Industries RIDM - Regulations, Guidelines and Manuals
Chapter 6 – Emergency Action Plans (Final Version)
The Division of Dam Safety and Inspections, Office of Energy Projects, has finalized revisions to Chapter 6 of the Engineering Guidelines for Emergency Action Plans. The guidelines are revised to be consistent with the Federal Guidelines for Dam Safety – Emergency Action Planning for Dams, FEMA P-64, July 2013. Other changes include:
- Incorporating FERC initiatives on EAPs which occurred since Chapter 6 was last revised in 2007.
- Making exercise terminology consistent with the Homeland Security Exercise and Evaluation Program (HSEEP).
- Including additional guidance and examples on inundation maps.
A detailed description of all changes is described by following this link: Revisions .
The primary item that will affect existing EAPs is the modification to emergency levels (pgs. 20-22). The reason for the change was to: (1) clarify procedures for notifying agencies about high flows; (2) describe procedures for incidents that would not likely lead to a dam failure but need additional investigation; and (3) eliminate the lettering system which confused some emergency responders and was inconsistent among dam safety organizations. While we recognize many EMAs are already familiar with the current emergency conditions used at projects under the FERC’s jurisdiction, we believe moving toward clear language instead of code words regarding dam safety emergencies will best serve emergency communications over the long-term. It is important that anytime someone is notified of an incident or emergency at a dam that the caller explains in plain language what is occurring and not assume all parties understand what an emergency level means. All Licensees should discuss the revised emergency levels with their primary EMAs before issuing their revised/reprinted EAP.
Emails we received during the open comment period on the draft guidelines included some common questions. These are addressed as follows:
- The EAP documents submitted to the FERC are treated as Critical Energy Infrastructure Information (CEII). The treatment of sensitive information in EAP documents provided by licensees to other plan holders is based on the licensees’ discretion and responsibility.
- Providing different versions of the EAP that are tailored to the needs of specific plan holders is not required but is often beneficial.
- The new EAP guidelines contain a number of appendices that were included in the revised FEMA 64 document and are considered optional. See Section 6-11 for clarification.
- The Summary of EAP Responsibilities section at the beginning of the revised EAP outline is optional.
- Similar to the new FEMA 64 appendices, which were intended to provide examples of information that could be beneficial to an EAP, the inundation mapping appendix (6-N) is provided to illustrate the state-of-the-practice for inundation mapping. The revised guidelines do not mandate that all licensees submit new inundation maps.
- While not required, Licensees that provide the information shown in the Appendix 6-C example will likely be compliant with the revised annual requirements. The information shown in the Appendix 6-C example eliminates the need to submit additional coordinating documentation such as verification cards.
For those licensees that are required to submit EAP reprints by December 31, 2015, that deadline is still effective. Extension of time requests to the FERC Regional Office should be submitted if more time is required and these will be reviewed on a case-by-case basis.