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.
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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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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.