Hydro Facility FERC Permit
Over $1M in potential fines avoided
Background
DuraBante was asked to support a hydro facility facing potential fines from the Federal Energy Regulatory Commission (FERC) for repeated violations of their permit. The utility recognized the need for Operational Procedures that focused on the activities performed in the Control Room to meet the requirements and limitations imposed by FERC.
What DuraBante Did
- Researched license requirements, limitations of the control board for remote activation of equipment, historical data, and engineering documentation.
- Reviewed time tests for water flows for different events to understand how long it takes to restore water from various scenarios.
- Interviewed subject matter experts from Hydro Control Operations and Environmental & Licensing.
- Participated in field trips to observe the equipment involved to better understand how systems worked together.
- Interviewed fish biologists to better understand their definition of what “good stewardship” of the river looks like.
- Facilitated meetings between all stakeholders to achieve alignment behind the objectives and operational definitions surrounding key language used to define those objectives.
- Defined clear procedure objectives by facilitating discussions between Operations and Environmental & Licensing. Focus was on the coordination of activities to be performed at the site that impacted the river and downstream operations with the goal of meeting the FERC license requirements while demonstrating “good stewardship” of the river.
- Worked with Control Room Operators to bring an understanding of intent and proof of intent into their responses to license requirements.
- Involved Operators and validated procedure objectives and action steps. Used the understanding of proof of intent to modify Control Room activities.
- Enabled Operators to use a combination of set points to prove intent, rather than using a combination of calculations and data from a gauge that was approximately two hours downstream. This greatly simplified the control room process and allowed them to prove their compliance to the license more readily.
Results
- Over $1M in potential fines avoided. FERC accepted the mitigation plan.
- No violations reported when Procedures were followed.
- The hydro facility received:
- A complete set of Maintenance Procedures.
- A complete set of Operations Procedures that incorporated:
- Proven engineering specifications and testing.
- Seasonal dates.
- Environmental stewardship controls.
- Methods for calculating output were based upon engineering configuration in real-time rather than using information from gauges with a two-hour delay.
By involving the Control Room Operations personnel in the development process, DuraBante achieved acceptance and procedural sustainability in a way that had been difficult for management to obtain in previous projects. Operations personnel accepted more accountability of the process, and DuraBante facilitated needed communication and acceptance with other departments. Operations ownership of the process and procedural content was evident in the follow-up discussions and recommendations. Operators started talking about establishing standardized routines and processes that they could all follow, rather than each one using their own methods of determining the set points on the board to achieve perceived objectives. Communications between stakeholders improved, and more conversations are occurring that look at the needs of all the stakeholders.