An IEAP is Thorough, Updated and Tested
An Incident and Emergency Action Plan (IEAP) is a formal document that identifies potential emergency conditions at a dam and specifies preplanned actions to be followed to minimize property damage and loss of life should those conditions occur. The IEAP contains procedures and information to assist the dam owner in issuing early warning and notification messages to responsible downstream emergency management authorities. It also should contain inundation maps to show the emergency management authorities the critical areas for action in case of an emergency.
The Indiana Dam Safety Program has a state-specific template for dam owners and emergency managers to use in developing IEAPs for HHP dams. In designing the template, IEAP forms and formats from several states and from federal agencies were reviewed, along with lessons learned from actual emergencies at dams in Indiana and elsewhere. For example, the template draws on some elements from Federal Guidelines for Dam Safety: Emergency Action Planning for Dam Owners (an update of the document FEMA 64). Although the Indiana template is 43pages in length, several pages contain explanations of terminology and others are most appropriate for larger dams. The Indiana template is meant to be user friendly and the resulting IEAP may be shorter, depending on the characteristics of the dam and its inundation zone.
Dam owners also could consider using the USDA Natural Resources Conservation Service (NRCS) IEAP template. A fact sheet of information on that template, directions on how to obtain it, and a copy of it are in the IEAP Help box on this page of the website. The general purpose of these guidelines from the Federal Emergency Management Agency is to encourage thorough and consistent emergency action planning. An emergency in terms of dam operation is defined as an impending or actual sudden release of water caused by an accident to, or failure of, a dam or other water retaining structure, or the result of an impending flood condition when the dam is not in danger of failure.
Organizations and individuals who own or are responsible for the operation and maintenance of dams are encouraged to use these guidelines to develop, update, and/or revise their IEAPs. IEAPs generally contain six basic elements:
- Notification Flowchart
- Emergency Detection, Evaluation, and Classification
- Inundation Maps
All of the elements should be included in a complete IEAP. The dam owner is responsible for the development of the IEAP. However, the development or revision of an IEAP must be done in coordination with those having emergency management responsibilities at the state and local levels. Emergency management agencies will use the information in a dam owner's IEAP to facilitate the implementation of their responsibilities. State and local emergency management authorities will generally have some type of plan in place, either a Local Emergency Operations Plan (EOP) or a Warning and Evacuation Plan.
Like an EOP, an IEAP for a dam should establish procedures (duties, responsibilities and actions) for emergency response such as warning the public and other functions. The IEAP development process should contain a functional format that spells out the Who, With What, and How of all critical emergency functions in time of disaster. Dam failures have unique considerations that require specific planning, such as the inundation mapping.
The effectiveness of IEAPs can be enhanced by promoting a uniform format which ensures that all aspects of emergency planning are covered in each plan. Uniform IEAPs and advance coordination with local and state emergency management officials and organizations should facilitate a timely response to a developing or actual emergency situation.
The U.S. Department of Agriculture is another federal agency that has a major role in dam safety and emergency planning. Indiana has hundreds of dams that were built as small watershed projects under the 1953 Public Law 566, and most are getting old and in need of more frequent inspection and repair. USDA's NRCS works with sponsors/owners of these dams, many of which fall under state regulation. NRCS has created guidelines and templates for IEAPs.
NRCS has posted its own IEAP form, which details a NRCS Directive that guides NRCS staff, dam owners, and emergency response authorities in completing an IEAP. NRCS staff are available to help dam owners in preparing their IEAP.
Indiana NRCS Dams
The Indiana Dam Safety Program does not know precisely how many IEAPs there are on Indiana's 127 earthen dams that are part of 33 NRCS watershed projects built under Public Law 566. About 15 years ago, a NRCS report projected that 30 of the dams will have reached their 50-year design life by now. At that time 34 of the dams had homes or other buildings downstream and needed to be upgraded to meet current dam safety laws to protect people and property. Several dams had slope instability. The Indiana Silver Jackets program has made a priority of working with owners and sponsors of these dams to develop IEAPs for them.
Maintaining and Testing an IEAP
After the IEAP has been developed, approved, and distributed, continual reviews and updates must be performed. Without periodic maintenance, the IEAP will become outdated and ineffective. The IEAP should be updated promptly to address changes in personnel and contact information, significant changes to the facility, or emergency procedures. The IEAP should be reviewed at least annually for adequacy and updated as needed. Even if no revisions are necessary, the review should be documented.
The review should include an evaluation of any changes in flood inundation areas, downstream developments, or in the reservoir and a determination of whether any revisions, including updates to inundation maps, are necessary. The IEAP should be updated promptly with the outcome of any exercises (testing of its assumptions and procedures), including periodic reviews and verifications of personnel and contact information from Notification Flowcharts and contact lists. Any changes to the dam and/or inundation zone should be reviewed because the changes may affect the inundation maps. Maps should be changed as soon as practicable and noted in the IEAP. Once the IEAP has been revised, the updated version (or only the affected pages in minor updates) should be promptly distributed to those on the distribution list.
If the IEAP action items and procedures are not exercised periodically, those involved in its implementation may lose familiarity with their roles and responsibilities. A proposed exercise schedule and plans for an IEAP exercise program should be included in the IEAP.