
constitutes unexpected behavior);
• Whether there are any historic readings or ongoing trends that may indicate
adverse behavior, including data from instruments that may have failed or are no
longer in use;
• Whether there are any readings that are inconsistent with other related
observations or readings from nearby instruments; and
• Whether any established thresholds, automated alarms, etc. are set such that they
will trigger appropriate follow-up actions prior to substantial progression of a
potential failure mode.
The discussion of instrumentation data in the PI-PIPR should cover the time period
through the most recent DSSMR; the PIR should include data through the date of the
field inspection.

The IC Team must review surveillance reports to supplement their field inspection
observations. The findings of previous inspections should be compared to the current
findings, with discrepancies and changes in performance noted.

In order to properly complete this aspect of the PI, the IC Team must understand the
purpose, function, and expected behavior of each instrument or feature. It is not sufficient
to simply identify trends or threshold exceedances, or the lack thereof. It is not acceptable
to rely entirely on a previous interpretation or to state that data is acceptable simply
because the behavior is consistent over time. The IC Team must thoughtfully consider
each instrument and surveillance report; describe the expected behavior of each; and
identify any observations or data that is unexpected or indicative of adverse performance.
Statistical analysis may be required for complex, heavily-instrumented projects or large
data sets. It is not acceptable to state that previous evaluations did not identify any
problems, that no changes in behavior were identified, and thus the data is
acceptable. The documented rationale may refer to previous evaluations but must not
rely on them.

The IC Team should consider collecting manual readings of critical monitoring


instruments (e.g., piezometers, crack gages, plumblines, etc.) during the field inspection.
This provides valuable information about the condition of the project at the time of the
inspection. It also gives the IC Team an opportunity to review the licensee’s manual data

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collection procedures. Any readings collected should be noted and evaluated in this
section.

Review and Evaluation of Dam and Public Safety Programs


The requirement for review of dam and public safety programs is established in
18 CFR § 12.35(d); the review of surveillance and monitoring is required by
18 CFR § 12.35(c). In each section, the PIR must include a clear statement that the IC
Team reviewed the information, along with any findings and recommendations. Some
additional considerations are discussed below.

This aspect of the review is documented in Sections 5.1 through 5.6 of the PIR.

Owner’s Dam Safety Program


Typical Scope
The IC Team is not required by the FERC to perform a detailed review of the written
ODSP document or conduct extensive, focused interviews with project staff. The FERC
requires only that the IC Team be sufficiently familiar with the written ODSP and the
FERC ODSP guidance that the IC Team is able to evaluate whether the ODSP is being
implemented appropriately with respect to the project being inspected.

During preparation and performance of the PI, the IC Team should take note of any
actions, requests, responses to unusual events, or other situations that may indicate
licensee staff do not strictly adhere to the tenets espoused in the written ODSP. These
should be noted in the PIR; if there are no such situations, that should be stated.

Potential Modified Scope


In some situations, a licensee may find benefits in having the IC Team perform an
external audit or peer review of the ODSP as part of the PI. This would be at the
discretion of the licensee and would require FERC approval in advance. The Part 12D
Inspection Plan would have to clearly incorporate the external audit or peer review and
the IC Team would have to include one or more individuals qualified to perform that
review. If a licensee pursues this option, then this section of the PIR should refer to a
standalone report documenting the external audit/peer review consistent with other
guidance regarding the ODSP.

Performance Monitoring Program (Surveillance and Monitoring)


The IC Team must be familiar with the written protocols for surveillance of the project
works, including any inspection checklists the licensee maintains, which are typically
documented in a Dam Safety Surveillance and Monitoring Plan. It is important to
understand the layout of existing instrumentation as well as the installation details,
function, performance, and reading frequency/procedures (both manual and automated).
The depth of review must be sufficient so the IC Team:

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• Understands the function and purpose of each instrument and surveillance


procedure;
• Knows what observations or recorded data may indicate the onset or progression
of a PFM, or conditions that are otherwise out-of-the-ordinary with respect to
general health; and
• Can make informed recommendations for improvements (e.g., new
instrumentation, changes to procedures, etc.).
The evaluation must consider both the surveillance procedures and instrumentation and
their effectiveness at monitoring for the identified PFMs as well as general health. For
each PFM, the IC Team must review whether the monitoring program is adequate to
detect the onset of the PFM, or conditions that may contribute to or “allow” development
of the PFM, in a timely manner. The ICs should provide comments that relate historic
and current performance indicators (i.e., monitoring data) to identified PFMs. The ICs
should also address whether the instrumentation at the dam is functioning properly and is
adequately maintained.

The ICs should specifically consider whether inspections during and after unusual
conditions (e.g., high pool elevations not previously experienced, high flow events,
seismic events, etc.) or related to inaccessible features are of an appropriate scope and
performed at an appropriate frequency.

The IC Team must also review procedures for and the timing of licensee engineering
review (e.g., data reduction and analysis) of instrumentation data and surveillance
reports, and any reporting of adverse or unusual findings to more senior personnel for
investigation or other action (e.g., an operator collects data, dam safety engineer
evaluates it and identifies a potential issue, and escalates the concern to the CDSE or
higher level management).

Hazard Potential Classification


Hazard potential classifications are defined in 18 CFR § 12.3(b)(13) and Chapter 1 of the
Engineering Guidelines. The IC Team is required to review the conditions upstream and
downstream of a project to evaluate:

• Whether the current hazard potential classification is appropriate, and


• Whether any changed conditions warrant reconsideration of the Sudden Failure
Assessment (SFA) or other procedures in the Emergency Action Plan.
The IC Team must review the conditions upstream and downstream of project structures
and take note of any changes to development (e.g., a significant increase in the
population at risk, new developments below structures classified as low or significant
hazard, or new structures closer to the project than those previously identified). When
evaluating whether the hazard potential classification remains appropriate, the IC Team

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should also consider the effects that failure may have on environmental and publicly-
disclosed cultural resources; critical infrastructure, such as major highways and
municipal water supplies; and other conditions as applicable.

A visual review is preferred but, in some cases, conversations with the licensee and a
review of aerial or satellite imagery may suffice. It is important to note the date of
publicly available imagery, as it can be out-of-date in remote areas. Conversations with
licensee staff regarding changes to downstream development should be documented. The
findings must be documented in the PIR and appropriate recommendations provided.

Emergency Action Plan


Typically, no members of the IC Team will be required to have specialized experience in
emergency response procedures. However, an EAP is such an important component of a
dam safety program that the IC Team must have sufficient general knowledge to review
and comment on it. There may be cases in which emergency response personnel would
be appropriate to include as part of the IC Team.

If the project is subject to 18 CFR Part 12, Subpart C, the IC Team must review the EAP,
including the inundation maps (the review of dam breach analysis is not a component of a
PI). The review must consider the written EAP document as well as the licensee’s
training procedures, coordination with outside persons and agencies, and the familiarity
of project staff with their roles and responsibilities.

If any EAP activations or functional/full-scale exercises have occurred since the previous
Part 12D Report, the IC Team must review and evaluate the after-action report and
licensee’s plan of action.

If an SFA has been performed for the project, the IC Team must review the assumptions,
procedures, and evaluate the findings. Any project with an excess response time (ERT)
less than 15 minutes, including negative ERTs, should be reviewed with a greater level of
scrutiny. The performance or non-performance of automatic notification systems should
be confirmed and their effectiveness evaluated, based on the results of periodic testing
thereof. The IC Team should observe operations of critical warning devices during the
field inspection or at another time, if possible. Warning systems should be evaluated for
their adequacy in providing timely warning; redundancy in detection and notification;
and the potential for single points of failure in the warning system.

If an SFA has not been performed, the IC Team should review and comment on whether
one should be performed.

Public Safety Plan


The IC Team must be familiar with the current Public Safety Plan (PSP) and the warning
signs, sirens, and access restrictions described therein. The IC Team is not expected to

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contain a public safety expert; however, one or more members should be adequately
familiar with industry standards and the FERC Guidelines for Public Safety at
Hydropower Projects. The intent is for the IC Team to take a common sense approach to
reviewing and evaluating the public safety measures that are in the immediate vicinity of
project structures and/or that are directly related to standard project operations. The IC
Team is not expected to increase the scope of the field inspection to observe specific
public safety devices.

During the field inspection, the IC Team should take note of any devices that are missing,
damaged, inoperable, or otherwise not as described in the PSP and should consider
whether any new devices are warranted based on their observations. The evaluation
should also consider any project-related public safety incidents that have occurred since
the previous Part 12D Inspection; standard operating procedures that may have the
potential to cause a hazardous situation for members of the public recreating at or near
the project site (e.g., prior to operation of spillway gates, do operators view cameras of a
tailrace or activate warning sirens; is warning signage at upstream recreation sites
updated during high flows; the timing of installation of removable boat barriers; etc.).
The findings should be documented and recommendations provided as needed.

Operations and Maintenance Programs


The IC Team must review records of periodic and routine maintenance activities and
consider whether any are potentially indicative of underlying defects that could result in
failure. This is particularly important when a certain type of maintenance activity is
performed repeatedly over many years to varying degrees of success (which can be an
indication of a more serious underlying issue that is unrecognized or not being addressed
by the maintenance activities), or is often deferred due to funding or other considerations.
The IC Team should review the procedures for identifying and requesting maintenance
items, implementing them, recording completion, evaluating the results, and notifying
appropriate regulatory agencies.

The IC Team must review the licensee’s written documentation related to regular and
periodic maintenance of project works, including:

• Maintenance tracking system used;


• Reports on identification, evaluation, and resolution of safety-related maintenance
issues;
• Documentation of completion of maintenance items;
• Inspection checklists; and
• Other items as appropriate.
The IC Team must also review written standard procedures, including what to do in the
event of floods or other emergencies. The written procedures for normal operating

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conditions, including coordination with upstream and downstream dams, should be


compared to what the operators actually do to evaluate the accuracy and
comprehensiveness of the procedures. Operator training must also be evaluated.

Additional Information for the PIR


The following sections provide details for additional information required in the PIR but
not discussed previously.

Summary of Findings
The first section of the PIR is structured to allow the IC to briefly summarize the findings
and recommendations provided in each of the subsequent sections of the PIR. The level
of detail provided should be enough to understand the findings and conclusions but
should not repeat the detailed content word-for-word.

Recommendations
Provide a table of recommendations to address deficiencies and concerns identified
during performance of the PI.

• Each recommendation presented in this section should be clear, concise, and have
one or more specific actions for the licensee to take.
• If multiple recommended actions or potential actions are provided in a single
recommendation, they should be provided as sub-recommendations (e.g., REC-
20XX-15a, REC-20XX-15b, etc.) so the licensee can more easily consider and
provide a proposed plan, schedule, and/or status update on each.
• The recommendation table should indicate the corresponding section(s) of the PIR
in which the IC Team’s rationale and supporting background information can be
found.
• The IC Team should recommend a timeline for addressing each recommendation.
Note that the Licensee may disagree with recommendations and timelines, and may
present their rationale for any disagreement in their letter transmitting a proposed plan
and schedule (refer to Section 16-7).

Project Description
The purpose of this section of the PIR is to provide the reader with a general overview of
the critical project features, methods of operation, potential failure modes, and risk.
Additional information is provided below for each of the categories.

Description of Project Features


Chapter 15 of the Guidelines requires Section 2 of the STID to contain a detailed project
description. Thus, a lesser level of detail is required in this section of the PIR. It is not

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necessary for the IC Team to completely rewrite the project description for inclusion in
the PIR; however, it is not acceptable to simply copy and paste that description without
critical review and consideration of the content. Past dam safety incidents that are critical
to the understanding of project history and performance should be discussed as well.

Standard Project Operations


The information contained in this section should give the reader an overall understanding
of how the project is operated (e.g., rule curves, seasonal restrictions, etc.) without going
into too much detail on step-by-step procedures. This section should not be confused with
the common phrase “standard operating procedures.”

Summary of Identified Potential Failure Modes


A basic understanding of the identified PFMs is critical; thus, the PIR is required to
include a summary table of the current identified PFMs for each project feature.

Summary of Project Risk


If a risk analysis has been completed, the PIR should include a brief summary of the
project risk. The intent is to help the reader understand the primary risk drivers so they
can consider the importance and value of recommendations for investigation or
remediation.

Changes Since the Previous Part 12D Report


It is important to understand what changes have occurred since the previous Part 12D
Report. The PIR provides structure for the IC(s) to document basic facts and changes to
the following information:

• Modifications to project works;


• Modifications to standard project operations;
• Hydrology;
• Seismicity; and
• Studies and previous recommendations.
Modifications to Project Works and Standard Project Operations
The IC Team should focus on modifications that have an impact with respect to dam
safety and/or public safety and provide a level of detail commensurate with the scale of
each modification. Major modifications to project works that are generally unrelated to
dam safety (e.g., a non-integral fish collection facility, recreation facilities, etc.) should
be considered and listed if they have any effect on project operations and/or public safety.

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Hydrology and Seismicity


In addition to providing a brief summary of the pertinent information related to
hydrology and seismicity, the IC Team must review data since the previous Part 12D
report to determine whether any events (i.e., storms, floods, or earthquakes) occurred that
exceed the current design parameters or are otherwise inconsistent with the assumptions
in the associated studies. The purpose of this section of the PIR is not to document a
detailed review of the hydrology and seismicity studies themselves; that level of
review is not part of the scope of a PI. However, if the IC Team determines that an
event occurred which exceeded either the previous historic record or the design basis
value, they should recommend that the licensee perform investigation/analysis to
determine the implications.

Status of Studies and Previous Recommendations


The IC Team must review the recommendations from prior Part 12D reports and
document the status of each. The scope of this task does not include providing an update
on every recommendation included with every Part 12D report ever filed on the project.
The IC Team is required to:

• Review and document the status of every recommendation from the Part 12D
Report immediately preceding the current PI.
o For any incomplete recommendation, the IC Team should state whether
they concur with the licensee’s current plan and schedule to address the
recommendation. If the IC Team does not concur, they should provide
comments.
o For any completed recommendation, the IC Team should state whether it
was addressed appropriately.
• Review and document the status of any other outstanding (incomplete)
recommendations from earlier Part 12D Reports.
The IC Team must review, list, and document the status of any outstanding or ongoing
studies related to project safety, as well as any studies related to project safety that were
completed since the previous Part 12D report.

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COMPREHENSIVE ASSESSMENTS

General
The scope of a Comprehensive Assessment is established in 18 CFR § 12.37 and
comprises the following:

• A thorough review and evaluation of prior reports, including studies and analyses
of record, site investigations, design reports and other documents, construction
records including changes during construction, as-built drawings, the STID, dam
safety incident reports (i.e., 12.10a reports), and other documentation;
• Review and evaluation of dam and public safety programs (e.g., Operations and
Maintenance Program, Public Safety Plan, Owner’s Dam Safety Program, etc.);
• Review and evaluation of instrumentation data and surveillance reports;
• A physical field inspection;
• Completion of a Potential Failure Modes Analysis and PFMA report;
• Completion of a Risk Analysis and the Risk Analysis Report; and
• Preparation of the Comprehensive Assessment Report.
This section provides more detail on the scope of each component of the CA along with
discussion of the documentation requirements. It describes the minimum expected level
of effort for preparation and performance of the CA and completion of the CAR. An
outline of the CAR, which is included in Appendix 16-D, can be used as a template and
rough guide for the contents of each section.

Review of Prior Reports


The IC Team is required “to have, at the time of the inspection under [18 CFR Part 12,
subpart D], a full understanding of the design, construction, performance, condition,
downstream hazard, monitoring, operation, and potential failure modes of the project
works” as well as “a full understanding of the risk… associated with the project works.”
This requirement is established in 18 CFR § 12.37. The review of prior reports is critical
and must be started well in advance of the field inspection, PFMA, and risk analysis to
ensure that the members of the IC Team are able to identify and evaluate potential issues.

Note that by reviewing and evaluating prior reports, the IC Team does not assume an
“Engineer-of-Record” level of responsibility for the design of the existing structures.

The FERC stresses the importance of advance review of prior reports. Remember that if
the IC Team is not adequately prepared, the FERC may require one or more IC
Team activities to be performed again, at a later date, following further review of
project records by the IC Team.

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A CAR is required to contain a review of both the STID and the analyses of record
(18 CFR § 12.37(e) and § 12.37(a), respectively). These are separate efforts – do not
conflate the review of the STID with the review of the analyses themselves. The CAR
includes separate sections to document:

• Review and Evaluation of Design and Construction (CAR Section 3)


• Review and Evaluation of Previous Analyses (CAR Section 4)
• Review and Evaluation of the STID (CAR Section 8.8)
Each of these items is discussed in more detail in the following sections.

Review and Evaluation of Design Basis and Construction

General
The importance of reviewing the design basis and project construction was explained
well by both the FAAP and the Oroville IFT, which identified several features of the
Oroville FCO chute design that were inconsistent with the current state-of-the-practice
and the original design intent. The FAAP stated that:

All parties involved in the Part 12 reviews/PFMA process or who are involved in
remediation, operation, and maintenance should be aware of the original design
and operational intent of the project components and changes made during original
and subsequent construction activities. 15

The IFT presented three questions to be answered with respect to the current state of the
practice, each of which should be addressed in the CAR:

• Is the feature consistent with current design and construction practice?


• If there are variations from current practice, do they compromise the structure and
present a risk of failure or unsatisfactory performance?
• If there is not enough information available to make those judgments, is the
potential risk sufficient to justify further study or evaluation? 16
The evaluation of the as-built structures requires that the IC Team understand the
methods of construction and the design intent such that they can identify deviations that
may affect the safety or stability of the project. For example, when conditions
encountered during construction differ significantly from those assumed by the designers,
often from limited field explorations, field personnel should communicate with the
designers to evaluate the condition and identify an appropriate solution. If that
communication does not occur or is somehow inadequate, structures can be built in a

15
FAAP Report, page 47.
16
IFT Report, page 76.

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manner that is not consistent with the presumed design intent. Thus, the IC Team’s
comparison with respect to the design intent should be based on a thorough review of
design basis reports, Board of Consultants (BOC) reports, construction records (e.g.,
photographs, progress reports, requests for information, amendments/revisions, change
orders, delivery records, quality control/assurance records, daily field reports, etc.), and
other available documentation.

The evaluation must also consider the operational intent and identify any changes that
may result in the structure experiencing previously unanticipated loading conditions or
otherwise lead to adverse performance. Changes to standard project operations – for
example, operational changes intended to address environmental concerns such as total
dissolved gases (TDG) or fish mortality, or to optimize power production – may result in
loading conditions that were not intended by the original designers.

The goal is to ensure that the project features, as-constructed and operated, reflect the
intent of the designers and that any unexpected conditions were addressed appropriately.
For example, the foundation beneath the Oroville service spillway chute (Flood Control
Outlet) was reported for many years to be hard, competent rock, but review of
construction reports revealed that was not the case. The rock anchors, which were
intended to resist uplift forces, were in some cases embedded into more soil-like material.
Another example is the installation of energy dissipation blocks to reduce TDG, which
can result in higher forces on spillways and/or reduced discharge capacity; even the spray
generated by the blocks can have significant operational effects if it freezes on critical
dam access routes or gate seals.

The IC Team is also expected to identify any differences between as-built and modern
construction methods. For example, filter design and spillway chute detailing (reinforcing
layout, joint details and foundation treatment, anchoring, drainage systems, etc.) have
changed significantly over the past fifty years. Depending on the era of construction, the
robustness of the design, and consequences of failure, inconsistency with the current state
of the practice may not present any significant implications with respect to dam safety;
however, they must be identified, evaluated, and properly documented.

Documenting the Review


This aspect of the review is documented in Section 3 of the CAR.

If the IC Team identifies any as-built features that are inconsistent with the design or
operational intent or current state-of-the-practice, they must document the inconsistencies
and evaluate the potential implications with respect to the safety and stability of project
works. As with the evaluation of the studies and analyses of record, independent
calculations may be required to justify the conclusions. If necessary, based on the
potential risk or uncertainty, the IC Team should recommend investigations and/or
analysis to address the concerns.

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Review and Evaluation of Previous Analyses

General
The IC Team’s review of the analyses must be in sufficient detail to properly evaluate the
assumptions, methodologies, calculations, results, and conclusions. The IC Team must
attempt to identify any differences or errors in analysis techniques and evaluate whether
new analyses are warranted. The IC Team must evaluate the accuracy, relevance, and
consistency with the current state of the practice of dam engineering, as described below.
It is imperative that the IC Team include members qualified to review each type of
analysis and perform independent calculations as needed.

Considerations for Review of Studies


When determining whether a completed study requires review by the IC Team, the status
of the FERC review is irrelevant. The IC Team must review all current completed studies
(i.e., those have been or are ready to be submitted to the FERC, and have not been
superseded). The IC Team may be requested to review in-progress studies (i.e., those that
have not been submitted to the FERC) on a case-by-case basis. Generally, the IC Team
will only be required to review studies completed by the date of the FERC approval of
the IC Team.

Evaluation Requirements
The regulations specify the requirements for the evaluation of the analyses of record. The
IC Team’s evaluation of the “assumptions, methods, calculations, results, and
conclusions” must:

• Address the accuracy, relevance, and consistency with the current state-of-the-
practice of dam engineering;
• Be accompanied by sufficient documentation of their rationale; and include, as
needed, new calculations by the independent consultant to verify that the
assumptions, methods, calculations, results, and conclusions in the analyses of
record are correct.
A list of types of studies for which this level of evaluation is required is provided below,
with further discussion for those items that are specifically included in the outline of the
CAR.

• Stability and stress analyses of any project feature (including embankments,


concrete structures, gates, penstocks, valves, etc.);
• Seismic hazard analyses;
• PMP and PMF studies;
• Dam breach analyses, incremental hazard analyses, and IDF evaluations;

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• Spillway analyses;
• Seepage and internal erosion analyses, including filter compatibility;
• Liquefaction evaluations;
• Foundation and/or abutment kinematic stability and/or erosion evaluations; and
• Other relevant studies, as applicable.
Note that this is not a comprehensive list and additional studies may require such
evaluation. The D2SI-Regional Engineer may occasionally provide an exemption from
reviewing specific analyses on a case-by-case basis, typically based on factors such as
how recent the study is and/or whether a Board of Consultants was convened to oversee
it. However, in the absence of an explicit exemption, it should be assumed that all
analyses of record require an in-depth review and evaluation by the IC Team.

Based on the review of each analysis of record, the CAR must contain explicit statements
documenting the IC Team’s conclusions regarding the accuracy, relevance, and
consistency with the current state-of-the-practice. Where applicable, comparisons must
also be made to criteria established elsewhere in the FERC Engineering Guidelines (e.g.,
sliding stability factors of safety for gravity dams are established in Chapter 3). The IC
Team should clearly state whether additional investigation or a new analysis is required.

Accuracy
The IC Team must review the reports, analyses, and underlying calculations for errors,
including invalid methodologies, use of inconsistent or incorrect parameters,
mathematical mistakes, etc. The IC Team is not expected to review every calculation ever
performed; however, they must perform due diligence, such as spot-checking and/or
producing limited independent calculations, to ensure that the analyses of record are
correct. The IC Team is not expected to be able to review every line of a finite element
model input file, but they must ensure that models were set up correctly with the
assumptions documented in the associated report(s), and that the output and conclusions
represent the model results and are interpreted appropriately.

Relevance
The IC Team must consider whether the analyses can answer the fundamental questions
they were performed to answer and identify any assumptions that may inhibit the
analysis’s ability to address the concerns. If an assumption or methodology prevents the
analysis from providing a valid conclusion – for example, if a finite element analysis of a
concrete gravity dam is intended to evaluate displacement during an earthquake, and the
analyst uses a tied contact at the concrete-rock interface, thus preventing any
displacement – then that analysis is not relevant. These issues must be identified to
ensure that the overall conclusion with respect to dam safety is sound.

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Consistency with the Current State-of-the-Practice


Analysis methods and design criteria change over time. It is important to periodically
reevaluate the assumptions and methods in key analyses because, after a period of time, a
modern analysis could reach a very different conclusion. For example, consider global
stability analyses for concrete gravity dams on rock foundations:

• It used to be common for stability analyses to include several hundred pounds per
square inch of cohesion at the concrete-rock interface; over time, cohesion has
been generally disregarded in favor of friction-only analyses.
• Rotational stability of gravity structures used to be expressed in terms of
“overturning safety factors.” The current methodology (at the time of this writing)
considers the length of a crack (non-compressive zone) along the dam-foundation
interface, iterating the uplift condition to determine whether or not the crack
would be expected to stabilize.
The IC Team must document the differences between the studies/analyses of record and
the modern approach. The potential implications must be evaluated to a sufficient degree
that the IC can make an informed conclusion as to whether the analysis remains
acceptable or if further investigation or remediation may be required. The FERC does not
require that an analysis be updated simply because it is out-of-date; if the IC Team
determines that the new methodology likely would not yield results that would
significantly change the understanding.

Independent Calculations
Independent calculations and/or simplified analyses may be required to justify the IC’s
evaluation, even if the conclusion is that the existing analyses are acceptable. For
example, if a gravity dam stability analysis shows adequate factors of safety and was
performed with no deviations from the current state-of-the-practice, a hand calculation
may still be necessary to demonstrate that the IC Team came to a similar numerical result
for a particular loading condition. In circumstances where deficiencies are identified in
the existing analyses, independent calculations are generally required in order to
document the potential implications of the deficiencies. The calculations are not
expected to be comprehensive or equivalent to an analysis of record.

The IC Team must use their judgement to determine an appropriate level of independent
calculations to be provided for each analysis of record. The independent calculations
must justify the IC’s conclusion as to whether the existing analyses are acceptable;
whether new analyses are or are not needed; and/or justify the urgency with which
any new analyses should be completed. Recommendations must be provided for any
critical deficiencies that the IC Team identifies.

Please note that an independent calculation performed by one IC Team for a CAR does
not constitute work that can later be “incorporated by reference” by an IC Team for a

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subsequent CAR. This would defeat the purpose of periodically performing independent
calculations.

Documenting the Review


This aspect of the review is documented in Section 4 of the CAR.

The required level of documentation will vary based on the type and criticality of the
study or analysis being reviewed, as well as the era in which it was performed. Typically,
it will not be necessary for an IC Team to reproduce a three-dimensional finite element
analysis from scratch to verify stability analysis results for a concrete gravity dam;
however, it is reasonable to spot-check a three-dimensional analysis using simplified two-
dimensional stability analyses. Similarly, transient pressure and penstock stress
calculations are relatively straightforward, and the IC Team can quickly confirm whether
the conclusions are valid. The table below provides some examples of the level of
confirmatory review that may be warranted. This table should not be interpreted as
strict requirements, either as a minimum acceptable or maximum required. Many
types of analyses, concerns, and types of project features are not listed in the table.
The IC Team should include as much or as little as they believe represents the breadth
and depth of their review.

Table 11: Analysis of Record Review Calculations (EXAMPLE)


Type of Concern/Condition Potential Documentation
Analysis
Probable Changes in relevant HMR Document correct HMR used
Maximum Statewide PMP developed Document review of watershed
Precipitation conditions and any changes that
(PMP) would affect PMP
Probable General confirmation of PMF Validate basin average rainfall
Maximum Flood development Validate volume of runoff and
(PMF) losses over the watershed
(inches)
Confirmation of peak inflow and
hydrographs
Project General confirmation of project Confirm tailwater and spillway
hydraulics ability to pass required flows. rating curves.
Confirm availability of
generating unit flow during flood
events
Confirm elevations of project
structures
Confirm wave run-up
calculations

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Type of Concern/Condition Potential Documentation


Analysis
Penstock stress NDT shows significant section Calculations of stress under
analyses loss. normal and transient conditions.
Gravity dam General confirmation of stabilityTwo-dimensional stability
stability of gravity sections. analysis of a representative
analyses critical section of the structure
Verification of design
assumptions, i.e. drains needed
for adequate stability and
verification of effectiveness
Document review of foundation
investigation to confirm
foundation friction angle used in
analyses
Documentation of zero cohesion
analyses or justification of
cohesion value if cohesion is
used
Embankment General confirmation of Identification of critical cross
slope stability embankment slope stability. section location.
analyses Appropriate embankment zoning
and foundation materials.
Appropriate method of analysis.
Verification of input parameters
(unit weight, shear strength,
water pressures, etc.).
Appropriate search limits and
failure surface shape employed.
Are results valid?
Filter General confirmation of internal Review of construction records
compatibility erosion potential between and boring logs to verify grain
various materials. size distributions and ensure they
are representative of the
materials..
Filter compatibility calculations
using industry accepted standards
for each material boundary along
flow path.

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Type of Concern/Condition Potential Documentation


Analysis
Liquefaction Ground motions increased and Appropriate methods used for
and deformation there are potentially continuous site investigation and
analyses liquefiable layers beneath the characterization of material
embankment shells. properties.
Appropriate method of analysis.
Appropriate seismic loading
selected.
Verification of input parameters.
Are results valid?
Radial (tainter) General confirmation of Structural analysis considering
gates structural adequacy of radial trunnion friction
gates. Review latest detailed
inspection/confirm all
recommendations completed or
scheduled
Seismic analysis of gates (if
required)
Confirm gate operability history
(binding, AAR, hoist issues, gate
chain issues, etc)

The outline of the CAR provides sections for documenting the review and evaluation of:

• Geology;
• Seismicity;
• Hydrology;
• Hydraulics of dams, spillways, other water conveyances, and dam breach studies;
• Analyses of Dams and Water Conveyances;
• Analyses of Spillway Gates, Other Gates, and Reservoir Control Devices; and
• Other relevant studies, such as erosion of abutments and/or the foundation; filter
compatibility; and internal erosion and/or piping.
Additional sections should be added as needed for studies not specifically listed herein.
Some specific considerations are provided below for each section listed above.

Geology
Site geology is one of the most important considerations for any project. It is important to
ensure that sufficient explorations have been performed and that they have been

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interpreted appropriately. Inaccurate or incomplete summaries of foundation information


can have a major impact on project safety. There are many case histories that include
sliding of structures along planes within the foundation, dissolution of foundation
materials, movement of rock blocks, liquefaction of soil layers, etc. It is important to
identify such concerns before they become dam safety issues.

The IC Team must review the available geologic information and current geologic
interpretation to ensure that they are consistent. If the IC Team can make alternative
interpretations from the same data, the IC Team should present the alternatives and
provide recommendations that may help resolve disagreement. The review should pay
particular attention to foundation material properties, foundation treatment, and how the
geologic interpretation(s) may affect project structures, including structural stability,
seepage, and other conditions. If the IC Team’s interpretation differs from the previously
accepted interpretation, the IC Team should provide recommendations for any additional
information that needs to be collected to confirm or disconfirm their conclusions.

Seismicity
General project seismicity must be reviewed periodically due to the ever-changing
understanding of ground motions and their effects on dams and appurtenant structures.
The IC Team must review seismic sources, foundation characteristics (e.g., shear wave
velocity), attenuation relationships, and other pertinent information that may affect the
seismic design parameters.

Hydrology
General project hydrology must be reviewed periodically due to the ever-changing state-
of-the-practice with regard to development of the Probable Maximum Precipitation
(PMP), Inflow Design Flood (IDF), and/or Probable Maximum Flood (PMF). The IC
Team must review the relevant studies and evaluate the parameters and methodologies,
including storm selection, transposition, infiltration, snowmelt, and other pertinent
information that may affect the PMP and PMF. The required level of review may vary
depending on whether the IDF is the PMF. The IC Team may also need to evaluate
whether project hydraulics (discussed in the subsequent section) were implemented
correctly in the reservoir routing model.

For site-specific PMP studies, any significant storm events that occurred within the
transposition limits of the project since the last review should be identified and
evaluated/screened for their potential impact to the PMP.

Significant flood events that occurred since the last review should be identified and
evaluated as to whether they may affect the hydrologic model for the watershed. Such
events also offer a valuable opportunity for the IC Team to compare real-life observations
with model predictions, which may help the IC Team evaluate the validity of the models.

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Hydraulics
Dams
Overall project hydraulics must be evaluated, including the loading on the dam
(headwater and tailwater elevations) and the various parameters used to develop the
stage-discharge curves. As with hydrology, it may be helpful to compare model
predictions versus real-life observations during high flow events.

Spillways
As illustrated by the Oroville spillway incident, the hydraulics of lined (and unlined)
spillway chutes must be considered and evaluated to ensure safe project operation during
high flow conditions. The IC Team must consider the potential for stagnation pressure,
slab jacking, cavitation, scour, erosion, overtopping of side walls, and other potentially
adverse conditions that may render a spillway unsafe to operate, unable to release
required discharges, unstable, or otherwise present a safety risk to the project.

Other Water Conveyances


The hydraulics of other water conveyances, including canals, penstocks, flumes, tunnels,
etc., must be evaluated to ensure that they are capable of conveying the expected flows.
The IC Team must review the assumptions, methodologies, and findings of analyses
related to hydraulic capacity and integrity of water conveyances (e.g., cavitation potential
in tunnels or penstocks).

Dam Breach Studies


Dam breach studies must be reviewed periodically to ensure that Emergency
Management Agencies (EMAs) have accurate inundation maps in the event of a dam
safety emergency. The IC Team must review the dam breach models – including the
input and output files, if possible – and evaluate the assumptions, methodologies, and
results. Confirm whether inundation maps have been generated for project features that
would result in significantly different inundation limits and/or consequences than the
primary structure.

Stress and Stability


Each stress and stability analysis of record must be reviewed. In general, the list of
analyses reviewed should match the list of analyses discussed in Section 8 of the STID. If
the review identifies project features for which there are no available stress or stability
analyses of record, or if the analyses of record are fundamentally flawed, the IC Team
must consider whether to perform independent calculations as part of the CAR or simply
recommend the completion of new analyses. Some questions that should be answered
include:

• Will the analysis address a concern related to credible identified PFM?

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o If so, is the PFM classified as “credible and urgent”?


• Do any visual observations or instrumentation data suggest that there is an active
or developing PFM or other performance issue which could be evaluated by the
analysis?
• Is the analysis necessary to evaluate the project feature with respect to the FERC
Engineering Guidelines? (For example, any concrete gravity section must be
evaluated for stability while not all penstocks require a stress analysis for transient
loading.)
Depending on the answers to the above questions, the IC(s) should include independent
calculations with the CAR. Otherwise, they should recommend new analyses and a
suggested schedule for completion.

Erosion of Abutments and/or the Foundation


The IC Team must review any studies related to the erodibility of foundation or abutment
material. Potential sources of erosion include normal or excessive releases from spillways
and valves, overtopping or outflanking of project structures, and breaches of penstocks or
other water conveyances.

Internal Erosion and Filter Compatibility


The IC Team must review any evaluations of filter compatibility involving embankment
zones and the foundation. Material gradations should be reviewed to ensure the
appropriate procedures were followed for the material types and that filter evaluations
were based on representative information. As-constructed material gradations should be
used when available rather than relying on design gradations. The full range of gradations
should be used for each material type in the analyses, not just the average or mean
gradation. Filter compatibility should be evaluated for each material boundary along
potential flow paths in, along, and through the embankment and foundation.

Overtopping
The IC Team must review and evaluate overtopping analyses for dams, other structures,
and the abutments thereof that may be subjected to overtopping; this includes evaluations
of the overtopping itself (e.g., over the crest of an embankment dam, a low-lying natural
feature, etc.) as well as jet impact on abutments or the foundation. When abutments or the
foundation comprise more than one type of material along the length or height, the IC
Team must consider each area that may be affected or impacted by flowing or falling
water, the potential for each to erode, and the potential consequences.

Other Studies
The IC Team must review and evaluate other studies as applicable to the project under
consideration. Typically, the Part 12D Inspection Reminder Letter issued by the FERC-
RO will list specific studies of concern, though the general rule is that if a study has been

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or should be summarized in the STID, it should be reviewed and evaluated by the IC


Team.

Review of the STID and Digital Project Archive (DPA)

General
Previously, the Part 12D guidance conflated the review of the STID with the review of
the analyses of record. Now, the purpose of the IC Team review of the STID is more
clearly stated:

• Evaluate whether the information in the STID accurately represents the source
material;
• Evaluate whether the STID fulfills the requirements of Chapter 15 of the
Guidelines; and
• Evaluate whether the STID is sufficiently comprehensive to be useful in the event
of a dam safety emergency and during future project reviews (e.g., subsequent
CAs and PIs). This could include ensuring that all relevant reference materials are
provided in the Digital Project Archive.
The depth of review of the STID should be commensurate with those goals.

Documenting the Review


This aspect of the review is documented in Section 8.8 of the CAR.

For each section of the STID, the CAR must include a clear statement that the IC Team
reviewed the information, along with the findings and any recommendations. The IC
Team must document any recommended updates to the STID as well as any deficiencies
in the comprehensiveness of the DPA. Section 1 of the STID (Potential Failure Modes
Analysis Report and Risk Analysis Report) is a special case – refer to Section 16-6.6.4 of
this Guideline.

Note that licensees may, at their discretion, elect to have the IC Team complete the
necessary updates to the STID and DPA instead of recommending specific updates. This
can streamline the process since the IC Team should already be reviewing the source
material in the DPA and the summary information in the STID. In this case, the IC Team
would still need to document the changes for review by the FERC, either by listing
recommendations, providing a detailed revision log, and/or providing a tracked changes
version of the STID.

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Potential Failure Modes Analysis and Risk Analysis

General
This aspect of the review is documented in Section 7 of the CAR. Limited information is
provided in this Guideline; refer to Chapters 17 and 18 of the Guidelines for additional
details regarding PFMAs and risk analyses, respectively. Depending on who facilitates
the PFMA/risk analysis and prepares the PFMA Report/risk analysis report, the IC’s
responsibilities vary with respect to the CAR; refer to Section 16-6.6.4 for details. As
discussed in Section 16-3.3.2.1, the licensee should carefully consider the role of the
IC(s) in conducting and documenting the PFMA and risk analysis.

Potential Failure Modes Analysis


18 CFR § 12.37(f) requires that the CA include a PFMA, which is one of the most critical
aspects of a CA.

Required Activities for a Comprehensive Assessment PFMA


The PFMA during a CA comprises more than a review of the previous PFMA Report.
Each PFMA must draw from the knowledge, experience, and creativity of the
personnel present, who will vary from PFMA to PFMA. Chapter 17 of the Guidelines
provides a significant amount of information regarding the process, qualifications, best
practices, and other useful information for performing a PFMA. With respect to a CA, a
PFMA must follow these steps:

• Begin each PFMA with a brainstorming session that discusses each project feature
and the ways in which it could fail under various loading conditions. During the
brainstorming session, the PFMA team – including the facilitator and any
other participants – must not refer to any previous PFMA Report or a
prepared list of common PFMs. Members of the PFMA team should do all
necessary preparatory work ahead of the PFMA, including reviewing background
information and taking note of any ideas for candidate PFMs.
• After the brainstorming is complete for every project feature, the team may
refer to the previous PFMA Report(s) and/or prepared lists of common PFMs to
identify items that were overlooked or to fill in gaps in the brainstormed
information. It is important not to refer back to prior materials until the
brainstorming is complete because if the team does not identify a particular PFM,
their motivation or confidence may be adversely affected. The result of this step
is a list of candidate PFMs to be screened.
• For each candidate PFM, the PFMA team completes the description, evaluation,
and screening processes, though it will be slightly different depending on whether
the candidate PFM was previously identified:

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o For brainstormed PFMs that were previously identified and documented in


a prior PFMA Report, the PFMA team may use the existing documentation
as a guide. The PFMA team reviews the existing documentation as a group;
evaluates the information provided in each section of the PFM description;
makes any necessary updates; and screens the PFM.
o For candidate PFMs not previously identified, the PFMA team follows the
steps to describe and screen the PFM, as documented in Chapter 17.

Documenting the Comprehensive Assessment PFMA


The findings of the CA PFMA must be documented in a PFMA Report, the format of
which is discussed in Chapter 17 of the Guidelines. Each PFMA Report contains a
significant amount of information and requires a great deal of effort to prepare, review,
and finalize. If the information contained in the previous PFMA Report was accurate –
and relevant facts, conditions, and the state of the practice have not changed – the
existing documentation may still be applicable. Thus, the PFMA Report does not have
to be written from scratch for each CA. However, the PFMA team must critically
review all of the information during the process described above.

If a previous PFMA Report is used as the basis for compiling the new PFMA Report, the
PFMA team must ensure that it is consistent with the most recent guidance available in
Chapter 17 of the Guidelines. In addition, by using the previous PFMA Report as the
starting point for the new PFMA Report, the party responsible for preparing the
PFMA Report takes ownership of the entire PFMA Report, not just the
updates/revisions to the PFMA Report.

Risk Analysis
Unless a written exemption is provided in advance by the Regional Engineer,
18 CFR § 12.37(g) requires a CA to include a risk analysis. Chapter 18 of the Guidelines
provides additional details regarding the scope and performance of a semi-quantitative
risk analysis as part of a CA.

Requirements for Review and Evaluation


There are special considerations related to the review of the PFMA Report and risk
analysis report. With regard to most aspects of the CA, the IC Team is expected to review
and evaluate the work of others (e.g., analyses of record, STID, special inspection
reports, etc.). The PFMA and risk analysis are such integral parts of the CA that a
licensee may develop a scope of work that tasks the IC Team with performance of the
PFMA and/or risk analysis and preparation of the report(s) thereon.

If the IC Team is responsible for performance and preparation of either the PFMA Report
or risk analysis report, it is unnecessary for the IC to evaluate that report separately since
preparation of either report implies that the IC is in concurrence with the contents. Thus,

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the CAR outline contains separate information requirements depending on whether the
PFMA and/or risk analysis report was prepared by the IC Team or another party.

If the IC Team is not responsible for performance and preparation of either the PFMA
report or risk analysis report, they will be expected to thoroughly review, evaluate, and
comment on the report(s). The IC has the discretion to emphasize or de-emphasize any of
the “team findings” presented in the PFMA or risk analysis report(s). It also allows for
incorporation of any new information, results of analyses, or other findings that may have
come to light during the IC’s inspection and report. The IC will be expected to verify the
accuracy of information in the report(s) and provide recommendations for updating
information, changing PFM dispositions, risk estimates, etc.

If as a result of the detailed inspection, the IC Team finds new or varying information or
has a professional opinion that necessitates revision of the findings of the PFMA or risk
analysis, the IC Team would provide the licensee with the appropriate revisions as a
supplement to the related report. For example, an IC Team could observe conditions that
were not considered in an existing PFM description but could be steps in the PFM
progression. The IC Team could prepare a fully developed revised PFM description as a
supplement to the PFMA report, or a revised risk estimate as a supplement to the risk
analysis report. After completion of FERC review and acceptance of the supplement, the
licensee would then provide copies to all holders of the STID with a request to append
the supplement to the PFMA and/or risk analysis report. The licensee’s cover letter
transmitting the revision to the PFMA and/or risk analysis report should discuss the
reason for the revision including who developed the supplemental PFMA and/or risk
analysis and its potential impact on project safety. That “updated” PFMA and/or risk
analysis would then be the foundation for the next Part 12D Independent Consultant
inspection report.

Observations and Evaluations of Performance


This section of the CAR has been structured to help ensure that findings are thoroughly
documented and evaluated for each project feature. Four headings, listed below, are
required for each project feature.

Field Inspection Observations


Review and Evaluation of Instrumentation Data and Surveillance Reports
Evaluation with Respect to Potential Failure Modes
Conclusion
The evaluation of PFMs for each feature must consider both the field inspection findings
and an independent interpretation of instrumentation data and surveillance reports. It is
not acceptable to rely entirely on previous interpretations, nor is it acceptable to
state that instrumentation data does not indicate a potential issue simply because it
is not changing over time.

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The CAR must include a discussion of the field observations relative to each of the
identified potential failure modes as well as the Independent Consultant’s own
assessment of the significance of the identified potential failure modes; whether any other
(previously unidentified) potential failure modes may exist; and conditions that have
changed and may impact previous conclusions regarding potential failure modes. The
CAR must provide sufficient documentation to support whatever the stated conclusion is
with respect to each identified PFM and the overall suitability of the feature for continued
operation.

The overall conclusion for each project feature should be clear and based on the
discussion that precedes it. It is not necessary to reiterate information as long as the
rationale is apparent from the preceding discussion. The requirements of physical field
inspection and review of instrumentation data and surveillance reports are discussed
below.

Physical Field Inspection


The requirement for a physical field inspection is established in 18 CFR § 12.37(b). The
physical field inspection must include a detailed visual observation of all physically
accessible project features by one or more members of the IC Team. Each portion of the
inspection should be observed by at least one Independent Consultant, plus any members
of the IC Team qualified to evaluate that type of project feature (e.g., a structural
engineer should not be the primary inspector for an embankment dam). The Bureau of
Reclamation Safety Evaluation of Existing Dams (SEED) Manual [Bureau of
Reclamation (1995)] may be used as a reference for general procedures related to the
inspection of dams and project works.

Reservoir Rim
The IC Team must inspect the reservoir rim during a CA to evaluate any credible PFMs
and, if there are none, whether any new conditions could warrant reevaluation of
previously dismissed (excluded or ruled out) PFMs. While it may be sufficient to observe
the reservoir solely from the dam crest during a Periodic Inspection, it will likely require
greater attention during a CA.

The scope of the reservoir rim inspection must be sufficient to observe all areas that
could contribute to the initiating conditions in any identified PFMs, regardless of whether
the PFMs are considered credible or not. In some cases it may be preferable for the
inspection to occur from a boat or aircraft, though inspections from the ground may
suffice. Drone video or recent satellite imagery may also be used, though satellite
imagery must be recent and not have potentially critical areas obscured by cloud cover.
The IC Team should ensure that the methods they use to perform the reservoir rim
inspection are sufficient for confirming facts and conditions related to relevant PFMs
(e.g., surveys may be helpful for evaluating low spots in generally flat areas that may

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overtop during floods or as a result of a seiche). The proposed method of performing the
reservoir rim inspection should be described in the Part 12D Inspection Plan.

Spillway Chutes
Spillway chutes, whether lined or unlined, should be inspected up close to the extent
possible. The FERC recognizes that some spillways are too steep to be inspected without
extensive preparation, and that in some cases a licensee or IC Team may choose to have
only a specially-trained (e.g., rope access) team perform the inspection for safety
considerations. In that case, it may be acceptable for the IC Team to review a recent
detailed inspection report (e.g., a focused spillway assessment report) prepared by
another qualified party. It is preferred, but not required, that one or more members of the
IC Team at least observe the special inspection.

If the IC Team reviews a detailed inspection report, it is important to ensure that the
report is timely and relevant; therefore, it is strongly preferred that the special inspection
occur within one year prior to the CA. It can be acceptable for the IC Team to review an
older report as long as the special inspection occurred since the previous Part 12D
inspection and no events have occurred that would reasonably be expected to change the
condition of the spillway chute (e.g., high spill events, seismic loading, chute
maintenance/repairs, etc.). The Regional Engineer may provide additional requirements
related to the spillway chute inspection in the inspection reminder letter.

Gate Operations
If possible, the relevant members of the IC Team should observe full-height spillway gate
test operations. In many cases, this may require significant coordination (e.g., placement
of dewatering bulkheads, a low reservoir, preexisting high flows to limit downstream
effects, etc.). If circumstances do not permit the observation of full-height gate tests, the
IC Team still must observe test operations of a representative number of gates such that
they can evaluate the gate performance, licensee’s standard operating procedures, and
provide informed conclusions.

The test operations must include use of the primary hoist equipment and, if possible,
backup lifting procedures (note that this aspect of the field inspection is exclusive to a
CA and is not included in a PI). For any traveling (shared) hoists, the tests must include
the full procedure to operate at least two gates; for example:

• Open and close gate #1;


• Detach traveling hoist from gate #1;
• Move traveling hoist to gate #2;
• Attach traveling hoist to gate #2; and
• Open and close gate #2.

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Every power source available for operation of gates should be tested and used to operate
a gate during the inspection. If there are multiple backup power sources – for example, a
diesel-powered generator, a portable propane-powered generator, and a battery bank –
each should be used. If the licensee’s standard operating procedures include other
emergency methods for operating a gate – such as using a lifting beam and portable
crane, or attaching a hand crank – the IC Team should confirm that the required
equipment is available and that licensee staff are sufficiently familiar with the
procedures. Demonstration of gate operation using these procedures is optional but may
be recommended based on the criticality to project safety.

Some projects may have restrictions such as ramping rates, water availability, circuit
switching, etc. that will require advance coordination to ensure that the IC Team is able
to observe and evaluate gate and backup power operations. Any circumstances that would
prevent the IC Team from observing these operations must be clearly described in the
Part 12D Inspection Plan for review and evaluation by the FERC. If necessary, the
licensee must propose an alternate scope that accomplishes the same goal, and the FERC
reserves the option to deny the alternate scope and require that the IC Team observe the
procedures as described above.

Other Special Inspection Reports


The IC Team must review all reports on special inspections that have occurred since the
previous Comprehensive Assessment or within the preceding ten years, whichever period
is longer. Some examples of special inspection reports are:

• Underwater inspections;
• Hands-on gate inspections;
• Focused spillway assessments;
• Special access inspections (confined space, rope access, etc.), including of
penstocks and tunnels;
• Camera scope inspections of drains, conduits, and other features;
• Aerial drone inspections; and
• Other inspections as applicable.
Inspections of Typically Inaccessible Features
Appropriate provisions must be made to enable the IC Team and FERC staff to inspect
typically inaccessible features or those that require special provisions (e.g., confined
spaces), except those that are adequately covered by a special inspection report that will
be reviewed and evaluated by the IC Team. When determining whether a particular
feature requires inspection, the IC Team should consider whether there are any credible
PFMs related to the feature; if there are none, the feature might not need to be inspected.

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Review of Instrumentation Data and Surveillance Reports


The requirement to review surveillance and monitoring data is established in
18 CFR § 12.37(c). This is a critical component of the CA and is equally important
as the field inspection. Previous dam safety incidents may have been avoided, or the
urgency of response and remediation reduced, had the instrumentation data been
reviewed with more careful consideration.

The review of monitoring data must be a critical, thorough review of the data itself. It is
not acceptable for the IC Team to review only the instrumentation data plots prepared by
the licensee and included in the annual DSSMR submittal. The licensee must provide the
IC Team with all available data, through the date of the field inspection, such that the IC
Team can identify, describe, and evaluate:

• Relationships between instrument readings and environmental factors such as


reservoir elevation, precipitation, air/water temperature, project operations, etc.;
• What constitutes expected behavior for each instrument (and, by extension, what
constitutes unexpected behavior);
• Whether there are any historic readings or ongoing trends that may indicate
adverse behavior; and
• Whether any established thresholds, automated alarms, etc. are set such that they
will trigger appropriate follow-up actions prior to substantial progression of a
potential failure mode.
The discussion of instrumentation data in the CA-PIPR should cover the time period
through the most recent DSSMR; the CAR should include data through the date of the
field inspection.

The IC Team must review surveillance reports to supplement their field inspection
observations. The findings of previous inspections should be compared to the current
findings, with discrepancies and changes in performance noted.

In order to properly complete this aspect of the CA, the IC Team must understand the
purpose, function, and expected behavior of each instrument or feature. It is not sufficient
to simply identify trends or threshold exceedances, or the lack thereof. It is not acceptable
to rely entirely on a previous interpretation or to state that data is acceptable simply
because the behavior is consistent over time. The IC Team must thoughtfully consider
each instrument and surveillance report; describe the expected behavior of each; and
identify any observations or data that is unexpected or indicative of adverse performance.
Statistical analysis may be required for complex, heavily-instrumented projects or large
data sets. It is not acceptable to state that previous evaluations did not identify any
problems, that no changes in behavior were identified, and thus the data is

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acceptable. The documented rationale may refer to previous evaluations but must not
rely on them.

The IC Team should consider collecting manual readings of critical monitoring


instruments (e.g., piezometers, crack gages, plumblines, etc.) during the field inspection.
This provides valuable information about the condition of the project at the time of the
inspection. It also gives the IC Team an opportunity to review the licensee’s manual data
collection procedures. Any readings collected should be noted and evaluated in this
section.

Review and Evaluation of Dam and Public Safety Programs


The requirement for review of dam and public safety programs is established in
18 CFR § 12.37(d); the review of the DSSMP is required by 18 CFR § 12.37(c). In each
section, the CAR must include a clear statement that the IC Team reviewed the
information, along with any findings and recommendations. Some additional
considerations are discussed below.

This aspect of the review is documented in Sections 8.1 through 8.6 of the CAR.

Owner’s Dam Safety Program


Typical Scope
The IC Team is not required by the FERC to perform a detailed review of the written
ODSP document or conduct extensive, focused interviews with project staff. The FERC
requires only that the IC Team be sufficiently familiar with the written ODSP and the
FERC ODSP guidance that the IC Team is able to evaluate whether the ODSP is being
implemented appropriately with respect to the project being inspected.

During preparation and performance of the CA, the IC Team should take note of any
actions, requests, responses to unusual events, or other situations that may indicate
licensee staff do not strictly adhere to the tenets espoused in the written ODSP. These
should be noted in the CAR; if there are no such situations, that should be stated.

Potential Modified Scope


In some situations, a licensee may find benefits in having the IC Team perform an
external audit or peer review of the ODSP as part of the CA. This would be at the
discretion of the licensee and would require FERC approval in advance. The Part 12D
Inspection Plan would have to clearly incorporate the external audit or peer review and
the IC Team would have to include one or more individuals qualified to perform that
review. If a licensee pursues this option, then this section of the CAR should refer to a
standalone report documenting the external audit/peer review consistent with Chapter 19
of the Guidelines.

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Performance Monitoring Program (Surveillance and Monitoring)


The IC Team must be familiar with the written protocols for surveillance of the project
works, including any inspection checklists the licensee maintains, which are typically
documented in a Dam Safety Surveillance and Monitoring Plan. It is important to
understand the layout of existing instrumentation as well as the installation details,
function, performance, and reading frequency/procedures (both manual and automated).
The depth of review must be sufficient so the IC Team:

• Understands the function and purpose of each instrument and surveillance


procedure;
• Knows what observations or recorded data may indicate the onset or progression
of a PFM, or conditions that are otherwise out-of-the-ordinary with respect to
general health; and
• Can make informed recommendations for improvements (e.g., new
instrumentation, changes to procedures, etc.).
The evaluation must consider both the surveillance procedures and instrumentation and
their effectiveness at monitoring for the identified PFMs as well as general health. For
each PFM, the IC Team must review whether the monitoring program is adequate to
detect the onset of the PFM, or conditions that may contribute to or “allow” development
of the PFM, in a timely manner. The ICs should provide comments that relate historic
and current performance indicators (i.e., monitoring data) to identified PFMs. The ICs
should also address whether the instrumentation at the dam is functioning properly and is
adequately maintained.

The ICs should specifically consider whether inspections during unusual conditions (e.g.,
high pool elevations not previously experienced, seismic events, etc.) or related to
inaccessible features are of an appropriate scope and performed at an appropriate
frequency.

The IC Team must also review procedures for and the timing of licensee engineering
review (e.g., data reduction and analysis) of instrumentation data and surveillance
reports, and any reporting of adverse or unusual findings to more senior personnel for
investigation or other action (e.g., an operator collects data, dam safety engineer
evaluates it and identifies a potential issue, and escalates the concern to the CDSE or
higher level management).

Hazard Potential Classification


Hazard potential classifications are defined in 18 CFR § 12.3(b)(13) and Chapter 1 of the
Engineering Guidelines. The IC Team is required to review the conditions upstream and
downstream of a project to evaluate:

• Whether the current hazard potential classification is appropriate, and

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• Whether any changed conditions warrant reconsideration of the sudden failure


assessment (SFA) or other procedures in the Emergency Action Plan.
The IC Team must review the conditions upstream and downstream of project structures
and take note of any changes to development (e.g., a significant increase in the
population at risk, new developments below structures classified as low or significant
hazard, or new structures closer to the project than those previously identified). When
evaluating whether the hazard potential classification remains appropriate, the IC Team
should also consider the effects that failure may have on environmental and publicly-
disclosed cultural resources; critical infrastructure, such as major highways and
municipal water supplies; and other conditions as applicable.

Note that significant changes in the population at risk or other consequences (i.e., an
order of magnitude or more) can affect the conclusions of the risk analysis.

A visual review is preferred but, in some cases, conversations with the licensee and a
review of aerial or satellite imagery can suffice. It is important to note the date of
publicly available imagery, as it can be out-of-date in remote areas. Conversations with
licensee staff regarding changes to downstream development should be documented. The
findings must be documented in the CAR and appropriate recommendations provided.

Emergency Action Plan


Typically, no members of the IC Team will be required to have specialized experience in
emergency response procedures. However, an EAP is such an important component of a
dam safety program that the IC Team must have sufficient general knowledge to review
and comment on it. There may be cases in which emergency response personnel would
be appropriate to include as part of the IC Team.

If the project is subject to 18 CFR Part 12, Subpart C, the IC Team must review the EAP,
including the inundation maps (the review of dam breach analysis is discussed separately,
as a component of the review of the hydraulic analyses of record). The review must
consider the written EAP document as well as the licensee’s training procedures,
coordination with outside persons and agencies, and the familiarity of project staff with
their roles and responsibilities.

If any EAP activations or functional/full-scale exercises have occurred since the previous
Part 12D Report, the IC Team must review and evaluate the after-action report and
licensee’s plan of action.

If a Sudden Failure Assessment (SFA) has been performed for the project, the IC Team
must review the assumptions, procedures, and evaluate the findings. Any project with an
excess response time (ERT) less than 15 minutes, including negative ERTs, should be
reviewed with a greater level of scrutiny. The performance or non-performance of
automatic notification systems should be confirmed and their effectiveness evaluated,

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based on the results of periodic testing thereof. The IC Team should observe operations
of critical warning devices during the field inspection or at another time, if possible.
Warning systems should be evaluated for their adequacy in providing timely warning;
redundancy in detection and notification; and the potential for single points of failure in
the warning system.

If an SFA has not been performed, the IC Team should review and comment on whether
one should be performed.

Public Safety Plan


The IC Team must be familiar with the current Public Safety Plan (PSP) and the warning
signs, sirens, and access restrictions described therein. The IC Team is not expected to
contain a public safety expert; however, one or more members should be adequately
familiar with industry standards and the FERC Guidelines for Public Safety at
Hydropower Projects. The intent is for the IC Team to take a common sense approach to
reviewing and evaluating the public safety measures that are in the immediate vicinity of
project structures and/or that are directly related to standard project operations. The IC
Team is not expected to increase the scope of the field inspection to observe specific
public safety devices.

During the field inspection, the IC Team should take note of any devices that are missing,
damaged, inoperable, or otherwise not as described in the PSP and should consider
whether any new devices are warranted based on their observations. The evaluation
should also consider any project-related public safety incidents that have occurred since
the previous Part 12D Inspection; standard operating procedures that may have the
potential to cause a hazardous situation for members of the public recreating at or near
the project site (e.g., prior to operation of spillway gates, do operators view cameras of a
tailrace or activate warning sirens; is warning signage at upstream recreation sites
updated during high flows; the timing of installation of removable boat barriers; etc.).
The findings should be documented and recommendations provided as needed.

Operations and Maintenance Programs


The IC Team must review records of periodic and routine maintenance activities and
consider whether any are potentially indicative of underlying defects that could result in
failure. This is particularly important when a certain type of maintenance activity is
performed repeatedly over many years to varying degrees of success (which can be an
indication of a more serious underlying issue that is unrecognized or not being addressed
by the maintenance activities), or is often deferred due to funding or other considerations.
The IC Team should review the procedures for identifying and requesting maintenance
items, implementing them, recording completion, evaluating the results, and notifying
appropriate regulatory agencies.

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The IC Team must review the licensee’s written documentation related to regular and
periodic maintenance of project works, including:

• Maintenance tracking system used;


• Reports on identification, evaluation, and resolution of safety-related maintenance
issues;
• Documentation of completion of maintenance items;
• Inspection checklists; and
• Other items as appropriate.
The IC Team must also review written standard procedures, including what to do in the
event of floods or other emergencies. The written procedures for normal operating
conditions, including coordination with upstream and downstream dams, should be
compared to what the operators actually do to evaluate the accuracy and
comprehensiveness of the procedures. Operator training must also be evaluated.

Evaluation of Spillway Adequacy

General
The basic requirements for the evaluation of spillway adequacy are defined in 18 CFR
§ 12.39 of the Commission’s regulations. The IC Team must also identify and address the
effects of the overtopping of non-overflow structures. This aspect of the review is
documented in Section 8.7 of the CAR. While this section will likely refer to information
included in various PFM descriptions and elsewhere in the CAR, it is important to clearly
and thoroughly evaluate the ability of the project to safely pass flows.

Conditions Affecting Spillway Capacity


The IC Team must consider the potential to occur, and effects of, abnormal conditions
that may reduce the usable discharge of the spillway below its rated discharge capacity.
18 CFR § 12.39(a)(3) lists four types of situations that must be specifically evaluated in
the Comprehensive Assessment Report. Each category is discussed in more detail below.
Other conditions not listed below should be considered, as appropriate.

Misoperation
Misoperation of gates, valves, and other discharge devices generally refers to situations
such as jammed gates, gates that open more slowly or later than planned, or gates
operated in a manner inconsistent with the standard protocols, resulting in adverse
conditions. For example, if there is a gate operation protocol for a total of ‘X’ feet of
opening based on the headwater elevation, and a staffing shortage results in late
operations and a total opening significantly less than required, the peak reservoir
elevation may be higher than it would have been had the gates been operated normally.

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Misoperation also includes situations in which a person takes actions that deviate from
the required procedure, due to inadequate training, confusion, a simple mistake, or an
operator’s personal concerns that their action to increase discharge may result in flooding
downstream.

Failure to Operate
Failure to operate can be seen as an extreme case of misoperation: instead of operating
slower or not as scheduled, the device does not operate at all. The resulting lack of
discharge may result in a surcharged reservoir. Some examples of “failure to operate”
scenarios include:

• When instructed to open or close via a SCADA system, push of a button, etc., a
gate or valve simply does not respond;
• The equipment required to operate the feature (e.g., a traveling hoist) is out of
service or otherwise nonfunctional;
• Gates or valves are sealed shut due to the accumulation of ice;
• Broken lifting equipment, such as wire ropes, chains, or their attachment points to
a gate; or
• Primary power is unavailable and the fuel supply for the backup system is
corrupted or empty.
This condition also applies to tripped devices, such as flashboards, which may be
designed with components that are supposed to fail under a certain load (e.g., a surcharge
reservoir elevation). If the designed-to-fail components are built out of specification – the
diameter is too large or the material is too strong, for example – the devices may not trip
and total discharge will be less than intended. Erodible fuse plugs are also susceptible to
this type of situation due to material gradation, compaction, frozen ground, vegetation
growth, pilot channel elevation, etc.

Blockage
Debris blockage of spillways and/or reservoir control valves has occurred in the past and
is a common potential failure mechanism at many projects. The IC Team must evaluate
the type of debris typical in the reservoir (and consider whether there is debris observed
during the reservoir rim inspection), whether that is representative of the debris to be
expected during flood events, the potential for such debris to block discharge pathways,
and the effect that may have on the reservoir elevation. The IC Team must consider the
potential for the failure of debris collection booms, which may result in significant debris
mats arriving at a spillway all at once instead of in smaller, more manageable quantities.

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Debilitating Damage
The IC Team must consider and evaluate the potential effects of severe damage to any
component of the spillway (e.g., gated control structure, weir, lined or unlined chute,
etc.), which may result in one or more of the following:

• Discharging through the spillway could exacerbate damage and potentially


progress to an uncontrolled release of the reservoir (e.g., headcutting through a
damaged chute causing undermining and instability of the control structure);
• Project staff may be reluctant to initiate or continue operations of the spillway;
• The project may be operated in a way inconsistent with standard operating
procedures (e.g., to permit a reservoir surcharge or prefer the use of secondary
discharge options).
While licensee actions during hypothetical situations cannot be predicted reliably, it is
useful to discuss the potential for such a situation and what options the licensee would
have for managing it. A well-known example of debilitating damage affecting project
operations is the February 2017 Oroville Dam spillway incident, which is discussed in the
preface to this Guideline.

Consequences of Inadequate Capacity


In addition to discussing how the spillway capacity could be affected, the CAR must
include an evaluation of the effects thereof. Some questions that could be answered
include:

• What frequency of flood could be passed safely (e.g., without reservoir surcharge,
without overtopping, etc.) if one gate were unavailable? Two gates?
o Gate unavailability should be consistent with the postulated cause. At a
project with ten gates, random failure of operating equipment may
realistically affect only one gate at a time; however, an earthquake
disabling unanchored hoist equipment may affect every gate.
• If a gate remains closed during flood conditions and a surcharge, would the gate
be expected to fail? This may require consideration of operating equipment and
power source reliability, including review of historic gate operation data with
respect to gate misoperation and/or failure to operate.
• How much discharge capacity could be lost due to debris plugging? Could a local
surcharge result in overtopping of an erodible structure, or prevent access to or
damage gate operation equipment?
Some of these questions assume that the project is able to pass the IDF/PMF without
overtopping. If a project feature is assumed to overtop even with all discharge devices at
full capacity, the evaluation of the effects of inadequate capacity must consider the

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magnitude of increase in overtopping as well as the effect that would have on the project
structures.

Documenting the Review


The CAR is required to include a narrative discussion of the IC Team’s review and
evaluation of each of the four conditions listed above, as well as any other potential
conditions that may result in a reduction of spillway capacity.

Additional Information for the CAR


The following sections provide details for additional information required in the CAR but
not discussed previously.

Summary of Findings
The first section of the CAR is structured to allow the IC to briefly summarize the
findings provided in each of the subsequent sections of the CAR. The level of detail
provided should be enough to understand the findings and conclusions but should not
repeat the detailed content word-for-word, with the exception of the section regarding the
Dam Safety Risk Classification (DSRC), as discussed below.

Risk Analysis and Dam Safety Risk Classification (DSRC)


This section should provide a summary of the findings from the PFMA, risk analysis, and
provide a discussion of the recommended DSRC and justification.

Potential Failure Mode Analysis


Provide a brief summary of the findings of the PFMA. This should include a summary
of:

1. The number of candidate potential failure modes identified by the team;


2. The number of potential failure modes ruled out and excluded from the risk
analysis; and
3. A list of potential failure modes with a short description/title for each.

Level 2 Risk Analysis


The findings of the Level 2 risk analysis should be summarized in this section. Risk
analysis results should be discussed and portrayed as indicated in Appendix D.

The Level 2 risk analysis results should be summarized and portrayed for the following
risk measures, as appropriate:

1. Societal Incremental Life Safety Risk

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2. Individual Incremental Risk (Annual Probability of Failure)


3. Financial/Damage State Risk
4. Non-Breach Risks
Economic risks and other consequences should also be identified, evaluated, and
discussed, as appropriate.

Dam Safety Risk Classification (DSRC)


Provide a discussion of the recommended DSRC and justification. The DSRC system
provides consistent and systematic means to communicate risk for appropriate actions to
address the dam safety issues and deficiencies of FERC regulated dams. FERC regulated
dams are assigned a DSRC informed by the probability of failure and the incremental
risk. The risk associated with the non-breach scenario will be estimated and
communicated, but it will not be used to inform the assignment of the DSRC.

The five risk classes used by the FERC dam safety risk management program are
summarized in Table 4-1 in Chapter 4 of the FERC Risk-Informed Decision Making
Guidelines, March 2016. The five classes depict the range of dams from those critically
near failure to those considered to have very low risk and meet all FERC Engineering
Guidelines. Between these two extremes are three classes that define distinctly different
levels of actions and urgencies of action that are commensurate with a transition from
critically near failure to very low risk. The choice of five action classes is to provide
adequate parsing in the range of levels of actions.

Recommendations
Provide a table of recommendations to address deficiencies and concerns identified
during performance of the CA.

• Each recommendation presented in this section should be clear, concise, and have
one or more specific actions for the licensee to take.
• If multiple recommended actions or potential actions are provided in a single
recommendation, they should be provided as sub-recommendations (e.g., REC-
20XX-15a, REC-20XX-15b, etc.) so the licensee can more easily consider and
provide a proposed plan, schedule, and/or status update on each.
• The recommendation table should indicate the corresponding section(s) of the
CAR in which the IC Team’s rationale and supporting background information
can be found.
• The IC Team should recommend a timeline for addressing each recommendation.
Note that the Licensee may disagree with recommendations and timelines, and may
present their rationale for any disagreement in their letter transmitting a proposed plan
and schedule (refer to Section 16-7).

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Project Description
The purpose of this section of the CAR is to provide the reader with a general overview
of the critical project features, methods of operation, potential failure modes, and risk.
Additional information is provided below for each of the categories.

Description of Project Features


Chapter 15 of the Guidelines requires Section 2 of the STID to contain a detailed project
description. Thus, a lesser level of detail is required in this section of the CAR. It is not
necessary for the IC Team to completely rewrite the project description for inclusion in
the Comprehensive Assessment Report; however, it is not acceptable to simply copy and
paste that description without critical review and consideration of the content. Past dam
safety incidents that are critical to the understanding of project history and performance
should be discussed as well.

Standard Project Operations


The information contained in this section should give the reader an overall understanding
of how the project is operated (e.g., rule curves, seasonal restrictions, etc.) without going
into too much detail on step-by-step procedures. This section should not be confused with
the common phrase “standard operating procedures,” which should be discussed in the
review of the associated section of the STID (Section 8.8.4 of the CAR).

Summary of Identified Potential Failure Modes


A basic understanding of the identified PFMs is critical; thus, the CAR is required to
include a summary table of the current identified PFMs for each project feature.

Summary of Project Risk


If a risk analysis has been completed, the CAR should include a brief summary of the
project risk. The intent is to help the reader understand the primary risk drivers so they
can consider the importance and value of recommendations for investigation or
remediation.

Changes Since the Previous Part 12D Report


It is important to understand what changes have occurred since the previous Part 12D
Report. The CAR provides structure for the IC(s) to document basic facts and changes to
the following information:

• Modifications to project works;


• Modifications to standard project operations;
• Hydrology;
• Seismicity; and

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• Studies and previous recommendations.


Modifications to Project Works and Standard Project Operations
The IC Team should focus on modifications that have an impact with respect to dam
safety and/or public safety and provide a level of detail commensurate with the scale of
each modification. Major modifications to project works that are generally unrelated to
dam safety (e.g., a non-integral fish collection facility, recreation facilities, etc.) should
be considered and listed if they have any effect on project operations and/or public safety.

Hydrology and Seismicity


In addition to providing a brief summary of the pertinent information related to
hydrology and seismicity, the IC Team must review data since the previous Part 12D
report to determine whether any events (i.e., storms, floods, or earthquakes) occurred that
exceed the current design parameters or are otherwise inconsistent with the assumptions
in the associated studies. The purpose of this section of the CAR is not to document a
detailed review of the hydrology and seismicity studies themselves; that information
is to be provided elsewhere in the CAR.

Status of Studies and Previous Recommendations


The IC Team must review the recommendations from prior Part 12D reports and
document the status of each. The scope of this task does not include providing an update
on every recommendation included with every Part 12D report ever filed on the project.
The IC Team is required to:

• Review and document the status of every recommendation from the Part 12D
Report immediately preceding the current CA.
o For any incomplete recommendation, the IC Team should state whether
they concur with the licensee’s current plan and schedule to address the
recommendation. If the IC Team does not concur, they should provide
comments.
o For any completed recommendation, the IC Team should state whether it
was addressed appropriately.
• Review and document the status of any other outstanding (incomplete)
recommendations from earlier Part 12D Reports.
The IC Team must review, list, and document the status of any outstanding or ongoing
studies related to project safety, as well as any studies related to project safety that were
completed since the previous Part 12D report.

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FOLLOW-UP AND CORRECTIVE MEASURES

General
The requirement to submit a plan and schedule to address the IC’s recommendations is
established by 18 CFR § 12.41. The plan and schedule must be submitted within 60 days
of the date the report is filed with the Regional Engineer.

In addition to the IC’s recommendations, include a table documenting any identified risk
reduction measures associated with PFMs classified as “urgent” or “credible,” along with
the licensee’s plan and schedule for implementation of those risk reduction measures.
Note that only “urgent”, “credible”, and “insufficient information” PFMs have to be
included in this table. Financial/damage state PFMs can be included at the option of the
licensee.

No Action and Alternatives


A licensee is not required to carry out a recommendation or risk reduction measure
simply because an IC has recommended it. However, adequate justification must be
provided in the plan and schedule for any recommendation or risk reduction measure for
which the licensee proposes no action or an alternative. The level of justification required
will vary depending on the criticality of the recommendation or risk reduction measure; it
may be as simple as a paragraph expressing disagreement and stating that implementing
the recommendation would have no dam safety benefit, or it may require detailed
analysis.

If a licensee intends to propose no action or a substantially different alternative, they


should discuss it in a conference call with both the IC Team and the FERC after the
report is filed but prior to submittal of the plan and schedule. Any proposal for no action
or an alternative action must be reviewed and accepted by the FERC prior to
implementation. The FERC may still require the licensee to complete recommendations
provided by the IC Team or risk reduction measures regardless of any justification
provided by the licensee.

An IC Team might recommend that the licensee perform a new analysis because they
were unable to review an analysis of record, as required by 18 CFR § 12.38(c)(3). If the
licensee has a sincere belief that the analysis exists and they were simply unable to locate
the documentation in time for the IC Team to review and evaluate it in their report, the
licensee may propose a two-part plan and schedule to address the recommendation:

1. A reasonable period of time, not to exceed six months from the date the report is
filed with the Regional Engineer, to locate the analysis, provide it to the IC Team
for their review and evaluation, and file a supplement with the Regional Engineer.
2. If the analysis still cannot be located, a new analysis should be performed on a
schedule proposed by the licensee, pending acceptance by the Regional Engineer.

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Emergency Corrective Measures


There are special provisions related emergency corrective measures, which are discussed
in 18 CFR § 12.41(b).

If the IC Team observes or identifies any “condition affecting the safety of a project or
project works,” as defined in 18 CFR § 12.3, the IC Team must immediately notify the
licensee. The IC Team is still required to document recommendations for emergency
corrective measures in the PIR/CAR, even if the recommendations are complete by the
time the PIR/CAR is submitted to the FERC.

Upon being notified by the IC Team of “a condition affecting the safety of a project or
project works,” the licensee must notify the Regional Engineer, pursuant to 18 CFR
§ 12.10(a). The licensee is required to provide a plan and schedule for addressing the
recommendations, even if they are completed by the time the plan and schedule is
submitted (within 60 days following submittal of the PIR/CAR).

While emergency corrective measures will likely be addressed on a timeline faster than
non-emergency corrective measures, they must still be documented in:

• The PIR/CAR;
• The licensee’s plan and schedule to address the IC Team’s recommendations; and
• Periodic updates, described in the subsequent section.

Periodic Updates
The licensee must prepare and maintain a status report of all the outstanding and ongoing
IC’s recommendations, and those that were completed since the previous update, in
accordance with 18 CFR § 12.41. At least once per year – either as a standalone
submittal, as an attachment to another annual submittal (such as the DSSMR), or in
advance of the FERC dam safety inspection – the status report must be submitted to the
Regional Engineer. A suggested format for providing this information is included as
Table 12. Any changes to the plan and schedule that have not previously been proposed
to and accepted in writing by the Regional Engineer must be identified and justified in
the cover letter and explicitly requested by the licensee.

Table 12: Suggested Format for Tracking IC Team Recommendations


Licensee’s Response Date of FERC
Date of Current Letter
Rec. Current Status / Accepting Plan
No. IC Team’s Rec. P&S Plan Schedule and Schedule

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Comprehensive Assessment Review Meeting


Within 60 days after the CAR is submitted by the licensee to the FERC, the IC Team is
required to present a summary of their findings, conclusions, and recommendations to the
licensee and the FERC. This meeting provides an opportunity for the Independent
Consultant(s) to present their observations and findings from their inspection and
assessment of the project and for FERC to clarify specific points after completing the
initial review of the CAR. The meeting also provides the Licensee an opportunity to ask
questions that may inform their plan and schedule for addressing the IC Team’s
recommendations.

An example meeting agenda is shown in Table 13. The suggested attendees at a CAR
review meeting include:

• Licensee staff: CDSE/CDSC, project engineer, other personnel as needed.


• IC Team: every IC should attend, plus any key supporting team members (e.g.,
those who were responsible for reviewing project features with urgent PFMs;
made recommendations for new analysis or investigation; or identified any critical
findings or evidence of active or developing PFMs in the instrumentation data,
inspection findings, or review of previous analyses and construction records).
• FERC: Regional Engineer and/or Branch Chief, project engineer, other members
of the D2SI review team as needed.
Table 13: Typical Comprehensive Assessment Review Meeting Agenda

Item Topic Lead Duration


1 Introductions FERC 5 min
2 Opening Statements FERC 5 min
Licensee/IC 5 min
3 Comprehensive Assessment Summary Presentation IC(s) 30-45 min
4 Questions from FERC Review Team FERC 20-30 min
5 Summary of Follow up Activities, if any FERC 0-10 min
6 Concluding Remarks Licensee/IC 5 min
FERC 5 min
7 Adjourn

A brief outline of the information required to be discussed in the CA Review Meeting


Presentation is included as Appendix 16-F.

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The review meeting may take place in person or remotely (e.g., via videoconference,
teleconference, or webinar), as dictated by time, location, and other considerations.

Scheduling, coordination, and logistics (webinar/call in information) of the review


meeting must be provided by the Licensee or IC. The meeting will be led by a FERC
representative. Depending on the size and complexity of the project, it is anticipated that
the meeting will last less than two hours.

A review meeting is not required after submittal of a PIR, unless directed by the
D2SI-Regional Engineer.

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REFERENCES
Bureau of Reclamation (1995), “Safety Evaluation of Existing Dams”, Denver, Colorado.

Federal Emergency Management Agency (1979), “Federal Guidelines for Dam Safety”,
Washington, D.C.

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Appendix A: Outline for the Part 12D Inspection Plan

APPENDIX 16-A OUTLINE FOR THE PART 12D INSPECTION PLAN

This appendix provides a brief outline for a Part 12D Inspection Plan, which is to be
submitted by the licensee to the FERC in advance of a Part 12D Inspection
(Comprehensive Assessment or Periodic Inspection) for review and evaluation by the
FERC. The Part 12D Inspection Plan must be accepted by the FERC in order for the
inspection to proceed.
Cover Letter
1. Project Information
• List the Project Name, FERC Project Number, and state(s)
• Identify the type of inspection (Comprehensive Assessment or Periodic
Inspection) and whether it includes a Risk Analysis (for a CA only).
• Provide a brief description of the project features to be inspected. For a CA
only, describe the proposed method of performing the reservoir rim inspection.
2. Independent Consultant Team Proposal
a. Identification of Technical Disciplines Required
Include information formatted similar to the example table below, as
discussed in Section 16-3.3.2.1.
IC Team Technical and Expertise Requirements
Relevant Technical
Project Feature Disciplines Issues/Technical Complexity

b. Proposed Independent Consultant Team and Facilitator(s)


Include information formatted similar to the example table below, as
discussed in Section 16-3.3.2.2.
Name Role Technical Discipline(s)

3. Schedule
Include the information discussed in Section 16-3.3.3.

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Appendix A: Outline for the Part 12D Inspection Plan

Attachments
Resumes
Include resumes for the proposed IC(s), as discussed in Section 16-3.3.2.3, and any IC
Team supporting members if identified by name at this time.
Additional Supporting Information, as needed

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CHAPTER 16, APPENDIX B: OUTLINE FOR THE PERIODIC INSPECTION


REPORT (PIR)

This appendix provides the outline for the report on a Periodic Inspection conducted in
accordance with 18 CFR § 12.35. As established by 18 CFR § 12.36, any Periodic
Inspection Report (PIR) is required to follow this format and provide the appropriate
information in each section.
The PIR must be filed as a searchable format that permits high resolution printing
and copying of text and graphics.
Note: In this appendix, the phrase “the previous Part 12D Report” refers to the most
recent report on a Periodic Inspection, Comprehensive Assessment, or an inspection
performed in accordance with the rules established by FPC Order 315 or FERC Order
122.

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GENERAL PROVISIONS

Cover Page
The cover page must include, at a minimum:
• Project name and number;
• The name of each Independent Consultant (IC) and, if applicable, the consulting
firm each represents;
• The date of the Periodic Inspection Report (PIR).
Table of Contents
Include a table of contents listing each section of the PIR and page numbers. Include
separate lists of tables and figures.
Identification of IC Team and Field Inspection Participants
• Identify each member of the Independent Consultant Team and their role.
• List all field inspection participants.
• Refer to the dates of the FERC letters requiring the Part 12D Inspection and
approving the Part 12D Inspection Plan and IC Team, which should be included
and referenced as Appendix A and Appendix B, respectively.
Certification
• Provide a reference to FERC Order 880 and 18 CFR § 12.36(g)
• Signature(s) and Professional Engineer (PE) stamp(s) of Part 12D Independent
Consultant(s).
Note: By signing the PIR, each Part 12D Independent Consultant is stating that the entire
report has been developed by them and/or under their direction. The IC must make a clear
statement that the findings, conclusions, recommendations, and evaluations in the report
represent their opinion and that, if there are multiple ICs, any disagreement between the
ICs is documented accordingly.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

SECTION 1: FINDINGS AND RECOMMENDATIONS

1.1 General Conditions and Evaluation of Performance


Summarize the findings of the physical field inspection and evaluation of instrumentation
data and surveillance reports. List any project features that were not considered to be in
satisfactory condition as well as any potential failure modes (PFMs) that were judged to
be active or developing.
Clearly state whether the Independent Consultants (ICs) judge the project to be suitable
for continued safe and reliable operation; if not, clearly indicate the reason(s) therefore
and reference the corresponding sections of the PIR for details. List any immediate
actions that are required to ensure safety, stability, and/or structural integrity of the
project.
Summarize any major modifications to project works or standard project operations. State
whether any hydrologic or seismic events have occurred that would warrant reevaluation
of the associated analyses.
1.2 Potential Failure Modes and Risk
Summarize the findings with respect to potential failure modes. Include a tabular
summary of all urgent, credible, insufficient information, and financial/damage state
PFMs and for each:
• Clearly state whether any observations or findings indicate the PFM is in progress,
developing, neither, or if the initiating loading condition has not occurred; and
• State whether any unusual related conditions were observed during the inspection
and review of instrumentation data and surveillance reports.
An example table is provided below. Please note that this table serves a different purpose
than the complete PFM documentation required later in the PIR.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

The example table provided below is for informational purposes only, to demonstrate
the expected level of detail.

PFM No. PFM Type PFM Status Unusual Conditions Unusual


During Inspection? Findings from
Instrumentation
Data?
LE-IE-N-2 Credible Potentially Yes Yes
developing
LE-SS-FL-4 Damage Loading has N/A N/A
State not occurred
SP-FS-N-6 Credible Not No Yes
developing
SP-FS-FL-6 Credible Loading has N/A N/A
not occurred
PH-FS-N-8 Damage Not Yes No
State developing

A formal review of previously performed Potential Failure Modes Analysis (PFMA) and
risk analysis is not required as part of the PIR. However, the IC must be familiar with the
previously identified PFMs for the project in preparation for the site inspection and
review and evaluation of the dam safety program. As part of this effort the IC should
provide any observations and recommendations related to revisions, additions, or
deletions relative to the previously identified and evaluated PFMs and risk analysis
results. If the IC has no observations or recommendations relative to the previously
identified PFMs or risk analysis results, then state so, otherwise provide a summary.
1.3 Review and Evaluation of Dam and Public Safety Programs
1.3.1 Owner’s Dam Safety Program
Summarize the evaluation of the Owner’s Dam Safety Program (ODSP). State whether
the ODSP is being implemented appropriately with respect to the project under
consideration, based on the experiences of the IC Team during the course of conducting
the Periodic Inspection (PI). Summarize identified human and organizational factors.
1.3.2 Dam Safety Surveillance and Monitoring Program
Summarize the evaluation of the surveillance and monitoring program. Clearly state
whether the surveillance procedures and instrumentation program are sufficient for
monitoring the identified PFMs and general health of the project features.

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1.3.3 Hazard Potential Classification


Summarize the evaluation of the hazard potential classification and clearly state whether
the current classification is appropriate. Identify any significant changes to the population
at risk since the previous Part 12D Inspection.
1.3.4 Emergency Action Plan
Summarize the evaluation of the Emergency Action Plan (EAP), including the document
itself, response provisions, and the licensee’s training procedures. Clearly state whether
the EAP is adequate or if any enhancements are recommended.
1.3.5 Public Safety Plan
Summarize the evaluation of the Public Safety Plan (PSP) and clearly state whether the
current public safety measures are sufficient for restricting public access to hazardous
areas.
1.3.6 Operations and Maintenance
Summarize the evaluation of the Operations and Maintenance (O&M) programs. Clearly
state whether the O&M programs are sufficient for ensuring safe and reliable operation of
the project.
1.4 Recommendations
Provide a tabular summary of all recommendations made elsewhere in the PIR (an
example table is provided below). The full context of and rationale for each
recommendation should be provided only in the appropriate section of the PIR.
Rec. PIR Section Summary of Recommendation Suggested
No. Reference Schedule

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

SECTION 2: DESCRIPTION OF PROJECT FEATURES AND


OPERATIONS

2.1 Location and Purpose


Provide the hazard potential classification; project location, stream, and nearest
community; a general physical description of the project; and reservoir storage capacity.
State the authorized project purposes (e.g., run-of-river power generation, water storage,
flow augmentation, flood management, etc.) and construction period.
If the project comprises part of a multi-development project system, describe how the
project discussed in this PIR fits into the overall operation of the project system.
Provide a project overview photograph or satellite image, annotated to identify all project
features. Include drawings of the plan, profile, and typical sections of each project feature
in Appendix C: Project Figures.
2.2 Description of Project Features
Provide a comprehensive description of the project features, including relevant
dimensions, physical properties, historical context, etc. Generally, this will be the same
information provided in Section 2 of the STID, though it is important that the IC Team
review all relevant project information such that they can describe project features and
not simply copy and paste the information from the STID. The order in which the project
features are discussed should be logical; guidance is provided below.
• For a project with a primary water-retaining feature (i.e., a main dam), that feature
should be discussed first, followed by its appurtenances (e.g., wing dams,
spillways, powerhouses, etc.).
• For a project that has a long dam that comprises multiple types of sections of equal
scale (e.g., left and right embankments, non-overflow gravity sections, a water-
retaining intake-powerhouse section, and a gated spillway section), it is
recommended that project features be discussed from left-to-right or right-to-left,
whichever makes the most sense for the project.
• For a project in which the primary feature is a canal or other water conveyance,
the order of discussion should begin at the diversion dam/intake/etc. and continue
along the canal or water conveyance.
• For a PIR that covers multiple developments, it is recommended to discuss the
developments beginning at the development furthest upstream and progressing
downstream.

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The order in which the features are discussed should also be consistent with the order of
discussion in other sections of the PIR (e.g., Section 4: Field Inspection Observations and
Interpretation of Monitoring Data).
Additional details are provided below regarding the information to be provided for
various types of project features.
Dam(s)
For each dam, dike, and canal, provide the information listed below that is relevant to the
particular type of structure:
• Type of dam (e.g., embankment, concrete gravity, arch, buttress, etc.);
• Structural height and hydraulic height;
• Crest elevation, length, width, and surface material (e.g., asphalt pavement,
unpaved, etc.);
• Briefly describe any embankment construction method (i.e., rolled fill, semi-
hydraulic/hydraulic fill, zoned embankments, homogenous fill, etc.). For zoned
fills a general description of the materials comprising each zone should be
included;
• Other relevant dimensions as applicable (e.g., monolith width for concrete dams;
radius for arch dams; minimum core width and filter widths for embankments;
etc.)
• Upstream and downstream slopes (H:V) and describe any slope protection;
• The location, dimensions, and purpose of any galleries;
• Briefly describe the foundation conditions (soil, bedrock, etc.); and
• Describe any key foundation features (e.g., location and depth of grout curtain,
location and depth of drainage curtain, location and depth of cutoff wall, etc.).
Spillway(s)
Describe any spillway(s) that are part of the project. For each, describe:
• The type of release facility (e.g., uncontrolled overflow, radial crest gates, etc.)
and list the crest elevation;
• The location of the spillway (e.g., center of dam, which abutment, etc.);
• The approach condition and any inlet structures;
• Description of the discharge path (e.g., unlined channel, lined channel, stilling
basin, etc.) along with pertinent details and dimensions;
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• Details and dimensions of other components as applicable; and


• The discharge capacity (and associated reservoir elevation).
For gated spillways, also include:
• The number and type of gate(s), their dimensions, methods of operation, and
sources of power (primary and backup);
• A description of any anchorage (post-tensioned or passive), wheels, trunnions,
etc.; and
• A brief description of any major modifications to the gates since original
construction.
Outlet Works
Describe any outlet works that are part of the project. For each:
• Describe any intake structure, upstream conduit, gate chamber, downstream
conduit, chute, stilling basin, and discharge channel, and provide pertinent details
and dimensions (including materials, diameter, length, etc.);
• List key elevations (e.g., intake sill, regulating gates, etc.);
• Describe the route of any conduit or tunnel and whether it passes through an
embankment, concrete section, abutment or foundation (and if so, whether it is
alluvium or rock), etc.; and
• List the discharge capacity (and associated reservoir elevation).
Water Conveyances
For each water conveyance, including penstocks:
• Identify the purpose of the conveyance and state the total length;
• Provide relevant dimensions (length and height/width/diameter/etc.) and describe
the materials for each distinct section, as well as the beginning and ending
stations;
• Describe any pressure-relief systems (e.g., surge tanks/towers, pressure-reducing
valves, tunnel lining drainage holes, etc.); and
• For elevated conveyances, describe the support and restraint systems.
Powerhouses
For each powerhouse:

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• Identify the location of the powerhouse and general operation protocols (e.g.,
peaking, base load, etc.);
• Describe the number and type of turbines, their rated generation capacity, and
discharge capacity;
• List any key elevations, such as the tailwater level that would result in flooding of
the powerhouse; and
• State if the powerhouse is required to be operational to pass flood flows.
Document any standard operating procedures required to ensure operability.
Other Features
List and describe any other relevant project features and provide a level of detail
commensurate with the importance of the feature.
Dam Safety Incidents
Provide a brief summary of previous dam safety incidents (failures, near-failures,
misoperations, etc.) and any resulting modifications or remediation.
2.3 Summary of Operations
General Information
Describe who (organization, company, agency, etc.) operates the dam.
Discuss where project operations personnel live (general vicinity, time and distance from
the project) and how often the operator visits the project. Describe the routes used for
access by project personnel as well as any haul routes that may be used to move
equipment or supplies in the event of a dam safety emergency. Briefly describe any
procedures used to prepare the project for winter, or to ensure that project works remain
operational during periods of cold weather.
Reservoir Operations
Describe the typical reservoir cycle (annual). Include graphical depictions of any
reservoir rule curves and minimum storage/flow requirements as applicable. List the
maximum water surface elevation to date. List the maximum historic releases and
associated dates through the spillway, outlet works, and powerhouse. Describe the safe
downstream discharge channel capacity and what damages may occur above that level (if
known).
Gate Operations
Describe any standard protocols related to operations of spillway gates and other
discharge pathways (e.g., powerhouse, outlet works, etc.). For example, identify:

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

• Lead and following gates/valves;


• Any preferentially operated gates/valves and the reasons therefore (e.g., due to
erosion or tailwater concerns);
• Gates/valves connected to automatic-operation controls;
• Allowable differentials between adjacent gates;
• Any procedures to safely allow discharge through powerhouse units without load;
and
• Other information as needed.
Describe all mechanisms and methods for operating gates, including traveling (shared)
hoists, dedicated hoists, and formalized backup procedures (e.g., manual operation, use of
an electric drill to drive gears, use of a crane to raise gates, etc.). Include a discussion of
primary and back-up power sources for gates and valves, as well as alternative means of
operation (i.e., if/how a gate/valve could be operated in the event of a failure of
mechanical components of the hoist system). Describe any remote operation capabilities,
including the communication facilities that enable such operation. Discuss the availability
of personnel, including their training, as it relates to being able to operate gates in the
required amount of time.
Attachments
Include the following attachments to this section:
• Reservoir stage-storage-area curve; and
• Discharge rating curves for each spillway and any outlet works.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

SECTION 3: PROJECT STATUS


3.1 Modifications to Project Works
Identify any changes or modifications to the project works since the previous Part 12D
Report.
3.2 Modifications to Project Operations
Identify any changes or modifications to the standard project operations, which are
discussed in Section 2.3: Summary of Operations, since the previous Part 12D Report.
3.3 Recommendations of Previous Independent Consultants
Include a summary table indicating the status/disposition (e.g., complete, study in
progress, etc.) of each recommendation from the previous Part 12D report, as well as
recommendations from earlier Part 12D reports that:
• Are incomplete at the time of the current Part 12D report; or
• Were completed after the previous Part 12D report but before the current Part 12D
report.
3.4 Outstanding/Ongoing Studies
List any major studies that are outstanding or ongoing at the time of the Periodic
Inspection. Include a concise summary of the purpose of each study and its schedule for
completion.
3.5 Completed Studies
List any major studies completed since the previous Part 12D Report. Include a concise
summary of the findings and conclusions of each study. It is not necessary to duplicate all
the information that was documented in the previous section.
3.6 Summary of Operations and Maintenance Programs
List any periodic or ongoing maintenance performed to maintain the project works in safe
and reliable operating condition (several examples are listed below). Clearly indicate
when each of the maintenance programs was performed.
• Maintenance of mechanical components of spillway gate hoists and valves;
• Lubrication of radial gate trunnions and other bearings (e.g., fixed wheel gates);
• Maintenance of backup power systems;
• Patching and sealing of concrete;
• Application of joint filler in spillway chutes;
• Scour repairs;
• Etc.

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3.7 Previously Identified PFMs


Provide a summary list of previously identified PFMs (in tabular form) in accordance
with the recommendations for Table 1 provided in Chapter 17 of the Engineering
Guidelines. For projects where the PI is performed before a Comprehensive Assessment
(CA) has been completed, the previously identified PFM category (I, II, III, or IV) may
be used as the PFM disposition. Otherwise, the PFM disposition should be as defined in
Chapter 17 of the Engineering Guidelines (ruled-out, excluded, credible, urgent, or
insufficient information).
Include a listing of the PFMA team members, including the facilitator(s) and location and
dates of the previous PFMA session(s).
Provide recommendations as needed to improve the PFMA and PFMs (e.g., expanding
the descriptions, correcting inaccurate information, identifying new PFMs, etc.). Note
that the IC Team for the PIR is not expected to actually rewrite the PFMs, only to
provide recommendations for improvements based on their findings.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

SECTION 4: FIELD INSPECTION OBSERVATIONS AND


INTERPRETATION OF MONITORING DATA
The site inspection should be performed in general conformance with the inspection
guidelines provided in Bureau of Reclamation, Safety Evaluation of Existing Dams
(SEED) Manual. Where the condition of a feature is described, the IC Team should use
consistent terminology that is identified and defined at the beginning of this section of the
PIR. For example, the terms “satisfactory,” “fair,” “excellent,” etc. may be used provided
that the meaning is clearly defined and consistent.
4.1 General
The site inspection report must include the following information:
• Date of inspection.
• Names and affiliations of inspection participants.
• Operating conditions at the time of the inspection, including:
o Weather conditions on the day of the inspection (note any recent
precipitation, which could affect seepage observations);
o Reservoir and tailrace water surface elevations;
o Inflows (if known);
o Releases, including through any spillway(s), outlet works, and
powerhouse(s).
For any seismic or hydrologic events that occurred and triggered a special inspection of
any project features since the previous Part 12D inspection:
• Identify the date of the event;
• Describe the reason a special inspection was performed (e.g., magnitude of an
earthquake, amount of discharge through the spillway, etc.); and
• Ensure that the findings of the inspection are discussed with respect to the relevant
project features.
For each project feature, include the subsections listed below. The project features should
be discussed in the same order as listed in Section 2.2: Description of Project Features.

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4.2 [Name of Project Feature 1]


4.2.1 Field Inspection Observations
Discuss the observations of the IC Team members during the field inspection. Provide
representative photographs with the text or clear references to photographs included in
Appendix E: Inspection Photographs
4.2.2 Review and Evaluation of Instrumentation Data and Surveillance
Provide a thorough review and evaluation of any instrumentation data collected to-date.
Discuss what constitutes expected behavior of each instrument and identify any trends or
unusual data (e.g., outside the expected range or historic range, or indicative of poor
instrument maintenance or procedures). Interpret and evaluate the data with respect to
performance of the project feature. Include in the body of the report, as needed, annotated
snapshots of data along with any statistical evaluation; alternatively, reference that
information as provided in Appendix D: Instrumented Monitoring Data Plots.
Provide a summary of the findings of routine or special surveillance performed by the
licensee or third-party consultants (e.g., a diver inspection of the upstream face of a
concrete gravity dam). This should incorporate a review of licensee inspection checklists,
contractor special inspection reports, etc. Evaluate the findings with respect to
performance of the project feature.
4.2.3 Evaluation with Respect to Potential Failure Modes
For each identified PFM related to the project feature:
• Provide a clear evaluation of whether the PFM is considered active or developing,
based on field observations and the review of instrumentation data and
surveillance. If the loading condition did not occur during the report period, state
so and limit the evaluation accordingly.
• Document any changed circumstances that could influence the PFM classification
(e.g., credible, dismissed, etc.), and briefly evaluate the potential impacts thereof.
• If there are any risk reduction measures in place, evaluate the effectiveness
thereof. For any risk reduction measures that were previously recommended but
not implemented, provide an evaluation of the stated rationale for not
implementing those risk reduction measures.
State whether any field observations, instrumentation data, or surveillance indicates that
an unidentified PFM is active or developing. If necessary, address it in the PFMA.
4.2.4 Conclusion
Provide a conclusion with respect to the condition of each project feature and its
suitability for continued operation.

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4.3 [Name of Project Feature 2]


4.3.1 Field Inspection Observations

4.3.2 Review and Evaluation of Instrumentation Data and Surveillance


4.3.3 Evaluation with Respect to Potential Failure Modes
4.3.4 Conclusion
4.4 [Name of Project Feature 3, 4, etc.]
Include additional sections for project features as needed.
4.5 Overall Interpretation of Instrumentation Data
(Note: the numbering for this section will depend on the number of project features
discussed.)
Discuss and evaluate any other instrumentation data that is unrelated to specific project
features, and any previously-discussed instrumentation data that may, when considered as
a whole and not constrained to a single project feature, may provide insight into the site
and project performance (e.g., groundwater profile at site).
Evaluate whether any instrumentation readings at the various project features may
indicate site or loading conditions that are inconsistent with the current understanding of
the project.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

SECTION 5: REVIEW AND EVALUATION OF DAM AND PUBLIC


SAFETY PROGRAMS

5.1 Owner’s Dam Safety Program


If the project is subject to 18 CFR Part 12, Subpart F:
State that the project is subject to 18 CFR Part 12, Subpart F. Discuss any observations
with respect to the implementation of the Owner’s Dam Safety Program. The discussion
should be based on interactions with licensee staff during preparation, performance, and
follow-up related to the Periodic Inspection. Unless specifically requested by the FERC,
or proposed by the licensee and accepted by the FERC, the IC is not expected to provide
a level of detail and evaluation of the ODSP that constitutes an external audit as required
by 18 CFR § 12.65.
Human and organizational factors should be identified and assessed, including
organizational culture and decision-making authority.
If the project is not subject to 18 CFR Part 12, Subpart F:
State that the project is not subject to 18 CFR Part 12, Subpart F and explain why.
5.2 Dam Safety Surveillance and Monitoring Program
Summarize the frequency and scope of licensee and third-party surveillance of project
features, including the inspection of any typically inaccessible features (e.g., toe drains,
submerged conduits, etc.). A tabular format is recommended. At a minimum, the
following information should be presented:
• Frequency (e.g., daily, monthly, quinquennial, etc.);
• Type of surveillance (e.g., visual, underwater, drone, etc.);
• Project features observed; and
• Who performs the inspection (e.g., operations staff, dam safety engineer,
consultant, etc.).
Evaluate whether the current surveillance procedures are sufficient for monitoring for the
development of the identified credible PFMs. Assess the frequency of inspection of all
project features, including those inaccessible features that are related to identified
credible PFMs. As needed, recommend enhancements to the surveillance program to
monitor for the development of credible PFMs, as general health monitoring, and for
post-event monitoring (e.g., post-earthquake, post-flood, etc.).
Summarize the instrumentation program and data collection. A tabular format is
recommended. At a minimum, the following information should be presented:
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• Instrument type and location;


• Frequency of manual and automated readings (if applicable); and
• A description of instrument behavior related to environmental factors (e.g.,
reservoir level, precipitation, temperature, etc.), if applicable.
Evaluate whether the current instrumentation program is sufficient for the detection of the
identified credible PFMs. As needed, recommend additional instrumentation to monitor
for the development of credible PFMs, as general health monitoring, and for post-event
monitoring (e.g., post-earthquake, post-flood, etc.).
5.3 Hazard Potential Classification
Identify the current hazard potential classification, the date of the dam breach analysis,
downstream hazard assessment of record, and provide a concise description of the
potential impacts of a hypothetical dam failure.
Document any significant changes in the downstream development and any previously
unidentified potential impacts within the inundation zone (e.g., critical transportation
infrastructure, schools or hospitals, water treatment facilities, etc.). Identify the nearest
non-project structure and its approximate distance and time-to-impact from the dam.
Describe how the review was performed (e.g., viewed from dam, aerial or satellite
imagery, verbal reports from licensee staff, etc.).
Evaluate whether the current hazard potential classification remains appropriate; whether
it should be changed; or whether additional investigations are required to determine the
appropriate classification.
5.4 Emergency Action Plan
If the project is subject to 18 CFR Part 12, Subpart C:
Identify the dates of the most recent reprint and annual revision of the EAP.
List any EAP activations and tests (annual drills, tabletop exercises, functional exercises,
etc.) conducted since the previous Part 12D Report. Evaluate the findings of those
activations and tests and state whether any recommended revisions were implemented
appropriately.
Discuss the communication methods, response procedures, and EAP training program.
Evaluate the adequacy of each.
If the project has a Sudden Failure Assessment (SFA), evaluate the detection,
verification, notification, and Emergency Management Agency (EMA) response times.
State the total Excess Response Time (ERT) and evaluate any enhancements the licensee
has implemented or is considering, including early warning systems. Document any

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interviews with first responders, which are strongly recommended if the ERT is less than
fifteen minutes. Provide additional recommendations for enhancements as needed.
If the project is required to complete a radiological response plan under 18 CFR
§ 12.22(c), discuss and evaluate those provisions.
If the project is not subject to 18 CFR Part 12, Subpart C:
State that the project is not subject to 18 CFR Part 12, Subpart C and explain why. If any
conditions were identified such that the IC recommends the project prepare an EAP,
thoroughly describe and document the conditions. Otherwise, state that the continued
exemption is appropriate.
If the project is required to complete a radiological response plan under 18 CFR
§ 12.22(c), discuss and evaluate those provisions.
5.5 Public Safety Plan
Identify the date of the current PSP. State whether the signs and devices observed during
the field inspection were consistent with those described in the plan. Identify any
discrepancies observed.
Document any project-related public safety incidents that have occurred since the
previous Part 12D Report, as well as the licensee’s response and implementation of any
required remediation measures. Evaluate the overall effectiveness of the PSP. If needed,
recommended improvements to the signage or devices.
5.6 Operations and Maintenance
Evaluate whether any maintenance activities could indicate an active or developing
potential failure mode, whether identified or not, and discuss any necessary maintenance
that has been deferred and why. Evaluate whether the operations and maintenance
programs listed in Section 3.6: Summary of Operations and Maintenance Programs are
considered sufficient for the safe and reliable operation of the project. Recommend any
changes as needed related to implementation, training, reporting, etc.

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APPENDICES FOR THE PERIODIC INSPECTION REPORT

Appendix A: FERC Letter Requiring Part 12D Inspection


Include only the letter in the hard copy Periodic Inspection Report. Any enclosures or
attachments to the letter should be included only in the digital copy.
Appendix B: FERC Letter Approving Part 12D Inspection Plan and IC Team
Include only the letter itself in the hard copy Periodic Inspection Report. Any enclosures
or attachments to the letter should be included only in the digital copy. If multiple letters
were issued (e.g., a conditional approval requesting supplemental information, or an
approval of a change in the team members), all must be included.
Appendix C: Project Figures
Include a set of legible figures sufficient to foster a clear understanding of the project
features. The level of detail should be informative but not excessive; FERC exhibit
drawings can be used. In a departure from previous guidance, this information must be
included in the PIR; binding the STID with the PIR to eliminate duplication is no longer
an option.
• A general location map, annotated with the location(s) of project facilities,
including water conveyances, access routes, major roads, and towns;
• Plan drawings of project facilities;
• Typical sections, elevations, and profiles of key project features (e.g., dams,
spillways, powerhouses, intakes, emergency/fuse plug spillways, chute profiles,
etc.);
• Typical sections and profiles of water conveyances;
• A satellite or aerial image of the project and downstream area, annotated as
needed; and
• Spillway and tailwater rating curves.
Additional information should be provided as needed.
Appendix D: Instrumented Monitoring Data Plots
This appendix must include any instrumented monitoring data plots and/or statistical
analysis prepared by the IC Team to evaluate the data and performance of project
features, along with any plots or excerpts from previous Dam Safety Surveillance and
Monitoring Reports (DSSMRs) that are considered critical to understanding the IC
Team’s evaluation.

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It is not necessary for the PIR to reproduce every plot that has already been provided in
an annual DSSMR. The IC Team should include a list of the annual DSSMRs that were
reviewed and provide appropriate references for any plots or excerpts.
Appendix E: Inspection Photographs
The hard copy Periodic Inspection Report must include representative photographs, either
in this appendix or in Section 4: Field Inspection Observations and Interpretation of
Monitoring Data.
Digital versions of the inspection photographs must be provided on the companion digital
reference (if required) and must be available as individual files at full resolution. An
index, naming convention, or other reference system should be established so
photographs can be located easily by reviewers.
Appendix F: Inspection Checklists and/or Field Notes
Include any inspection checklists and/or field notes digitally with the PIR.
Appendix G: Operation and Maintenance Documentation
Include any operation and maintenance documentation as needed. Some examples of this
type of documentation include:
• Spillway gate testing and trunnion lubrication records;
• Backup power maintenance logs;
• Crack sealing;
• Concrete repairs; and
• Other information as needed.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

CHAPTER 16, APPENDIX C: OUTLINE FOR THE PERIODIC INSPECTION PRE-


INSPECTION PREPARATION REPORT (PI-PIPR)

This appendix provides the outline for the Pre-Inspection Preparation Report on a
Periodic Inspection conducted in accordance with 18 CFR § 12.35. Any Periodic
Inspection Pre-Inspection Preparation Report (PI-PIPR) is required to follow this format
and provide the appropriate information in each section. The requirement to provide a
PI-PIPR is established in 18 CFR § 12.42.
Several important notes regarding this appendix:
• This outline generally provides only the section headings. Unless otherwise
indicated, the information required in each section is the same information
required in the corresponding section of the Periodic Inspection Report (PIR), an
outline of which is available as Chapter 16, Appendix B. The PI-PIPR maintains
the numbering of sections in the PIR for simplicity; sections that require no
information in the PI-PIPR state that the section is a placeholder, and any
subsequent subheadings have been omitted.
• Clarification is provided in some cases to limit the expected depth of information
provided in the PI-PIPR. However, the more detail that is provided in the PI-PIPR,
the better prepared the team will be for the field inspection and preparation of the
PIR.
• Any evaluations and conclusions in the PI-PIPR are considered preliminary.
It is entirely acceptable, and even expected, for the IC Team to acquire new
information or a different understanding of the project and its components
between completion of the PI-PIPR and the PIR. The FERC does not intend to
compare the PI-PIPR to the PIR to identify changes in evaluations or
conclusions.
• The phrase “the previous Part 12D Report” refers to the most recent report on a
Periodic Inspection, Comprehensive Assessment, or an inspection performed in
accordance with the rules established by FPC Order 315 or FERC Order 122.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

GENERAL PROVISIONS

Cover Page
The cover page must include, at a minimum:
• Project name and number;
• The name of each Independent Consultant and, if applicable, the consulting firm
each represents;
• The date of the Periodic Inspection Pre-Inspection Preparation Report (PI-PIPR).
Table of Contents
Include a table of contents listing each section of the PI-PIPR and page numbers. Include
separate lists of tables and figures.
Identification of IC Team
• Identify each member of the Independent Consultant Team and their role. Attach
resumes for those IC Team members whose resumes were not included with the
Part 12D Inspection Plan.

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SECTION 1: FINDINGS AND RECOMMENDATIONS


This section is reserved as a placeholder so the numbering is consistent with the PIR. No
content is required to be provided in this section of the PI-PIPR.

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SECTION 2: DESCRIPTION OF PROJECT FEATURES AND


OPERATIONS

2.1 Location and Purpose

2.2 Description of Project Features

2.3 Summary of Operations

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SECTION 3: PROJECT STATUS


3.1 Modifications to Project Works

3.2 Modifications to Project Operations

3.3 Recommendations of Previous Independent Consultants

3.4 Outstanding/Ongoing Studies

3.5 Completed Studies

3.6 Summary of Operations and Maintenance Programs

3.7 Previously Identified PFMs

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SECTION 4: FIELD INSPECTION OBSERVATIONS AND


INTERPRETATION OF MONITORING DATA

4.1 General
For each project feature, include the subsections listed below. The project features should
be discussed in the same order as listed in Section 2.2: Description of Project Features.
4.2 [Name of Project Feature 1]
4.2.1 Field Inspection Observations
This section is reserved as a placeholder so the numbering is consistent with the PIR. No
content is required to be provided in this section of the PI-PIPR.
4.2.2 Review and Evaluation of Instrumentation Data and Surveillance
Provide a thorough review and evaluation of any instrumentation data collected to-date.
Discuss what constitutes expected behavior of each instrument and identify any trends or
unusual data (e.g., outside the expected range or historic range, or indicative of poor
instrument maintenance or procedures). Interpret and evaluate the data with respect to
performance of the project feature. Include in the body of the report, as needed, annotated
snapshots of data along with any statistical evaluation; alternatively, reference that
information as provided in Appendix D: Instrumented Monitoring Data Plots.
Provide a summary of the findings of routine or special surveillance performed by the
licensee or third-party consultants (e.g., a diver inspection of the upstream face of a
concrete gravity dam). This should incorporate a review of licensee inspection checklists,
contractor special inspection reports, etc. Evaluate the findings with respect to
performance of the project feature.
4.2.3 Evaluation with Respect to Potential Failure Modes
This section is reserved as a placeholder so the numbering is consistent with the PIR. No
content is required to be provided in this section of the PI-PIPR.
4.2.4 Conclusion
This section is reserved as a placeholder so the numbering is consistent with the PIR. No
content is required to be provided in this section of the PI-PIPR.
4.3 [Name of Project Feature 2]

4.3.1 Field Inspection Observations

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4.3.2 Review and Evaluation of Instrumentation Data and Surveillance

4.3.3 Evaluation with Respect to Potential Failure Modes

4.3.4 Conclusion

4.4 [Name of Project Feature 3, 4, etc.]


Include additional sections for project features as needed.
4.5 Overall Interpretation of Instrumentation Data
(Note: the numbering for this section will depend on the number of project features
discussed.)

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SECTION 5: REVIEW AND EVALUATION OF DAM AND PUBLIC


SAFETY PROGRAMS

5.1 Owner’s Dam Safety Program

5.2 Dam Safety Surveillance and Monitoring Program

5.3 Hazard Potential Classification

5.4 Emergency Action Plan

5.5 Public Safety Plan

5.6 Operations and Maintenance

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APPENDICES FOR THE PERIODIC INSPECTION REPORT

Appendix A: FERC Letter Requiring Part 12D Inspection

Appendix B: FERC Letter Approving Part 12D Inspection Plan and IC Team

Appendix C: Project Figures


Include a set of legible figures sufficient to foster a clear understanding of the project
features. The level of detail should be informative but not excessive; FERC exhibit
drawings can be used.
• A general location map, annotated with the location(s) of project facilities,
including water conveyances, access routes, major roads, and towns;
• Plan drawings of project facilities;
• Typical sections, elevations, and profiles of key project features (e.g., dams,
spillways, powerhouses, intakes, emergency/fuse plug spillways, chute profiles,
etc.);
• Typical sections and profiles of water conveyances;
• A satellite or aerial image of the project and downstream area, annotated as
needed; and
• Spillway and tailwater rating curves.
Additional information should be provided as needed.
Appendix D: Instrumented Monitoring Data Plots
This appendix must include any instrumented monitoring data plots and/or statistical
analysis prepared by the IC Team to evaluate the data and performance of project
features, along with any plots or excerpts from previous Dam Safety Surveillance and
Monitoring Reports (DSSMRs) that are considered critical to understanding the IC
Team’s evaluation.
It is not necessary for the PI-PIR to reproduce every plot that has already been provided
in an annual DSSMR. The IC Team should include a list of the annual DSSMRs that
were reviewed and provide appropriate references for any plots or excerpts.

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Appendix E: Inspection Photographs


This section is reserved as a placeholder so the numbering is consistent with the PIR. No
content is required to be provided in this section of the PI-PIPR.
Appendix F: Inspection Checklists and/or Field Notes
This section is reserved as a placeholder so the numbering is consistent with the PIR. No
content is required to be provided in this section of the PI-PIPR.
Appendix G: Operation and Maintenance Documentation
This section is reserved as a placeholder so the numbering is consistent with the PIR. No
content is required to be provided in this section of the PI-PIPR.

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CHAPTER 16, APPENDIX D: OUTLINE FOR THE COMPREHENSIVE


ASSESSMENT REPORT (CAR)

This appendix provides the outline for the report on a Comprehensive Assessment
conducted in accordance with 18 CFR § 12.37. As established by 18 CFR § 12.38, any
Comprehensive Assessment Report (CAR) is required to follow this format and provide
the appropriate information in each section.
The CAR must be filed as a searchable file format that permits high resolution
printing and copying of text and graphics.
Note: In this appendix, the phrase “the previous Part 12D Report” refers to the most
recent report on a Periodic Inspection, Comprehensive Assessment, or an inspection
performed in accordance with the rules established by FPC Order 315 or FERC Order
122.

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GENERAL PROVISIONS

Cover Page
The cover page must include, at a minimum:
• Project name and number;
• The name of each Independent Consultant (IC) and, if applicable, the consulting
firm each represents;
• The date of the Comprehensive Assessment Report (CAR).
Table of Contents
Include a table of contents listing each section of the CAR and page numbers. Include
separate lists of tables and figures.
Identification of IC Team and Field Inspection Participants
• Identify each member of the Independent Consultant Team and their role.
• List all field inspection participants.
• Refer to the dates of the FERC letters requiring the Part 12D Inspection and
approving the Part 12D Inspection Plan and IC Team, which should be included
and referenced as Appendix A and Appendix B, respectively.
Certification
• Provide a reference to FERC Order 880 and 18 CFR § 12.38(h)
• Signature(s) and Professional Engineer (PE) stamp(s) of Part 12D Independent
Consultant(s).
Note: By signing the CAR, each Part 12D Independent Consultant is stating that the
entire report has been developed by them and/or under their direction. The IC must make
a clear statement that the findings, conclusions, recommendations, and evaluations in the
report represent their opinion and that, if there are multiple ICs, any disagreement
between the ICs is documented accordingly.

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SECTION 1: FINDINGS AND RECOMMENDATIONS

1.1 General Conditions and Evaluation of Performance


Summarize the findings of the physical field inspection and evaluation of instrumentation
data and surveillance reports. List any project features that were not considered to be in
satisfactory condition as well as any potential failure modes (PFMs) that were judged to
be active or developing.
Clearly state whether the Independent Consultants (ICs) judge the project to be suitable
for continued safe and reliable operation; if not, clearly indicate the reason(s) therefore
and reference the corresponding sections of the CAR for details. List any immediate
actions that are required to ensure safety, stability, and/or structural integrity of the
project.
Summarize any major modifications to project works or standard project operations. State
whether any hydrologic or seismic events have occurred that would warrant reevaluation
of the associated analyses.
1.2 Review and Evaluation of Design and Construction
Summarize the findings of the review and evaluation of design and construction. List any
significant findings that may warrant reevaluation of prior conclusions with respect to
project safety.
1.3 Review and Evaluation of Previous Analyses
Summarize the findings of the review and evaluation of previous analyses. List any
previous analyses that were determined to be inaccurate, irrelevant, or inconsistent with
the current state-of-the-practice to a degree that does or may warrant reevaluation of prior
conclusions with respect to project safety.
1.4 Review and Evaluation of Dam and Public Safety Programs
1.4.1 Owner’s Dam Safety Program
Summarize the evaluation of the Owner’s Dam Safety Program (ODSP). State whether
the ODSP is being implemented appropriately with respect to the project under
consideration, based on the experiences of the IC Team during the course of conducting
the Comprehensive Assessment (CA). Summarize identified human and organizational
factors.
1.4.2 Dam Safety Surveillance and Monitoring Program
Summarize the evaluation of the surveillance and monitoring program. Clearly state
whether the surveillance procedures and instrumentation program are sufficient for
monitoring the identified PFMs and general health of the project features.

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1.4.3 Hazard Potential Classification


Summarize the evaluation of the hazard potential classification and clearly state whether
the current classification is appropriate. Identify any significant changes to the population
at risk since the previous Part 12D Inspection.
1.4.4 Emergency Action Plan
Summarize the evaluation of the Emergency Action Plan (EAP), including the document
itself, response provisions, and the licensee’s training procedures. Clearly state whether
the EAP is adequate or if any enhancements are recommended.
1.4.5 Public Safety Plan
Summarize the evaluation of the Public Safety Plan (PSP) and clearly state whether the
current public safety measures are sufficient for restricting public access to hazardous
areas.
1.4.6 Operations and Maintenance
Summarize the evaluation of the Operations and Maintenance (O&M) programs. Clearly
state whether the O&M programs are sufficient for ensuring safe and reliable operation of
the project.
1.4.7 Spillway Adequacy
Summarize the findings with respect to spillway adequacy. List any critical issues
identified with respect to the potential for misoperation, failure to operate, blockage, and
debilitating damage. Describe and evaluate the expected performance of any spillways
during the computed discharge capacity. Clearly state whether the spillway capacity is
adequate for ensuring project safety.
1.4.8 Supporting Technical Information Document
Summarize the findings of the review and evaluation of the Supporting Technical
Information Document (STID). Provide a concise description of the overall extent of
updates required to ensure the STID meets the requirements of Chapter 15 of the
Guidelines. Identify any key information that was found to be factually incorrect or
sufficiently misleading that it does or may require reassessment of previous conclusions.
1.5 Potential Failure Modes Analysis, Risk Analysis, and Dam Safety Risk
Classification
In this section, summarize the results of the potential failure mode analysis (PFMA),
Level 2 risk analysis, and the evaluation of the Dam Safety Risk Classification (DSRC).
Additional information to include for each of these topics is included below.
1.5.1 Potential Failure Modes Analysis
Summarize the findings with respect to the potential failure mode analysis. Include the
number of candidate potential failure modes identified by the team and the number of

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potential failure modes ruled out and excluded from the risk analysis. Include a tabular
summary of all urgent, credible, insufficient information, and financial/damage state
PFMs and for each:
• Clearly state whether any observations or findings indicate the PFM is in progress,
developing, neither, or if the initiating loading condition has not occurred; and
• State whether any unusual related conditions were observed during the inspection
and review of instrumentation data and surveillance reports.
An example table is provided below. Please note that this table serves a different purpose
than the complete PFM documentation required later in the CAR.

The example table provided below is for informational purposes only, to demonstrate
the expected level of detail.
PFM No. PFM Type PFM Status Unusual Conditions Unusual
During Inspection? Findings from
Instrumentation
Data?
LE-IE-N-2 Credible Potentially Yes Yes
developing
LE-SS-FL-4 Damage Loading has N/A N/A
State not occurred
SP-FS-N-6 Credible Not No Yes
developing
SP-FS-FL-6 Credible Loading has N/A N/A
not occurred
PH-FS-N-8 Damage Not Yes No
State developing

1.5.2 Level 2 Risk Analysis


Summarize the types of risks included in the Level 2 risk analysis (life safety,
financial/damage state, economic, etc.). State whether consequences other than life safety
were also considered in the risk analysis.
Include a copy of the societal incremental life safety risk matrix and provide a brief
summary of the risk-driving potential failure modes (i.e., those potential failure modes
that contribute significantly to the total risk). Provide a list of potential failure modes that
exceed the annualized probability of failure guideline of 1 E-04.

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Identify and provide a brief description of any potential failure modes that have other
significant consequences, including economic, financial/damage state, environmental,
etc. Provide a brief summary of the non-breach risks.
1.5.3 Dam Safety Risk Classification
Provide a recommended DSRC and justification. Detailed guidance related to the DSRC
Table is provided in Chapter 4 of the FERC Risk-Informed Decision-Making guidelines,
March 2016.

The example discussion provided below is for informational purposes only, to


demonstrate the expected level of detail.
This Comprehensive Assessment identified several minor dam safety actions, as
summarized above – none of which are considered urgent or major. Previously
reported dam safety concerns with cracking and spalling of the service spillway
chute slabs have been repaired by construction modifications in 2003 and these
modifications continue to be inspected and monitored. A filter berm was
constructed in 2010 over the reported uncontrolled seepage exiting from the
lower left abutment. These seepage flows have been channeled to a weir box
and seepage flows are monitored daily.
Based on the results of this risk assessment, the team was reasonably confident
that all risk-driver potential failure modes are expected to be sufficiently below
the tolerable risk guidelines. Based on the above, the ICs recommend that the
dam be classified DSRC IV (low urgency). Dams in this class have low
incremental risk, in that the combination of life, economic, or environmental
consequences with probability of failure is low, and the dam may not meet all
FERC dam safety guidelines.
1.6 Recommendations
Provide a tabular summary of all recommendations made elsewhere in the CAR (an
example table is provided below). The full context of and rationale for each
recommendation should be provided only in the appropriate section of the CAR.
Rec. CAR Section Summary of Recommendation Suggested
No. Reference Schedule

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SECTION 2: DESCRIPTION OF PROJECT FEATURES AND


OPERATIONS

2.1 Location and Purpose


Provide the hazard potential classification; project location, stream, and nearest
community; a general physical description of the project; and reservoir storage capacity.
State the authorized project purposes (e.g., run-of-river power generation, water storage,
flow augmentation, flood management, etc.) and construction period.
If the project comprises part of a multi-development project system, describe how the
project discussed in this CAR fits into the overall operation of the project system.
Provide a project overview photograph or satellite image, annotated to identify all project
features. Include drawings of the plan, profile, and typical sections of each project feature
in Appendix C: Project Figures.
2.2 Description of Project Features
Provide a comprehensive description of the project features, including relevant
dimensions, physical properties, historical context, etc. Generally, this will be the same
information provided in Section 2 of the STID, though it is important that the IC Team
review all relevant project information such that they can describe project features and
not simply copy and paste the information from the STID. The order in which the project
features are discussed should be logical; guidance is provided below.
• For a project with a primary water-retaining feature (i.e., a main dam), that feature
should be discussed first, followed by its appurtenances (e.g., wing dams,
spillways, powerhouses, etc.).
• For a project that has a long dam that comprises multiple types of sections of equal
scale (e.g., left and right embankments, non-overflow gravity sections, a water-
retaining intake-powerhouse section, and a gated spillway section), it is
recommended that project features be discussed from left-to-right or right-to-left,
whichever makes the most sense for the project.
• For a project in which the primary feature is a canal or other water conveyance,
the order of discussion should begin at the diversion dam/intake/etc. and continue
along the canal or water conveyance.
• For a CAR that covers multiple developments, it is recommended to discuss the
developments beginning at the development furthest upstream and progressing
downstream.

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The order in which the features are discussed should also be consistent with the order of
discussion in other sections of the CAR (e.g., Section 4.4: Analyses of Project Features
and Section 6: Field Inspection Observations and Interpretation of Monitoring Data).
Additional details are provided below regarding the information to be provided for
various types of project features.
Dam(s)
For each dam, dike, and canal, provide the information listed below that is relevant to the
particular type of structure:
• Type of dam (e.g., embankment, concrete gravity, arch, buttress, etc.);
• Structural height and hydraulic height;
• Crest elevation, length, width, and surface material (e.g., asphalt pavement,
unpaved, etc.);
• Briefly describe any embankment construction method (i.e., rolled fill, semi-
hydraulic/hydraulic fill, zoned embankments, homogenous fill, etc.). For zoned
fills a general description of the materials comprising each zone should be
included;
• Other relevant dimensions as applicable (e.g., monolith width for concrete dams;
radius for arch dams; minimum core width and filter widths for embankments;
etc.)
• Upstream and downstream slopes (H:V) and describe any slope protection;
• The location, dimensions, and purpose of any galleries;
• Briefly describe the foundation conditions (soil, bedrock, etc.); and
• Describe any key foundation features (e.g., location and depth of grout curtain,
location and depth of drainage curtain, location and depth of cutoff wall, etc.).
Spillway(s)
Describe any spillway(s) that are part of the project. For each, describe:
• The type of release facility (e.g., uncontrolled overflow, radial crest gates, etc.)
and list the crest elevation;
• The location of the spillway (e.g., center of dam, which abutment, etc.);
• The approach condition and any inlet structures;
• Description of the discharge path (e.g., unlined channel, lined channel, stilling
basin, etc.) along with pertinent details and dimensions;
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• Details and dimensions of other components as applicable; and


• The discharge capacity (and associated reservoir elevation).
For gated spillways, also include:
• The number and type of gate(s), their dimensions, methods of operation, and
sources of power (primary and backup);
• A description of any anchorage (post-tensioned or passive), wheels, trunnions,
etc.; and
• A brief description of any major modifications to the gates since original
construction.
Outlet Works
Describe any outlet works that are part of the project. For each:
• Describe any intake structure, upstream conduit, gate chamber, downstream
conduit, chute, stilling basin, and discharge channel, and provide pertinent details
and dimensions (including materials, diameter, length, etc.);
• List key elevations (e.g., intake sill, regulating gates, etc.);
• Describe the route of any conduit or tunnel and whether it passes through an
embankment, concrete section, abutment or foundation (and if so, whether it is
alluvium or rock), etc.; and
• List the discharge capacity (and associated reservoir elevation).
Water Conveyances
For each water conveyance, including penstocks:
• Identify the purpose of the conveyance and state the total length;
• Provide relevant dimensions (length and height/width/diameter/etc.) and describe
the materials for each distinct section, as well as the beginning and ending
stations;
• Describe any pressure-relief systems (e.g., surge tanks/towers, pressure-reducing
valves, tunnel lining drainage holes, etc.); and
• For elevated conveyances, describe the support and restraint systems.
Powerhouses
For each powerhouse:

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• Identify the location of the powerhouse and general operation protocols (e.g.,
peaking, base load, etc.);
• Describe the number and type of turbines, their rated generation capacity, and
discharge capacity;
• List any key elevations, such as the tailwater level that would result in flooding of
the powerhouse; and
• State if the powerhouse is required to be operational to pass flood flows.
Document any standard operating procedures required to ensure operability and
ensure those procedures are reviewed and evaluated in Section 8.8.4: Standard
Operating Procedures.
Other Features
List and describe any other relevant project features and provide a level of detail
commensurate with the importance of the feature.
Dam Safety Incidents
Provide a brief summary of previous dam safety incidents (failures, near-failures,
misoperations, etc.) and any resulting modifications or remediation.
2.3 Summary of Operations
General Information
Describe who (organization, company, agency, etc.) operates the dam.
Discuss where project operations personnel live (general vicinity, time and distance from
the project) and how often the operator visits the project. Describe the routes used for
access by project personnel as well as any haul routes that may be used to move
equipment or supplies in the event of a dam safety emergency. Briefly describe any
procedures used to prepare the project for winter, or to ensure that project works remain
operational during periods of cold weather.
Reservoir Operations
Describe the typical reservoir cycle (annual). Include graphical depictions of any
reservoir rule curves and minimum storage/flow requirements as applicable. List the
maximum water surface elevation to date. List the maximum historic releases and
associated dates through the spillway, outlet works, and powerhouse. Describe the safe
downstream discharge channel capacity and what damages may occur above that level (if
known).

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Gate Operations
Describe any standard protocols related to operations of spillway gates and other
discharge pathways (e.g., powerhouse, outlet works, etc.). For example, identify:
• Lead and following gates/valves;
• Any preferentially operated gates/valves and the reasons therefore (e.g., due to
erosion or tailwater concerns);
• Gates/valves connected to automatic-operation controls;
• Allowable differentials between adjacent gates;
• Any procedures to safely allow discharge through powerhouse units without load;
and
• Other information as needed.
Describe all mechanisms and methods for operating gates, including traveling (shared)
hoists, dedicated hoists, and formalized backup procedures (e.g., manual operation, use of
an electric drill to drive gears, use of a crane to raise gates, etc.). Include a discussion of
primary and back-up power sources for gates and valves, as well as alternative means of
operation (i.e., if/how a gate/valve could be operated in the event of a failure of
mechanical components of the hoist system). Describe any remote operation capabilities,
including the communication facilities that enable such operation. Discuss the availability
of personnel, including their training, as it relates to being able to operate gates in the
required amount of time.
Attachments
Include the following attachments to this section:
• Reservoir stage-storage-area curve; and
• Discharge rating curves for each spillway and any outlet works.

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SECTION 3: REVIEW AND EVALUATION OF DESIGN BASIS AND


CONSTRUCTION
General section guidance: The intent of this section is to provide a general overview of
the design basis and construction of the project features. It is not intended to duplicate or
repeat information currently available in the STID. Do not just repeat the information
summarized in the STID. The IC Team must perform an independent review and
evaluation of the associated project records and document their understanding and
assessment of the design basis and construction.
As part of this effort, the IC Team must evaluate the records reviewed for completeness;
evaluate whether the drawings reflect “as-built” conditions with any significant
deviations or modifications identified; evaluate whether standard operating procedures
(SOPs) are current and consistent with the design intent; and discuss whether all other
relevant documents have been identified and located.
Any drawings of significance to the evaluation and performance of the project, and
referenced in this section, should be included in Appendix D. Examples include:
• Geologic plan, profile, and section drawings of dam and key appurtenant
structures;
• Drawings of summary logs of foundation explorations for the dam and key
appurtenant structures (i.e., key drawings and not every drawing showing every
single log);
• Drawings of filter and/or drainage blankets and foundation treatments, including
grout curtains and fault treatments;
• Toe drain/foundation drain plan typical section;
• Spillway/outlet drainage features; and
• Other important sections and details.
Specific figures, plots, and other critical supporting information should be included in the
text or placed at the back of the section. Examples of information to be included behind
this section include:
• Copies of critical or key construction photographs (only if they show features,
construction methods, etc. that have significance to discussion in this section of
the CAR).
• As-built summaries, plots, and charts of construction materials (e.g., gradation
plots of embankment and foundation materials, compressive strength testing of
concrete materials, etc.).

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Each section below should not only be a general discussion of the design and
construction of the feature, but should also include an assessment of those practices to the
current state-of-the-practice; for any that may be considered deficient, discuss and
evaluate the potential implications with respect to performance of the project. If needed,
recommend investigations or remediation as appropriate.
For each section, as appropriate, the IC Team should consider and answer the following
questions posed by the Oroville Independent Forensics Team (IFT):
• Is the feature consistent with current design and construction practice?
• If there are variations from current practice, do they compromise the structure and
present a risk of failure or unsatisfactory performance?
• If there is not enough information available to make those judgments, is the
potential risk sufficient to justify further study or evaluation?
3.1 Engineering Geology
3.1.1 Regional Geology
Provide a brief, general overview of the regional geology and geologic setting,
highlighting any geologic features that may be particularly relevant to the design or
performance of the dam and other project works.
3.1.2 Site Geology
Describe the site geology, providing discussions of the thicknesses and lateral extent (and
continuity) of various foundation units, including overburden. Provide a general
description of all of the units present at the project and within the reservoir, with a focus
on those features that have engineering significance to the project structures. This
includes offering insight into key rock and soil properties such as compressibility,
strength, permeability, and liquefaction potential (soils). Include applicable geologic
drawings (plan, profile, cross sections) to illustrate foundation conditions.
Include a discussion of available information on the strike and dip of various units, as
well as any information on discontinuities (orientation, infilling present, aperture,
roughness, etc.) present in the foundation of the dam or appurtenant structures.
3.1.3 Foundation Explorations
Summarize the past exploration programs, providing dates and types of explorations,
purpose of programs, and tests conducted. Reference sources of additional information on
these past programs. Include a summary drawing, if already available, of the location of
explorations.

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3.1.4 Geologic Hazards


Summarize information on any landslides in the foundation or reservoir area. Report key
thicknesses and volumes of landslides, as well as the general classification of the slide.
Summarize any past studies of slide areas, and the findings and conclusions.
Discuss any other geologic hazards in the vicinity of the dam, including but not limited to
volcanoes, lahars and mudflows, fault offsets, etc. Summarize any key information on the
size or activity of such features, and report findings and conclusions of past studies on
these types of hazards.
3.2 Dam
This subsection deals with the details of the design and construction of the primary
water-retaining feature (typically, the dam). The following headings are strongly
encouraged, although it is recognized that certain facilities may have features that
require additional (and in rare cases, fewer) heading topics.
3.2.1 Design Considerations
This subsection discusses the key features of the design, including both strengths and
vulnerabilities. Topics worthy of discussion include:
• Designer and the timeframe of the design
• Prime influences on the design (e.g., materials availability, abutment geometry,
seepage concerns, etc.)
• General description of design features, referencing key drawings that are to be
included at the back of this section
• Discussion of any unique features of the design
• Assessment of how the design compares to current (at the time of the
Comprehensive Assessment) state of practice
3.2.2 Foundation Excavation and Treatment
This subsection details the pertinent aspects of foundation excavation and foundation
treatment measures (for the dam and appurtenant structures). Topics to address may
include:
• Methods of excavation
• Observations of excavated foundation surfaces
• Any test results or material properties of foundation
• Dewatering difficulties or observations

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• Foundation treatment measures such as foundation filters, slush grouting, dental


concrete, and blanket and curtain grouting. Include the grout takes in various
portions of the foundation.
• Foundation drains (installation, performance, maintenance)
• Discussion of any past performance issues with foundation (seepage, settlements,
slumps, etc.)
3.2.3 Materials and Placement
This subsection describes the properties of the materials used to construct the dam. For
concrete dams, include a discussion of available information on concrete strengths,
reinforcement details, aggregate sources, any concerns with deterioration, and other
issues.
For embankment dams, include a listing of the various zones (conveniently done as
numbered subheadings). To the extent practicable, provide the following information:
• Borrow source (means of excavation is also relevant with respect to uniformity)
• General gradation (and include average curves if available)
• Key material properties such as plasticity index, compaction density, and moisture
content
• Placement and compaction procedures.
3.2.4 Construction Details
Key construction details should be discussed in this subsection. Summarize and evaluate
construction methods, sequences, problems, and design changes associated with
construction. Possible topics include:
• General description of construction operations or methods, particularly if unusual.
• Use of staged contracts, long work stoppages, or similar unusual schedules.
• Inspection, testing, or instrumentation observations that appear relevant or
unusual.
• Observations of foundation surfaces or materials used in construction. Include
construction photographs if useful in portraying conditions in dam or foundation.
3.2.5 Modifications
For each major modification completed since original construction, provide a subheading
and narrative discussion that addresses the relevant items from each modification,
including:

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• Brief description of purpose of modification, the project features that were


modified, and the year of the modification.
• General description of construction operations or methods, particularly if unusual.
• Inspection, testing, or instrumentation observations that appear relevant or
unusual.
• Observations of foundation surfaces or materials used in construction. Include
construction photographs if useful in portraying conditions in dam or foundation.
3.3 Spillway
If the facility has a spillway, report any key information on the design, construction, and
past performance in this subsection. Topics to address may include:
• Design capacity, and basis for original design
• Any unusual aspects of design
• Any limitations on capacity (structural, social, etc.)
• Previous model studies, if any
• Presence or lack of filters if spillway structure penetrates an embankment
• Construction details, particularly any foundation observations or unusual
conditions
3.4 Outlets
If the facility has an outlet works, report any key information on the design, construction,
and past performance in this subsection. Topics to address may include:
• Design capacity, and basis for original design
• Any unusual aspects of design
• Any limitations on capacity (structural, social, etc.)
• Previous model studies, if any
• Presence or lack of filters if outlet works conduit penetrates an embankment
• Construction details, particularly any foundation observations or unusual
conditions
3.5 Powerhouse
If the facility contains any power structures or other structures that either comprise an
integral component of the dam or could lead to a dam safety issue, include a discussion of
that structure in this subsection. Topics to address may include:

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• Design capacity, and basis for original design


• Any unusual aspects of design
• Any limitations on capacity (structural, social, etc.)
• Previous model studies, if applicable
• Construction details, particularly any foundation observations or unusual
conditions
3.6 Other Structures
For any other structure that either comprises an integral component of the dam or could
lead to a dam safety issue, include a discussion of that structure in this subsection. Topics
to address may include:
• Design capacity, and basis for original design
• Any unusual aspects of design
• Any limitations on capacity (structural, social, etc.)
• Previous model studies, if applicable
• Construction details, particularly any foundation observations or unusual
conditions
3.7 Mechanical
3.7.1 Spillway
If the facility has mechanical components related to the spillway structure(s), include a
discussion of the design and construction of the mechanical features in this subsection.
Topics to address include:
• Design capacity, and basis for original design
• Any unusual aspects of design
• Any limitations on capacity
• Previous model studies, if applicable
• Construction details, particularly any unusual conditions
3.7.2 Outlets
If the facility has mechanical components related to the outlet structure(s), include a
discussion of the design and construction of the mechanical features in this subsection.
Topics to address include:
• Design capacity, and basis for original design

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• Any unusual aspects of design


• Any limitations on capacity
• Previous model studies, if applicable
• Construction details, particularly any unusual conditions
3.7.3 Powerhouse
If the facility has mechanical components related to the powerhouse structure(s), include
a discussion of the design and construction of the mechanical features in this subsection.
Topics to address include:
• Design capacity, and basis for original design
• Any unusual aspects of design
• Any limitations on capacity
• Previous model studies, if applicable
• Construction details, particularly any unusual conditions

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SECTION 4: REVIEW AND EVALUATION OF PREVIOUS ANALYSES


Per 18 CFR § 12.38(c), each section listed below must include a clear evaluation of the
analyses of record that considers:
• Assumptions, methods, calculations, results, and conclusions of the analysis,
including the accuracy thereof;
• Relevance with respect to any associated PFM for which the evaluation thereof is
informed by the analysis; and
• Consistency with the current state-of-the-practice.
In each section, identify the analysis of record and document the review thereof; provide
a clear conclusion. While many section headings correspond to those in the STID, do not
conflate the review of the analyses with the review of the STID itself, which is
documented in Section 8.8: Supporting Technical Information Document and Digital
Project Archive.
The level of detail provided in this section of the CAR must demonstrate that a thorough
review was performed. Invalid assumptions, methodologies, or calculation errors that
may significantly affect the results and/or conclusions of the analysis must be clearly
identified and documented. The CAR must also contain a comparison between the
analysis and the current state-of-the-practice; with discrepancies identified and the
potential implications discussed.
Include independent calculations and analysis as needed to justify the evaluation.
Independent calculations performed as part of the CAR (flood routings, filter analyses,
stability analyses, etc.) should be referenced in the appropriate section and included in
their entirety in Appendix J: Independent Calculations.
Recommendations for additional studies, investigations, or remediation must be provided,
as needed.
Further guidance is provided below for several categories of analyses. The CAR must
contain additional sections as needed to discuss other relevant studies, as required by
18 CFR § 12.37(a)(2)(iv).
4.1 Geology
Evaluate whether the existing geologic information has been adequately identified,
appropriately interpreted and correctly applied. Discuss any identified potential
weaknesses in the foundation and abutments (e.g., adversely oriented joints, weak seams,
soluble materials, etc.) and evaluate their potential impacts to the project.

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Discuss the methods to determine material properties from previous investigations.


Include a comparison of those methods to the current state-of-the-practice. Identify any
gaps in the available geologic information and understanding of the site.
4.2 Seismicity
Document the review of project seismicity. List the most recent available peak ground
acceleration (PGA) and spectrum for each of the following, as applicable, highlighting
the period range of interest for project structures:
• Maximum Credible Earthquake (MCE);
• United States Geological Survey (USGS) 1:2,475 year event; and
• Any probabilistic seismic hazard assessments.
State whether any seismic events have occurred since the previous Part 12D Report that
would warrant reevaluation of the analysis that established the current seismic design
criteria and any stress and stability analyses based thereon.
Note any other reasons why the seismic loading may have increased or decreased since
the previous Comprehensive Assessment, and whether the previous analyses are based on
methodologies that are no longer current. Evaluate whether a new seismic hazard analysis
is required. Make any recommendations as appropriate.
4.3 Hydrology and Project Hydraulics
Summarize the previous hydrologic and hydraulic analyses in this section.
4.3.1 Precipitation and Snowmelt
State the PMP study of record (e.g., Hydrometeorological report, state study, or site-
specific study) and describe key aspects of the methodology; evaluate whether the
information and results are still valid for the project. Discuss how the storm was
distributed over the watershed and what storm hyetograph was used. Indicate if snowpack
and snowmelt were included in the model and, if so, which snowmelt methodology was
used.
List the following information as applicable:
• 1-, 6-, 24-, and 72-hour PMP depths for general storms;
• 1- and 6-hour PMP depths for local storms.
4.3.2 Flood Loading and Routings
List the current Flood of Record, Inflow Design Flood (IDF), and Probable Maximum
Flood (PMF) inflow and outflow values (as applicable). List the following information as
applicable:
• Spillway capacity at the normal maximum water surface elevation
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• Zero freeboard spillway capacity


• Peak spillway discharge since the previous Part 12D Report
• Peak reservoir elevation(s) during the previous five years.
Also discuss the following as applicable:
• Past flood loadings, both in terms of Probable Maximum Flood or probabilistic
floods;
• If flood loadings have increased or decreased since the previous flood study,
explain why;
• Report results of previous flood routings, including amount of resulting freeboard
for all structures at a project, or the depth and duration of any overtopping at all
structures; and
• Identify any deficiencies with the past flood routings.
State whether any events have occurred since the previous Part 12D Report that would
warrant reevaluation of the analysis that established the current IDF/PMF and any
hydraulic, scour, and/or overtopping analyses based thereon.
Note any other reasons why the hydrologic loading may have increased or decreased
since the previous Comprehensive Assessment, and whether the previous analyses are
based on data or methodologies that are no longer current. Evaluate whether a new
hydrologic hazard analysis is required. Make any recommendations as appropriate.
4.3.3 Dam Breach Studies
Evaluate the assumptions made in the dam breach analyses, including which project
features have been evaluated (e.g., main dam, auxiliary dam, spillway gate, etc.).
Evaluate whether the model results are accurate and representative of the expected
inundation extent. Identify the modeling software used and whether the model is still
valid and appropriate for the project. Recommend additional dam breach analyses as
needed.
4.4 Analyses of Project Features
This section must document the review and evaluation of the analyses of project features,
preferably in the same order as they are listed in Section 2.2: Description of Project
Features. For each project feature, include a set of numbered headings (e.g., 4.4.X.Y) that
contains the subsections discussing the various types of analyses relevant to that type of
project feature (e.g., gravity sections, embankment sections, arch dams, spillways, etc.).
Where applicable, the results must be stated in terms of factors of safety and compared to
the relevant FERC criteria or guideline. Any deficiencies in the analyses must be

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identified and the potential implications discussed, with recommendations for further
investigation, if needed.
4.4.1 Analyses of [Project Feature 1]
4.4.1.1 Static Analyses of [Project Feature 1]
Document the review and evaluation of analyses under static loading conditions
(including normal, hydrologic, and other special cases as needed). Provide clear
delineation of the discussion as it relates to normal and hydrologic loading conditions;
while these two loading conditions are similar in that they represent static conditions, the
magnitude of loading and response of the structure(s) may be very different.
Stress and Stability
This section should document the review and evaluation of analyses related to the stress
and stability of project features, and is applicable to all dam types; canals; spillways;
penstocks, conduits, and other water conveyances; gates and valves; and other
appurtenances, as well as powerhouses (whether water-retaining or not).
Foundation and/or Abutment Stability
This section should document the review and evaluation of any analyses related to the
stability of the foundation or abutments under static loading conditions.
Seepage and Internal Erosion
This section should document the review and evaluation of any analyses related to static
seepage, and internal erosion (piping) potential, and is applicable to embankment dams
and certain types of foundations and abutments.
• Static seepage (gradients, quantity, and quality); and
• Internal erosion, including between and within embankment, foundation, and
abutment materials. Available gradations of adjacent embankment and foundation
materials should be plotted, and filter compatibility evaluated based on current
criteria. If filter criteria are not satisfied, apply University of New South Wales
excessive and/or continuing erosion criteria to check the potential for filtering
after some erosion occurs. Additional issues to evaluate and discuss may include:
• Are any of the materials internally unstable?
• Are there upstream zones that may serve as crack stoppers?
• Do the downstream zones (or filters) contain excessive or plastic fines, or
cementitious materials, that may impact their ability to collapse (and instead be
able to sustain a crack)?

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Settlement/Deformation
This section should document the review and evaluation of analyses related to the
settlement, consolidation, or deformation of embankment (soil or rock) or foundation
(soil or rock) materials under static loading conditions.
4.4.1.2 Seismic Analyses of [Project Feature 1]
This section must be provided for all structures regardless of whether seismic analyses
have been performed.
If any seismic analyses have been performed, the relevant information must be
documented in the appropriate subsection (listed below).
If seismic analyses have not been performed, the IC Team must document in this section
the rationale for recommending or not recommending the completion of such analyses.
Seismic Loading
State the source(s) of information for seismic loads applied to the project feature. Include
any relevant figures that show the time history, response spectrum, etc.
Dynamic Stress and Stability Analyses
This subsection applies to concrete dams and may include the structure and its
foundation.
If any dynamic analyses have been performed, discuss:
• The general methodology;
• Development of any numerical models, including input parameters such as
material properties, boundary conditions, etc.;
• Evaluation criteria; and
• Interpretation of model output and results.
Liquefaction Analyses
This subsection applies to embankment dams (including the structure and its foundation)
as well as any project that includes another type of dam (e.g., concrete gravity dam)
constructed atop a soil foundation.
Identify whether or not embankment and/or foundation liquefaction has been evaluated in
previous studies. Include the date of the analysis and the method of analysis (qualitative
based on material observations; quantitative through the use of SPT, CPT, BPT, iBPT, or
shear wave velocity; or other methods). Evaluate the analysis methodology, input
parameters, analysis assumptions, findings and conclusions. Note any deficiencies in the
past analyses or evaluations.
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Post-Liquefaction Stability
This subsection applies to embankment dams as well as any project that includes another
type of dam (e.g., concrete gravity dam) constructed atop a soil foundation.
If performed, describe dates and methods used in past analyses of post-liquefaction
stability. Evaluate and document results (methodology, inputs, assumptions, factors of
safety, and conclusions). Note any deficiencies in the past analyses.
Deformation Analyses
This subsection applies to embankment dams.
Dynamic deformations may have been analyzed in previous analyses, whether by simple
methods or possibly sophisticated finite element methods. Conditions or assumptions of
liquefaction or no liquefaction may have been assumed. Evaluate and summarize the
specific details, assumptions, methods, and dates of any past deformation analyses.
Review and evaluate the findings and conclusions. Note any deficiencies in the past
analyses.
4.4.1.3 Hydraulic and Overtopping Analyses of [Project Feature 1]
Hydraulic Analyses
This section will generally apply to spillway chutes, though there may be other structures
for which hydraulic analyses have been performed.
This section should document the review and evaluation of any analyses related to
stagnation pressure, cavitation, training wall overtopping, etc. related to spillway chutes.
Overtopping and Erosion Analyses
This section should document the review and evaluation of any analyses related to
erosion of embankments, abutments, or the foundation; including erosion caused by
overtopping or by expected project releases during normal and flood conditions.
Transient Analyses
This section should document the review and evaluation of any transient pressure
analyses for penstocks, tunnels, and other water conveyances.
4.4.1.4 Other Analyses of [Project Feature 1]
This section should document the review and evaluation of any other analyses.

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4.4.2 Analyses of [Project Feature 2]


4.4.2.1 Static Analyses of [Project Feature 2]
4.4.2.2 Seismic Analyses of [Project Feature 2]
4.4.2.3 Hydraulic and Overtopping Analyses of [Project Feature 2]
4.4.2.4 Other Analyses of [Project Feature 2]
4.4.3 Analyses of [Project Feature 3, 4, etc.]

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SECTION 5: PROJECT STATUS


5.1 Modifications to Project Works
Identify any changes or modifications to the project works since the previous Part 12D
Report.
5.2 Modifications to Project Operations
Identify any changes or modifications to the standard project operations, which are
discussed in Section 2.3: Summary of Operations, since the previous Part 12D Report.
5.3 Recommendations of Previous Independent Consultants
Include a summary table indicating the status/disposition (e.g., complete, study in
progress, etc.) of each recommendation from the previous Part 12D report, as well as
recommendations from earlier Part 12D reports that:
• Are incomplete at the time of the current Part 12D report; or
• Were completed after the previous Part 12D report but before the current Part 12D
report.
5.4 Outstanding/Ongoing Studies
List any major studies that are outstanding or ongoing at the time of the Comprehensive
Assessment. Include a concise summary of the purpose of each study and its schedule for
completion.
5.5 Completed Studies
List any major studies completed since the previous Part 12D Report. Include a concise
summary of the findings and conclusions of each study. It is not necessary to duplicate all
the information that was documented in the previous section.
5.6 Summary of Operations and Maintenance Programs
List any periodic or ongoing maintenance performed to maintain the project works in safe
and reliable operating condition (several examples are listed below). Clearly indicate
when each of the maintenance programs was performed.
• Maintenance of mechanical components of spillway gate hoists and valves;
• Lubrication of radial gate trunnions and other bearings (e.g., fixed wheel gates);
• Maintenance of backup power systems;
• Patching and sealing of concrete;
• Application of joint filler in spillway chutes;
• Scour repairs;
• Etc.

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SECTION 6: FIELD INSPECTION OBSERVATIONS AND


INTERPRETATION OF MONITORING DATA
The site inspection should be performed in general conformance with the inspection
guidelines provided in Bureau of Reclamation, Safety Evaluation of Existing Dams
(SEED) Manual. Where the condition of a feature is described, the IC Team should use
consistent terminology that is identified and defined at the beginning of this section of the
CAR. For example, the terms “satisfactory,” “fair,” “excellent,” etc. may be used
provided that the meaning is clearly defined and consistent.
6.1 General
The site inspection report must include the following information:
• Date of inspection.
• Names and affiliations of inspection participants.
• Operating conditions at the time of the inspection, including:
o Weather conditions on the day of the inspection (note any recent
precipitation, which could affect seepage observations);
o Reservoir and tailrace water surface elevations;
o Inflows (if known);
o Releases, including through any spillway(s), outlet works, and
powerhouse(s).
For any seismic or hydrologic events that occurred and triggered a special inspection of
any project features since the previous Part 12D inspection:
• Identify the date of the event;
• Describe the reason a special inspection was performed (e.g., magnitude of an
earthquake, amount of discharge through the spillway, etc.); and
• Ensure that the findings of the inspection are discussed with respect to the relevant
project features.
For each project feature, include the subsections listed below. The project features should
be discussed in the same order as listed in Section 2.2: Description of Project Features.

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6.2 [Name of Project Feature 1]


6.2.1 Field Inspection Observations
Discuss the observations of the IC Team members during the field inspection. Provide
representative photographs with the text or clear references to photographs included in
Appendix E: Inspection Photographs
6.2.2 Review and Evaluation of Instrumentation Data and Surveillance
Provide a thorough review and evaluation of any instrumentation data collected to-date.
Discuss what constitutes expected behavior of each instrument and identify any trends or
unusual data (e.g., outside the expected range or historic range, or indicative of poor
instrument maintenance or procedures). Interpret and evaluate the data with respect to
performance of the project feature. Include in the body of the report, as needed, annotated
snapshots of data along with any statistical evaluation; alternatively, reference that
information as provided in Appendix D: Instrumented Monitoring Data Plots.
Provide a summary of the findings of routine or special surveillance performed by the
licensee or third-party consultants (e.g., a diver inspection of the upstream face of a
concrete gravity dam). This should incorporate a review of licensee inspection checklists,
contractor special inspection reports, etc. Evaluate the findings with respect to
performance of the project feature.
6.2.3 Evaluation with Respect to Potential Failure Modes
For each identified PFM related to the project feature:
• Provide a clear evaluation of whether the PFM is considered active or developing,
based on field observations and the review of instrumentation data and
surveillance. If the loading condition did not occur during the report period, state
so and limit the evaluation accordingly.
• Document any changed circumstances that could influence the PFM classification
(e.g., credible, dismissed, etc.), and briefly evaluate the potential impacts thereof.
• If there are any risk reduction measures in place, evaluate the effectiveness
thereof. For any risk reduction measures that were previously recommended but
not implemented, provide an evaluation of the stated rationale for not
implementing those risk reduction measures.
State whether any field observations, instrumentation data, or surveillance indicates that
an unidentified PFM is active or developing. If necessary, address it in the PFMA.
6.2.4 Conclusion
Provide a conclusion with respect to the condition of each project feature and its
suitability for continued operation.

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6.3 [Name of Project Feature 2]


6.3.1 Field Inspection Observations
6.3.2 Review and Evaluation of Instrumentation Data and Surveillance
6.3.3 Evaluation with Respect to Potential Failure Modes
6.3.4 Conclusion
6.4 [Name of Project Feature 3, 4, etc.]
Include additional sections for project features as needed.
6.5 Overall Interpretation of Instrumentation Data
(Note: the numbering for this section will depend on the number of project features
discussed.)
Discuss and evaluate any other instrumentation data that is unrelated to specific project
features, and any previously-discussed instrumentation data that may, when considered as
a whole and not constrained to a single project feature, may provide insight into the site
and project performance (e.g., groundwater profile at site).
Evaluate whether any instrumentation readings at the various project features may
indicate site or loading conditions that are inconsistent with the current understanding of
the project.

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SECTION 7: PFMA AND RISK ANALYSIS

7.1 General
Provide a brief summary of the PFMA and risk analysis sessions (e.g., location, dates,
attendees and their roles).
Provide a list of key documents or information used in performing the PFMA and risk
analysis.
Evaluate the procedures used to perform the PFMA and risk analysis with respect to the
established procedures in Chapters 17 and 18 of the Engineering Guidelines and provide
an assessment whether the analyses were or were not performed in general conformance
with the Engineering Guidelines. List any procedural deviations from the Engineering
Guidelines.
7.2 Probabilistic Hydrologic Loading
If a probabilistic hydrologic hazard analysis has been performed:
Provide a brief summary and evaluation of the work that was performed in developing
the probabilistic hydrologic loading. Document and review key inputs and assumptions.
Include key figures and tables including the probabilistic hydrologic hazard curve. It is
not necessary to reproduce all of the information discussed in Section 4.3 Hydrology and
Project Hydraulics.
If a probabilistic hydrologic hazard analysis has not been performed: state so.
7.3 Probabilistic Seismic Loading
If a probabilistic seismic hazard analysis has been performed:
Provide a brief summary and evaluation of the work that was performed in developing
the probabilistic seismic loading. Document and review key inputs and assumptions.
Include key figures and tables including the probabilistic seismic hazard curve. It is not
necessary to reproduce all of the information discussed in Section 4.2 Seismicity.
If a probabilistic seismic hazard analysis has not been performed: state so.
7.4 Consequences
If a consequences analysis has been performed:
Provide a brief summary and evaluation of the work that was performed in developing
the consequence estimates. Summarize and evaluate the overall methodology used to
develop the consequence estimates. Document and review the inundation scenarios,
breach assumptions, description of impacted areas, population at risk, and estimated life

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loss. Document and evaluate key inputs and assumptions in estimating the life loss
consequences, including warning times, mobilization times, and fatality rates.
Evaluate estimates for other consequences (economic, environmental, cultural, etc.) if
performed.
If a consequences analysis has not been performed: state so and explain, qualitatively,
any consequence considerations made for the PFMA.
7.5 PFMA
If the PFMA report was prepared by the IC Team, include a copy of the PFMA report in
Appendix H: Potential Failure Modes Analysis Report.
If the PFMA report was not prepared by the IC Team, then the IC Team must provide a
summary and evaluation of the PFMA report, as follows:
Provide a brief summary of the work that was performed for the PFMA. Include a listing
of the PFMA team members, including the facilitator and location and dates of the PFMA
session. Provide a summary and brief description of all considered potential failure
modes (tabular form is acceptable) and the final disposition of each PFM considered
(ruled-out, excluded, credible, urgent, or insufficient information). The PFMs should be
organized by project feature, loading condition, and failure mechanism.
Provide additional discussions (rationale, appropriate actions/studies, etc.) for PFMs that
are classified as urgent and insufficient information.
Summarize the major findings and understandings of the PFMA.
For each identified PFM:
• Evaluate the full description of the PFM, including the loading conditions, step-
by-step progression, adverse and positive factors, disposition, relevant engineering
data, potential surveillance and monitoring, risk reduction measures, and
conclusions.
• Provide a clear statement of concurrence or non-concurrence with the above listed
information and any recommendations.
When evaluating each PFM, the ICs should ensure that the descriptions include thorough
documentation of any unusual conditions associated with:
• Design, construction, and foundation geology
• Performance history
• Field inspection
• Field exploration program results
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• Seismic and/or hydrologic loadings


• Engineering analysis results
• Surveillance and monitoring results
Provide recommendations as needed to improve the PFMA and PFMs (e.g., expanding
the descriptions, correcting inaccurate information, identifying new PFMs, etc.).
7.6 Risk Analysis and Summary
If a risk analysis has not been performed, or if the Regional Engineer granted a waiver
from performing a risk analysis with the Comprehensive Assessment, state so and
reference the date of any letter granting a waiver.
If a risk analysis has been completed and the report was prepared by the IC Team:
include a copy of the risk analysis report in Appendix I: Risk Analysis Report.
If a risk analysis has been completed and the report was not prepared by the IC Team,
then the IC Team must provide a summary and evaluation of the risk analysis report, as
follows:
Provide a brief summary of the work that was performed for the risk analysis (analyses).
Include a listing of the team members, including the facilitator and location and dates of
the risk session(s), if different than the PFMA session. Provide a concise description of
the risk drivers for the project. Include a tabular summary of the results of the risk
analysis and graphical representations as needed (e.g., risk matrix).
For each risk-driver potential failure mode evaluated, describe the failure likelihood and
key evidence supporting the assessment. Describe the primary consequence center(s)
including proximity to the dam, population at risk, and life loss potential. Be sure to
address the following:
• What makes each failure mode more or less likely?
• Which failure modes contribute the greatest risk?
• What uncertainties enter into the estimate of risk?
• What information could be generated to reduce the uncertainty?
• What outcomes could reasonably be expected to result from more info?
• How could the risk be affected by each outcome?
• What are reasonable options/actions, including scope of required effort?
Summarize the major findings and understandings of the risk analysis.
Provide recommendations for any follow-on studies.

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The IC must provide a detailed evaluation of the report, as follows.


For each PFM evaluated in the risk analysis:
• Evaluate the portrayed risk (failure likelihood and consequence).
• Evaluate if the report provides adequate documentation that supports the portrayal
of the risk.
• Provide a clear statement of concurrence or non-concurrence with the risk
portrayal and any recommendations.
When evaluating each PFM, the ICs should ensure that the risks reflect any unusual
conditions associated with:
• Design, construction, and foundation geology
• Performance history
• Field inspection
• Field exploration program results
• Seismic and/or hydrologic loadings
• Consequences
• Engineering analysis results
• Surveillance and monitoring results
Evaluate if any potential failure modes were excluded from the risk analyses that should
not have been.
Provide recommendations as needed to improve the risk analysis (e.g., correcting
inaccurate information, revisions to likelihood of failure and consequences, etc.).

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SECTION 8: REVIEW AND EVALUATION OF DAM AND PUBLIC


SAFETY PROGRAMS

8.1 Owner’s Dam Safety Program


If the project is subject to 18 CFR Part 12, Subpart F:
State that the project is subject to 18 CFR Part 12, Subpart F. Discuss any observations
with respect to the implementation of the Owner’s Dam Safety Program. The discussion
should be based on interactions with licensee staff during preparation, performance, and
follow-up related to the Comprehensive Assessment. Unless specifically requested by the
FERC, or proposed by the licensee and accepted by the FERC, the IC is not expected to
provide a level of detail and evaluation of the ODSP that constitutes an external audit as
required by 18 CFR § 12.65.
Human and organizational factors should be identified and assessed, including
organizational culture and decision-making authority.
If the project is not subject to 18 CFR Part 12, Subpart F:
State that the project is not subject to 18 CFR Part 12, Subpart F and explain why.
8.2 Dam Safety Surveillance and Monitoring Program
Summarize the frequency and scope of licensee and third-party surveillance of project
features, including the inspection of any typically inaccessible features (e.g., toe drains,
submerged conduits, etc.). A tabular format is recommended. At a minimum, the
following information should be presented:
• Frequency (e.g., daily, monthly, quinquennial, etc.);
• Type of surveillance (e.g., visual, underwater, drone, etc.);
• Project features observed; and
• Who performs the inspection (e.g., operations staff, dam safety engineer,
consultant, etc.).
Evaluate whether the current surveillance procedures are sufficient for monitoring for the
development of the identified credible PFMs. Assess the frequency of inspection of all
project features, including those inaccessible features that are related to identified
credible PFMs. As needed, recommend enhancements to the surveillance program to
monitor for the development of credible PFMs, as general health monitoring, and for
post-event monitoring (e.g., post-earthquake, post-flood, etc.).
Summarize the instrumentation program and data collection. A tabular format is
recommended. At a minimum, the following information should be presented:
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• Instrument type and location;


• Frequency of manual and automated readings (if applicable); and
• A description of instrument behavior related to environmental factors (e.g.,
reservoir level, precipitation, temperature, etc.), if applicable.
Evaluate whether the current instrumentation program is sufficient for the detection of the
identified credible PFMs. As needed, recommend additional instrumentation to monitor
for the development of credible PFMs, as general health monitoring, and for post-event
monitoring (e.g., post-earthquake, post-flood, etc.).
8.3 Hazard Potential Classification
Identify the current hazard potential classification, the date of the dam breach analysis,
downstream hazard assessment of record, and provide a concise description of the
potential impacts of a hypothetical dam failure.
Document any significant changes in the downstream development and any previously
unidentified potential impacts within the inundation zone (e.g., critical transportation
infrastructure, schools or hospitals, water treatment facilities, etc.). Identify the nearest
non-project structure and its approximate distance and time-to-impact from the dam.
Describe how the review was performed (e.g., viewed from dam, aerial or satellite
imagery, verbal reports from licensee staff, etc.).
Evaluate whether the current hazard potential classification remains appropriate; whether
it should be changed; or whether additional investigations are required to determine the
appropriate classification.
8.4 Emergency Action Plan
If the project is subject to 18 CFR Part 12, Subpart C:
Identify the dates of the most recent reprint and annual revision of the EAP.
List any EAP activations and tests (annual drills, tabletop exercises, functional exercises,
etc.) conducted since the previous Part 12D Report. Evaluate the findings of those
activations and tests and state whether any recommended revisions were implemented
appropriately.
Discuss the communication methods, response procedures, and EAP training program.
Evaluate the adequacy of each.
If the project has a Sudden Failure Assessment (SFA), evaluate the detection,
verification, notification, and Emergency Management Agency (EMA) response times.
State the total Excess Response Time (ERT) and evaluate any enhancements the licensee
has implemented or is considering, including early warning systems. Document any

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interviews with first responders, which are strongly recommended if the ERT is less than
fifteen minutes. Provide additional recommendations for enhancements as needed.
If the project is required to complete a radiological response plan under 18 CFR
§ 12.22(c), discuss and evaluate those provisions.
If the project is not subject to 18 CFR Part 12, Subpart C:
State that the project is not subject to 18 CFR Part 12, Subpart C and explain why. If any
conditions were identified such that the IC recommends the project prepare an EAP,
thoroughly describe and document the conditions. Otherwise, state that the continued
exemption is appropriate.
If the project is required to complete a radiological response plan under 18 CFR
§ 12.22(c), discuss and evaluate those provisions.
8.5 Public Safety Plan
Identify the date of the current PSP. State whether the signs and devices observed during
the field inspection were consistent with those described in the plan. Identify any
discrepancies observed.
Document any project-related public safety incidents that have occurred since the
previous Part 12D Report, as well as the licensee’s response and implementation of any
required remediation measures. Evaluate the overall effectiveness of the PSP. If needed,
recommended improvements to the signage or devices.
8.6 Operations and Maintenance
Evaluate whether any maintenance activities could indicate an active or developing
potential failure mode, whether identified or not, and discuss any necessary maintenance
that has been deferred and why. Evaluate whether the operations and maintenance
programs listed in Section 5.6: Summary of Operations and Maintenance Programs are
considered sufficient for the safe and reliable operation of the project. Recommend any
changes as needed related to implementation, training, reporting, etc.
8.7 Spillway Adequacy
Document the review of and evaluate the spillway capacity as required by 18 CFR
§ 12.39. Document the range of flows that are being considered in the evaluation; if the
maximum flood flow considered is less than the PMF, ensure that Section 8.3: Hazard
Potential Classification contains sufficient justification and provide a reference to that
section for information.
Discuss any conditions that may result in the spillway discharging less than its rated
capacity, such as:
• Misoperation;
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• Failure to operate;
• Blockage; and
• Debilitating damage to the spillway and/or its appurtenances.
For each condition and/or combination thereof, identify the potential effect on discharge
and peak reservoir elevation. Evaluate whether the spillway capacity is adequate, based
on the above discussion. Recommend further investigation and/or modifications as
needed.
8.8 Supporting Technical Information Document and Digital Project Archive
The purpose of this section of the CAR is to document the review of the STID and
evaluation of its conformance with Chapter 15 of the Engineering Guidelines, not to
evaluate the analyses themselves.
Evaluate whether the STID as prepared is suitable as a complete, quick reference for
information in the event of a dam emergency. Subsequently, for each section of the
STID:
• Evaluate whether the hard copy STID contains all the information required by
Chapter 15 of the Guidelines;
• Evaluate whether the information in the hard copy is correct and whether it
accurately represents the source material;
• Evaluate whether the references contained on the companion digital reference are
comprehensive or if additional materials should be provided; and
• Include recommendations as needed to correct any identified deficiencies.
The sections must be numbered as shown below to correspond with the sections of the
STID.
8.8.1 Potential Failure Modes Analysis and Risk

8.8.2 Project Description

8.8.3 Construction History

8.8.4 Standard Operating Procedures

8.8.5 Geology, Seismicity, and Geotechnical Data

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8.8.6 Hydrology and Hydraulics

8.8.7 Dam Safety Surveillance and Monitoring Plan

8.8.8 Stability, Stress, and Other Analyses of Dams and Water Conveyances

8.8.9 Gates, Valves, and Other Water Level Control Devices

8.8.10 Pertinent Correspondence Related to the Safety of Project Works

8.8.11 References

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APPENDICES FOR THE COMPREHENSIVE ASSESSMENT REPORT

Appendix A: FERC Letter Requiring Part 12D Inspection


Include only the letter in the hard copy Comprehensive Assessment Report. Any
enclosures or attachments to the letter should be included only in the digital copy.
Appendix B: FERC Letter Approving Part 12D Inspection Plan and IC Team
Include only the letter itself in the hard copy Comprehensive Assessment Report. Any
enclosures or attachments to the letter should be included only in the digital copy. If
multiple letters were issued (e.g., a conditional approval requesting supplemental
information, or an approval of a change in the team members), all must be included.
Appendix C: Project Figures
Include a set of legible figures sufficient to foster a clear understanding of the project
features. The level of detail should be informative but not excessive; FERC exhibit
drawings can be used. In a departure from previous guidance, this information must be
included in the CAR; binding the STID with the CAR to eliminate duplication is no
longer an option.
• A general location map, annotated with the location(s) of project facilities,
including water conveyances, access routes, major roads, and towns;
• Plan drawings of project facilities;
• Typical sections, elevations, and profiles of key project features (e.g., dams,
spillways, powerhouses, intakes, emergency/fuse plug spillways, chute profiles,
etc.);
• Typical sections and profiles of water conveyances;
• A satellite or aerial image of the project and downstream area, annotated as
needed; and
• Spillway and tailwater rating curves.
Additional information should be provided as needed.
Appendix D: Instrumented Monitoring Data Plots
This appendix must include any instrumentation monitoring data plots and/or statistical
analysis prepared by the IC Team to evaluate the data and performance of project
features, along with any plots or excerpts from previous Dam Safety Surveillance and
Monitoring Reports (DSSMRs) that are considered critical to understanding the IC
Team’s evaluation.

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It is not necessary for the CAR to reproduce every plot that has already been provided in
an annual DSSMR. The IC Team should include a list of the annual DSSMRs that were
reviewed and provide appropriate references for any plots or excerpts.
Appendix E: Inspection Photographs
The hard copy Comprehensive Assessment Report must include representative
photographs, either in this appendix or in Section 6: Field Inspection Observations and
Interpretation of Monitoring Data.
Digital versions of the inspection photographs must be provided on the companion digital
reference (if required) and must be available as individual files at full resolution. An
index, naming convention, or other reference system should be established so
photographs can be located easily by reviewers.
Appendix F: Inspection Checklists and/or Field Notes
Include any inspection checklists and/or field notes digitally with the CAR.
Appendix G: Operation and Maintenance Documentation
Include any operation and maintenance documentation as needed. Some examples of this
type of documentation include:
• Spillway gate testing and trunnion lubrication records;
• Backup power maintenance logs;
• Crack sealing;
• Concrete repairs; and
• Other information as needed.
Appendix H: Potential Failure Modes Analysis Report
If the PFMA report was prepared by the IC Team and signed by the Independent
Consultant(s):
Include a complete copy of the PFMA Report with the CAR. The PFMA Report must be
included digitally and in hard copy, bound separately from the CAR so it can be
incorporated as Section 1 of the STID. The PFMA Report must conform to the
requirements provided in Chapter 17 of the Guidelines.
If the PFMA report was prepared by a party other than the IC Team and/or not signed by
the Independent Consultant(s):

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Include any detailed documentation required to support the IC’s evaluation of each PFM.
The licensee is required to submit the PFMA report bound separately from the CAR so it
can be incorporated in Section 1 of the STID.
Appendix I: Risk Analysis Report
If the Risk Analysis report was prepared by the IC Team and signed by the Independent
Consultant(s):
Include a complete copy of the Risk Analysis Report (RAR) with the CAR. The RAR
must be included digitally and in hard copy, bound separately from the CAR if necessary.
The RAR must conform to the requirements provided in Chapter 18 of the Guidelines.
If the Risk Analysis report was prepared by a party other than the IC Team and/or not
signed by the Independent Consultant(s):
Include any detailed documentation required to support the IC’s evaluation of project
risk. The licensee is required to submit the RAR bound separately from the CAR so it can
be incorporated in Section 1 of the STID.
Appendix J: Independent Calculations
Include any independent calculations performed to evaluate the analyses of record. The
full calculations should be included digitally; only include a table of contents in the hard
copy CAR.

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CHAPTER 16, APPENDIX E: OUTLINE FOR THE COMPREHENSIVE


ASSESSMENT PRE-INSPECTION PREPARATION REPORT (CA-PIPR)

This appendix provides the outline for the Pre-Inspection Preparation Report on a
Comprehensive Assessment conducted in accordance with 18 CFR § 12.37. Any
Comprehensive Assessment Pre-Inspection Preparation Report (CA-PIPR) is required to
follow this format and provide the appropriate information in each section. The
requirement to provide a CA-PIPR is established in 18 CFR § 12.42.
Several important notes regarding this appendix:
• This outline generally provides only the section headings. Unless otherwise
indicated, the information required in each section is the same information
required in the corresponding section of the Comprehensive Assessment Report
(CAR), an outline of which is available as Chapter 16, Appendix D. The CA-PIPR
maintains the numbering of sections in the CAR for simplicity; sections that
require no information in the CA-PIPR state that the section is a placeholder, and
any subsequent subheadings have been omitted.
• Clarification is provided in some cases to limit the expected depth of information
provided in the CA-PIPR. However, the more detail that is provided in the CA-
PIPR, the better prepared the team will be for the field inspection, PFMA and RA
session(s), and preparation of the CAR.
• Any evaluations and conclusions in the CA-PIPR are considered preliminary.
It is entirely acceptable, and even expected, for the IC Team to acquire new
information or a different understanding of the project and its components
between completion of the CA-PIPR and the CAR. The FERC does not intend to
compare the CA-PIPR to the CAR to identify changes in evaluations or
conclusions.
• The phrase “the previous Part 12D Report” refers to the most recent report on a
Periodic Inspection, Comprehensive Assessment, or an inspection performed in
accordance with the rules established by FPC Order 315 or FERC Order 122.

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GENERAL PROVISIONS

Cover Page
The cover page must include, at a minimum:
• Project name and number;
• The name of each Independent Consultant and, if applicable, the consulting firm
each represents;
• The date of the Comprehensive Assessment Pre-Inspection Preparation Report
(CA-PIPR).
Table of Contents
Include a table of contents listing each section of the CA-PIPR and page numbers.
Include separate lists of tables and figures.
Identification of IC Team
• Identify each member of the Independent Consultant Team and their role. Attach
resumes for those IC Team members whose resumes were not included with the
Part 12D Inspection Plan.

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SECTION 1: FINDINGS AND RECOMMENDATIONS


This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.

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SECTION 2: DESCRIPTION OF PROJECT FEATURES AND


OPERATIONS

2.1 Location and Purpose

2.2 Description of Project Features

2.3 Summary of Operations

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SECTION 3: REVIEW AND EVALUATION OF DESIGN BASIS AND


CONSTRUCTION

3.1 Engineering Geology

3.1.1 Regional Geology

3.1.2 Site Geology

3.1.3 Foundation Explorations

3.1.4 Geologic Hazards

3.2 Dam

3.2.1 Design Considerations

3.2.2 Foundation Excavation and Treatment

3.2.3 Materials and Placement

3.2.4 Construction Details

3.2.5 Modifications

3.3 Spillway

3.4 Outlets

3.5 Powerhouse

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3.6 Other Structures

3.7 Mechanical

3.7.1 Spillway

3.7.2 Outlets

3.7.3 Powerhouse

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SECTION 4: REVIEW AND EVALUATION OF PREVIOUS ANALYSES

4.1 Geology

4.2 Seismicity

4.3 Hydrology and Project Hydraulics

4.3.1 Precipitation and Snowmelt

4.3.2 Flood Loading and Routings

4.3.3 Dam Breach Studies

4.4 Analyses of Project Features

4.4.1 Analyses of [Project Feature 1]

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4.4.1.1 Static Analyses of [Project Feature 1]


Stress and Stability
Foundation and/or Abutment Stability
Seepage and Internal Erosion
Settlement/Deformation
4.4.1.2 Seismic Analyses of [Project Feature 1]
Seismic Loading
Dynamic Stress and Stability Analyses
Liquefaction Analyses
Post-Liquefaction Stability
Deformation Analyses
4.4.1.3 Hydraulic and Overtopping Analyses of [Project Feature 1]
Hydraulic Analyses
Overtopping and Erosion Analyses
Transient Analyses
4.4.1.4 Other Analyses of [Project Feature 1]

4.4.2 Analyses of [Project Feature 2]

4.4.2.1 Static Analyses of [Project Feature 2]

4.4.2.2 Seismic Analyses of [Project Feature 2]

4.4.2.3 Hydraulic and Overtopping Analyses of [Project Feature 2]

4.4.2.4 Other Analyses of [Project Feature 2]

4.4.3 Analyses of [Project Feature 3, 4, etc.]

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SECTION 5: PROJECT STATUS

5.1 Modifications to Project Works

5.2 Modifications to Project Operations

5.3 Recommendations of Previous Independent Consultants

5.4 Outstanding/Ongoing Studies

5.5 Completed Studies

5.6 Summary of Operations and Maintenance Programs

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SECTION 6: FIELD INSPECTION OBSERVATIONS AND


INTERPRETATION OF MONITORING DATA

6.1 General
For each project feature, include the subsections listed below. The project features should
be discussed in the same order as listed in Section 2.2: Description of Project Features.
6.2 [Name of Project Feature 1]

6.2.1 Field Inspection Observations


This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
6.2.2 Review and Evaluation of Instrumentation Data and Surveillance
Provide a thorough review and evaluation of any instrumentation data collected to-date.
Discuss what constitutes expected behavior of each instrument and identify any trends or
unusual data (e.g., outside the expected range or historic range, or indicative of poor
instrument maintenance or procedures). Interpret and evaluate the data with respect to
performance of the project feature. Include in the body of the report, as needed, annotated
snapshots of data along with any statistical evaluation; alternatively, reference that
information as provided in Appendix D: Instrumented Monitoring Data Plots.
Provide a summary of the findings of routine or special surveillance performed by the
licensee or third-party consultants (e.g., a diver inspection of the upstream face of a
concrete gravity dam). This should incorporate a review of licensee inspection checklists,
contractor special inspection reports, etc. Evaluate the findings with respect to
performance of the project feature.
6.2.3 Evaluation with Respect to Potential Failure Modes
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
6.2.4 Conclusion
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
6.3 [Name of Project Feature 2]

6.3.1 Field Inspection Observations

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6.3.2 Review and Evaluation of Instrumentation Data and Surveillance

6.3.3 Evaluation with Respect to Potential Failure Modes

6.3.4 Conclusion

6.4 [Name of Project Feature 3, 4, etc.]


Include additional sections for project features as needed.
6.5 Overall Interpretation of Instrumentation Data
(Note: the numbering for this section will depend on the number of project features
discussed.)

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SECTION 7: PFMA AND RISK ANALYSIS


This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.

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Document Accession #: 20230329-3010 Filed Date: 03/29/2023

SECTION 8: REVIEW AND EVALUATION OF DAM AND PUBLIC


SAFETY PROGRAMS

8.1 Owner’s Dam Safety Program

8.2 Dam Safety Surveillance and Monitoring Program

8.3 Hazard Potential Classification

8.4 Emergency Action Plan

8.5 Public Safety Plan

8.6 Operations and Maintenance

8.7 Spillway Adequacy


This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
8.8 Supporting Technical Information Document and Digital Project Archive
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.

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APPENDICES FOR THE COMPREHENSIVE ASSESSMENT REPORT

Appendix A: FERC Letter Requiring Part 12D Inspection

Appendix B: FERC Letter Approving Part 12D Inspection Plan and IC Team

Appendix C: Project Figures


Include a set of legible figures sufficient to foster a clear understanding of the project
features. The level of detail should be informative but not excessive; FERC exhibit
drawings can be used.
• A general location map, annotated with the location(s) of project facilities,
including water conveyances, access routes, major roads, and towns;
• Plan drawings of project facilities;
• Typical sections, elevations, and profiles of key project features (e.g., dams,
spillways, powerhouses, intakes, emergency/fuse plug spillways, chute profiles,
etc.);
• Typical sections and profiles of water conveyances;
• A satellite or aerial image of the project and downstream area, annotated as
needed; and
• Spillway and tailwater rating curves.
Additional information should be provided as needed.
Appendix D: Instrumented Monitoring Data Plots
This appendix must include any instrumented monitoring data plots and statistical
analysis prepared by the IC Team to evaluate the data and performance of project
features, along with any plots or excerpts from previous Dam Safety Surveillance and
Monitoring Reports (DSSMRs) that are considered critical to understanding the IC
Team’s evaluation.
It is not necessary for the CA-PIPR to reproduce every plot that has already been
provided in an annual DSSMR. The IC Team should include a list of the annual DSSMRs
that were reviewed and provide appropriate references for any plots or excerpts.

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Appendix E: Inspection Photographs


This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
Appendix F: Inspection Checklists and/or Field Notes
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
Appendix G: Operation and Maintenance Documentation
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
Appendix H: Potential Failure Modes Analysis Report
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
Appendix I: Risk Analysis Report
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.
Appendix J: Independent Calculations
This section is reserved as a placeholder so the numbering is consistent with the CAR. No
content is required to be provided in this section of the CA-PIPR.

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Appendix F: Outline for the CA Review Meeting Presentation

APPENDIX 16-F OUTLINE FOR THE CA REVIEW MEETING


PRESENTATION

This appendix provides a brief outline for a Comprehensive Assessment Review Meeting
Presentation.

1. Title Slide (dam name, state, FERC regional office, dam owner/licensee,
photograph)
2. Project Location Map
3. Project Team (names and roles for IC team and facilitators)
4. Project Description (include key drawings)
5. Summary of Review of Design, Construction, and Analysis
6. Review of STID
7. Key Field Inspection Findings
8. Review of Dam Safety Surveillance and Monitoring Report
9. Summary of PFMA (overall summary of PFMs)
10. Loading Curves (hydrologic and seismic)
11. Consequence Summary (life loss, economic, and other)
12. Risk Analysis Summary (risk plot, discussion of risk-driving PFMs)
13. Review of Dam and Project Safety Programs (ODSP, DSSMP, EAP, PSP, O&M,
etc.)
14. Summary of Findings and Recommendations (key findings, status of outstanding
recommendations, summary of new recommendations)

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Document Content(s)
Chapter 16 - Part 12D Program (rev 1).pdf ................................1

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