The Federal Power Act provides for FERC’s regulatory jurisdiction over a  portfolio of about 1,000 non-federal hydropower projects comprising over  2,500 dams. FERC Staff Collect Safety Information during Inspections of Individual Dams, but FERC Has Not Analyzed Dam Safety across Its Entire Portfolio

		FERC Staff Generally Followed Guidance to Collect Information during Safety Inspections of Individual Dams That We Reviewed but Have Inconsistently Recorded Such Information Information Collection

We found, based on our analysis of the 42 dam safety inspections we  reviewed, that FERC staff generally conducted and collected information  from these inspections consistent with guidance in its Operating Manual. To assess safety, FERC staff we  interviewed stated that they primarily rely on their engineering  judgment. FERC’s approach to recording inspection information is inconsistent  because FERC has not provided standard language and procedures  about how staff should record and track deficiencies including which  system to use. FERC Has Not Used Inspection Information to Fully Assess Safety Risks across Its Regulated Portfolio of Dams

While FERC uses inspection information to monitor a licensee’s efforts to  address a safety deficiency for an individual dam, FERC has not analyzed  information collected from its dam safety inspections to evaluate safety  risks across the entire regulated portfolio of dams. According to  FERC officials, these assessments identified 27 dam spillways with  varying degrees of safety concerns. FERC officials stated that they are working  with the dam licensees to address these safety concerns. A similar and  proactive approach based on analysis of common deficiencies across the  portfolio of dams under FERC’s authority could also help to identify any  safety risks that may not have been targeted during the inspections of  individual dams and prior to a safety incident. FERC regulations and guidelines describe the types and  frequency of studies and analyses required based on dams’ hazard  classifications. FERC’s Engineering Guidelines provides a  framework for the review of engineering studies, though the Guidelines  recognizes that each dam is unique and allows for flexibility and  exemptions in their use. As part of FERC’s quality control  and internal oversight process, multiple FERC staff are to review the  studies produced by the licensee and its consultant, with the number  of successive reviews proportional to the complexity or importance of  the study, according to FERC officials. While FERC has  not yet conducted such an analysis, a proactive assessment of common  safety inspection deficiencies across FERC’s portfolio of licensed dams— similar to its identification of dam spillways with safety concerns following  the Oroville Dam incident—could help FERC and its licensees identify  safety risks prior to a safety incident and to develop approaches to  mitigate those risks. Appendix III: Objectives, Scope, and Methodology

This report assesses: (1) how FERC collects information from its dam  safety inspections and the extent to which FERC analyzes it; (2) how  FERC evaluates engineering studies of dam performance to analyze  safety, and (3) the extent to which FERC reviews dam safety information  during relicensing and the information FERC considers. We also reviewed dam safety documentation, including  dam performance studies, FERC memorandums, the most recent  completed inspection report, and other information, from a non-probability  sample of 14 projects encompassing 42 dams relicensed from fiscal  years 2014 through 2017.
Why GAO Did This Study

In February 2017, components of California's Oroville Dam failed, leading to the evacuation of nearly 200,000 nearby residents. FERC is the federal regulator of the Oroville Dam and over 2,500 other dams associated with nonfederal hydropower projects nationwide. FERC issues and renews licenses—which can last up to 50 years—to dam operators and promotes safe dam operation by conducting safety inspections and reviewing technical engineering studies, among other actions.
GAO was asked to review FERC's approach to overseeing dam safety. This report examines: (1) how FERC collects information from its dam safety inspections and the extent of its analysis, and (2) how FERC evaluates engineering studies of dam performance to analyze safety, among other objectives. GAO analyzed documentation on a non-generalizable sample of 42 dams associated with projects relicensed from fiscal years 2014 through 2017, selected based on geography and hazard classifications, among other factors. GAO also reviewed FERC regulations and documents; and interviewed FERC staff associated with the selected projects and technical consultants, selected based on the frequency and timing of their reviews.

What GAO Found

The Federal Energy Regulatory Commission's (FERC) staff generally followed established guidance in collecting safety information from dam inspections for the dams GAO reviewed, but FERC has not used this information to analyze dam safety portfolio-wide. For these 42 dams, GAO found that FERC staff generally followed guidance in collecting safety information during inspections of individual dams and key structures associated with those dams. (See figure.) However, FERC lacks standard procedures that specify how and where staff should record safety deficiencies identified. As a result, FERC staff use multiple systems to record inspection findings, thereby creating information that cannot be easily analyzed. Further, while FERC officials said inspections help oversee individual dam's safety, FERC has not analyzed this information to identify any safety risks across its portfolio. GAO's prior work has highlighted the importance of evaluating risks across a portfolio. FERC officials stated that they have not conducted portfolio-wide analyses because officials prioritize the individual dam inspections and response to urgent dam safety incidents. However, following the Oroville incident, a FERC-led initiative to examine dam structures comparable to those at Oroville identified 27 dam spillways with varying degrees of safety concerns, on which FERC officials stated they are working with dam licensees to address. A similar and proactive portfolio-wide approach, based on analysis of common inspection deficiencies across the portfolio of dams under FERC's authority, could help FERC identify safety risks prior to a safety incident.
Guidelines recognize that each dam is unique and allow for flexibility and exemptions in its use. FERC staff use the studies to inform other components of their safety approach, including the analysis of dam failure scenarios and their review of safety to determine whether to renew a license.

What GAO Recommends

GAO recommends that FERC: (1) develop standard procedures for recording information collected as part of its inspections, and (2) use inspection information to assess safety risks across FERC's portfolio of dams. FERC agreed with GAO's recommendations.