HomeMy WebLinkAboutOroville Facilities - Comments of FOR, Sierra Club, SYRCL, CSPA, and American Whitewater BUTTE COUNTY
ADMINISTRATION
FEB 12 2018
OROVILLE,CALIFORNIA
UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
In the Matter of ) February 7, 2018
State of California )
Department of Water Resources ) Project No. 2100
}
"Oroville Facilities" }
COMMENTS OF
FRIENDS OF THE RIVER, SIERRA CLUB
SOUTH YUBA RIVER CITIZENS LEAGUE,
CALIFORNIA SPORTFISHING PROTECTION ALLIANCE,
AND AMERICAN WHITEWATER
SUMMARY OF COMMENTS
On January 16, 2018, we filed comments with the Commission about information
revealed in legislative informational hearing by representatives of the California Department of
Water Resources (DWR)that DWR believed there was risk of losing all power supply to the
spillway radial gate hoists on Oroville Dam's main spillway during the February 2017 Oroville
Dam spillway incident.I
This statement of DWR's representatives is at odds with the description of standby power
for the radial gates in DWR's Bulletin 200. We asked the Commission to require DWR to
describe the basis for their testimony and whether standby power such as described in Bulletin
200 has been supplied, and to require standby power if it has not.
Neither the Commission nor DWR responded to our filing. However, DWR has
responded to press inquiries and has reversed the statements provided at the hearing.
LICENSING BACKGROUND
Friends of the River(FOR), Sierra Club, and the South Yuba River Citizens League
(SYRCL) are parties to the Oroville Dam relicensing proceeding.z In their intervention, FOR,
Sierra Club, and SYRCL requested that the Commission address in relicensing or other
I eLibrary#20180117-5012
2 Motion to Intervene of Friends of the River, Sierra Club, South Yuba River Citizen's League,Project
No. 2100-052 (filed Oct. 17, 2005),eLibrary no. 20051017-5033 (FOR et al. Intervention).
Comments of FOR,Sierra Club,SYRCL,CSPA,and American Whitewater Page I
expeditious proceeding the physical deficiencies at the Oroville Facilities, and in particular
deficiencies in the infrastructure needed to conduct(when necessary) floodwater-management
surcharge operations over the dam's emergency/auxiliary spillway. The California Sportfishing
Protection Alliance (CSPA) is also an intervenor. CSPA's intervention supported FOR's
arguments in relation to flood-related facilities modifications.' American Whitewater(AW)
intervened as well, citing the FOR et al. intervention. In its intervention,AW recommended that
the licensee respond to concerns relating to the ungated spillway at Oroville Dam and that the
Commission analyze these concerns.'
The FOR et al. intervention described the damage that could result if the spillway hillside was
used for a spillway discharge, including problems to transmission towers,power lines, and
backwater conditions that would prevent operation of the Hyatt Powerhouse.
Based on geologic opinions from DWR, FERC's'Division of Dam Safety and Inspections did not
accept the concerns of FOR et al. as factual.5 FERC's Office of Energy Projects (OEP) issued a
Final EIS for the relicensing of the Oroville Facilities on May 27, 20076 that rejected the
relevance of the matter in a licensing proceeding? and that apparently rejected the factual basis of
these concerns.
In February 2017, both Oroville Dam complex spillways experienced significant damage,
causing a major dam-safety incident that resulted in the evacuation of 188,000 residents in the
Feather River Basin. Contrary to FERC's Division of Safety of Dam and Inspections and DWR's
2005-06 representations, major hillside erosion occurred.$ The incident gained worldwide
attention.
s Comments and Motion to Intervene, Draft Environmental Impact for the Oroville Facilities(filed
December 19,2006), eLibrary no. 20061219-5001, p. 3. (CSPA Intervention)
d Motion to Intervene of American Rivers, American Whitewater and Chico Paddleheads(filed march
31, 2017), eLibrary no.20060331-5090, p. 5 (AW Intervention).
s Memo from John Onderdonk, Senior Civil Engineer, San Francisco Regional Office, Division of Dam
Safety and Inspections Emergency Spillway Safety Questions related to Intervention Motion, Proj.No.
2100, Letter to John Mudre; FERC Division of Hydropower Licensing, July 27,2006. (Onderdonk
Memo), eLibrary no. 20060801-0158. Independent Forensics Team Report, Oroville Dam Spillway
Incident,January 5, 2018, Appendix C, Sections 3.13 &3.14,pp. C-28-32. On January 26,2018,the
Commission issued a letter to many of its licensees with a link to the Report on the Commission's
website, eLibrary no. 20180126-4002.
hups://www.fere.gov/industries/hydropower/safet�/projects/oroville.asp
6 Federal Energy Regulatory Commission Final Environmental ImpactStatementfor the Oroville
Facilities Project Docket No. P-2100-052, May 18,2007,eLibrary no. 20070518-4001. (FERC Oroville
Facilities FEIS)
7 Id.p. C-10, eLibrary no.20070518-4001.
s Appendix C of the Independent Forensics Team Report, Oroville Dam Spillway Incident,provides a
detailed discussion on the history of the erroneous erosion-resistant hillside belief.Section 4.0, pp. C-38-
40,the summary, provides a concise description of this appendix.
Comments of FOR,Sierra Club,SYRCL,CSPA,and American Whitewater Page 2
In a letter to the Commission on April 19, 2017, FOR et al., CSPA, and AW asked the
Commission to clarify what decisions of concern to relicensing participants the Commission
would make in the apparent Dam Safety reconstruction process and what decisions the
Commission would make in the licensing process. This April 19, 2017 letter also asked the
Commission to devise a transparent and expeditious process to make these decisions with
involvement by an informed public.9
The Commission has not clarified these issues. The Commission has not issued a new Project
license.
JANUARY 16,2018, COMMENT LETTER
In our January 16, 2018, comment letter we noted that DWR Bulletin 200 states that standby
power to the radial gates is part-of the as-constructed Oroville Dam project.10
We reported to the Commission that DWR Deputy Directors Joel Ledesma and Cindy Messer
told a recent California State Assembly joint informational hearing that loss of the normal
transmission line/powerhouse power would have prevented DWR from operating the radial
spillway gates for"a few days." I I
We found it difficult to reconcile Bulletin 200 and the testimony provided by DWR to the
legislature and asked the Commission to request clarification from DWR and to require standby
power if such project works are not in existence. We also conceded that DWR's testimony could
have been in error.
We noted that the Independent Forensic Team Report12 did not discuss the lack of an
independent means to provide standby power to the Oroville Dam Flood Control Outlet radial
gates.
9 FOR,Sierra Club, SYRCL, CSPA, and American Whitewater Request for Clarification and Public
Process,Project 2100;April 19, 2017,eLibrary no. 20170419-5231 (FOR et al. Request for Clarification)
10 California State Water Project, Volume III Storage Facilities, Bulletin 200,November 1974. State of
California,the Resources Agency, Department of Water Resources, p. 100.
htts://www.documentcloud.or documents/3532240-DWR-Bulletin-200-State-Water-Project.html.
11 DWR Deputy Directors Joel Ledesma, Cindy Messer at the California State Assembly joint
informational hearing, OrovilIe Dam and Dam Safety Efforts, a hearing of the California Assembly's
Accountability and Oversight and Water Parks and Wildlife Committees,January 10,2018,time 36.50-
37.20 &41.20-41.48. htta/assembl .ca. ov/media/'oint-hearing,-accountability-ad min istrative-review-
water-
-accountabilit -administrative-review-
water- arks-wildlife-201801IO/video.
12 Independent Forensics Team Report,January 2018.To the extent that the fear of complete loss of
power to the radial affected DWR's assessment of the balances and risks that resulted in the use of the
emergency/auxiliary spillway,the availability or non-availability of standby power should have been
covered in the IFT Report. See section 2.1 p. 3.
Comments of FOR,Sierra Club,SYRCL,CSPA,and American Whitewater Page 3
the structure could be compromised led to evacuation orders on Feb. 12 for more than
ift000 people downstream.
"It needs to be resolved as soon as possible," Shutes said.
The.independent forensic team report released Jan. 5 found that department officials
were weighing several risks before they decided to use the emergency spillway.
Some scary possibilities included continuing erosion of the main spillway leading to the
loss of a transmission tower nearby and also water heading toward the headgate
structure because of erosion. However,the forensic team report did not discuss the lack
of a fallback power source for the radial gates,the group's letter states.
Shutes described the radial gates as similar to guillotines,
hoisted up to allow water releases down the nation's
tallest spillway.
"The farther you raise it up, the more water escapes,"he
said. "If you can't raise them, (the gates) can't allow water
to go out at the same rate it's going in(the reservoir),"
If the department had lost control of the gates and was The Orovi[le Dam spillway gates,near the
waterline in this photo taken from the lake on
therefore unable to crank up releases, more water would APril 1,2017,were in danger of being
inoperable during the spillway crisis.Dan Raidel
have backed up in the reservoir and streamed down the -Enterprise-Rcenrd File
emergency spillway, he said.
'Kind of a big deal'
Dave Steindorf, special projects director for American Whitewater, said that in his mind,
this highlighted a need for more transparency about issues relating to the spillway
failures. It is puzzling that transmission lines were placed in the area to begin with, he
said.
"It's rather astounding that (below the emergency spillway)there was a set of power
lines in the path of water coming down," Steindorf said.
If backup electricity was accessible, upping releases when the reservoir was getting
dangerously full should not have been such a dilemma, he said.
"The question becomes, `were those generators not working?'which is kind of a big
deal,"Steindorf said.
Transmission lines around the emergency spillway were turned off Feb. 10 and
eventually rerouted away from the area.
Ron Stork, senior policy advocate for Friends of the River, was taken aback when he
heard at the oversight hearing that the department could have lost control of the gates.
"I was floored," Stork said on Tuesday. "We know power lines are now out of harm's
way. But regardless, it's a simple matter to make sure you've got backup power,because
you don't want to lose control of those gates."
He said the group was very careful in the letter not to assume anything it didn't know.
He hopes discussion about radial gate power routing can come before the public.
Hyatt Powerplant
The department also could have lost access to the Hyatt Powerplant for months because
of downed transmission lines, department officials said in their testimony at the Jan. 10
oversight hearing. This was addressed in the forensic report.
"This would result in significant long-term water management issues, mainly in view of
environmental effects and water deliveries," the forensic report stated. "It would also
affect the logistics in water management during repairs to the damaged service(main)
spillway. However,the unknown risks of using the emergency spillway were also a major
concern, in view of the major unexpected erosion of the service spillway foundation."
A DWR spokesperson did not respond to a request for comment before the deadline for
this story.
Contact reporter Risa Johnson at 896-776.3.
About the Author:Risa Johnson covers local politics in Butte County and the City of
Oroville for the Chico Enterprise-Record and Oroville Mercury-Register newspapers.
Since February 2017,she has written extensively about the OrovilIe Dam crisis.She is a
proud alumna of Chico State University.Reach the author at rjohnson@chicoe7..com or
`a follow Risa on Twitter: @risamjohnson.
h www.chicoer.com article NA 2ol8oz2 NEWS 18Ol2 S
ENTERPRiLsE a RFicom
DWR says there was redundant power for spillway gates
By Risa Johnson, Chico Enterprise-Record
Posted: ox/25/x8, 6:oo PM PST
The state Department of Water Resources now says there
were"many redundant systems"to ensure the Oroville Dam
spillway radial gates had power during February's crisis.
This comes after environmental groups voiced concern in an
article published in this newspaper Wednesda about, F
seemingly, a lack of backup generators that would allow the
department to control the gates even if crucial power lines ' "
went down. Radial gates at the top of the spillway allow for
water releases. `
Friends of the River,American Whitewater and others sent a
letter to the Federal Energy Regulatory Commission last week
asking the commission to confirm whether the department
had backup power for the gates, and if not, to require it be Helicopters haul power poles by air as
addressed. The letter references testimony by Cindy Messer "'r crews remove towers along the
Diversion Pool to reroute transmission
DWR's deputy director, at a le islative oversi ht hearin mw
on bans on Feb.22,2017 at the Oro
fileAd .Dan Reide[—Enterprise-Rerd file
the dam Jan. 1o: photo
"DWR needed to protect the power lines, as Joel (Ledesma)just described to us, that
were installed on the hillside that was parallel to the main spillway, the same hillside
that was eroding.Without these power lines, as Joel pointed out, DWR would have
temporarily lost not only its ability to operate the power plant but also the main gates at
the top of the spillway, and this would have temporarily, could have been just a few days,
but in the case of the power plant might have been months."
Erin Mellon, a department spokeswoman, responded via email on Thursday to a request
for comment for the original story two days prior.
"Even though we had many redundant systems to ensure we could continue operating
the gates, it was important to prioritize the power lines because without them, DWR
would have had to depend on backup systems for weeks or months to control the
spillway gates," Mellon wrote. "These same power lines are also the primary power
source to operate releases from Hyatt Powerplant.With a broken main spillway, Hyatt
became even more important as the primary way to safely manage lake levels since the
emergency."
She said there was personnel on site at all hours during the spillway emergency to
evaluate and monitor main and backup power sources needed to control the gates.
"The Oroville Complex has redundant power sources including backup generators to
ensure operation and control of critical equipment at the facility including the spillway
gates," Mellon wrote. "Those redundant systems existed before the emergency.
Additional generators were brought in during the emergency to provide a back up to the
existing emergency generators."
Contact reporter Risa Johnson at 896-7763.
~ : About the Author:Risa Johnson covers local politics in Butte County and the City of
Orovillefor the Chico Enterprise-Record and OrovilIe Mercury-Register newspapers.
Since February 2o17,she has written extensively about the Oroville Dam crisis.She is a
proud alumna of Chico State University.Reach the author at rjohnson@chicoer.com or
follow Risa on Twitter: @a risamjohnson.
h www.chicoer.com eneral-news 2018012 dwr-sa s-there-was-redundant- ower-or-s illwa - ares