HomeMy WebLinkAbout11.24.25 Board Correspondence - FW_ Compliance Directives issued in FERC P-803-000From:Clerk of the Board
To:Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa; Krater,
Sharleen; Lee, Lewis; Little, Melissa; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug; Zepeda,
Elizabeth; Loeser, Kamie
Cc:Nuzum, Danielle
Subject:Board Correspondence - FW: Compliance Directives issued in FERC P-803-000
Date:Monday, November 24, 2025 4:42:39 PM
Please see Board Correspondence -
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Subject: Compliance Directives issued in FERC P-803-000
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On 11/24/2025, the Federal Energy Regulatory Commission (FERC), Washington D.C., issued this document:
Docket(s): P-803-000
Lead Applicant: Pacific Gas and Electric Company
Filing Type: Compliance Directives
General Correspondence
Delegated Order
Description: Letter in response to filing of the Comprehensive Assessment Part 12D Inspection Plan and Independent Consultant
Team Proposal for Philbrook Dam, under P-803.
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FEDERAL ENERGY REGULATORY COMMISSION
Office of Energy Projects
Division of Dam Safety and Inspections
888 First Street, NE Routing Code: PJ-13
Washington, DC 20426
(202) 502-6314 Office
November 24, 2025
In reply refer to:
P-803-CA
VIA FERC Service
Mr. Russell Cruzen, P.E., Director
Power Generation, Asset Excellence
Pacific Gas and Electric (PG&E) Company
300 Lakeside Dr.
Oakland, CA 94612-3534
Subject: Part 12D Inspection Plan and Independent Consultant Team Proposal, 2026
Comprehensive Assessment, Philbrook Dam.
Dear Mr. Cruzen:
This is in response to your October 16, 2025, letter that submitted the Part 12D
Inspection Plan (Inspection Plan) for the Comprehensive Assessment (CA) of Philbrook
Dam, which is part of the DeSabla Centerville Hydroelectric Project, FERC No. 803. We
have reviewed the Inspection Plan and have identified items that require additional detail
or clarification to fulfill the expectations as outlined in Chapter 16 of the Commissions
Engineering Guidelines for the Evaluation of Hydropower Projects (Guidelines).
1. We have the following comments on the proposed Independent Consultant (IC)
Team:
a. The resume provided for Mr. Christopher Hunt (covering geotechnical,
seismic, instrumentation and pipelines disciplines) demonstrates that he fulfills
the requirements of 18 CFR § 12.31(a), has the appropriate experience and
expertise to serve in the proposed role of IC for the project features and type of
inspection identified in the Inspection Plan, and is thus accepted for that role.
b. The Inspection Plan demonstrates that the IC Team members Mr. Rick
Poeppelman (covering structures and gates disciplines), Dr. Michael George
(covering engineering geology and erodibility disciplines), Mr. James Barbis
Document Accession #: 20251124-3084 Filed Date: 11/24/2025
2
(covering hydrology and hydraulics disciplines), Dr. Christie Hale (covering
seismic hazard discipline), and Ms. Stephanie Owen (covering consequences
discipline) meet the requirements of 18 CFR § 12.31(b) and have the
appropriate experience and expertise to serve as IC Team members for the
project features and type of inspection identified in the Inspection Plan.
c. The Inspection Plan identifies Dr. Kathleen Darby as the PFMA/L2RA
facilitator. Dr. Darby’s resume indicates that she has the required risk
facilitator training; however, her resume (given the dates of her educational
degrees) does not demonstrate she has “a minimum of ten years of experience
in the evaluation, design, construction, monitoring, and operation of dams”, as
required in Section 17-4.3.3 of Chapter 17 or our Guidelines. Therefore, revise
Dr. Darby’s resume to document how she meets the experience requirement in
dam engineering and dam safety (note: time spent pursuing educational
degrees does not count toward experience) or propose a new PFMA/L2RA
facilitator. Please ensure the resume of the proposed facilitator clearly
demonstrates the fulfilment of the requirements of Section 17-4.3.3 and
Section 18-5.3 of Chapters 17 and 18, respectively, of our Guidelines.
d. The Inspection Plan lists Dr. Matthew Burral as “Recorder”. Since he will not
serve as Subject Matter Expert for this CA, he is considered as support staff
but not a formal IC Team member needing our approval.
2. Revise the Inspection Plan to address the following comments:
a. Section 2.2.2: Provide a description of the spillway radial gate hoist system and
every power source available for gate operation.
b. Section 2.2.2: The Inspection Plan states that the IC Team will “observe as the
gate is exercised from its current operational position to full close and back to
the operation position by PG&E operation personnel.” We do not concur with
the proposed testing plan. Section 16-6.7.1 of Chapter 16 of our Guidelines
states that “[i]f possible, the relevant members of the IC Team should observe
full-height spillway gate test operations.” If full-height gate test operations
cannot be performed during the field inspection, then justify this and instead
either: 1) Have the IC Team observe full-height gate test operations at a
separate time of the field inspection; 2) Have the IC Team observe a
representative number of gate test operations such that they can evaluate the
gate performance, the licensee’s standard operating procedures, and provide
informed conclusions, or; 3) Propose an alternative scope that accomplishes
the same goal. The gate testing for the IC Team observation must include the
testing of every power source available for the operation of the gate. If the gate
standard operating procedures include other emergency methods for the gate
operation, the IC Team should confirm that the required equipment is available
and that the licensee staff are sufficiently familiar with the procedures. You
Document Accession #: 20251124-3084 Filed Date: 11/24/2025
3
must provide a description of how the project’s gate will be test operated for
this CA in a revised Inspection Plan.
c. Section 2.2.2: The Inspection Plan states that “[t]he IC Team will walk along
the spillway discharge channel, observing conditions along the length of the
channel until reaching the discharge to Philbrook Creek. If the spillway is
passing flow, the IC Team will observe the visible portions of the spillway
from the bridges and downstream spillway walls and adjacent to the discharge
channel, and, if deemed necessary, a follow up inspection will be scheduled to
walk the spillway channel…”. Our interpretation of this plan is that if during
the IC Team site inspection, the spillway discharges preclude the inspection of
the spillway structure and discharge channel slopes and bottom, then the IC
Team will conduct a follow up inspection by walking the spillway discharge
channel at a later time when the discharges are sufficiently low or stopped to
provide observation and inspection of these features. We concur with this plan
given the history of erosion and Potential Failure Modes (PFMs) identified in
the previous Part 12D report. If this interpretation does not reflect your intent,
revise the Inspection Plan to clarify the scope of the inspection for the spillway
structure and discharge channel.
d. Section 2.2.2: The IC Team should inspect the log boom and its anchor points.
We note that the previous Part 12D report identify embankment dam
overtopping PFMs that could be initiated/progressed by failure of the log
boom.
e. Section 2.2.5: The IC Team should discuss with project operations center staff
that the SCADA alarms and other parts of the monitoring system are
adequately working.
f. Revise Section 3.1, Table 6 (page 16) to indicate that the last Part 12D report
documented that the remote operated vehicle inspection completed in 2010
found several missing rivet heads in the LLO conduit that could potentially
enable seepage. This observation should be considered by the IC Team in their
inspection and evaluation of PFMs.
3. The official field inspection will be conducted during the week of July 13, 2026,
after the project site becomes accessible. This official site inspection is currently
scheduled after the PFMA/L2RA workshops. We have the following comments:
a. If the IC Team identifies any new vulnerabilities or new candidate PFM(s) or
their site observations change the understanding of previously characterized
PFM(s) from the recently completed PFMA, then these PFMs should be
addressed by the IC Team in a supplemental PFMA and L2RA and document
the results in the PFMA/L2RA report as part of the CA efforts.
Document Accession #: 20251124-3084 Filed Date: 11/24/2025
4
b. Identify in Section 4 of the Inspection Plan the IC Team members that will
participate in the Field Inspection scheduled for the Week of July 13, 2026. If
there are IC Team members not participating in the field inspection, the revised
Inspection Plan should clearly explain why the IC Team members will not
participate in the field inspection. We note that field inspection participation of
the IC Team members covering Hydraulic, Engineering Geology and
Erodibility will be appropriate to observe the conditions of the erosion at the
spillway discharge channel.
4. The proposed schedule in the Inspection Plan does not provide a specific date for
the field inspection; it states the “week of.” Nor does it propose specific backup or
contingency dates should the PFMA/L2RA sessions take longer than expected. A
CA will require the participation of FERC staff; thus, it is essential that we know the
specific dates for all key milestones of the CA. Revise the Inspection Plan to
provide the specific date(s) scheduled for the field inspection and the contingency
days set aside for the PFMA/L2RA sessions.
5. The Inspection Plan does not provide a definitive date for the CAR review meeting.
A specific date for the CAR review meeting should be established in your revised
Inspection Plan.
6. Your proposed schedule includes a proposed date for the second coordination call
with our office. The scheduling of the second coordination call is not part of the
Inspection Plan. Our staff will coordinate a different date for this call with you
separately once your inspection plan is approved or conditionally approved.
Per 18 CFR § 12.34(a), you are required to obtain the approval of the IC Team
from the Director, Division of Dam Safety and Inspections, prior to the performance of
this CA. At this time, we are unable to provide that approval pending the resolution of the
comments 1 through 5, above.
Within 30 days from the date of this letter, submit a revised Inspection Plan that
addresses the above comment. File your submittal using the Commission’s eFiling
system at https://www.ferc.gov/ferc-online/overview. When eFiling, select: Hydro; Dam
Safety; Washington, DC; and Independent Consultant Approval Request. The cover page
of the filing must indicate that the material was eFiled. For assistance with eFiling,
contact FERC Online Support at FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll
free), or (202) 502-8659 (TTY).
Document Accession #: 20251124-3084 Filed Date: 11/24/2025
5
Thank you for your continued cooperation and interest in dam safety. If you have
any questions, please contact me at (202) 502-6740 or carlos.zambrano@ferc.gov.
Sincerely,
Carlos Zambrano, P.E.
Senior Civil Engineer
Division of Dam Safety and Inspections
Document Accession #: 20251124-3084 Filed Date: 11/24/2025
CARLOS
ZAMBRANO
NARVAEZ
Digitally signed by
CARLOS ZAMBRANO
NARVAEZ
Date: 2025.11.24 14:15:48
-05'00'
Document Content(s)
P-803 Philbrook CA Plan Review.pdf........................................1
Document Accession #: 20251124-3084 Filed Date: 11/24/2025