Case study · Energy & utilities
Hydro facility FERC permit violations
Over $1M in potential fines avoided by rebuilding control room procedures with the operators who use them.
The challenge
Background
A hydro facility faced potential fines from the Federal Energy Regulatory Commission (FERC) for repeated violations of its permit.
The utility recognized it needed operational procedures focused on control room activities to meet the requirements and limitations imposed by FERC. Operators were setting water flow using calculations and data from a gauge roughly two hours downstream.
Our approach
What DuraBante did
Researched the requirements
License requirements, control board limitations for remote equipment activation, historical data, and engineering documentation.
Tested real timing
Reviewed water-flow time tests for different events to understand how long restoration takes in each scenario.
Listened to every stakeholder
Interviewed Hydro Control Operations, Environmental & Licensing, and fish biologists on what “good stewardship” of the river looks like, and walked the equipment in the field.
Built alignment
Facilitated meetings to agree on objectives and the operational definitions behind key license language.
Wrote procedures with operators
Operators validated objectives and action steps, bringing “proof of intent” into their responses to license requirements.
Simplified the control room
Operators now use a combination of set points to prove intent, instead of calculations and delayed downstream gauge data.
Outcome
Results
- Over $1M in potential fines avoided; FERC accepted the mitigation plan.
- No violations reported when procedures were followed.
- A complete set of maintenance procedures.
- A complete set of operations procedures incorporating proven engineering specifications and testing, seasonal dates, and environmental stewardship controls.
- Output calculated from real-time engineering configuration rather than gauges with a two-hour delay.
Because control room operators helped build the procedures, they accepted them and kept using them, something management had struggled to achieve on earlier projects. Operators took more ownership of the process, began standardizing routines instead of each using their own methods for set points, and communication across departments improved.
Facing a regulatory finding?
If you need a partner to evaluate your response to regulatory requirements, Joe Alvarez, our Director of Client Engagement, will reach out within one business day.