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HomeMy WebLinkAbout09.30.26 Board Correspondence - FW_ Compliance Directives issued in FERC P-77-000,et al.From:Clerk of the Board To:Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Dubose, Teri; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa; Krater, Sharleen; Lee, Lewis; Ritter, Tami; Simmons, Katie; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug; Zepeda, Elizabeth Cc:Loeser, Kamie; Cannon, Jamie Subject:Board Correspondence - FW: Compliance Directives issued in FERC P-77-000,et al. Date:Wednesday, September 30, 2026 11:50:13 AM Please see Board Correspondence - Lewis Lee Administrative Technician - Confidential Butte County Administration 25 County Center Drive, Suite 200 • Oroville, CA 95965 T: 530.552.3326 www.buttecounty.ca.gov | lelee@buttecounty.ca.gov -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Wednesday, September 30, 2026 11:47 AM Subject: Compliance Directives issued in FERC P-77-000,et al. .ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying.. On 9/30/2026, the Federal Energy Regulatory Commission (FERC), Washington D.C., issued this document: Docket(s): P-77-000 P-96-000 P-137-000 P-175-000 P-233-000 P-606-000 P-619-000 P-803-000 P-1061-000 P-1121-000 P-1354-000 P-1962-000 P-1988-000 P-2105-000 P-2106-000 P-2107-000 P-2130-000 P-2310-000 P-2661-000 P-2687-000 P-2735-000 Lead Applicant: Pacific Gas and Electric Company Filing Type: Compliance Directives General Correspondence Description: Letter to Pacific Gas and Electric Company providing comments on the 2024 Owner's Dam Safety Program re the Potter Valley Project et al. under P-77 et al. 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Comments and Suggestions can be sent to this email address: mailto:FERCOnlineSupport@Ferc.gov FEDERAL ENERGY REGULATORY COMMISSION Office of Energy Projects Division of Dam Safety and Inspections –San Francisco Regional Office September 30, 2026 In reply refer to: Project Nos. 77, 96, 137, 175, 233, 606, 619, 803, 1061, 1121, 1354, 1962, 1988, 2105, 2106, 2107, 2130, 2310, 2661, 2687, and 2735-CA VIA FERC Service Mr. Russell Cruzen, P.E., Director Power Generation, Asset Excellence Pacific Gas and Electric Company 300 Lakeside Dr. Oakland, CA 94612-3534 Re:2024 Owner’s Dam Safety Program Dear Mr. Cruzen: This is in response to a letter dated July 1, 2024 from Mr. David Ritzman that submitted the 2024 Owner’s Dam Safety Program (ODSP) including Utility Policy PG- 01 (Revision 5), Utility Standard PG-2760S (Revision 5), and the current (as of June 2024) dam safety program organization and staffing charts for the projects listed in Enclosure 1.Our Project Engineers contact information is included in Enclosure 2. We appreciate the effort that you undertook to put together this important document that will help to improve both the technical and organizational aspects of the dam safety program. Your submitted ODSP generally conforms to the requirements outlined in our letter dated May 4, 2012. However, there are some areas that require further information as outlined in Enclosure 3. To the extent that your ODSP does not already include these, Enclosure 4 includes our recommended enhancements of best practices to consider in further developing your ODSP. The ODSP should be considered to be a living document that will require revision from time to time. Therefore, as revisions are made, we request that a complete resubmittal of the ODSP be made to us. Within 45 days of the date of this letter, address our comment in Enclosure 3 or provide a plan and schedule to address our comment in Enclosure 3. File your submittal 2 using our eFiling system at https://www.ferc.gov/ferc-online/overview. When eFiling, select Hydro: Dam Safety; San Francisco Regional Office from the eFiling menu. The cover page of the filing must indicate that the material was eFiled. For assistance with eFiling, contact FERC Online Support at FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659 (TTY). You are reminded that your ODSP should undergo an external audit every 5 years. Prior to conducting an audit of your ODSP, submit a statement of qualifications of the proposed auditor for our review and acceptance. We note that your ODSP audit is currently underway We appreciate your continued efforts in this aspect of our dam safety program. If you have any questions,contact me at (415) 369-3318. Sincerely, Frank L. Blackett, P.E. Regional Engineer Enclosures (4) 1.Projects and D2SI Project Engineers 2.D2SI Project Engineers Phone Numbers 3.Recommended Revisions to ODSP 4.ODSP Best Practices Projects Included in Enclosure 1 PG&E’s ODSP Report Page 1 of 1 Table 1. Projects and Project Engineers Covered by the 2021 ODSP Audit Report Project No.Project Name Engineer 77 Potter Valley Ryan Tom 96 Kerckhoff Samuel Lee 137 Mokelumne River Vincent Vigil 175 Balch Samuel Lee 233 Pit No. 3, 4, and 5 Fenggang Ma 606 Kilarc-Cow Creek Samuel Lee 619 Bucks Creek Eunhye Kim 803 De Sabla-Centerville Eunhye Kim 1061 Phoenix Vincent Vigil 1121 Battle Creek Samuel Lee 1354 Crane Valley Samuel Lee 1962 Rock Creek-Cresta Eunhye Kim 1988 Haas-Kings River Samuel Lee 2105 Upper North Fork Feather River Eunhye Kim 2106 McCloud-Pit Fenggang Ma 2107 Poe Eunhye Kim 2130 Spring Gap-Stanislaus Vincent Vigil 2310 Drum-Spaulding Mynul Chowdhury, Thao Bui 2661 Hat Creek Nos. 1 and 2 Fenggang Ma 2687 Pit No. 1 Fenggang Ma 2735 Helms Samuel Lee FERC Project Engineers’ Phone Numbers for Enclosure 2 The Projects listed in Table 1 Page 1 of 1 Table 2. FERC Project Engineer Phone Numbers FERC Engineer Phone Number Ryan Tom (415) 369-3347 Vincent Vigil (415) 369-3315 Fenggang Ma (415) 369-3319 Eunhye Kim (415) 369-3321 Samuel Lee (415) 369-3393 Mynul Chowdhury (415) 369-3313 Thao Bui (415) 369-3312 Recommended Revisions to ODSP Enclosure 3 Project Nos. 77, 96, 137, 175, 233, 606, 619, 803, 1061, 1121, 1354, 1962, 1988, 2105, 2106, 2107, 2130, 2310, 2661, 2687, and 2735-CA Page 1 of 1 1.Provide a list of all your dams covered by this ODSP. 2.The dam safety expectations are provided in the documents titled PG-2763P-01 and PG-2761S. Provide summaries of all relevant documents regarding the dam safety expectations in the body of the ODSP. 3.Responsibilities for dam safety for the following individuals should be included: Chief Executive Officer (CEO), board of directors, powerhouse managers, powerhouse staff, and consultant. 4.Include the name(s)of your CEO,board of directors; and attach the resume of the Chief Dam Safety Engineer (CDSE). 5.Include a succession plan for the powerhouse managers, engineering staff and support staff. Recommended Revisions to ODSP Enclosure 4 Page 1 of 1 Based on a nationwide review of the submitted ODSPs, we have compiled the following list of Best Practices that may be beneficial to your organization. 1.In general, an owner should have one ODSP for all their dams. 2.Although the ODSP program officially applies only to dams with high and significant hazard potential classifications, best practices are that it should be applied to dams with low hazard potential classifications as well. 3.Including citations of the applicable parts of the Federal Power Act and Title 18 of the Code of Federal Regulations (18 CFR) is encouraged in the ODSP. 4.Clauses in the ODSP that state that the employees should have “no fear of reprisal” for reporting dam safety concerns are encouraged. 5.Clauses in the ODSP noting that dam safety has priority over “production or business objectives” are encouraged. 6.Record keeping should be at least for the life of the facility (see 18 CFR, Part 125.21) and should also comply with 18 CFR Part 12.12. 7.Many ODSPs include discussions regarding various engineering tasks and dam safety management activities associated with physical modifications to projects. Please note that operational/management changes to a project may also require the same level of dam safety management and oversight by the Chief Dam Safety Engineer (CDSE) and others as do day-to-day operations. 8.The ODSP should include recommendations for the scope of training, which should be extended down to the Operator level. Attendance at conferences sponsored by FERC and other dam safety organizations such as the Association of State Dam Safety Officials (ASDSO), the United States Society on Dams (USSD), and the National Hydropower Association/Hydro Users Group (NHA/HUG) is encouraged. 9.Internal audits of ODSPs may be performed annually by the CDSE. External audits should be conducted by an outside third party as needed based on dam safety observations/considerations, but at least once every five years.