Dam Safety: FERC Should Analyze Portfolio-Wide Risks
Fast Facts
The Federal Energy Regulatory Commission oversees over 2,500 dams used for hydropower. The near failure of a FERC-licensed dam in California in 2017 highlights the safety risks of dams. What does FERC do to ensure safety?
FERC engineers inspect dams and review engineering studies as key safety steps. This helps FERC understand the risks at individual dams. However, a lack of standard language and procedures for recording inspection results limits FERC's ability to identify comparable safety risks at other dams.
We recommended that FERC develop standard language and procedures for inspection information and assess safety risks portfolio-wide.
Dam and Related Key Structures
Illustration of a dam used to produce hydropower.
Highlights
What GAO Found
The Federal Energy Regulatory Commission's (FERC) staff generally followed established guidance in collecting safety information from dam inspections for the dams GAO reviewed, but FERC has not used this information to analyze dam safety portfolio-wide. For these 42 dams, GAO found that FERC staff generally followed guidance in collecting safety information during inspections of individual dams and key structures associated with those dams. (See figure.) However, FERC lacks standard procedures that specify how and where staff should record safety deficiencies identified. As a result, FERC staff use multiple systems to record inspection findings, thereby creating information that cannot be easily analyzed. Further, while FERC officials said inspections help oversee individual dam's safety, FERC has not analyzed this information to identify any safety risks across its portfolio. GAO's prior work has highlighted the importance of evaluating risks across a portfolio. FERC officials stated that they have not conducted portfolio-wide analyses because officials prioritize the individual dam inspections and response to urgent dam safety incidents. However, following the Oroville incident, a FERC-led initiative to examine dam structures comparable to those at Oroville identified 27 dam spillways with varying degrees of safety concerns, on which FERC officials stated they are working with dam licensees to address. A similar and proactive portfolio-wide approach, based on analysis of common inspection deficiencies across the portfolio of dams under FERC's authority, could help FERC identify safety risks prior to a safety incident.
Dams and Related Key Structures
FERC staff follow agency guidance and apply professional judgment to assess engineering studies on key aspects of dam performance and safety. Licensees and their consultants develop engineering studies that assess dam performance and safety in consideration of expected conditions—as related to hydrology and seismicity, for example—and that FERC staff then use to inform their safety determinations. FERC has established policies, such as requiring multi-layered reviews, to ensure the accuracy of these studies. For example, FERC's Engineering Guidelines provide a framework for the review of engineering studies, though the Guidelines recognize that each dam is unique and allow for flexibility and exemptions in its use. FERC staff use the studies to inform other components of their safety approach, including the analysis of dam failure scenarios and their review of safety to determine whether to renew a license.
Why GAO Did This Study
In February 2017, components of California's Oroville Dam failed, leading to the evacuation of nearly 200,000 nearby residents. FERC is the federal regulator of the Oroville Dam and over 2,500 other dams associated with nonfederal hydropower projects nationwide. FERC issues and renews licenses—which can last up to 50 years—to dam operators and promotes safe dam operation by conducting safety inspections and reviewing technical engineering studies, among other actions.
GAO was asked to review FERC's approach to overseeing dam safety. This report examines: (1) how FERC collects information from its dam safety inspections and the extent of its analysis, and (2) how FERC evaluates engineering studies of dam performance to analyze safety, among other objectives. GAO analyzed documentation on a non-generalizable sample of 42 dams associated with projects relicensed from fiscal years 2014 through 2017, selected based on geography and hazard classifications, among other factors. GAO also reviewed FERC regulations and documents; and interviewed FERC staff associated with the selected projects and technical consultants, selected based on the frequency and timing of their reviews.
Recommendations
GAO recommends that FERC: (1) develop standard procedures for recording information collected as part of its inspections, and (2) use inspection information to assess safety risks across FERC's portfolio of dams. FERC agreed with GAO's recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Federal Energy Regulatory Commission | FERC should provide standard language and procedures to its staff on how to record information collected during inspections, including how and where to record information about safety deficiencies, in order to facilitate analysis of safety deficiencies across FERC's portfolio of regulated dams. (Recommendation 1) |
FERC regulates over 2,500 dams used to produce hydropower by issuing and renewing licenses to the non-federal operators of these dams. Dams have long service lives-licenses can last up to 50 years-and FERC promotes the safe operation of these dams over this time period by conducting safety inspections and reviewing technical engineering studies, among other actions. In 2018, we reported, based on our review of a non-generalizable sample of 42 dam safety inspections, that FERC staff generally conducted and collected information from these inspections consistent with guidance in its Operating Manual. While we found that FERC staff conducted inspections and collected inspection findings consistently in the files we reviewed, FERC's approach to recording information varied across its regions, thus limiting the usefulness of the information. FERC's approach to recording inspection information was inconsistent because FERC had not provided standard language and procedures about how staff should record and track deficiencies including which system to use. Federal standards for internal control state that agencies should design an entity's information system and related control activities to achieve objectives and control risks. FERC officials acknowledged that there were inconsistent approaches in where and how staff recorded safety deficiency information, approaches that limited the information's usefulness as an input to its oversight. By developing standard language and procedures to standardize the recording of information collected during inspections, FERC officials could help ensure that the information shared across these systems was comparable, steps that would allow FERC to identify the extent of and characteristics associated with common safety deficiencies across its entire portfolio of regulated dams. In light of these findings, we recommended that FERC provide standard language and procedures to its staff on how to record information collected during inspections, including how and where to record information about safety deficiencies, in order to facilitate analysis of safety deficiencies across FERC's portfolio of regulated dams. In 2022, we confirmed that FERC developed and issued new standard operating procedures for its Data and Management System (DAMS) related to the tracking of requirements from dam safety inspections and other dam safety reviews. In particular, the procedures list task codes that FERC staff are to use to identify specific actions that were determined to be needed following a dam's inspection and to track the response. Further, FERC awarded a contract for IT modernization that it expects will enhance the capabilities of DAMS to facilitate the complete recording and subsequent analysis of safety deficiencies from inspections across FERC's portfolio of regulated dams. With a consistent approach to recording information from individual dam safety inspections, FERC is better positioned to proactively identify comparable safety deficiencies across its portfolio and to tailor its inspections towards evaluating them.
|
| Federal Energy Regulatory Commission | FERC should use information from its inspections to assess safety risks across its portfolio of regulated dams to identify and prioritize safety risks at a national level. (Recommendation 2) |
FERC regulates over 2,500 dams used to produce hydropower by issuing and renewing licenses to the non-federal operators of these dams. Licensees are responsible for the safety and liability of dams, pursuant to the Federal Power Act, and for their continuous upkeep and repair using sound and prudent engineering practices. In 2018, we reported that while FERC used inspection information to monitor a licensee's efforts to address a safety deficiency for an individual dam, FERC had not analyzed information collected from its dam safety inspections to evaluate safety risks across its entire regulated portfolio of dams. For example, FERC had not reviewed inspection information to identify common deficiencies among certain types of dams. Federal standards for internal control state that agencies should identify, analyze, and respond to risks related to their objectives. These standards note that one method for management to identify risks is the consideration of deficiencies identified through audits and other assessments. Dam safety inspections are an example of such an assessment. In our previous work on federal facilities, we have identified that an advanced use of risk management involving the ability to gauge risk across a portfolio of facilities could allow stakeholders to comprehensively identify and prioritize risks at a national level and direct resources toward alleviating them. FERC officials stated that they had not conducted a portfolio-wide analysis in part due to the inconsistency of recorded inspection data and because such an evaluation has not been a priority compared to inspecting individual dams. Therefore, we recommended that FERC use information from its inspections to assess safety risks across its portfolio of regulated dams to identify and prioritize safety risks at a national level. In response, FERC reported in 2021 that it had completed a screening-level risk analysis of 754 high- and significant-hazard dams in its portfolio and initiated 24 projects to address the risks it identified. FERC assessed each of these dams for failure risks in four categories and developed a risk score for each dam that it used in making portfolio-wide risk-based comparisons. We confirmed with FERC that, among other actions affecting those dams determined to be at higher risk, the agency will use the results of the assessment to set priorities for studies and modification projects, provide more focused review and potentially require more frequent testing of emergency action plans, and perform greater oversight of surveillance and monitoring plans. Further, FERC updated its dam safety regulations to adopt a new two-tier structure for the independent consultant safety inspections that are to be conducted every five years at higher risk dams. The required scope of these inspections will alternate between a new, more in-depth assessment and a periodic inspection. The newly-required in-depth assessment will include, among other features, a detailed review of the dam's design and construction history and a risk analysis. Collectively, FERC's enhanced efforts to assess safety risks across its regulated dams portfolio should help both the agency and its licensees identify safety risks prior to a safety incident and to develop approaches to mitigate those risks
|