Frequently Asked Questions
Q1. What is an Emergency Action Plan (EAP)?
- An EAP is a formal document used to assist dam owners in identifying unusual or emergency conditions at the dam. The document also prescribes specific actions to reduce the potential for downstream loss of life and property damage in the event of a dam failure.
Q2. Why did I get this EAP?
- Starting in 2017, the Dam Safety Program began update their EAP template in order to modernize it to federal guidelines and to create and provide inundation map technology which can be used to identify downstream hazards.
- As an ongoing effort for each high and significant hazard dam to have an up-to-date EAP, these dam-specific draft templates were generated by the Department and mailed for the dam's owners to review, complete, and return to the Department.
- While all owners of a given dam should review, check for completeness, and sign the EAP, only one copy of the EAP was sent per dam to encourage dam owners to work jointly and to allow all owners to review all information. Based on the best available information, the Department made an attempt to identify a reasonable owner who would be best equipped to be the initial point of contact for this process.
Q3. Why do I need to have an EAP?
- All dams regulated by the South Carolina Department of Health and Environmental Control (the Department) that are classified as High (Class 1) or Significant (Class 2) Hazard should have an up-to-date EAP.
- Ultimately, the dam owner is solely responsible for detecting dam incidents and initiating the appropriate emergency response.
Q4. Why am I identified as a dam owner?
- Per S.C. Dams and Reservoirs Safety Act Regulations, an "Owner" of a dam (including appurtenant works such as spillways, gates, or water conduits) is defined as "…those who own, control, operate, maintain, manage, or propose to construct a dam or reservoir."
- Please note that state law considers anyone who owns a portion of the dam or an appurtenant structure relating to the dam (e.g., inlet structure or auxiliary spillway) to be an owner or co-owner of the dam.
Q5. What should I do if I am not a dam owner, or if there are other owners of this dam not identified on the EAP template?
- If you believe you are not a dam owner, please submit proposed ownership changes within the template alongside any documentation that may aid the Department in determining dam ownership under state law. These may include, but are not limited to, deeds, plats, and easement records.
Q6. Who is responsible if my dam fails?
- The owner of the dam is responsible if the dam fails. Under the Dams and Reservoirs Safety Act, dam owners are responsible for maintaining their dam in a safe condition throughout the life of the structure (Section 49-11-50). The owners of all dams within the state are bound by this responsibility.
Q7. Why has the Department's EAP template been revised?
- The new template was modernized using guidelines established in the Federal Emergency Management Agency (FEMA) publication P-64. The Department has revised the standard EAP template to assist owners of High and Significant Hazard dams in creating an effective EAP. The updated template provides dam owners guidance on how to properly monitor the dam and also incorporates new inundation map technology which can be used to identify downstream hazards.
Q8. Do I need to submit an EAP in this format? Can I change/modify this template?
- No, the EAP does not have to be in this format. This template is used as a baseline for dam owners, and owners who fully complete this template will be meeting basic regulatory requirements. EAPs of any format are subject to Department review and must meet Department requirements including, but not limited to:
- Acknowledgement that all owners or parties responsible for a dam have reviewed the EAP and signed off on its contents;
- Contact information for dam owners and/or owner representatives;
- Basic dam information that may be useful during an emergency response;
- A system for identifying dam deficiencies and notifying the proper authorities of a dam incident;
- The best available inundation map identifying potential downstream at-risk population, structures, and properties; and,
- A process and contact information for notifying all potentially inundated properties in the downstream inundation area in the event of a failure.
- For customized template questions, please contact the Department
Q9. How was the inundation map prepared?
- The inundation map was created using the DSS-WISE Lite inundation modeling tool based on a top-of-dam “sunny-day” dam failure. This means that the water level is modeled to be at the top of the dam when failure occurs, and there is no additional flooding downstream.
- The Department considers this model to be a conservative estimate of an unexpected dam failure.
Q10. What if I disagree with the provided inundation map?
- If you disagree with the provided inundation map, the Department may be willing to re-model the dam if you can provide surveyed elevation data for the dam, reservoir, and downstream locations. If the Department’s information is correct or new information does not substantially change the model results (i.e., no change to potentially impacted properties), you may also utilize a licensed Professional Engineer to develop a more sophisticated inundation map of the downstream area and potential impacts from dam failure.
Q11. The EAP's list of potentially inundated properties does not have phone numbers. How am I supposed to collect this information?
- Specific contact information for the inundated property owners can be obtained in a number of ways left to the dam owner's discretion. Note that the dam owner is ultimately responsible for ensuring that downstream property owners are notified if a possible or active dam failure situation arises. Potential additions or removals can be proposed and will be reviewed by the Department.
- We recommend coordinating with your local Emergency Management Division to see if they are equipped and willing to assist with notifications in the event of an emergency or if an alternative notification plan would be more appropriate.
Q12. I am not able to find all the necessary phone numbers for downstream property owners. What do I do?
- Notification and evacuation plans that are custom-made in conjunction with local emergency management agencies are strongly encouraged. If not all phone numbers can be obtained for the notification plan, an alternative plan may be substituted provided it meets all regulatory requirements. If an entity other than the dam owner will be conducting notifications, that entity's plan and responsibilities should be documented in the EAP.
- Incomplete EAPs will be reviewed by the Department and may be subject to compliance and enforcement actions. (See: “What happens if I do not complete or submit the EAP?”)
Q13.What do I need to fill out and turn in to the Department?
- Submitted EAPs will be reviewed by the Department, which will be checking for the following:
- Verifying all owners or owner representatives have signed the EAP
- Reviewing any revised or newly-provided owner contact information
- Verifying the potentially inundated properties associated with the attached inundation map have contact phone numbers listed OR will be notified through a substitute plan.
Q14. How do I submit my edited pages to the Department?
- By mail to:
- Dam Safety Program
- Bureau of Water
- 2600 Bull Street
- Columbia, SC 29201
- By e-mail to:
Q15. How does the document validation process work?
- The Department will be reviewing every EAP it receives. Dam owner edits, including the potentially inundated properties contact information, will be evaluated for completeness. The Department may contact you if there are questions or to verify any information or edits that are submitted.
Q16. My local emergency management agency or other government agency/function has agreed to assume notification responsibility for downstream owners. How can I capture that in the EAP?
- A written agreement from any and all agencies must be included in the EAP and also provided to the Department.
Q17. How often do I need to revise my EAP?
- Law and regulations require that a current EAP be provided at every routine Department-scheduled inspection. This is a minimum requirement, and Updated EAPs can be provided to the Department at any time. The standard routine inspection cycle is every two years for High Hazard (Class 1) dams and every three years for Significant Hazard (Class 2) dams.
- Some major EAP revisions that should be presented to the Department as they occur are:
- Changes in dam ownership;
- New inundation maps or revisions to existing maps and linked notification plans; and,
- Changes in owner or responsible party contact information.
Q18. How do I determine if my dam is at risk of failure?
- Dam owners should be aware of the overall health of the structure and monitor for any changes. Appendix C of the template contains helpful information for identifying problems that can lead to failure. If an issue is identified, the Emergency Response portion of the template contains a chart to help determine which emergency response notification tree to execute. It is better to err on the side of caution and contact the Department for a consultation.
Q19. What happens if I do not complete or submit the EAP?
- The Department would like to assist you to ensure this does not happen. If you are having difficulty understanding or completing the EAP, please contact the Department. Insufficient or absent EAPs may lead to compliance and enforcement actions, which may result in fines.
Q20. I just received a letter from DHEC with requirements and deadlines. How do EAPs fit into this?
- All requirements and deadlines not associated with an EAP (e.g. a deadline to submit a permit application) are still in effect. New EAP-related requirements and deadlines will supersede any older EAP-related deadlines. Please contact the Department if you are unsure of requirements associated with your dam
Q21. How is the Department handling situations with more than one dam owner?
- The Department will select one owner to serve as the primary point-of-contact for the EAP update process. That owner will be provided the draft EAP for review, editing, and obtaining all owner signatures. The point-of-contact should ensure the document is distributed to all other owners and responsible parties. A single, consolidated EAP should be submitted to the Department. Multiple EAPs from multiple owners will not be accepted and could result in compliance and enforcement action.
Q22. How do I get in touch with other owners?
- All dam owners or responsible parties currently listed in Departmental records, as well as associated contact information, are provided in the EAP. All owners must sign the document for it to be validated by the Department.
- If you are having difficulty getting in touch with other owners, getting an owners to sign the document, or are afraid the draft EAP may be lost after it passes out of your hands, please contact the Department. Owners are encouraged to keep track of their efforts to complete the EAP and to keep the Department updated about these efforts.
Q23. How should I distribute this document to other owners?
- The Department recommends distributing the document via mail, email, or hand-delivery after making your proposed edits. A copy should be retained in the event the original is lost in transit or not submitted by another owner.
Q24. Can I get an extension for my EAP deadline?
- Extensions are available upon request pending Department concurrence.
Q25. I want to understand this process and the concept of EAPs in greater depth. What resources can I turn to?
- The Department included a flyer on Emergency Action Planning that was created by the Association of State Dam Safety Officials for dam owners that lists many internet resources. The flyer is also available at: https://damsafety.org/sites/default/files/files/Printable%20Brochures%202017%20-%20Orange.pdf - PDF
- The Association of State Dam Safety Officials website has an entire section on emergency action planning at: https://damsafety.org/dam-owners/emergency-action-planning
- The US Federal Emergency Management Agency's guidelines for EAPs is available at: https://www.fema.gov/media-library-data/5b20db599c212f77fd5e85d256f471a3/EAP_Federal_Guidelines_FEMA_P-64.pdf - EAP_Federal_Guidelines_FEMA_P-64
- Department staff would be happy to arrange a face-to-face meeting with any dam owner to discuss the EAP requirements or to assist in completing the final document. Please contact the Dam Safety Program to schedule an appointment.