AN AUDIT WITH NO CREDIBILITY
COMMENTS ON MUSKRAT FALLS GENERATION
COMMENTS ON MUSKRAT FALLS GENERATION
Independent Dam Safety Review And Audit By Hatch
February, 2017
Guest Post by James L. Gordon, P. Eng. (Ret'd)
James L. Gordon, P. Eng. |
I have read the "Hatch "Audit" released by Nalcor just a few days ago. The first issue that I noticed
is that a company cannot “audit” its own work – it is a blaring conflict of
interest, and I am surprised that Hatch accepted the assignment. Of course
everything is perfect, why would Hatch say otherwise when commenting on their
own work?
The second issue is that the report is limited to a review of
the project management and operation – quote from slide 11 - “The objective of this presentation is to
cover the results of a dam safety audit and overall review performed for the
Muskrat Falls GS between January 29 – February 2, 2017” And – quote from
slide 17 – “The review of the design of
structures did not form part of this audit”.
So, the entire report can be deposited in File 13¹. Bearing
this in mind – what is missing from the report? The immediate reply is no
numbers! The entire report is based on the opinion of one geotechnical
engineer, with no supporting documentation. I would have expected to see at
least the following -
From the Executive Summary –
1. Quote
from Slide 5 - “Inspection and reporting
– Extensive instrumentation, real time data and collection and assessment”.
This is similar to a doctor asking an intern how the patient is progressing,
and receiving a reply “Well, we are monitoring his heart, measuring blood
pressure, pulse rate and oxygenation”. The intern’s reply does not tell the
doctor whether the patient is progressing or on the verge of passing away. In
the audit there is no data and no analysis of any data.
2. Quote
from Slide 5 - “Emergency preparedness –
Well documented, dam break assessments performed, actual level 2 emergency
response performed”. During the cofferdam incident last November, the
emergency preparedness plan was found to be deficient when the residents of Mud
Lake were not notified of the emergency. There is no mention of how this was
rectified, nor any mention of a test of the system. Tests are essential, and
usually reveal the weak links in the command structure.
3. Quote
from Slide 5 - “Operations, Maintenance
and Surveillance – Number, quality of instruments and surveillance frequency
exceeds typical industry best practices”. See comment #1. There is no
mention of instrumentation data.
For
example – some North Spur piezometers reacted to an increase in headpond level
several years ago. How did the same piezometers react to the increased headpond
level last November? Was there no reaction confirming the impermeability of the
cut-off walls?
Another
example – impermeable clay and till placed on the face of the North Spur and in
the cofferdam needs to be compacted to 95% Proctor (a measure of the
compaction) to attain the required impermeability. There is no mention of how
many tests achieved this standard, and no mention of the percentage of tests
below 95%.
And
another example – the spillway and intake form part of the dam containing
structures. There is no mention of the compression tests on concrete cylinders
from each concrete pour – how many achieved the required strength and what %
were below strength.
4. Quote
from Slide 6 – “Upstream cofferdam
remedial program – Cofferdam instrumentation, monitoring and inspections
sufficient to minimize risks while cofferdam is remediated” See comment #1.
The only way to tell whether the remedial measures are effective is to monitor
the volume of seepage. This is difficult in winter with everything covered in
ice and snow.
There
is mention on slide 51 that cofferdam seepage is currently being read once per
day, and during impoundment the rate will increase to every 2 hours. This is
reasonable, but the method of recording seepage should have been mentioned, and
data provided for seepage flows since the completion of the two upstream
temporary cofferdams.
The chart
on Slide 43 shows piezometer water levels, with only one piezometer (0+291)
showing any decrease as would be expected from the remedial measures. Without
knowing the precise location of the piezometers, interpretation of the data is
not possible. A drawing showing a cross-section through the cofferdam with
piezometer locations is missing.
The next
chart on Slide 44 shows the reaction of piezometers to the rising water levels.
However, there is no link between piezometers to show the reaction of
individual piezometers, which moved up, and where were the piezometers located
with respect to the cofferdam cross-section.
Other miscellaneous comments on lack of numbers are –
5. About
the middle of the presentation, slide 33 shows a plan photo of the cofferdam
taken last fall, before major seepage started. It clearly shows the green
seepage flowing across the dewatered area between the cofferdams, and the green
discharge from the downstream culvert. This seepage should have been stopped
prior to placing the impervious fill between the two upstream temporary
cofferdams, and is the reason for current difficulties. Impervious fill should
have been placed on the face of the upstream cofferdam until the seepage
stopped.
6. On
the cofferdams, there is the statement, from slide 35, quote – “Current levels of leakage in line with what
would be expected for a cofferdam of this type” I would beg to differ. The
seepage through the upstream cofferdam was excessive from the start, it was
never staunched and resulting in depositing the impermeable clay through water,
with the fine material coming in contact with the rock foundation being flushed
downstream, resulting in the current seepage issues.
And from
the same slide – quote – “Remediation
program underway to deal with increased leakage that occurred on first
impoundment ‒ Measures are appropriate and appear to be effective.” The
continued grouting program, now extending for almost 4 months since the seepage
increased on headpond filling and no decrease in piezometer water levels
contradict this statement.
It would have been far preferable to engage a consultant with
no prior contracts with NALCOR to undertake the audit. There are several such
as Klohn Crippen Berger and Golder Associates with an office in St. Johns. If
there is another audit, NALCOR should consider the above consultants.
To reiterate – it is not possible for a company to audit its
own work – put the report in file 13 and forget about it.
Jim Gordon P.Eng.
(Retired)
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1. "File 13" is a euphemism for the trash can.