FEDERAL ENERGY REGULATORY COMMISSION
`Office of Energy Projects
`Division of Dam Safety and Inspections - Atlanta Regional Office
`Gwinnett Commerce Center
`3700 Crestwood Parkway, Suite 950
`Duluth, Georgia 30096
`(678) 245-3000 Office - (678) 245-3010 Facsimile
`
`September 14, 2023
`
`In reply refer to:
`P-02332 Gaston Shoals
`P-02601 Bryson
`P-02603 Franklin
`P-02619 Mission
`P-10896 Pinnacles
`
`VIA Electronic Mail
`Mr. Chuck Ahlrichs
`President
`Northbrook Power Management, LLC
`cahlrichs@nbenergy.com
`
`Subject:
`
`Owner’s Dam Safety Program (ODSP) External Audit
`
`Dear Ms. Ahlrichs:
`
`Your ODSP is an important factor in maintaining the safety of your dam(s) and
`preventing a dam failure. As an owner of high and significant hazard dams, FERC requires
`that you develop and maintain an ODSP and complete an internal review of your ODSP
`each year. Additionally, 18 CFR §12.65 requires that your ODSP undergo an external audit
`every 5 years. Our records indicate you have not completed an external ODSP audit since
`purchasing FERC-regulated dams in 2019. Therefore, an external audit of your ODSP is
`due by December 31, 2024.
`
`Prior to conducting an audit of your ODSP, you must submit a statement of
`qualifications of your proposed auditor(s) or peer review team for our review and
`acceptance. File the statement using the Commission’s eFiling system and select Hydro:
`Dam Safety and Atlanta Regional Office. You can access the Commission’s eFiling system
`at https://www.ferc.gov/ferc-online/overview. 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).
`
`

`

`Within 90 days of the date of this letter, submit a qualification statement for your
`selected external auditor or audit team along with a plan and schedule to submit your
`external audit report.
`
`We appreciate your continued effort in maintaining this document. The ODSP is a
`living document that will require revision from time to time. As you make revisions, please
`re-submit the completely revised ODSP to the Commission using the eFiling guidance
`above. If you have any questions, contact Mr. Adam Sugrue of this office at (678) 245-
`3076 or by e-mail at adam.sugrue@ferc.gov.
`
`Sincerely,
`
`William J. Brown, P.E.
`Regional Engineer
`
`Enclosure
`
`

`

`Federal Energy Regulatory Commission
`01/02/2019
`Division of Dam Safety and Inspections
`GUIDANCE FOR ODSP EXTERNAL AUDITS
`
`Page 1 of 5
`
`GUIDANCE FOR ODSP EXTERNAL AUDITS
`
`To assure that an Owners Dam Safety Program is continuing to improve, independent
`audits should be conducted periodically by a qualified dam safety expert. Audits are
`intended for dam owners to continue to improve their dam safety program, help them
`understand how well their program is working, and to identify areas where their dam
`safety program may need improvement. The time period between program audits should
`reflect the risk exposure of the organization. For owners of one or more high hazard
`classification dams, their dam safety program should be externally audited on a schedule
`not to exceed five years. More frequent audits could be necessary if there has been a
`significant dam safety incident, or major changes in personnel and organizational
`structure have occurred. A statement of qualifications of the proposed auditor should be
`submitted to the Regional Engineer for review and acceptance prior to performing the
`audit. Upon completion of the audit, the Chief Dam Safety Engineer should review the
`audit report and prepare a summary report for presentation to the senior management of
`the organization. A copy of the summary document along with the full audit reports
`should be submitted to the FERC for review and comment, along with the licensee’s plan
`and schedule to implement any recommendations.
`Typically, an external audit includes the following type of items in a Scope of Work, but
`should be customized to the specific projects:
` Review reports, correspondence, and information with respect to the ODSP prior
`to performing the actual audit.
` Review operating and maintenance records for each facility to determine if proper
`procedures area being followed.
` Review personnel training records to ensure that dam safety training is being
`conducted in accordance with the latest training plan defined in the ODSP, and
`that all personnel have taken appropriate training.
` Conduct interviews, examinations, or utilize other methods to evaluate the
`effectiveness, completeness, and familiarity with dam safety training.
` Attend and participate in project site visits or inspections with field personnel
`at each project.
`Interview the Chief Dam Safety Engineer and all dam safety staff; including but
`not necessarily limited to: facility managers; staff engineers, and hydro plant
`technicians to determine their understanding of the DSP and the implementation
`of their respective responsibilities.
`
`
`
`

`

`Federal Energy Regulatory Commission
`01/02/2019
`Division of Dam Safety and Inspections
`GUIDANCE FOR ODSP EXTERNAL AUDITS
`
`Page 2 of 5
`
` Obtain independent views from staff personnel of the effectiveness and
`completeness of the ODSP.
` Evaluate the licensee’s commitment and its priorities with respect to dam
`safety, including senior executives. This includes meeting directly with senior
`management to discuss the DSP.
` Provide opinion as to whether the licensee’s dams are being adequately
`operated, inspected and maintained.
` Assess how proactive the licensee is in implementing their dam safety program.
`Determine if they take initiative to address dam safety issues on their own without
`waiting for FERC to require action.
` Provide conclusions, and if appropriate, recommendations for the Licensee
`to further improve management of their dam safety program.
`
`The intention of the audit is to improve your ODSP and help you understand how
`well your program is working. For further guidance on completing an external audit, please
`visit:
`
`https://www.ferc.gov/sites/default/files/2020-04/guidance-odsp.pdf
`For further information on improving your program overall, please visit:
`
`https://www.ferc.gov/industries-data/hydropower/dam-safety-and-inspections/
`owners-dam-safety-program-odsp
`
`Frequently Asked Questions
`
`1. Who should be hired to perform the ODSP audit? What experience and
`qualifications are needed by the auditor?
`
`For smaller licensees with only a couple of dams, a single individual could
`perform the audit. For larger licensees with numerous dams and complex
`organizations, ideally a two or more person audit or peer review team would
`be used.
`
`The auditor(s) should be from an external organization that was not involved
`in drafting the ODSP document or responsible for routine ODSP activities
`such as internal dam safety inspections or drafting DSSMRs.
`
`

`

`Federal Energy Regulatory Commission
`01/02/2019
`Division of Dam Safety and Inspections
`GUIDANCE FOR ODSP EXTERNAL AUDITS
`
`Page 3 of 5
`
`Qualifications for potential auditor(s) would include:
` Engineer(s) experienced in dam safety design, operation,
`and maintenance of the types of dams being evaluated.
` A current/former CDSE who has worked in a dam owning
`organization with a strong dam safety program.
` Someone with a regulatory dam safety background (e.g. current
`or former state or federal employee).
` Engineering Consultant with expertise in dam and hydro
`safety management.
`2. Do I need to submit the proposed auditor’s resume to the FERC for approval?
`Yes. As indicated in our annual letter, prior to conducting an audit of your
`ODSP, you should submit a statement of qualifications of the proposed auditor
`to the Regional Engineer for review and acceptance prior to performing the
`audit. A copy of the final audit report should also be submitted to the FERC for
`review and comment.
`3. Can we just use our Part 12 Independent Consultant to conduct our audit?
`For smaller licensees with only a few dams and a simple organizational
`structure, it may be possible to use your Part 12 Independent Consultant,
`provided
`their
`experience
`includes
`understanding of
`organizational
`management and leadership principles. In our experience, this option is being
`over-utilized, possibly as a simplification of contracting or familiarity.
`It
`reflects on your ODSP to make the most appropriate choice of an auditor who
`can fully understand and evaluate a dam safety program, as well as provide an
`independent review of the entire dam safety program.
`4. Can we use the same auditor for every audit?
`
`In general, it is preferred that you use a different auditor for each 5-year external
`audit. However, there may be situations where there is a logical reason to do
`so, such as following a major organizational change. You should check with
`your Regional Office first if you wish to use the same auditor twice.
`
`5. Can the FERC provide us with some names of potential auditors?
`
`

`

`Federal Energy Regulatory Commission 01/02/2019
`Division of Dam Safety and Inspections
`GUIDANCE FOR ODSP EXTERNAL AUDITS
`
`Page 4 of 5
`
`The FERC does not maintain a list of individuals who are qualified to perform
`an audit. We do maintain a list of Part 12 Independent Consultants who may
`or may not be qualified to perform an audit. Professional Organizations such
`as the Association of State Dam Safety Officials (ASDSO), U.S. Society on
`Dams (USSD), and the American Society of Civil Engineers (ASCE) may be
`able to help with finding qualified auditors or peer reviewers.
`
`

`

`Federal Energy Regulatory Commission
`01/02/2019
`Division of Dam Safety and Inspections
`GUIDANCE FOR ODSP EXTERNAL AUDITS
`
`Page 5 of 5
`
`Example Table of Contents for Audit Report
`
`1.0 - Introduction
`
`2.0 - Executive Summary
`
`3.1
`3.2
`3.3
`
`4.1
`4.2
`4.3
`4.4
`4.5
`4.6
`4.7
`4.8
`
`- Scope of Work
`- Audit Methodology
`- Discussions and Interviews
`
`- Audit of Program and Procedures
`- Authority of the Chief Dam Safety Engineer
`- Dam Safety Surveillance and Monitoring Plan
`- Non-Conformance Reporting
`- Internal Communications and Reporting
`- External Communications and Reporting
`- Training
`- Audits and Assessments
`
`5.0 - Records
`
`6.0 - Conclusions
`
`7.0 - Recommendations
`References
`
`