FERC Emergency Action Plans (EAP)

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Emergency Action Plan (EAP) Program\

Background

The “Guidelines for Preparation of Emergency Action Plans” were established in November 1979. The Guidelines were subsequently included as the Appendix to Order No. 122 of the Commission’s Regulations, issued January 21, 1981. Then, in accordance with the provisions of Section 12.22 (a) (1) of the Commission’s regulations, which states that “an emergency action plan must conform with the Guidelines established, and from time to time revised, …”, the guidelines were revised on April 5,1985, to provide more specific comprehensive guidance in the development of an EAP. Although the revised Guidelines established a specific format to assist in preparing an effective, workable EAP, it was not mandatory at that time that EAPs on file prior to April 5, 1985, comply with this format.

The EAP Guidelines were further revised on February 22, 1988, to provide a more workable EAP that included a notification flowchart located at the front of the EAP and clearer, concise, easy-to-read inundation maps depicting the dam break scenario. In addition, a need existed for a periodic reprinting and redistribution of the EAP to improve this aspect of its dam safety program.

Since that time, an initiative was developed to provide national (Federal, State, local) consistency in the content of Emergency Action Plans at dams throughout the country. As a result, the ad hoc Interagency Committee on Dam Safety (ICODS) prepared and approved federal guidelines for emergency action planning at dams which was published by FEMA in October 1998. As a result of the federal initiative, the FERC EAP Guidelines were further revised in November 1998.

The following were issued by FERC regarding EAPs:

Preparations for Handling Emergencies and Potential Emergencies at Projects
A draft guidance paper was prepared by FERC staff in 2004 incorporating lessons learned from recent dam failures and EAP activations. This paper highlights critical actions that should be taken by FERC staff and dam owners for emergency operations.

Fort Worth Workshop Initiative
A workgroup composed of FERC staff and representatives from 25 hydropower licensees was created from the February 2005 FERC Fort Worth Workshop to provide guidance and suggestions to the FERC for improving coordination and communication among dam owners and emergency response and law enforcement personnel. The product of the Workgroup is a “white paper” on emergency coordination that will provide useful information directly to dam owners and will assist FERC in revising the EAP chapter of the FERC Engineering Guidelines.

Coordination and Communication for Emergencies
The “white paper” on emergency coordination resulting from the 2005 Fort Worth Workshop workgroup is now available in final format. This paper provides guidance and suggestions for improving coordination and communication among dam owners and emergency response and law enforcement personnel. The paper will be attached to the EAP chapter of the FERC Engineering Guidelines as an appendix.

Draft Recovery Plan Format
A suggested Table of Contents and Guidance for an Internal Emergency Recovery (Response) Plan was initiated from the 2005 Fort Worth and 2006 Washington D.C. Workshop workgroup and is now available in Draft format. This Internal Emergency Recovery Plan (IERP) is designed as a separate document which can supplement the primary Emergency Action Plan (EAP). Whereas the primary EAP is designed to facilitate early warning and evacuation of potentially affected downstream areas, this document deals with MITIGATION AND EMERGENCY REPAIR OF AFFECTED COMPANY STRUCTURES AND PLANT FACILITIES. This plan should be utilized for any emergency arising at the site, whether from natural or manmade causes. The content of the Recovery Plan should avoid duplication of existing plans (such as the EAP) as much as possible. The Recovery Plan is intended for internal use and response only.

FERC is accepting comments about the Draft Recovery Plan Format until August 18, 2006. To provide a comment, please send an email message to Frank Calcagno 

FERC Emergency Action Plan (EAP) Program

 

Emergency Action Plans, Chapter 6 (Final Version) 
The Commission has revised Chapter 6 of the Engineering Guidelines on Emergency Action Plans. The chapter incorporates/addresses comments we received from licensees in response to the draft version issued in April-June 2007.

http://www.ferc.gov/industries/hydropower/safety/guidelines/eng-guide/chap6.asp

The following table briefly describes the changes to the chapter since the last revision in November 1998:

Pages Section Description of Changes
1 6-1 Modified section to highlight what is in chapter.
2-6 6-2.2 Added new section describing schedules for EAP submittals and exercises.
11-12 6-3.1.8 Added new section on EAP document security.
12 6-3.2.1 Noted that changes to the EAP format should be coordinated with agencies and explained to the Regional Engineer.
15-18 6-3.2.2 I Discussed emergency dispatch centers and revised sample notification flowchart.
17 6-3.2.2 III Added sentence on document security.
19-21 6-3.2.2 IV Added discussion on emergency classifications.  Referred to Non-Failure Emergency Condition as Condition C.
23-24 6-3.2.2 V B Added example emergency message and introduced Incident Command System.
25 6-3.2.2 V C Explained section can reference EOPs.
32-40 6-3.2.2 VII Revised section on inundation maps. Discussed map preparation, content, coordination, updates, and populations at risk.  Included sample maps.

41

6-3.2.2 App A Revised section on dam break analyses to reference Engineering Guidelines Chapter 2.
43 6-3.2.2 App B Added that training plan should include public education, if appropriate.
45 6-3.2.2 App D Revised “Documentation” section and removed “Approval of EAP” section.

46-66

6-4.2 Revised detailed discussions on exercises. Provided orientation seminar requirements and possible discussion topics. Noted that testing emergency equipment should be done once a year and be considered part of the drill. Added methods for conducting tabletop exercises. Discussed scheduling functional exercises.
70 6-4.5 Deleted expenditures section on results from exercises.
71-73 6-5 Added new section on ensuring effective EAPs.
74-75 6-6 Discussed annual requirements for projects exempt from EAPs.
77-78 6-9 Added section on temporary construction emergency action plans.
Appendices Eliminated dam break parameters since they are found in Chapter 2 of the Engineering Guidelines.
80 App. 6-A Updated FEMA documents/classes.
86 App. 6-C Made minor changes to evaluation report format.
88-92 App. 6-D Provided requirements for submitting GIS inundation map information to the Commission.
94 App. 6-E Provided Sample Coordination Checklist for EAP Status Reports.