FERC tells Granite County to prepare for deeper "Part 12" comprehensive assessment of Flint Creek project; county given schedule and new documentation rules

Federal Energy Regulatory Commission staff on Jan. 7 told Granite County commissioners and licensee representatives that the agency’s revised Part 12 inspection rules require a deeper, more document‑intensive review of the Flint Creek hydroelectric project and set firm deadlines for the county’s contractor selection and submissions.

The agency’s regional presenter, Kareem, joined by Doug Johnson (regional engineer) and Katie Clarkson (branch chief), walked commissioners through the new requirements for a ‘‘comprehensive assessment’’ (CA) under 18 CFR Part 12 Subpart D and the engineering guidelines. Kareem said, “This is a fairly relatively new process, for the Part 12.” The county was reminded that the final comprehensive‑assessment report is due on Jan. 1, 2027.

Why it matters: the updated Part 12 approach follows recent dam incidents and agency audits and replaces the older periodic inspection practice with a deeper 10‑year CA that requires independent consultant teams to review source documents, perform a potential failure‑modes analysis (PFMA) and a Level‑2 risk analysis (L2RA), and submit new preparatory work products before field work begins.

FERC staff reviewed specific expectations and the timeline the county must follow. Major points conveyed to the commissioners and licensee representatives:

- Regulations and guidance: FERC staff pointed commissioners to 18 CFR Part 12 and to the engineering guidelines (chapters 15–18) on FERC’s website for technical and submittal formats.

- Scope and new deliverables: The IC (independent consultant) team must prepare a Pre‑Inspection Preparation Report (PIPR) demonstrating the team has reviewed source documents and is prepared to conduct the CA. The PIPR is a new, required product; incorporation‑by‑reference to prior Part 12 reports is no longer accepted—every CA must ‘‘stand on its own.’’

- Timing: FERC staff reiterated schedule constraints in the December 3, 2024 reminder letter. The county must submit the Part 12 inspection plan and IC‑team proposal at least 180 days before the first field activity; the CA PIPR must arrive at least 30 days before the first activity; FERC will perform an expedited review and may postpone the inspection if deadlines are missed. Staff emphasized that earlier submission of the inspection plan increases the IC team’s available preparation time.

- Technical scope: The IC team must inspect all project features required under 18 CFR 12.37 (spillway, embankments, reservoir components, valve vaults and instrumented monitoring) and perform independent evaluations of prior analyses if necessary. FERC highlighted that the IC team is expected to review source technical documents rather than rely on summaries and may need to perform independent calculations.

- PFMA and L2RA content: The CA must include PFMA and Level‑2 risk analyses, which require seismic and hydraulic loading studies and credible consequence estimates. FERC staff specifically pointed to the guidelines’ chapters on PFMA and L2RA for required content and methods.

- Data and instrumentation: The IC team must critically analyze monitoring data and surveillance reports, describe expected versus observed instrument behavior, and explain what the data imply about project performance.

- Licensee responsibilities: Granite County, as licensee, must scope the CA, provide the IC team with the supporting technical information document (STID) and digital project archive (DPA) materials, arrange logistics, and submit the IC team’s comprehensive‑assessment report by the due date. Licensees also must develop corrective‑action plans and annual status reports for any IC recommendations.

FERC staff responded to county questions about cost, timing and eligibility of consultants. Doug Johnson and other staff acknowledged the process is more demanding than previous Part 12 inspections but said the deeper review was prompted by safety incidents and audit findings and is intended to identify risks earlier. Doug said the changes follow failures such as Oroville and other incidents and described the CA as a ‘‘deep dive’’ that is more involved for the first cycle but is intended to produce a clearer risk profile for each project.

County and consultant representatives asked about practical scheduling constraints given Montana weather and staffing. Jonathan Weaver of Great West said he would check with the county’s consultant contacts about timelines. FERC staff and county participants agreed the inspection plan and staffing decisions should be made soon: staff advised issuing an IC request for proposals and aiming to have the inspection plan to FERC well ahead of the 180‑day deadline to allow time for review and to avoid postponement.

What happens next: FERC staff said there will be a second coordination call after the inspection plan is submitted and reviewed. The county was advised to consult the December 3, 2024 reminder letter and chapters 15–18 of the engineering guidelines on FERC’s website for details. The county must submit the comprehensive‑assessment report by Jan. 1, 2027, and then prepare corrective‑action plans and annual status reporting for any IC recommendations.

Ending: County staff and commissioners said they would begin soliciting IC proposals and work with FERC staff to clarify scoping and schedule details. FERC reiterated that it will accept follow‑up questions from the regional office and encouraged early submissions to preserve preparation time for the independent consultant team.