Hydro Leader October 2020 by Water Strategies

Leader ydro H VOLUME 1 ISSUE 2

october 2020

Sharon Powers of the U.S. Society on Dams: Supporting the Dam and Levee Industry

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Sharon Powers of the U.S. Society on Dams: Supporting the Dam and Levee Industry

Contents

October 2020 Volume 1, Issue 2 5 E nsuring U.S. Dams’ Safety and Success By Kris Polly 6 Sharon Powers of the U.S. Society on Dams: Supporting the Dam and Levee Industry 12 Israel Water Education and Trade Tour Preview, June 27–July 7, 2021 14 A n Insider’s Look at the Bureau of Reclamation’s Dam Safety Program

22 E nsuring the Efficiency and Competitiveness of Reclamation’s Hydropower Fleet 30 T he Course Offerings of Voith’s HydroSchool WATER LAW 34 F ERC Proposes Significant Changes to Dam Safety Regulations in Wake of Michigan Dam Failures By Chuck Sensiba and Melissa Horne

Hydro Leader Hydro Leader is published 10 times a year with combined issues for July/August and November/December by

an American company established in 2009.

STAFF: Kris Polly, Editor-in-Chief Joshua Dill, Managing Editor Tyler Young, Writer Stephanie Biddle, Graphic Designer Eliza Moreno, Web Designer Milo Schmitt, Media Intern Caroline Polly, Production Assistant and Social Media Coordinator SUBMISSIONS: Hydro Leader welcomes manuscript, photography, and art submissions. However, the right to edit or deny publishing submissions is reserved. Submissions are returned only upon request. For more information, please contact our office at (202) 698-0690 or hydro.leader@waterstrategies.com. ADVERTISING: Hydro Leader accepts half-page and full-page ads. For more information on rates and placement, please contact Kris Polly at (703) 517-3962 or hydro.leader@waterstrategies.com. CIRCULATION: Hydro Leader is distributed to all hydroelectric facility owners in the United States, to hydrorelated businesses, and to every member of Congress and governor’s office. For address corrections or additions, or if you would prefer to receive Hydro Leader in electronic form, please contact our managing editor, Joshua Dill, at joshua.dill@waterstrategies.com. Copyright © 2019 Water Strategies LLC. Hydro Leader relies on the excellent contributions of a variety of natural resources professionals who provide content for the magazine. However, the views and opinions expressed by these contributors are solely those of the original contributor and do not necessarily represent or reflect the policies or positions of Hydro Leader magazine, its editors, or Water Strategies LLC. The acceptance and use of advertisements in Hydro Leader do not constitute a representation or warranty by Water Strategies LLC or Hydro Leader magazine regarding the products, services, claims, or companies advertised.

hydroleadermagazine.com

Do you have a story idea for an upcoming issue? Contact our editor-in-chief, Kris Polly, at kris.polly@waterstrategies.com.

4 | HYDRO LEADER | October 2020

hydro_leadr

COVER PHOTO:

The spillway at Santee Dam, South Carolina. Photo courtesy of Santee Cooper.

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PHOTO COURTESY OF USSD.

Coming soon in Hydro Leader November/December: Leslie James, Executive Director, CREDA

Ensuring U.S. Dams’ Safety and Success By Kris Polly

ams and hydropower facilities in the United States bring local communities immense benefits—flood control, reliable power, water storage, jobs, and recreational benefits among them. But to ensure that their benefits are known, they must be successfully communicated to the public and to federal and local policymakers. That is the mission of the U.S. Society on Dams (USSD), whose executive director, Sharon Powers, is featured in this month’s cover interview. Ms. Powers tells us about how the USSD helps empower U.S. dam and levee professionals to advance the sustainable benefits of dams and levees for society through education, collaboration with national and international organizations, and career development activities. We also bring you two important interviews with Bureau of Reclamation staff on hydropower-related issues. First, we speak with Karen Knight, Reclamation’s director for dam safety and infrastructure; Bob Pike, the chief of Reclamation’s dam safety program; and Brian Becker, a senior advisor at Reclamation and the agency’s design, estimating, and construction oversight and dam safety officer, about Reclamation’s dam safety activities. Second, we speak with Max Spiker, Reclamation’s senior advisor for hydropower, about how the agency keeps its facilities and

operations up to date to ensure that hydropower remains a long-term cost-competitive energy source. Then, we speak with Inna Kremza about the Voith HydroSchool, which offers Voith clients and the public a wide variety of courses on the design, modernization, and rehabilitation of turbines and generators and the operation and maintenance of hydropower plants. Finally, we feature an article by Chuck Sensiba and Melissa Horne of law firm Troutman Pepper on new proposed changes to the Federal Energy Regulatory Commission’s dam safety regulations in the wake of the 2017 Oroville spillway failure and the failures of two Michigan dams in May 2020. Hydropower and dams are crucial parts of our nation’s economy. To make sure that this continues to be so, U.S. dam owners must ensure that their facilities are safe and that those facilities’ benefits are clearly communicated to the publics they serve. H Kris Polly is the editor-in-chief of Hydro Leader magazine and the president and CEO of Water Strategies LLC, a government relations firm he began in February 2009 for the purpose of representing and guiding water, power, and agricultural entities in their dealings with Congress, the Bureau of Reclamation, and other federal government agencies. He may be contacted at kris.polly@waterstrategies.com.

Leaders’ Training

Water Strategies LLC is organizing Leaders’ Training to provide a series of professional development and training opportunities for personnel in the irrigation, municipal, and hydrogeneration industries. All training sessions are virtual, 60 minutes in length, and scheduled for 2:00 p.m. Eastern, 1:00 p.m. Central, 12:00 p.m. Mountain, and 11:00 a.m. Pacific.

Human Resources Compliance Manager Training Program In this training series, we will tackle crucial issues in the web of human resources rules and regulations. This program is aimed at providing managers with the skills to navigate the hiring process, to manage employee performance, to take appropriate steps in workplace investigations, and to implement a termination when it is time.

Instructor:

Diane Campanile, SHRM-SCP, has more than 20 years of human resources experience in federal and state regulatory compliance, workplace investigations, employee relations, performance management, employee handbook development/implementation and employee benefits and compensation benchmarking.

October 1: October 8: October 22: October 29:

Hiring Practices: Ensuring Compliance Performance Management: Developing Talent Workplace Investigations: Following Proper Steps Employment Termination: Avoiding Litigation

Training fee: $200.00 per individual “Thank you for your review our Employee Handbook. Your review will help ensure that our Handbook is more concise. Your professionalism and responsiveness is very much appreciated.” —Robert Boatman, Carlsbad Irrigation District

To register, please see our website at irrigationleadermagazine.com. hydroleadermagazine.com

October 2020 | HYDRO LEADER

Sharon Powers of the U.S. Society on Dams: Supporting the Dam and Levee Industry

USSD board member Marty Teal visits the Chaudière Falls Generating Station on an ICOLD tour of Ottawa, Ontario.

he U.S. Society on Dams (USSD) is the U.S. national committee of the International Commission on Large Dams (ICOLD) and has been in operation for more than nine decades. Its mission is to empower professionals to advance the sustainable benefits of dams and levees for society. It advances this mission by hosting educational programs and conferences, encouraging collaboration with national and international organizations, and fostering career paths in the industry. In this interview, USSD Executive Director Sharon Powers tells Hydro Leader about the history and current activities of the society. Hydro Leader: Please tell us about your background and your current position.

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Hydro Leader: Please tell us about USSD and its history. Sharon Powers: USSD is the U.S. national committee of ICOLD. The United States was one of the founding members of ICOLD, which was established in 1928, hydroleadermagazine.com

PHOTOS COURTESY OF USSD.

Sharon Powers: I’ve been a nonprofit professional for over 25 years, spending most of that time in C-suite positions in chambers of commerce. Before joining USSD, I was a department director at the American Water Works Association. While I spent my childhood in Pittsburgh, my father was from

Denver. I always knew that I wanted to get back to Denver, which I did a little over 10 years ago. USSD is headquartered in Westminster, Colorado, in the northern Denver metro area. As the chief staff executive of USSD, I’m responsible for managing the association and carrying out the strategic plan approved by the board of directors. This includes financial and operational management, collaboration with other organizations, volunteer management, event planning, and state and federal regulation compliance. We have an exceptionally small staff—there are only 1¾ positions, including my own—so I like to tell people that in addition to all my other roles, I’m the chief cook and bottle washer.

USSD President Denise Bunte-Bisnett delivering remarks. Denise Bunte-Bisnett and Sharon Powers are the first women leaders in USSD's history.

and the U.S. committee was originally known as the U.S. Committee on Large Dams, or USCOLD. In 1988, it rebranded itself as USSD. Our members are professionals in the dam and levee industry and include some of the top engineers in their fields of expertise. They include members of federal and state agencies, consulting engineers, contractors, manufacturers, technicians, and academics, among others. A number of our members have been appointed to high-profile forensic teams, including the forensic team that investigated the 2017 Oroville spillway failure and the recent Michigan dam failures. Our connection with ICOLD gives our members access to the international dam community. Hydro Leader: What are your members’ top issues? Sharon Powers: Infrastructure funding is the paramount issue. Many of the dams in the United States are 50 years old or older and need to be maintained. Without adequate hydroleadermagazine.com

infrastructure funding and attention by dam owners, a lot of necessary repairs and maintenance are not being done. This increases the risk of dam failures. Another issue is the public perception of dams. Dams and levees seem to have negative connotations in the minds of the general public, and the public does not understand the benefits of having dams and levees in their communities. Without dams, many communities would cease to exist in their current form. Both dams and levees provide economic and environmental benefits to communities as well as irrigation, energy generation, water storage, and a lot of recreational opportunities. There is also a lack of regulatory enforcement. Regulations on dams and levees exist, but they are not enforced. In the case of the Edenville Dam failure in Michigan, the dam owner had lost its Federal Energy Regulatory Commission (FERC) license to operate due to deficiencies, and the dam went under state oversight. However, it appears the actions needed to ensure that the dam could operate in a safe manner were not carried out. October 2020 | HYDRO LEADER

2018 USSD President Dean Durkee signs a memorandum of understanding with the Korea National Committee on Large Dams.

We also have a shortage of individuals coming into the dam industry. Since the discipline is not being widely taught in postsecondary schools, there are not a large number of engineers qualified to work on various aspects of dams and levees. Our consulting engineer members are extremely busy, and there is more work than they can handle. Hydro Leader: Is safety an important concern for your members? Sharon Powers: Of course; it’s a huge concern. USSD’s new vision statement describes a world where all dams and levees are safe and valued by the communities they serve. Safe dams provide significant benefits to communities. Hydro Leader: How can the hydropower industry be more effective in communicating with the public?

Hydro Leader: Would you tell us about the conferences and educational programs that USSD hosts? Is USSD providing remote or virtual events during the pandemic?

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Hydro Leader: How does USSD help encourage young professionals to pursue careers in the dam and levee field? Sharon Powers: Actually, our outreach extends to students who have not yet launched their engineering careers. When we talk to dam and levee engineers, one thing that we hear is that they fell into the field by accident. Most of them graduate from college with degrees in civil, geotechnical, environmental, or structural engineering; there are few schools that have a focus on dam engineering. We need to do a better job of exposing students to this industry as early as their middle school years. USSD has a number of opportunities for young professionals and students, hydroleadermagazine.com

PHOTOS COURTESY OF USSD.

Sharon Powers: I think that the dam and levee community as a whole, including the hydropower industry, can be more effective in the way it communicates the benefits of safe and sustainable dams. That includes getting in front of stakeholders prior to failures, when it’s easy to point out the positive aspects. It’s easier to be proactive than reactive. Hydropower is a clean, renewable energy source. I lived in Las Vegas, which has Hoover Dam in its backyard, for a number of years. Hoover Dam is a major energy producer for not only Nevada, but Arizona and California as well. Without Hoover Dam, utility costs would be significantly higher. I always viewed Hoover Dam as an asset because I understood its benefits.

Sharon Powers: USSD holds a technical conference each spring as well as a number of workshops. However, due to COVID‑19, our 2020 conference was canceled. We are currently converting our fall workshop series from face-to-face events to webinars. In addition to the virtual workshops, we have asked a number of our paper authors to transition their papers into a webinar. We had been talking about doing online training for a few years, and the pandemic accelerated the project. Virtual training is not going to go away after the pandemic subsides; it is here to stay. One new program that we rolled out in August is the USSD leadership skills series. While USSD excels in technical training, technical knowledge is only one piece of a well-rounded employee or professional. The leadership skills training focuses on soft, or power, skills—things like communication, leadership development, and negotiations. We kicked the series off in August with a series of nine webinars focusing on communication skills for engineers.

ADVERTISEMENT starting with greatly reduced membership and conference registration fees. Each of our technical committees has a slot in its leadership for a young professional vice chair. This provides young professionals with the ability to not only learn valuable leadership skills, but to become known to more-seasoned professionals. We had planned to hold a career fair in April during our conference and invite students from the metro Denver schools. This is something we will consider for future years. Hydro Leader: What is your message to Congress? What should its members know about USSD and hydropower in general?

the funding needs and estimated funding for dams and a gap of about $70 million for levees. Money has been appropriated through the Water Infrastructure Finance and Innovation Act; money has also been appropriated to the National Levee Safety Program. It’s important that the funding needed to repair and maintain the over 90,000 dams and over 100,000 miles of levees in the United States is made available. H

USSD Webinars USSD is hosting the following expanded education and training webinars this fall. While many were originally slated as in-person workshops, COVID-19 necessitated their transformation into virtual events. October 1: Asphalt Core Embankment Dams: Why, Where and How? October 7: Introduction to Probabilistic Dam Breach Modeling October 8: Understanding Potential Life Loss From Flooding: Shining a Light Into the Black Box That Is HEC-LifeSim October 12–16: Leveraging PFMA to Perform SQRA

USSD board member Marty Teal presenting at the 2018 ICOLD annual meeting.

Sharon Powers: Our message to Congress is that hydropower represents clean, renewable energy. It provides benefits to the electric grid, and unlike other forms of energy, it can be instantly turned on. With coal and even solar and wind, there is a ramp-up period before they begin generating power. With hydro, you get energy at the flip of a switch. It should be one of the primary sources of energy that the country is focused on. I would also draw attention to the fact that the owners of dams that generate hydro energy provide benefits to the communities they serve. One of the conditions of a FERC license, for example, is that the dam provide recreational access to the public. That includes boat docks, ramps, natural trails, and more. The community does not pay for that construction— it’s the dam owner who funds it—but the community reaps all the benefits. The only thing that the utility can charge for is the electricity it sells. This needs to change. If a community is reaping the benefits of the infrastructure a dam owner has constructed, there should be some offset or payment to the dam owner so that they can recoup their costs. Congress needs to provide infrastructure funding. According to the American Society of Civil Engineers, there is an investment gap of about $39.4 million between hydroleadermagazine.com

October 20: Evaluating Complex Systems as Part of a Semiquantitative Risk Assessment October 21: What the f-N? Clarifying Misconceptions about Risk Plots October 27–30: Introduction and Overview of Rock Scour November 10: Instrumentation and Performance Monitoring of Dams November 18: Seismic Thresholds for Embankment Dams and Their Return Periods December 8: Reclamation Consequences Estimating Methodology

Sharon Powers is the executive director of the U.S. Society on Dams. She can be contacted at sharon@ussdams.org.

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October 2020 | HYDRO LEADER

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An Insider’s Look at the Bureau of Reclamation’s Dam Safety Program

Bartlett Dam, northeast of Phoenix, Arizona, was built between 1936 and 1939 and was modified by Reclamation between 1994 and 1996 to address safety concerns.

Hydro Leader: Please tell us about your backgrounds and how you came to be in your current positions. Karen Knight: Thank you for highlighting how Reclamation is maintaining its dams in a safe and reliable manner that protects the health and safety of the public and Reclamation employees. I’m originally from the Midwest. Prior to coming

14 | HYDRO LEADER | October 2020

to Reclamation, I worked in private civil engineering. I worked on a lot of federal dams on various aspects of dam safety, so I’ve been working in dam safety for over 30 years. When I joined Reclamation in 2000, I was a design engineer in the Technical Service Center (TSC). After that, I advanced through management, becoming the division chief for the geotechnical services division in the TSC. Then I became the division chief for the dam safety office. Since then, I have moved into a senior leadership position with Reclamation and am the director for dam safety and infrastructure. Bob Pike: Thanks for showcasing how Reclamation is proactively maintaining our nation’s critical infrastructure. I graduated from Montana State University in 1982. My focus in college was on hydraulics and hydrology, so I had an interest in water infrastructure. My first job was in central Wyoming on what was known as a rehab and betterment project for the Midvale Irrigation District. I did a lot of design work, surveying, drilling, construction, and inspection. After about 2 years, at which point that job was winding hydroleadermagazine.com

PHOTO COURTESY OF THE BUREAU OF RECLAMATION.

he Bureau of Reclamation is internationally recognized as a leader in dam safety. The 1978 Reclamation Safety of Dams Act established an independent dam safety program within Reclamation. This program covers routine dam inspections and evaluations as well as corrective work and repairs and has become the global standard in the dam safety field. In this interview, Karen Knight, Reclamation’s director for dam safety and infrastructure; Bob Pike, the chief of Reclamation’s dam safety program; and Brian Becker, a senior advisor and the design, estimating, and construction oversight and dam safety officer at Reclamation, tell Hydro Leader about Reclamation’s impressive and comprehensive dam safety activities.

ADVERTISEMENT down, I moved to the regional office in Billings, Montana, and spent about 5 years as the civil engineer there, focusing on things like water operations and reservoir inflow forecasts. In 1989, a job opened up for the regional dam safety coordinator. It fit with my career interests, so I applied, got the job, and have been working in the dam safety program ever since. I was a regional coordinator from 1989 until 2011, when I moved down to Denver to work as a program manager in the dam safety office. In 2014, I was selected as the deputy chief of the dam safety program. In early 2019, I was selected as chief of the dam safety program. Brian Becker: I was born and raised in a small town in southern Minnesota and went to college at North Dakota State University. I came to Colorado shortly after graduation, worked for a consulting firm for a bit, and then came to work for Reclamation. I have been with Reclamation for over 30 years. I started back in 1985. I’ve spent most of that time working on dams and other water infrastructure. For probably two-thirds of that time, I worked directly in dam safety activities. I did much of that work from within the dam safety program. For the last 5 years, I have been Reclamation’s dam safety officer, a position that exists to provide a programmatic internal control to promote information quality and robust decisionmaking, separate from the dam safety program office itself.

PHOTO COURTESY OF WATERARCHIVES.ORG.

Hydro Leader: How many dams has Reclamation constructed?

Karen Knight: Reclamation has constructed about 600 dams since the early 1900s. There are currently 492 dams included in the national inventory of dams, which is a comprehensive database of dams in the United States. Reclamation is dedicated to the safety of all those dams. Brian Becker: Many of our structures are well over 100 years old, and ensuring their safe, reliable operation is the primary focus of Reclamation’s dam safety program. Hydro Leader: Please tell us about the history of Reclamation’s dam safety program. Brian Becker: Reclamation’s dam safety program got its beginnings after the Teton Dam failure in Idaho in 1976. The Reclamation Safety of Dams Act became law in 1978 and has been amended several times since then. That act gave Reclamation the authority to modify Reclamation facilities explicitly for safety purposes and launched Reclamation’s safety of dams activities to prevent accidents and ensure sound infrastructure. Bob Pike: Among the major dam failures of the 1970s were those of Laurel Run Dam in Pennsylvania and Kelly Barnes Dam in Georgia, both of which were non-Reclamation dams. Both occurred in 1977 and, unfortunately, each resulted in fatalities.

The failure of Teton Dam in 1976 was the impetus for the development of Reclamation’s dam safety program.

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October 2020 | HYDRO LEADER

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The 30th SEED International Technical Seminar and Study Tour was held in June 2019 and involved participants from 11 countries.

Hydro Leader: After the Teton Dam failure in 1976, what changes were instituted to increase safety across Reclamation? Bob Pike: We formally established the Reclamation dam safety program, which has evolved significantly since that time. We initially started performing what we call Safety Evaluation of Existing Dams (SEED) evaluations of all our infrastructure in order to get a handle on the issues and risks faced at each facility. The dam safety program has evolved and today can be broken into three major components: first, SEED evaluations, which I mentioned; second, the Initiate Safety Corrective Action (ISCA) program; and third, Reclamation training for the U.S. Department of the Interior. The SEED program is the program under which we undertake all the routine risk-management activities for all our high- and significant-hazard dams. Those activities include the regular inspection of our dams, performance monitoring, instrumentation monitoring, the evaluation of potential issues, and risk analysis at all our facilities.

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Brian Becker: Since the safety of dams is so important to Reclamation, there are people in many locations and roles whose work touches on the topic. There are people in the area offices who are involved in dam safety activities, including inspections, monitoring, and dam safety program activities. The TSC in Denver puts together all the designs and puts together the contract documents. Construction staff throughout Reclamation manage the construction projects. The dam safety program staff who focus 100 percent on dam safety activities are primarily located at our Denver office. The number of people who are associated with dam safety activities is likely in the hundreds at any given time, but there are probably 15–20 people who exclusively work on program management activities, all of them in the Denver office. Those staff work closely with the regional area offices and coordinate activities throughout the organization. Hydro Leader: How often are dams inspected? Bob Pike: At the most basic level, our dam operators are looking at our dams on an almost-daily basis, especially if we have onsite dam operators. They also go through a monthly inspection checklist, checking all the features of the dam and noting any changes or unexpected changes in performance. Reclamation also performs an annual site inspection of every high- and significant-hazard-potential dam; that is typically performed by engineers from our area offices, which are scattered throughout the western United States. There are also two higher-level inspections that are performed on a 4‑year rotating basis. One is the periodic facility review, which is usually conducted by dam safety engineers in our regional offices. They’re informed by the participation of the technical response teams (TRTs) that are assigned to each dam. These teams are made up of technical experts at the TSC. They review the overall performance of the dam over the previous 4 years and provide recommendations on areas of focus to the inspector hydroleadermagazine.com

PHOTO COURTESY OF THE BUREAU OF RECLAMATION.

Karen Knight: The ISCA component of the dam safety program is our method for rapidly taking corrective actions. If the SEED program identifies a risk and determines that an embankment or a concrete dam needs to be repaired, we initiate a corrective action study. At this point, a portion of the costs needs to be reimbursed by the project beneficiary. Under the corrective action program, we develop a whole host of alternatives, including no action, structural modifications, and reservoir restrictions, and then select our preferred alternatives. The one that is most commonly selected is structural modification. Then we develop what’s called a modification report, which goes to the Office of Management and Budget and then to Congress for approval. It is essentially a project justification report. From that point forward, we can award a contract, undertake construction, and modify the facility. Once we’re finished with construction, we don’t just walk away from the dam. We move the dam back into the SEED program and continue with routine risk management, which is the third phase.

Hydro Leader: How many people are associated with Reclamation’s safety of dam program?

ADVERTISEMENT before they go out in the field. The TRT reviews the results of the examination report and, in conjunction with the regional inspector, makes recommendations on how to address any potential dam safety issues. The other 4‑year inspection is what we call a comprehensive review. It is led by a senior-level engineer from the TSC who specializes in embankment dams or concrete dams, as appropriate. The engineer is supported by a team of engineers, geologists, and hydrologists from the TSC as well as engineers from the regional office and the area offices. In performing the examination, the comprehensive review team also performs a review of all potential failure modes associated with the dam and the relative risks represented by those potential failure modes. All these examinations and associated processes form the routine risk-management activities that we undertake to continuously assess the relative risk of our dams and to ensure that we’re adequately protecting the American public. Hydro Leader: If a problem is discovered with a dam, what steps do you take to assess the danger level? Bob Pike: I was the regional coordinator at the time when certain safety issues arose at Red Willow Dam in Frenchman-Cambridge Irrigation District in Nebraska, so I have some experience with the potential need for urgent action. If our monitoring processes identify high risks that demand urgent action, we quickly do a detailed issue evaluation to make sure that we understand what we’re dealing with and that the risk warrants moving into a corrective action study, the costs of which are partially reimbursable by the water users. In the case of Red Willow Dam, we discovered upstreamto-downstream cracks in the embankment below the reservoir water surface level. We lowered the reservoir water level to mitigate the risk and did more detailed investigations. Within about 2 months, we determined that additional actions were needed. We began a corrective action study and completed it within 9–12 months. We also simultaneously performed the final design of the modifications while pursuing authorization to construct modifications. Within about 2 years after finding the problem, we were moving into construction. At other dams, there are high-risk issues associated with extreme floods and earthquakes with relatively remote probabilities of occurrence. It may be somewhat more complicated to understand the probabilities of these events, the performance of the dam when subjected to these remote probability events, and the right actions to address them, so the evaluation process can take a bit longer. Overall, we have a risk-informed program. We prioritize our actions based on our current understanding of risk at our facilities. That prioritization takes into account our level of knowledge about risk levels: Do we need additional hydroleadermagazine.com

information to better understand risk at a given dam, or are we pretty confident in our assessment and ready to move forward with figuring out how to reduce those risks? We use a dam safety priority rating that starts at 1, which applies to a dam that is in an imminent state of failure, and moves down the scale to 5, which generally indicates that a dam has low to very low estimated potential safety risk. We use our risk-informed process to address the higher-risk issues first and address lower-risk issues when the funding is available. This allows us to reduce risks to the American public in a timely manner and to spend our money wisely. Hydro Leader: How are the costs of those repairs divided between the project beneficiaries and Reclamation? Karen Knight: I would like to note that there are no costs to the project beneficiaries until we have identified a risk and decided to move into corrective action. All the routine risk management that Bob talked about earlier is conducted year in and year out at no cost to the beneficiary. Once we move into corrective action, in the majority of cases, 15 percent of the costs are covered by the beneficiary and 85 percent are covered by Reclamation. That cost-share breakdown is written right into the Reclamation Safety of Dams Act. Brian Becker: The repairs are funded through congressional appropriations that form part of Reclamation’s budget. The 15 percent of the total costs that the project beneficiaries need to reimburse goes back to the Treasury rather than directly to Reclamation. Hydro Leader: Over what period of time is that 15 percent paid back? Is there a set time period, or is it negotiated for every project? Brian Becker: It depends on the project purpose. If it primarily benefits irrigation, the repayment period is usually a bit longer—it can be up to 50 years with no interest. If the primary project beneficiaries are municipal, industrial, or power-generation entities, the term is generally shorter, and there may be interest involved. Hydro Leader: Does Reclamation have a set-aside line item for its dam safety program, or does the money for it come out of Reclamation’s general budget? Brian Becker: There are three separate dam safety budget lines. One is for the SEED program. Another is for the ISCA program. There is also a Department of the Interior line item, since Reclamation is the lead agency for dam safety within Interior. As the lead for dam safety, Reclamation carries out various oversight activities for the other Interior agencies to help ensure that they’re managing and maintaining their dams in a safe and appropriate manner. October 2020 | HYDRO LEADER

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ADVERTISEMENT Hydro Leader: Would you tell us about the congressional appropriations that fund Reclamation’s dam safety program?

Hydro Leader: How do you feel about working for the dam safety program at Reclamation?

Bob Pike: In general, Congress has funded Reclamation’s dam safety program each year. In the last 5 years, the program has been funded up to $93 million. The president’s fiscal year 2021 proposed budget includes a $107 million request for dam safety.

Karen Knight: When I worked in the private sector, the company I worked for had a contract with Reclamation, the U.S. Fish and Wildlife Service, and the Bureau of Indian Affairs, so I worked on several federal projects. I took advantage of the opportunity to move to Reclamation because I wanted to be a part of bringing dam safety to the public. I have dedicated a big chunk of my life to dam safety. What I love about Reclamation is that each project is unique, so I feel like I’m continuously learning, not just for my benefit, but for the benefit of the organization.

Hydro Leader: Does Reclamation have enough funds for its dam safety projects? Karen Knight: There is a significant demand on Reclamation’s dam safety budget beyond levels of past appropriations. For examples, needed dam safety modifications at B.F. Sisk Dam in California are expected to cost $1.1 billion in today’s dollars, all of which will need to be funded by Reclamation and its partners. Reclamation has 19 additional dam safety projects that will be ready for funding within the next decade. Hydro Leader: Does Reclamation offer any kind of dam safety training for project beneficiaries? Brian Becker: Yes. Reclamation offers them its SEED training, which is an introductory course on dam safety inspections that covers things to look for, how program activities are conducted, and the state of the art of dam safety risk management and risk analysis. Reclamation has been providing that training for more than 30 years. Reclamation also provides other dam safety training courses for different entities and organizations. We work closely with the U.S. Society on Dams and the Association of State Dam Safety Officials to provide information and training throughout the country. Hydro Leader: What is Reclamation’s message to all its water users about its dam safety program? Karen Knight: Reclamation is committed to keeping the public safe. We continue to monitor all our dams to ensure the safety of the American public and to ensure that we can continue to deliver water benefits to them.

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Brian Becker: It’s a great place to work. It’s a supportive and family-friendly organization that is committed to doing the right thing. It’s also a learning, forward-looking, and dynamic organization. We’re recognized worldwide for our expertise, particularly in the field of dam safety. We’ve been doing risk analysis and risk management and making formal riskinformed decisions for well over 20 years. It’s a state-of-theart practice. The U.S. Army Corps of Engineers, the Federal Energy Regulatory Commission, the Tennessee Valley Authority, and other agencies look to Reclamation as the leader in dam safety. The same is true internationally. Other countries look to Reclamation as the standard bearer in terms of operating and maintaining our structures safely. H

Brian Becker, P.E., is a senior advisor and the design, estimating and construction oversight and dam safety officer at the Bureau of Reclamation. He can be contacted at bbecker@usbr.gov. Karen Knight, P.E., is Reclamation’s director for dam safety and infrastructure. She can be contacted at kknight@usbr.gov. Bob Pike, P.E., is the chief of Reclamation’s dam safety program. He can be contacted at rpike@usbr.gov. hydroleadermagazine.com

PHOTOS COURTESY OF THE BUREAU OF RECLAMATION.

Brian Becker: Our primary obligation and interest is the safety of the people who live downstream from our dams. We want to ensure that we’re operating and maintaining our facilities in such a manner that we can continue to provide benefits to the American public, including irrigation water, domestic water, power generation, and recreation. We want to continue to do that in an economically efficient manner while protecting the American public. We’ve been entrusted with an incredible inventory of structures. All it takes is a visit to a place like Hoover, Shasta, or Grand Coulee Dams to realize the significance and importance of those aweinspiring structures. We take that seriously.

Bob Pike: Just last week, I gave a presentation on almost the same question. I focused on why I am still doing what I’ve always done in my career at Reclamation, considering that I started in the dam safety program back in 1989. My answer boiled down to the fact that I get to work on some of the most interesting infrastructure in the world with some of the greatest engineers and scientists in the world. Also, I learned a lesson early in my career about the overall importance of the job: We are protecting the lives of people. We aren’t dealing with numbers; we’re dealing with people.

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Ensuring the Efficiency and Competitiveness of Reclamation’s Hydropower Fleet

PHOTOS COURTESY OF THE BUREAU OF RECLAMATION.

Hoover Dam, the Bureau of Reclamation’s most iconic hydroelectric facility.

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hydroleadermagazine.com

he Bureau of Reclamation owns 78 hydroelectric power facilities that supply a capacity of over 15,500 megawatts (MW), of which it directly operates and maintains 53. This puts it second only to the U.S. Army Corps of Engineers in terms of its hydropower capacity. Max Spiker is a 32‑year Reclamation veteran who today serves as the agency’s senior advisor for hydropower and as an electric reliability officer. In these capacities, he coordinates the implementation of corporate partnership efforts involving Reclamation’s power functions and serves as the liaison on intergovernmental initiatives associated with hydropower delivery. In this interview, Mr. Spiker tells Hydro Leader about Reclamation’s hydro fleet and how the agency is ensuring that hydropower remains a long-term costcompetitive energy source. Hydro Leader: Please tell us about your background and how you came to be in your current position. Max Spiker: Today, I serve as a senior advisor of hydropower for Reclamation. I lead the oversight of the programmatic functions of Reclamation’s hydropower program—not only the policies and oversight, but also the initiatives that leadership wants to implement within the program. I work with our customers to ensure that our facilities are maintained at operational and reliable levels and that they provide the value our customers expect and deserve. I’ve been with Reclamation for 32 years, having started with the agency during college as a supply clerk at a power facility. Eventually, I gravitated toward power plant maintenance, working as a hydroelectric mechanic at the Hoover Dam at the time of its generator upgrade program. It involved uprating the turbines to a more efficient design with greater horsepower, which also allowed the generators to be uprated to take advantage of the enhanced turbine horsepower, leading to increased energy output. After Hoover, I ran several smaller power plant facilities as a power plant supervisor and facility manager and eventually became a power manager in Reclamation’s Upper Colorado region. It was during this time that I worked closely with the Colorado River Energy Distributors Association to implement new programoperation and maintenance protocols for the Colorado River Storage Project facility plants. After that, I became an analyst for the operations and maintenance program in the power program office in Reclamation’s Denver office. A few years later, I became the manager of the power resources office, and in 2016, I was named senior advisor for hydropower, which is the position I hold today. It’s been a wonderful opportunity, and while it has always involved a lot of work, it seems easy when you are working on a good program that you truly believe in. That’s not to say that we don’t face challenges. Many of our facilities have aging infrastructure, and most of our plants are well over 50 years old. Beyond the operations and maintenance costs that aging infrastructure poses, we are hydroleadermagazine.com

The first generating unit at Hoover Dam, one of Reclamation’s most iconic facilities, went into full operation in 1936.

seeing additional costs that contribute to rate increases. We are in the era of low-cost natural gas as well as emerging nonhydro renewable energy sources. While nonhydro renewables are still in their infancy, their infrastructure costs have gradually become more affordable, allowing them to offer more competitive rates. Our rates are escalating or staying relatively flat at the very time that theirs are decreasing, causing rate pressures in certain locations. That’s been an issue that we’ve been working with our customers to resolve over the last few years, and we will continue to do so. Hydro Leader: Would you give us an overview of Reclamation’s hydropower program? Max Spiker: The Bureau of Reclamation was established in 1902 to reclaim the arid West by providing the resources that would allow it to be populated and to thrive. The cornerstone of Reclamation’s mission was water supply, in the beginning primarily for agriculture, but today for municipal and industrial uses as well. That water storage capacity also provided the opportunity for storing energy through hydropower. For the first half of the 20th century, great swaths of rural America, particularly in the West, did not have ready access to electricity or water. Federal hydropower facilities played a dramatic role in changing all that. Not only did they provide water for agriculture, they helped develop towns and cities and enabled the industrialization that followed. Today, you could say that Reclamation has four major areas of focus: water supply, power production, flood control, and recreation. October 2020 | HYDRO LEADER

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Reclamation's Grand Coulee Dam is the largest hydropower producer in the United States, with a total generating capacity of 6,809 megawatts.

Hydro Leader: Please tell us about Reclamation’s federal hydropower fleet and the ages and sizes of the installations that form part of it.

24 | HYDRO LEADER | October 2020

Max Spiker: Reclamation owns 78 hydroelectric power facilities with a total of over 15,500 MW of capacity. Of the 78 facilities it owns, Reclamation directly operates and maintains 53, making up the bulk of that capacity—over 14,700 MW. We refer to the 53 facilities directly operated and maintained by Reclamation staff as reserved works. The remaining 25 facilities are generally referred to as transferred works, since facility operations and maintenance responsibilities have been transferred to a nonfederal entity through a formal agreement. To give you a little perspective, our reserved facilities generate about 40 million megawatt-hours annually and constitute about 15 percent of hydroelectric power capacity and generation in the United States. In terms of capacity and generation, we are second only to the Army Corps, which oversees facilities that account for nearly 25 percent of the nation’s hydroelectric power capacity. Since the 1980s, we’ve done a lot to upgrade our facilities, which, as I mentioned, are generally decades old. It is a constant effort. hydroleadermagazine.com

PHOTOS COURTESY OF THE BUREAU OF RECLAMATION.

On the power side, our facilities generate power for our own on-project use and for others. Figures vary by project and time of year, but over an average year, we use about 20 percent of our power capacity for internal project-use operations, such as pumping water uphill to an elevation from which it can travel by gravity to the customers it’s been designated for. The other 80 percent of our capacity is what we refer to as surplus power. Surplus power is marketed by the U.S. Department of Energy’s Power Marketing Administrations at cost-based rates, with preference given to municipalities, public corporations, cooperatives, and other nonprofit organizations. This surplus power provides a primary source of revenue for Reclamation project repayment, initial construction, operations and maintenance, and replacement costs.

The Mt. Elbert Power Plant is the largest hydroelectric power plant in Colorado.

Just in the past 20 years, we’ve replaced 62 turbines, which has improved our overall efficiency by about 4 percent. We’ve also completed 24 generator uprates, delivering a little over 200 MW of incremental capacity over what was originally installed. Hydro Leader: How many employees does the hydro program have? Max Spiker: Reclamation has a little over 5,000 employees in total; of those, approximately 1,300 work directly in our hydropower-related facilities. Hydro Leader: Would you describe the nonfederal hydroelectric power development that is occurring on Reclamation-owned projects? Max Spiker: There are two avenues to develop nonfederal power plants on Reclamation projects. One is the Federal Energy Regulatory Commission (FERC) licensing process; the other is the Reclamation process known as Lease of Power Privilege (LOPP). Which process is appropriate for a given development depends on the purpose for which the underlying Reclamation project feature was originally authorized. If the original project feature was authorized for a nonpower purpose, nonfederal development would be permitted through the FERC licensing process; if the project feature was authorized hydroleadermagazine.com

for federal power development, nonfederal development would be permitted through the LOPP process. Right now, there are 65 nonfederal power facilities with over 500 MW of capacity in operation on Reclamation projects. There are also 26 conventional nonfederal projects in active development on Reclamation projects. Hydro Leader: What role does Reclamation’s hydropower program play in the administration’s domestic energy strategy and supporting initiatives? Max Spiker: Reclamation’s hydropower programs support a number of the administration’s initiatives, such as Executive Order 13783 on Promoting Energy Independence and Economic Growth. They also support the president’s agenda for the U.S. Department of the Interior, which is to ensure energy and economic security for the United States, as highlighted in Interior’s strategic plan for fiscal years 2018–2022. In that plan, Interior has identified incremental hydropower capability as a key performance indicator. Our goals for the mission area are focused on increasing generating capability by an average of 10 MW per year for the duration of the strategic plan. Over the last 3 years, we have far surpassed that figure, realizing a 53 MW gain. Hydro Leader: Has that all occurred through enhanced efficiencies and upgrades? October 2020 | HYDRO LEADER

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ADVERTISEMENT Max Spiker: Yes, as well as some nonfederal development on Reclamation’s nonpower dams and facilities. Hydro Leader: What is Reclamation doing to ensure that hydropower remains a long-term cost-competitive energy source? Max Spiker: Reclamation’s hydropower generation is marketed at a cost-base rate that is inclusive of recoverable and reimbursable project costs allocated to the hydropower beneficiaries. Our surplus power rates have obviously risen throughout our history, but this has been the case in a more pronounced manner in recent years, as we continue to invest in facilities and as wholesale market rates in some locales have decreased due to the emergence of renewable energy sources and inexpensive natural gas generation. Some of our power customers have expressed concerns over our rates. Another difficulty is posed by the fact that at certain points of any day, you can buy an energy mix that has an overall lower cost than what our contract is priced at. In response, Reclamation has implemented a power initiative to ensure that its hydropower remains a longterm cost-competitive energy resource that will secure a committed customer base. The power initiative focuses on identifying opportunities to curb or stabilize hydropower program costs and to achieve operational and administrative efficiencies. It involves the development and deployment of technological innovation as well as collaborations with federal and nonfederal industrial partners to conduct hydropower program benchmarking to ensure that our performance is in line with that of the industrial hydropower sector and that we are using best practices to achieve overall operational efficiencies. Hydro Leader: What are some of the innovative tools that Reclamation uses in the operations of its facilities?

26 | HYDRO LEADER | October 2020

Hydro Leader: What is your message to those who depend on Reclamation projects for power? Max Spiker: I think it important for them to understand that we are that cornerstone I alluded to. Do we have challenges? Yes. Are we taking steps to overcome those and remain the partner of strength that we have always been? Yes. Can they rely on us to continue identifying efficiencies and other innovations that will ensure we can offer them affordable and reliable services? Yes. Reclamation was formed, and its facilities were built, to respond to a major national objective; we did that on a massively successful scale. Reclamation will never let go of the spirt of innovation and accomplishment, and that is why I’m confident that we will be able to evolve in ways that ensure we will always be of great value to our customers and the nation. H

Max Spiker is a senior advisor for hydropower and electric reliability officer at the Bureau of Reclamation. For more about the Bureau of Reclamation, visit www.usbr.gov.

hydroleadermagazine.com

PHOTO COURTESY OF THE BUREAU OF RECLAMATION.

Max Spiker: One example is a partnership we undertook with the Army Corps to develop a corporate hydropower optimization system called HydrOS, or the Hydropower Optimization System. HydrOS is a flexible, standalone computer package featuring modern hardware and algorithms configurable to all Reclamation hydropower plants. HydrOS recommends an optimal way to operate units to maximize facility efficiency and generation, given water or power targets entered by the facility operator. In addition to maximizing facility generation, HydrOS delivers water conservation benefits, as less water is required to meet power targets. We have deployed it at most Reclamation control centers and are working on the remaining installations.

Just by changing how we operate our individual generators, the HydrOS system has resulted in efficiency gains of 1.75 percent on average. In some facilities, we’ve seen operational efficiencies of over 10 percent. While we are squeezing out efficiencies, it is also gratifying to know that the vast majority of our facilities were already being operated at highly efficient levels. We are also looking into participating in the Hydropower Research Institute, which is digitally enhancing the hydropower industry’s availability, flexibility, and adaptability in order to ensure that it remains a cornerstone of the electric grid. It’s focused on aggregating and standardizing hydropower operational data from across the industry and using those data to do predictive analytics to understand and learn from how a given fleet is performing. The benefit of this will vary among hydro asset owners, manufacturers, and researchers, but will ultimately result in a decrease in operational costs and forced outages, stronger research and development efforts, and better service delivery to customers in our changing marketplace. It is important to take the time to collect and analyze data from our own systems to inform our future decisionmaking and our responses to outages or other operational issues.

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The Course Offerings of Voith’s HydroSchool

Through the Voith HydroSchool, Voith customers can keep their skills and proficiencies up to date and have direct access to a global network of subject-matter experts.

oith Hydro is a complete system supplier that produces turbines and generators for the world’s hydropower stations, from the smallest to the largest. Like many companies, Voith has developed numerous internal training programs to help train new hires and improve the skills of longtime employees. However, it has also opened similar courses up to its clients and the public through the Voith HydroSchool. The HydroSchool offers a wide variety of courses on the design, modernization and rehabilitation of turbines and generators and the operation and maintenance of hydropower plants. In this interview, Inna Kremza, Voith’s hydro customer and educational training manager, tells Hydro Leader about how the HydroSchool was started and the important benefits it provides to customers today.

without a clear idea of what I was going to do with my life. I was fortunate to start my career in the hydro business with Voith about 24 years ago. I have mostly worked in our engineering department, which has many different divisions. As a technical expert with extensive experience throughout the hydro industry, I was selected to lead Voith’s HydroSchool.

Hydro Leader: Please tell us about your background and how you came to be in your current position.

Hydro Leader: How long have you been associated with the Voith HydroSchool?

Inna Kremza: I have a degree in electromechanical engineering from the Polytechnic University of Odessa, Ukraine. Shortly after graduating, I came to North America,

Inna Kremza: My involvement in this training program started about 8 years ago. The HydroSchool actually started as an internal Voith initiative. There were a lot of new

Inna Kremza: I participated in Voith’s career development program and have worked in Brazil and Germany as well as Canada.

hydroleadermagazine.com

PHOTOS COURTESY OF VOITH HYDRO.

30 | HYDRO LEADER | October 2020

Hydro Leader: Have you been based in Canada during your entire time at Voith?

ADVERTISEMENT people joining the company, and we were looking to help them become familiar with Voith products and their roles within the company more quickly. I had the idea of creating a Hydro 101 class. The class was popular and got a lot of positive feedback. Voith recognized that the hydro industry workforce was aging and decided to create a HydroSchool under our hydropower service organization, Voith HyService. I enthusiastically got involved as a trainer. I already had teaching experience from my role in the Hydro 101 class, which had become one of Voith’s most-requested trainings. I loved the teaching experience, so when the opportunity came, I asked if I could lead HydroSchool in North America. Today, I work with engineer-trainers, helping them to develop presentation skills and focusing on how they can better engage with clients. I also work closely with our clients to better understand their requirements and help them bridge the knowledge gap for new employees. We started the HydroSchool with a lot of enthusiasm. To develop our training, we needed to follow the methodology and standards summed up by the term ADDIE: analyze, design, develop, implement, and evaluate. Hydro Leader: Is the HydroSchool certified or accredited? Inna Kremza: The HydroSchool complies with the standards of the International Association of Continuing Education and offers continuing education units.

Hydro Leader: What are some examples of the types of training that Voith provides, and who generally takes the training? Inna Kremza: The training can be delivered in many formats. These include traditional classroom training, onthe-job training, and online training, which is popular today. The most common training we provide is a dedicated training performed at our clients’ locations. The training is customized to meet their needs and is often helpful for those who are planning a big outage or modernization project for a power plant. We bring our experts on site and conduct the training there. We support clients in their decisionmaking processes with training that is based on real case studies and best practices. The other type of training occurs when the equipment is already installed, and personnel need to be trained on how to operate and maintain it. This training is more hands on. We work at the power plant and perform real-life simulations of the equipment operation. I should also mention the open courses that are provided through our Hydro Workshop. The Hydro Workshop has become a Voith tradition and takes place every 2–3 years. This event is in demand from our clients because it is a great opportunity for them to meet Voith experts and leaders from the energy industry. Our last Hydro Workshop took place in November 2019 in York, Pennsylvania. Turnout was high; attendees included representatives from both governmentowned and private facilities across North America.

Voith customers can receive customized trainings on numerous hydropower topics, including condition assessment and the rehabilitation and modernization of turbines or generators, regardless of manufacturer. Voith’s most common training is called dedicated training and is performed on site at the client’s facility.

hydroleadermagazine.com

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ADVERTISEMENT The workshop started with a full-day training program focused on the design of turbines and hydro generators. There were also 2 more days of technical sessions covering technical topics such as horizontal machines; small hydro; and digital technology and service topics, such as how to repair turbine blades, how to address stator winding failure, and how to clean a generator in order to extend its service life. The workshop incorporated technical tours, including a tour of the Voith mechanical shop, which has state-of-the-art machinery, and the hydraulic lab, which is the only one of its kind in North America. In this lab, Voith engineers do model testing on scaled-down 3‑D prototypes of turbines that will be installed in hydropower plants. That enables us to tune the design’s cavitation behavior and its other performance parameters before building full-scale machines. Workshop participants also had the opportunity to visit a local hydropower plant to see the equipment in operation and network with some of their peers. As you can see, this program is versatile and gives our clients a great opportunity to learn about hydro design and hydro manufacturing. It’s important to mention that HydroSchool is international, so not only do we train people in North America, we also host people from around the world. Hydro Leader: When do you expect your next HydroSchool training to take place? Inna Kremza: Unfortunately, we have postponed our traditional in-person trainings until 2021 because of the COVID‑19 situation. However, in the meantime we are offering online trainings for our clients. We recently completed a 2‑day online operations and maintenance training for one of our clients. We also completed a series of free webinars on technical topics. The webinars offered a collaborative approach that enabled the learners to interact with each other as well as with the trainers. Communicating with our customers is important to us, so we are staying connected through these virtual events. Hydro Leader: What types of safety training do you provide?

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Hydro Leader: What should all your customers and potential customers know about Voith’s training programs? Inna Kremza: Our training programs have been created to help our customers train their personnel. At the end of the day, training is all about performance. One of today’s greatest risks is an unprepared workforce. We need a trained and skilled workforce to have better performance in the operation of power plants. The HydroSchool provides added value to our customers. We offer e-learning as well as traditional classroom training and hands-on training. We are also working on a new training that will be offered in a blended format. We customize our programs and prepare learning objectives to meet our customers’ needs. Hydro Leader: Aside from the shift to online courses caused by the pandemic, what trends do you see in hydro industry training? Inna Kremza: Technology is always changing, and we are moving into the digital world. Voith is launching a new 4.0 training platform called DRIVE: Digital Readiness Ideation Velocity Engagement. We’re creating a new, flexible, user-friendly training platform that will allow our clients to customize their training based on their goals. Online learning will be a big part of it. DRIVE puts knowledge at the learner’s fingertips whenever they need it. It will provide on-demand training sessions accessible at any time on any computer. It is currently an internal initiative; later, we will open it to our clients. Hydro Leader: Is there anything else that you would like to add? Inna Kremza: Voith’s HydroSchool is ready for your readers. Learning is an important part of professional development. I’ve been at Voith for 24 years, and I am still learning every day. I always welcome opportunities to do so. Creating the HydroSchool was one of the best initiatives I have been part of. H Inna Kremza is the hydro customer and educational training manager at Voith Hydro. She can be contacted at inna.kremza@voith.com.

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PHOTO COURTESY OF VOITH HYDRO.

Inna Kremza: Safety is a top priority for Voith. Every single training session we hold includes a safety topic. We also offer a full-day training course called Safety by Design. It covers the principles that designers have to follow to ensure the safe operation of a power plant or any component. The training is based on the idea of engineering reliability and is designed to protect people, the environment, and our client’s investment. It wasn’t easy to create an effective class on this topic. For years, our engineers collected case studies from around the world. During the training session, we review these case studies to learn from them. As engineers analyze the case studies, they apply Voith’s principles on how risk can be minimized and identify

safety measures for the power plant’s owners. It’s one of my favorite training courses because it’s engaging and interesting. Even small challenges in hydro can affect safety, and we teach participants to identify those risks. For example, a poorly built road to a power plant can cause the loss of equipment during transportation.

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FERC Proposes Significant Changes to Dam Safety Regulations in Wake of Michigan Dam Failures By Chuck Sensiba and Melissa Horne

A satellite image of the Edenville Dam after the breach.

A satellite image of the Sanford Dam after overtopping.

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Background: The Edenville and Sanford Dam Failures FERC’s proposed revisions to its dam safety program come on the heels of the catastrophic failure of two dams in central Michigan in mid-May. On May 19, 2020, the Edenville Dam on the Tittabawassee and Tobacco Rivers was breached during historic flooding. The downstream FERC-licensed Sanford Dam was overtopped by the increased flows from the Edenville breach. Evacuation orders were issued for around 10,000 residents in the area, and floodwaters from the dam failures encroached on downtown Midland, Michigan, and a nearby Dow Chemical complex. The Edenville Dam had formerly been licensed by FERC, but in 2018, after a long history of dam safety noncompliance, FERC directed the licensee to cease

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IMAGES CONTAIN MODIFIED COPERNICUS SENTINEL DATA.

n July 24, 2020, the Federal Energy Regulatory Commission (FERC) published a Notice of Proposed Rulemaking (NOPR) that proposes to overhaul the FERC dam safety regulations promulgated under section 10(c) of the Federal Power Act. The NOPR proposes revisions to part 12 of FERC’s regulations governing dam safety, including the replacement of subpart D, which provides for independent consultant safety inspections, in its entirety. Coincident with the NOPR, FERC also proposes to update its Engineering Guidelines for the Evaluation of Hydropower Projects by adding four new chapters addressing supporting technical information documents, the part 12 independent consultant safety inspection process, potential failure mode analysis, and level 2 risk analyses.

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ADVERTISEMENT generation operations and then revoked its license, invoking its rarely used enforcement powers under section 31 of the Federal Power Act. Because FERC had revoked its license in 2018, the Edenville Dam, at the time of its failure, was under the jurisdiction of the Michigan Department of Environment, Great Lakes, and Energy (EGLE). Following the Edenville and Sanford Dam failures, FERC ordered the licensee to fully lower the reservoirs behind the three FERC-licensed dams that were affected by the dam failure (Sanford Dam, Secord Dam, and Smallwood Dam), to perform safety inspections of the dams, and to immediately begin the formation of a fully independent forensic investigation team. FERC’s letter specifically noted that since the Edenville Dam was not under its jurisdiction, it would be coordinating with the EGLE to investigate the breach in that dam. According to public statements made by FERC staff when formally introducing the NOPR to the commissioners at the monthly FERC public meeting on July 14, 2020, the proposed revisions to the dam safety regulations were not a response to the Edenville and Sanford Dam failures: The NOPR was substantially complete prior to the dam failure event. FERC staff instead described the revisions as a direct response to the 2017 spillway incident at the Oroville Dam in California, which caused the evacuation of close to 190,000 people living in communities downstream. This focus on the Oroville incident is echoed in the NOPR itself, which points to particular findings of the Oroville Independent Forensic Team and FERC’s own after-action panel as the basis for many of the revisions. Nonetheless, the regulatory history leading up to the Michigan dam failures—which drew heavy criticism from Capitol Hill—may have been a strong impetus for FERC to move forward with the rulemaking. The FERC commissioners mentioned the Michigan dam failures in their public remarks during the July 14 meeting in which FERC released the NOPR. Commissioner Richard Glick, in particular, indicated that it was quite possible that FERC would need to further strengthen the regulations once a report on the Michigan dam failures was issued. He also indicated that Congress needed to give the issue of dam safety some attention, postulating that it was possible that FERC did not currently have sufficient authority to protect the public, particularly when a licensee is reluctant to make investments in a project.

Summary of the Proposed New Dam Safety Regulations

The proposed revisions to FERC’s part 12 dam safety regulations consist of three major components: • the establishment of a two-tiered inspection process alternating between comprehensive assessments that would be more in depth than current inspections and periodic inspections that would be slightly narrower in scope; hydroleadermagazine.com

• revisions to ensure that independent inspection teams possess the specific expertise necessary for the particular project for which they are selected; and • the codification of existing guidance that requires licensees of one or more high- or significant-hazardpotential dams to have an owner’s dam safety program. Each of these major changes is examined below, along with the potential industry response.

New Two-Tiered Inspection Process

The proposed new regulations maintain the current 5‑year interval between inspections. Under the proposed twotiered inspection process, the periodic inspection would include a physical field inspection as well as reviews of prior reports, surveillance and monitoring plan data, and dam and public safety programs. The comprehensive assessment would include all the elements of the periodic inspection, plus a potential failure mode analysis, a semiquantitative risk analysis, and the review of prior reports and analyses of record and the Supporting Technical Information Document. According to the NOPR, a potential failure mode analysis has been required under current inspections since 2002, but it is now being codified as part of the comprehensive assessment. The regulations allow the regional engineer to waive the semiquantitative risk analysis requirement so that this requirement can be gradually phased in while FERC staff are being trained, which will allow FERC to initially focus on higher-risk projects. Some in the industry have suggested that FERC should also be allowed to waive the potential failure mode analysis. The industry has also expressed interest in receiving training on these analyses as well as on other aspects of the enhanced inspection process. In addition to the above requirements, the report for a comprehensive assessment must include an evaluation of the following items: spillway adequacy; the potential for internal erosion and/or the piping of embankments, foundations, and abutments; the structural integrity and stability of all structures under credible loading conditions; and analyses of record pertaining to geology, seismicity, hydrology, hydraulics, or project safety. The proposed regulations expand the existing requirements for evaluating spillway adequacy to include the potential for misoperation of, failure to operate, blockage of, and debilitating damage to a spillway, as well as the resulting effects on the maximum reservoir level and the potential for overtopping. The NOPR explains that these additional requirements are intended to address scenarios similar to the Oroville Dam spillway incident.

Timing of Periodic Inspections and Comprehensive Assessments

Under the proposed rules, the first inspection report for any project that was inspected prior to January 1, 2021, must be filed within 5 years of the due date of the previous report. The regional engineer may require that the first report October 2020 | HYDRO LEADER

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The Washington, DC, headquarters of the Federal Energy Regulatory Commission.

filed under the new regulations be either a comprehensive assessment or a periodic inspection in order to balance the number of comprehensive inspections over the 10‑year cycle. Regardless, the first comprehensive assessment must be completed, with the report filed, by December 31, 2034. Additionally, the regional engineer may require a project to undergo a comprehensive assessment when it would otherwise be scheduled for a periodic inspection if there has been a dam safety incident; extreme loading conditions, such as those caused by an earthquake or unprecedented flooding; or some other significant change in condition. Alternatively, the regional engineer may extend the interval for comprehensive assessments for projects with no life safety consequences and a low total project risk.

Independent Consultant Requirements

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Owner’s Dam Safety Program

The Owner’s Dam Safety Program, which has been imposed via guidance since 2012 and is now proposed for codification under FERC’s NOPR, imposes three main requirements on licensees of dams or other project features with a high or significant hazard potential. First, the licensee must designate either a chief dam safety engineer (in the case of high hazard potential) or a chief dam safety coordinator to oversee the implementation of the dam safety program. Outside parties may serve in this role, but if so, the owner hydroleadermagazine.com

PHOTO COURTESY OF RYAN MCKNIGHT.

The proposed regulatory revisions require independent consultant teams to collectively possess expertise “commensurate with the scale, complexity, and relevant technical disciplines of the project and type of review being performed.” The NOPR indicates that expectations will be higher for teams involved with comprehensive assessments or with projects with higher risk, a history of “unusual or adverse performance,” or a greater number of more technically challenging project features. Licensees would be required to submit the résumés of all members of the independent consultant team rather than just that of the consultant and to obtain written approval of the team rather than simply submitting résumés, as is currently required. Some licensees have indicated a desire for greater clarity on what qualifications are necessary for an inspection team prior to beginning their solicitation processes.

Under FERC’s current regulations, an independent consultant must be a licensed professional engineer with at least 10 years of dam safety experience and may not be, or have been in the past 2 years, employed by the licensee or its affiliates. FERC notes in the NOPR that 10 years of experience would only be required of the designated independent consultants, not of the supporting members of the independent consultant team. The proposed revisions add an additional requirement that restricts the consultant from having been an agent acting on behalf of the licensee or its affiliates “in a manner and for a time period as defined in the [Engineering] Guidelines.” The NOPR indicates that FERC purposefully avoided setting specific thresholds for the scope or duration of the services previously provided by the consultant and that it intends to interpret this provision narrowly, “with the primary goal of ensuring that independent consultants are not responsible for reviewing work products to which they contributed to substantially.” Some in the industry are concerned that this additional restriction and the greater scrutiny afforded to the selection of independent consultants in general will limit the pool of consultants qualified to perform inspections.

ADVERTISEMENT must designate an individual responsible for overseeing the day-to-day implementation of the program and retains ultimate responsibility for the safety of the dams and other features covered by the program. Second, the program must be signed by the owner and the chief dam safety engineer or coordinator. Third, the program must be reviewed and updated annually and discussed with senior management. For licensees of one or more dams or project features with a high hazard potential, an independent external audit or peer review of the dam safety program must be conducted at least every 5 years. The qualifications of the proposed reviewers must be submitted to and accepted by the regional engineer. The industry has indicated some concerns regarding the requirement for an external audit in addition to the review of the Owner’s Dam Safety Program that is already embedded in the periodic evaluation and comprehensive assessment processes on the basis that the external audit is duplicative.

PHOTOS COURTESY OF TROUTMAN PEPPER.

Additional Proposed Revisions

A facility can become subject to FERC’s inspection requirements in one of three ways: first, by having a dam over a certain height or an impoundment over a specified storage capacity; second, by having a project feature with high hazard potential; or third, at the discretion of the regional engineer. The proposed new regulations provide that, consistent with FERC’s existing informal practice, independent inspections are required for projects with any project feature (a dam, canal, or water conveyance structure) that has a high hazard potential, not only to projects with a dam. As with the existing regulations, FERC would retain its discretion to exempt projects from its dam safety regulations for good cause, but the proposed regulations provide that all existing exemptions would be rescinded and licensees would have to reapply in order to receive an exemption. The proposed rules provide that good cause includes showing that the project features qualify as low hazard potential. Licensees have raised questions regarding whether lowhazard-potential projects that previously did not have to apply for an exemption would now have to apply and whether, as is suggested by chapter 16 of the Engineering Guidelines, a comprehensive assessment would be required in order for an exemption to be granted. The NOPR also proposes several revisions to existing public-safety reporting requirements. The revised regulations express a “preference” for an initial oral report of a project-related safety incident within 72 hours. Reporting requirements are expanded to include rescues in addition to deaths or injuries, but FERC has attempted to limit the definition of project related by removing language that suggested an incident was project related if it occurred near a dam. FERC indicates that the revised definition clarifies that licensees are only required to report incidents that are “related to the operation of hydropower projects,” but some in the industry believe this raises the question of what types hydroleadermagazine.com

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of incidents can be considered related, so FERC can expect requests for additional clarification from licensees. The NOPR also revises recordkeeping requirements to require that projects subject to its dam-safety regulations provide the regional engineer with physical and electronic copies of records required to be maintained under the damsafety regulations. FERC indicated in the NOPR that it has historically required this information to be provided via the supporting technical information document and that, accordingly, this does not represent a change in practice. However, some in the industry object to the requirement to submit physical documentation in place of electronic versions.

What’s Ahead

FERC will be reviewing comments from the industry and other stakeholders on the proposed rules in the coming months against the backdrop of the Michigan dam failures, which—like the Oroville incident in 2017—placed FERC’s dam safety requirements under public scrutiny. In addition, FERC will undoubtedly be feeling pressure from Congress, which has already requested and received a response from the commission to a number of questions related to the dam breaches, to take action to prevent such incidents in the future. At the same time, FERC is fielding complaints from the owners of land adjacent to the FERC-licensed Sanford, Smallwood, and Secord Dams regarding the effect of the reservoir drawdowns on their property values and the stability of the shoreline. As in any rulemaking process, FERC will need to consider all public comments submitted in the NOPR process as it finalizes a rule that is intended to strengthen existing regulations and formalize long-standing informal practices into its dam safety regulatory regime, including comments raised by the industry, the public, and other interested parties. In addition, as suggested by Commissioner Glick in FERC’s July 14 public meeting, Congress may decide to take action. For example, the proposed Moving Forward Act (H.R. 8) contains several provisions that are intended to strengthen FERC’s dam safety program. H

Chuck Sensiba is a partner at Troutman Pepper. He can be contacted at charles.sensiba@troutman.com.

Melissa Horne is an associate at Troutman Pepper. She can be contacted at melissa.horne@troutman.com.

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Upcoming Events

October 1–December 8 U.S. Society on Dams, 2020 Fall Workshop Series (virtual) October 5–6 Edison Electric Institute, Virtual Fall TDMMA Conference October 7, 14, 21, and 28 National Hydropower Association, Hydraulic Power Month Virtual Seminars October 12–14 Hydropower Foundation, Hydro Think Tank, Niskayuna, NY October 13 American Public Power Association, Legal and Regulatory Virtual Conference October 25–28 Edison Electric Institute, Fall National Key Accounts Workshop (virtual) October 27 American Public Power Association, Customer Connections Virtual Conference October 27 Northwest Hydroelectric Association and National Hydropower Association, Northwest Regional Workshop (virtual) November 8–11 Edison Electric Institute and American Gas Association, Taxation Committee Meeting, Scottsdale, AZ November 9–11 Edison Electric Institute, Virtual Financial Conference November 10 American Public Power Association, Public Power Forward Virtual Summit November 15–18 Edison Electric Institute, Fall Accounting Conference, Bay Lake, FL November 16 American Public Power Association, Cybersecurity Virtual Summit November 19 Edison Electric Institute, Property Accounting and Depreciation Training Seminar, Bay Lake, FL November 28–December 3 International Commission on Large Dams, 88th Annual Meeting, New Delhi, India December 3 National Hydropower Association, California Regional Meeting (virtual) CANCELED: December 14–16 Colorado River Water Users Association, Annual Conference, Las Vegas, NV Date TBD National Water Resources Association, 89th Annual Conference (virtual)

Join us for the Israel Water Education and Trade Tour, June 27–July 7, 2021. Sponsored in part by Hydro Leader magazine. Register by March 29, 2021. To sign up to receive Hydro Leader in electronic form, please contact our managing editor, Joshua Dill, at joshua.dill@waterstrategies.com. hydroleadermagazine.com

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Hydro Leader October 2020

Articles inside

FERC Proposes Significant Changes to Dam Safety Regulations in Wake of Michigan Dam Failures

The Course Offerings of Voith’s HydroSchool

Ensuring the Efficiency and Competitiveness of Reclamation’s Hydropower Fleet

An Insider’s Look at the Bureau of Reclamation’s Dam Safety Program

Sharon Powers of the U.S. Society on Dams: Supporting the Dam and Levee Industry

Ensuring U.S. Dams’ Safety and Success