dam failure response plan - hsdl

Dam Failure Response 1

Running Head: DAM FAILURE RESPONSE

Dam Failure Response Plan

Charles G. Goodman Jr.

Denton Fire Department, Denton, TX


CERTIFICATION STATEMENT

I hereby certify that this constitutes my own product, that where the language of others is

set forth, quotation marks so indicate, and that appropriate credit is given where I have

used the language, ideas, expressions, or writings of another.

Signed: ___________________________________________


Abstract

The problem was, the Denton Fire Department did not have a dam failure

response plan. The purpose of this project was to establish the risk and identify the

components of an effective dam failure response plan and provide recommendations to

develop such a plan. Research sought to answer the following questions:

Was there a significant risk of dam failure at Lake Ray Roberts?

What was the industry standard for an emergency response plan for a dam failure?

What were the dam failure response recommendations from the Denton County

Emergency Management Office?

What were the components used by other Denton County fire departments in their

dam failure response plans?

A descriptive research method was used to identify the risk and describe the type

of plan needed. Literature review identified the risk and provided a model plan to follow.

Personal interviews revealed the lack of an existing plan and identified sources for

additional information, helpful in developing a plan. A telephone survey was used to

identify what neighboring communities were doing to address the risk.

Research revealed that there was a risk of a failure of the Lake Ray Roberts dam.

Geology of the area suggested there was a risk of an earthquake that could result in dam

failure. Sufficient information was found to begin the process of developing a response

plan.

Research culminated in the development of the following recommendations. First,

contact the US Army Corp of Engineers and use their information to develop an


emergency action plan. The plan should contain: early warning system, evacuation routes,

a resource list, and notification flowchart. Second, private sector resources should be

identified and contracts in place. Lastly, coordinate a tabletop exercise, and possibly a

full-scale disaster drill to test the plan.


Table of Contents

Abstract………………………………………………………....………………...………3

Table of Contents…………………………………………………….……..…………….5

Introduction…………………………………………………………...…………………..6

Background and Significance……………………………………………………………..6

Literature Review…………………………………………………………………...……11

Procedures………………………………………………………………………………..16

Results……………………………………………………………………………………19

Discussion………………………………………………………………………………..25

Recommendations………………………………………………………………………..27

References………………………………………………………………………………..30

Appendices

Appendix A: SMU Heat Flow in Texas Study…...................................................……..32

Appendix B: USGS, Seismic Hazard Map, Texas……………………………….......….33

Appendix C: Telephone survey……………………………….........................................34

Introduction


Problem Statement

The problem is the Denton Fire Department (DFD) does not have an effective

dam failure response plan in place.

Purpose Statement

The purpose of this research paper is to identify the components of an effective

dam failure response plan and make recommendations to improve the DFD‘s response,

should a catastrophic flood occur as the result of such an event. A descriptive research

method will be used to answer the following questions:

Is there a significant risk of dam failure at Lake Ray Roberts?

What is the industry standard for an emergency response for a catastrophic flood?

What are the flood response recommendations from the Denton County

Emergency Management Office?

What are the components of an effective flood response plan used by other

Denton County fire departments?

Background and Significance

On April 22, 2007, the City of Denton, Texas experienced what was

determined to be the equivalent of a 100 year flood. The area received nine to ten inches

of rain in a two hour period. Many areas of the city were inundated with water, creeks

overflowed, streets were flooded and entire sections of the community were completely

isolated. The DFD was responsible for answering the more than 100 calls for service

during the event and the time after the event until the waters receded.

On duty personnel were quickly overwhelmed and simply responded to the

calls as best they could. It was quickly realized that available resources could not keep up.


A second alarm assignment was paged out , as well as the swift water rescue team. The

swift water response team is comprised of twenty five swift water technicians The team is

equipped with personal floatation devices, one powered zodiac and one non-powered

zodiac, an assortment of ropes, and throw bags. Most of the personnel who responded to

the “all call” could not reach the stations where their equipment was stored or the areas

where calls for service were coming from.

Thirty two minutes later, an “all call” page was sent out for all off-duty personnel

to respond. The system was officially overloaded. The communications center placed

calls for assistance to neighboring cities, but to no avail. All of the neighboring

communities were dealing with the same conditions and unable to send personnel or

equipment.

The Fire Chief, in coordination with the DFD Emergency Manager,

activated the City of Denton Emergency Operations Center (EOC). Due to rising water

and blocked roadways, personnel assigned to the EOC were prevented from reaching the

designated location.

DFD personnel were forced to do the best they could with the resources they

currently had in place. Most calls for service were answered by personnel trained only to

the awareness level. Due to the lack of resources, even ambulance crews were sent out to

attempt rescues. This resulted in the loss of one ambulance, when it was washed off the

road by fast moving water. The community was fortunate, even though there were

numerous people trapped by the rising waters, there were no injuries and no fatalities.

Due to the topography of the area, the entire event was over in less than five hours.

In September 2008, Denton County Emergency managers were asked to


put together a task force to deploy to the Texas gulf coast region in response to hurricane

Ike. A spur-of-the-moment call for assistance was sent out and a task force of personnel

and equipment was assembled to deploy. Since the fire departments in Denton County had

never participated in any such deployment, the task force was comprised of equipment

that each department could spare at the time. Once the task force arrived in the affected

area, they quickly found out they had sent equipment that was ill-suited for the task at

hand.

The task force leader did an excellent job of utilizing his available

resources to best suit the tasks that were assigned by the Orange County Incident

Commander. All efforts in the region were coordinated by the Texas Forestry Service as

part of a state-wide mutual aid agreement known as Texas Intrastate Fire Mutual Aid

System (TIFMAS). The TIFMAS system had only recently been put in place and only had

one or two tabletop exercises to work out the finer points of managing a large-scale

incident.

The deployment of the task force was a success. Personnel were able to

provide most, if not all, of the assistance they were tasked with providing for the citizens

in Orange County. The task force leader conducted an after action critique that revealed

several areas that could be improved upon for future deployments. A plan was devised to

set the task force up as an “all hazards” task force. (D. Brown, personal communication,

June 1, 2010) Apparatus, equipment and personnel lists were devised for future

deployments. For the time being, lists have not been set up to respond to specific threats,

but the task force leader has developed a county-wide resource list from which to choose

from in the event of a future request from TIFMAS. However, no resources have been


identified from the private sector. (D. Brown, personal communication, June 1, 2010)

As discussed in the Executive Analysis of Fire Service Operations in

Emergency Management (EAFSOEM), plans need to be in place before the incident

occurs, to ensure the resources are available when needed. Incident specific equipment

needs should be identified and resource lists developed. If specific equipment is needed

and is only available from the private sector, contracts and written agreements should be

in place, identifying costs, availability and contacts. In the case of the Denton County task

force, the only agreements in place currently are with the neighboring fire departments.

When local resources are deemed to be insufficient, procedures are in place for requesting

State and Federal assistance. (North Central Texas Council of Governments [NCTCOG],

2007)

As stated earlier, the initial response for the 100 year flood event that

occurred in Denton on April 22, 2007 was over in a matter of four or five hours. The

likelihood of a bigger flood event is highly unlikely, unless there was a failure of the dam

at Lake Ray Roberts. According to the Denton County Local Mitigation Strategy

(DCLMS), a document published by the North Central Texas Council of Governments

(NCTCOG), the dam at Lake Ray Roberts is listed as a “High Hazard” dam. (NCTCOG,

2007) The lake covers an area of 46 square mile and has a normal capacity of 799,600

acre feet. According to the DCLMS, the dam at Lake Ray Roberts is an earthen dam with

a rock/soil foundation. (NCTCOG, 2007) The dam was constructed in 1986 and required

modification in 1990. The dam is unlikely to experience a catastrophic failure unless it

experiences some sort of seismic activity. (NCTCOG, 2007)

According to the DCLMS, there is an inactive geological fault line located


in the vicinity of the lake itself. The last know seismic activity of the fault was in

September of 1985. The document states that the most likely cause of any future seismic

activity would be from earthquakes originating in Oklahoma, Tennessee or Missouri.

However, it does cite the possibility of seismic activity resulting from oil and gas

production in the area. (NCTCOG, 2007) According to a geological heat flow study

conducted at the Southern Methodist University, there are numerous geological fault lines

and a tectonic boundary located in the North Texas area. (Appendix A)

According to the US Geological Survey, the risk of the North Texas area

experiencing an earthquake is small. There is roughly a five percent chance one will occur

in the next 50 years. (Appendix B) As recently as November 2008, minor seismic activity

has occurred in the North Central Texas region (NBC Dallas-Ft. Worth [NBCDFW],

2008). Some citizen groups think the tremors were the after effects of extensive drilling

operations in the North Central Texas area after natural gas deposits were discovered in

the Barnett Shale. (Fox News [FN], 2008) An earthquake, caused by gas well drilling

operations, triggering an earthquake in the inactive geological fault located in the area of

the Ray Roberts dam is a possibility. Such an earthquake could cause a catastrophic

failure of the dam. Should such an event occur, the resources of the DFD would quickly

be overwhelmed. With no particular plan in place for such an event, the only option

would be to contact the Denton County Emergency Manager and activate the Denton

County Task Force (DCTF). Their resources would also be overwhelmed, if they were

even able to assemble a team.

Most of the cities who participate in the DCTF are located to the south and east of

Denton. Those communities located to the east of Denton would be unable to respond due


to road closures. A failure of the dam would wash out FM 455, FM 426, Hwy 380, the

Lake Lewisville Toll Bridge and probably Hwy 121. These are the major east/west

thoroughfares in Denton County. Those cities to the south of Denton would probably be

dealing with their own high water incidents and unable to send personnel or equipment.

Not having a comprehensive response plan for the failure of the dam at Lake Ray

Roberts will severely hamper the DFD in the performance of its sworn duty. The

community as a whole would benefit from the development of such a plan. By developing

a dam failure response plan, the DFD would be working toward accomplishing one of the

US Fire Administration’s operational objectives; 2500 communities will have a

comprehensive multi-hazard risk reduction plan led by or including the local fire service.

Literature Review

Based on information published by FEMA, it is imperative that the Denton Fire

Department devise a plan to prepare for the possibility of a catastrophic failure of the

Lake Ray Roberts dam. (Federal Emergency Management Administration [FEMA], 2008)

Some of the information that is helpful in preparation for such an event is:

Is the dam a high-risk dam?

Who owns/maintains the dam?

Is there a emergency action plan?

Are there early warning procedures in place?

While this information is published with the intent of informing the public, it is useful for

emergency services providers as well. (FEMA, 2008)

Lake Ray Roberts sits on Denton County’s northern border with Cooke

county. The lake’s capacity is 1.9319e+06 acre feet. (NCTCOG, 2007) Based on the size


definition found in 30 TAC 299.13, the Lake Ray Roberts dam is classified as a large

dam. (TCEQ, 2009) The dam is an earthen dam with a rock/soil foundation. The dam and

the lake are controlled and maintained by the United States Army Corp of Engineers.

(NCTCOG, 2007) The flood plain between Lake Ray Roberts and Lake Lewisville to the

south, splits Denton county (NCTCOG, 2007). The lake Ray Robertss dam is listed as a

high hazard dam (NCTCOG, 2007). One of the four major causes of dam failure is

seismic activity. (TCEQ, 2009)

There are five major roadways connecting the eastern and western sections of

Denton County; FM 455, FM 426, Hwy 380, the Lake Lewisville Toll Bridge, and Hwy

121. Should the dam fail, these roads would be impassable. Effectively cutting the county

in half and hampering response efforts. Task force resources from the eastern part of the

county would be unable to provide assistance.

According to a heat flow study conducted b the Southern Methodist University,

there are numerous inactive fault lines and heat flow boundaries and a tectonic boundary

line in the North Central Texas area. (Negraru, 2006) A copy of the map showing the

relative locations is located in appendix A. According to the US Geological Survey, the

risk of an earthquake in the Denton area is relatively low. (US Geological Survey

[USGS], 2008) A copy of the map identifying the areas at risk is contained in appendix B.

As recently as November 2008 a number of small earthquakes have shook the North

Central Texas area. (NBCDFW, 2008) Some speculate that the quakes are the result of

natural gas well drilling operations in the north Texas area. (FN, 2008) One of these

minor earthquakes, caused by gas drilling operations, triggering a seismic event in the

inactive fault is a possibility. Since there is a geological fault in the area of the Lake Ray


Roberts dam, a catastrophic failure of the dam is possible. (NCTCOG, 2007)

Local governments have the primary responsibility for flood plain management.

(TCEQ, 2006) According to the City of Denton Emergency Manager, there is no

emergency action plan addressing the failure of the Lake Ray Roberts dam. (M. Penaluna,

personal communication, May 25, 2010) The city does have a plan in place that addresses

the possibility of a 500 year flood. This plan is part of the Denton County Local

Mitigation Strategy (DCLMS), published by the NCTCOG. The DCLMS addresses the

possibility of a 500 year flood event, a failure of the dam would far exceed that

amount of water Texas. (NCTCG, 2007)

According to the Denton County Emergency Manager, there is no emergency

action plan in place, at the county level, in case a dam failure. He referred to the DCLMS,

which only addresses the possibility of a 500 year flood. (J. Gonzales, personal

communication May 28, 2010) He also stated that it would be a good idea and asked to be

provided copies of any information discovered during the course of this research.

The US Army Corp of Engineers (USACE) has an emergency action plan in place

for a catastrophic dam failure at Lake Ray Roberts as a part of the National Inventory of

Dams. However, due to homeland security issues, any information found in that

document cannot be published. This information can be accessed and used by local

governments, but is not subject to Freedom of Information/Public Records acts or similar

statues. (National Inventory of Dams, personal communication, June 11, 2010) A local

government agency may request access to the information website, but must sign a non-

disclosure agreement prior to being granted access to the information. Since the

information contained within the website could not be published in this document, the


website was accessed only to compile a list of what information was contained on the

site. No information specific to the dam, the reservoir, or the emergency action plan were

used in this report.

The State of Texas Office of Emergency Management, which is a division of the

Department of Public Safety, does not have specific guidelines for the development of an

action plan addressing a dam failure. They do publish an all-hazard response plan. The

plan breaks down who is responsible for specific functions. It lists the functions and what

state agency has primary and support responsibilities. (Texas Department of Public Safety

[TDPS], 2009) The plan also lists corresponding federal agencies. The state plan did

provide some helpful information in the form of an organizational chart indicating some

of the groups that local agencies would likely be relying on. (TDPS, 2009)

The National Flood Insurance Program (NFIP) is a nation-wide effort to help

states, local communities, and individuals with the tremendous responsibility of

protecting the public in the event of a devastating flood. (Flood) The NFIP is based on an

agreement between the local jurisdiction and the federal government. (TCEQ, 2006)

NFIP regulations in Section 59.22 (b)(1) require the local jurisdiction to designate an

official who has the responsibility, authority to enforce, and the means to implement

ordinances to manage the flood plain inside the jurisdiction. (TCEQ, 2006)

The Texas Commission on Environmental Quality (TCEQ) is the State agency

charged with coordinating with the NFIP. (TCEQ, 2006) The TCEQ publishes a

document titled Guide To Developing Emergency Action Plans For Dam in Texas. This

document is published as a guide for dam owners and operators for determining if their

dam meets the federal requirements to have a emergency action plan (EAP) on file with


the TCEQ and how to put a plan together. (TCEQ, 2009) According to the Texas

Administration Code (30 TAC 299.61), owners of high risk or significant risk dams must

submit an EAP to the TCEQ. (TCEQ, 2009)

An EAP must include the contain the following components: contents, title page,

statement of purpose, description, notification flowchart, emergency detection,

evacuation, and classification, responsibilities, preparedness, inundation maps, and

implementation plan. (TCEQ, 2008) In addition, the TCEQ requires the owner/operator

of a high risk or significant risk dam to review the EAP annually, or when any

downstream development is done. (TCEQ, 2008) This is required to ensure contacts are

current and procedures are up to date. Copies of the EAP are to be provided to the local

emergency managers. Dam owners are required to conduct a tabletop exercise of the EAP

with all at least every five years. (TCEQ, 2008) A copy of the EAP for the Lake Ray

Roberts dam has not been furnished to the COD emergency manager, nor the Denton

County emergency manager. (M. Penaluna, personal communication on May 25, 2010)

(J. Gonzales, personal communication on May 28, 2010) No tabletop exercise has ever

been conducted. (M. Penaluna, personal communication on June 10, 2010)

The Traralgon Township in California has published the “Flood Response

Guidelines for the Community”. In this document, the public is provided the information

to prepare themselves in the event of a flood. (Latrobe City [LC], 2009) It details the early

warning and flood monitoring system that the community has put in place. It also

identifies who in local and county government is responsible for what functions during the

flood event. The document identifies evacuation routes and contains a notification

flow chart to ensure that all responsible entities are notified. (LC, 2009) The document


and the plan are well thought out and very comprehensive.

Procedures

A descriptive research method was used in this project. The purpose of this

research paper was to establish the risk of a dam failure and identify the components of an

effective emergency action plan for a possible failure of the dam at Lake Ray Roberts,

located north of the City of Denton, Texas. Since there was found to be no such plan in

place, an attempt was made to identify the components of an effective dam failure

response plan and identify and industry standards that might exist.

Research sought to answer the following questions:

Was there a significant risk of dam failure at Lake Ray Roberts?

What are the industry standards, if any, for an effective dam failure

response plan?

What are the recommendations for a dam failure response from the Denton

County Office of Emergency Management?

What components have other Denton County fire departments included in

their flood response programs?

The procedures of this research were designed to first determine if a significant

risk exists for the failure of the dam at Lake Ray Roberts. Secondly, research sought to

find information that would provide recommendations for developing and implementing a

flood response plan in the event of such a catastrophic dam failure. The three methods

utilized to support this research were: literature review, personal interviews, and a

telephone survey. These research methods will be discussed in order.

Literature Review


A number of articles, websites, and government publications were researched to

determine if the risk of a dam failure at Lake Ray Roberts was significant enough that the

DFD should address the issue. While the possibility may be remote, the information

discovered indicates the risk is significant enough that plans should be developed and put

into place.

Literature review provided a significant amount of information for background

and significance. While the likelihood of a catastrophic failure of the Lake Ray Roberts

dam is unlikely, there is evidence that a threat is present. The dam is listed as a high risk

dam. It is an earthen dam. There is an inactive geological fault in the area of the dam.

(NCTCOG, 2007) There are numerous inactive geological fault lines and a tectonic

boundary line located in the North Texas area. (Appendix A) The risk of the North Texas

area experiencing an earthquake are relatively small. (Appendix B) However, recent gas

well drilling in the Barnett Shale has triggered minor earthquakes in the North Central

Texas area. (NBCDFW, 2008) The possibility of seismic event leading to a dam failure is

a possibility.

Numerous articles were reviewed in trade journals, magazines, and internet

websites regarding flooding and flood response. However, few articles were found that

outlined specific requirements or guidelines for setting up an effective flood response due

to the failure of a dam. Three government publications were reviewed containing a great

deal of information concerning the federal requirements and the development of an EAP

for dam owners or operators.

Telephone Survey

Emergency managers, or other personnel responsible for emergency management,


from neighboring communities were contacted in order to determine if they had flood

response plans in place in the event of a dam failure. Only the neighboring communities

located in Denton county and south of the Lake Ray Roberts dam were contacted. These

were the only communities that would likely be affected in the event of a dam failure.

Cities located to the east of the flood plain were not contacted since they would likely be

unable to respond to Denton due to the roads being washed out.

Personal Interviews

A personal interview was conducted with the City of Denton Emergency Manager

to ascertain if a plan was in place, if not, develop ideas about where to start looking for

information. He provided a copy of the DCLMS and discussed its scope. A second

interview was conducted with the Denton County Emergency Manager, seeking the same

information. A third personal interview was conducted with Darrel Brown, the Denton

County task force leader, to discover the capabilities of the task force.

Limitations

The limitations that were encountered were: lack of useful information and

restricted access to some information. Numerous magazine, journal, and internet articles

were reviewed that contained information concerning flooding events, dam failure, and

seismic activity, but few provided any insight into the development of a response plan.

While the USACE had a significant amount of information concerning the dam,

the reservoir, and a response plan in case of a dam failure, this material was restricted due

to security issues. While the information is available to local government entities upon

request, in order to be allowed access to the information, a non-disclosure agreement

must be signed. The security measures go so far as to supersede any Freedom of


Information or Public Access acts.

Results

The results of each procedure included in this research are presented in

succession. The procedure used in each area will provide facts, as well as insight, into the

stated problem and seek to answer the research questions stated in the introduction. The

goal of the Denton Fire Department is to provide the best possible level of service to its

citizens and to do so requires that plans be in place to ensure an effective response to a

myriad of scenarios, including the unlikely event of a catastrophic failure of the dam at

Lake Ray Roberts.

Literature Review

The literature review was performed to answer the following questions:

Is there a significant risk of dam failure at Lake Ray Roberts?

What is the industry standard for an emergency response for a catastrophic

flood?

What are the flood response recommendations from the State Emergency

Management Office?

Research has shown that there is sufficient information available to indicate a

significant risk that the dam at Lake Ray Roberts could experience a catastrophic failure.

The lake covers an area of 46 square mile and has a normal capacity of 799,600 acre feet.

(NCTCOG, 2007) According to the DCLMS, the dam at Lake Ray Roberts is an earthen

dam with a rock/soil foundation. The dam was constructed in 1986 and required

modification in 1990. (NCTCOG, 2007) The dam is unlikely to experience a catastrophic

failure unless it is acted upon by some outside force.


According to the DCLMS, there is an inactive geological fault line located in the

vicinity of the lake itself. The last know seismic activity of the fault was in September of

1985. (NCTCOG, 2007) The US Geological Survey estimates the chances of the North

Texas area experiencing an earthquake in the next fifty years is around five percent.

(Appendix B) The document states that the most likely cause of any future seismic

activity would be from earthquakes originating in Oklahoma, Tennessee or Missouri.

There is the possibility of seismic activity resulting from oil and gas production in the

area. (NCTCOG, 2007) According to a heat flow study conducted at the Southern

Methodist University, there are several fault lines and a tectonic boundary line located in

the North Texas area. (Appendix A)

Recent gas well drilling in the Barnett Shale is believed to be the cause of several

minor earthquakes in the North Central Texas area. (NBCDFW, 2008) As recently as

November 2008, minor seismic activity has occurred in the North Central Texas region.

Some citizens group think the tremors were the after effects of extensive drilling

operations in the North Central Texas area after natural gas deposits were discovered in

the Barnett Shale. (FN, 2008) The possibility exists for an earthquake, caused by gas well

drilling operations, to trigger an earthquake in the inactive geological fault located in the

area of the Ray Roberts. Such an earthquake could result in the catastrophic failure of the

dam. (TCEQ, 2008)

Should such an event occur, the resources of the DFD would quickly be

overwhelmed. With no particular plan in place for such an event, the only option would

be to contact the Denton County Emergency Manager and activate the Denton County

Task Force. Their resources would also be overwhelmed. Most of the cities who


participate in the DCTF are located to the south and east of the city of Denton. The

communities located to the east would be unable to reach Denton due to the loss of Hwy

380, Hwy 455, the Lake Lewisville Toll Bridge and Hwy 121. Those cities to the south of

Denton would likely be dealing with their own high water issues and be unable to spare

additional resources.

While no evidence of an industry standard was found, a significant amount

of information was found concerning the importance of having a plan. Information was

found, which provided guidance for developing a comprehensive plan. Local

governments have the primary responsibility for flood plain management. (TCEQ, 2006)

According to the City of Denton Emergency Manager, there is no emergency action plan

addressing the failure of the Lake Ray Roberts dam. (M. Penaluna, personal

communication, May 25, 2010) The city does have a plan in place that addresses the

possibility of a 500 year flood. This plan is part of the Denton County Local Mitigation

Strategy (DCLMS), published by the North Texas Council of Governments. The

DCLMS addresses the possibility of a 500 year flood event, a failure of the dam would far

exceed that amount of water Texas. (NCTCOG, 2007)

According to the Denton County Emergency Manager, there is no emergency

action plan in place at the county level which addresses a dam failure. He referred to the

DCLMS, which only addresses the possibility of a 500 year flood. (J. Gonzales, personal

communication on May 28, 2010)

The State of Texas Office of Emergency Management, which is a division of the

Department of Public Safety, does not have specific guidelines for the development of an

action plan addressing a dam failure. They do publish an all hazard response plan. The


plan breaks down who is responsible for individual functions. It lists these functions,

what state agency has primary and support responsibilities. The plan also lists

corresponding federal agencies. (TDPS, 2009)

The National Flood Insurance Program (NFIP) is a nation-wide effort to help

states, local communities, and individuals with the tremendous responsibility of

protecting the public in the event of a devastating flood. (TCEQ, 2006) The NFIP is

based on an agreement between the local jurisdiction and the federal government.

(TCEQ, 2006) NFIP regulations in Section 59.22 (b)(1) require the local jurisdiction to

designate an official who has the responsibility, authority to enforce, and the means to

implement ordinances to manage the flood plain inside the jurisdiction. (TCEQ, 2006)

The Texas Commission on Environmental Quality (TCEQ) is the State agency

charged with coordinating with the NFIP. (TCEQ, 2006) The TCEQ publishes a

document titled Guide To Developing Emergency Action Plans For Dam in Texas. This

publication is published as a guide for dam owners and operators for determining if their

dam meets the federal requirements to have a emergency action plan (EAP) on file with

the TCEQ and how to put a plan together. According to the Texas Administration Code

(30 TAC 299.61), owners of high risk or significant risk dams must submit an EAP to the

TCEQ. (TCEQ, 2009)

The TCEQ recommends that an EAP contain the following components: contents,

title page, statement of purpose, description, notification flowchart, emergency detection,

evacuation, and classification, responsibilities, preparedness, inundation maps, and

implementation plan. (TCEQ, 2008) In addition, the TCEQ requires the owner/operator

of a high risk or significant risk dam to review the EAP annually, or when any


downstream development is done. This is required to ensure contacts are current and

procedures are up to date. Copies of the EAP are to be provided to the local emergency

managers. Dam owners are required to conduct a tabletop exercise of the EAP with all at

least every five years. (TCEQ, 2008)

Latrobe City, California has published a document titled, “Flood Response

Guidelines”. (LC, 2009) The document outlines the steps that private citizens can take to

ensure their own safety, in the event of a flood. It details the early warning and flood

monitoring system that the community has put in place. It also states who in local and

county government is responsible for what functions during the flood event. (LC, 2009)

The document and the plan are well thought out and very comprehensive. This plan could

easily be adapted to develop an effective plan for the COD.

Personal Interviews

A personal interview was conducted with the Emergency Manager for the DFD.

There is no official plan in place to address the issue of a failure of the Lake Ray Roberts

dam. (M. Penaluna, personal communication on May 25, 2010) He provided a copy of the

Denton County Local Mitigation Strategy (DCLMS) and said, “that was all that was

currently available“. (M. Penaluna, personal communication, May 25, 2010) This

document was a multi-hazard response guideline published by the North Texas Council

of Governments containing information gathered from the participating municipalities in

Denton County. While this document addresses 100 year and 500 year flooding events, it

does not address the failure of the dam at Lake Ray Roberts. (NCTCOG, 2007)

Mr. Penaluna suggested that the Denton County Emergency Manager might

possibly have such a plan, since such an incident would involve numerous communities


in the area. Mr. Penaluna also provided information concerning the Code Red early

warning system, currently in place in the COD. This system is capable of notify up to

1000 resident per minute. The system has the capability to be pre-programmed to target

specific groups or specific geographical locations. (M. Penaluna, personal

communication, May 25, 2010)

Mr. Penaluna suggested contacting the USACE. He felt that since they are

required to maintain inundation studies, that they might have a response plan. (M.

Penaluna, personal communication May 25, 2010) This was good information, but proved

to be another dead end. While the USACE does have inundation studies, an emergency

action plan, and a early warning system in place, I was not able to publish the information

in this paper. Any government agency is allowed access to the information through

written or email request. However, before being allowed to access the information the

applicant must agree to a non-disclosure agreement, required by the US Department of

Homeland Security. The security regulations even specify that the information, once

accessed by a local government entity, is not subject to Freedom of Information Act

requests. (National Dam Inventory, personal communication on June 2, 2010)

Information provided by the USACE could be used by any local government agency to

develop an Incident Action Plan, but they would not be allowed to publish any of the

information obtained from the USACE.

The Denton County Emergency Manager advised there was no response plan in

place at the county level. (J. Gonzales, personal communication on May 28, 2010) He

referred to the DCLMS, discussed earlier. He also suggested contacting the USACE.

The Denton County Task Force leader was contacted. While the task force is set


up to be a all hazard task force, there is no plan in place for a dam failure. While there is a

county-wide resource list available, it does not have any private sector resources included.

(D. Brown, personal communication on June 2, 2010)

Telephone Survey

The telephone survey was conducted to specifically answer the following

question: What components have other Denton County fire departments included in their

flood response programs? (Appendix C) Of the four fire departments contacted, none had

a response plan in place. Two of the four suggested checking the DCLMS, discussed

earlier.

Discussion

Research has shown that there is sufficient evidence to suggest a real threat from a

total failure of the dam at Lake Ray Roberts. The dam is listed in the DCLMS as a high

hazard dam. (NCTCOG, 2007) That fact alone indicates the need for an emergency action

plan. Add to that, it is an earthen structure located near an inactive geological fault line,

and the risk increases. (NCTCOG, 2007) One of the four major causes for dam failure is

seismic activity. (TCEQ, 2008) There was an earthquake associated with that fault line, as

recently as 1985. (NCTCOG, 2007) There are numerous geological fault lines and even

an tectonic boundary line located in the North Texas area. (Appendix A) The USGS says

the risk of an earthquake occurring in the North Texas area in the next 50 years is around

five percent. (USGS, 2008) With the recent occurrence of minor earthquakes due to gas

well drilling operations in the Barnett Shale, the possibility of a larger earthquake

occurring increases. (NBCDFW, 2008) That increases the chances that an earthquake

could occur that is severe enough to cause a failure of the dam at Lake Ray Roberts.


EAFSOEM curriculum suggests that plans need to be in place before a major

event occurs. Procedures should be in place to ensure that the appropriate entitles are

notified and activated. Resource lists should been developed to ensure that resources are

available when the incident occurs. When necessary, contracts and written agreements

should be in place with the private sector for the use of specialized equipment.

There is no plan in place by the DFD, in case the dam at Lake Ray Roberts should

fail. (M. Penaluna, personal communication on May 25, 2010) There is no plan in place at

the county level. (J. Gonzales, personal communication on May 28, 2010) In addition,

none of the Denton county communities located downstream from the dam, have plans in

place. (Appendix C)

The DCAHTF leader has developed a all-hazards resource list. These resources

are not specific to any particular emergency. It is comprised of whatever equipment and

personnel each community would be able to spare on any given day. (D. Brown, personal

communication on June 1, 2010) However, in an event such as a dam failure, those

resources would be unable to reach Denton, due to loss of roadways. The personnel and

equipment that would be available would be drastically reduced, due to flooding

problems in surrounding communities. They would likely be dealing with the same

conditions in their own communities. There are no private sector resources identified and

no contracts or agreements in place. (D. Brown personal communication on June 1, 2010)

This would leave the DFD with little hope of receiving reinforcements.

Latrobe City, California publishes a flood response guide for the use of it’s

citizens. In their plan, they discuss actions to be taken by individuals as well as the

government entities. (LC, 2009) They list evacuation routes and detail their early


warning system. Their plan details the various functions that would need to be addressed

and which government entity would be responsible. (LC, 2009)

The USACE has an EAP on their website that is written specifically for the Lake

Ray Roberts dam, complete with an inundation study, contact flowchart and outlining

their early warning system. While the USACE information cannot be published, due to

homeland security issues, parts of it could be used to develop a plan without violating the

non-disclosure agreement.

Having established that a credible risk exists, the DFD needs to develop a dam

failure response plan. Between the information found in the Latrobe flood response plan

and the information contained in the USACE emergency action plan, the DFD should be

able to compile a comprehensive plan that addresses all the pertinent points.

One of the operational objectives listed in the DFD five-year strategic plan is to

provide effective and efficient emergency services. This can only be accomplished by

being prepared for any event, including the possible failure of the dam at Lake Ray

Roberts. Utilizing the information found during the course of this research would allow

the DFD to develop a plan that could be used as a model for communities located in

Denton County.

Recommendations

While the likelihood of a total failure of the dam at Lake Ray Roberts is unlikely,

there is sufficient evidence to support the possibility that such an event could occur. By

recognizing this fact, the DFD would have already taken the first step toward developing a

response plan. The following is a list of recommendations to develop a comprehensive

and effective response plan should such an event occur.


The first recommendation is to contact the USACE and obtain all the information

they have on file, including inundation studies, early warning plan, and emergency action

plans. While this information cannot be published, it can be used as a model to help

develop a plan for the DFD.

Second, inundation studies should be used to develop an early warning group in

the Code Red early warning system currently used by the DFD. The Code Red system is

already in place and it shouldn’t require much effort to set up a target group based on the

geographical locations and their relation to the areas likely to be inundated.

Third, based on the information from the inundation study, evacuation routes

should be identified and that information provided to the community.

Fourth, the DFD should develop a resource list comprised of public and private

sector entities. Where needed, agreements that will ensure that resources are available,

should be negotiated and signed, prior to such an event.

Fifth, all of these items should be incorporated in an emergency action plan that

spells out what actions private citizens need to take, what agency is responsible for what

function, resource lists, contact information, and procedural guidelines.

Lastly, coordinate with the USACE to set up a tabletop exercise based on their

EAP. If possible, a full scale disaster drill should be scheduled incorporating all the

entities likely to be involved in such an incident.

One of the ten operational objectives in the DFD Five Year Strategic Plan is to

“provide effective and efficient emergency services“. By initiating these

recommendations the DFD can put together an emergency response plan that will ensure

the best possible outcome to such a devastating event. Doing so also accomplishes one of


the operational objectives of the US Fire Administration; to have 2500 communities will

have a comprehensive multi-hazard risk reduction plan lead by or including the local fire

service. This one plan does not complete that objective, but it is a step in the right

direction.


References

Federal Emergency Management Administration. (2008). What to Do Before a Dam

Failure. Retrieved from http://fema.gov/hazard/damfailure/df_before.shtm

Fox News. (October 31, 2008). Several Small Earthquakes Rattle Texas. Retrieved on

June 1, 2010, from http://foxsnews.com/story/0,2933,445567,00.html

Latrobe City. 2009. Flood Response Guidelines for the Community. Retrieved on May 15,

2010, from http://www.Latrobe.vic.gov.au/WebFiles/Emergency%20Info/flood-

response-web.pdf

NBC Dallas-FT. Worth. (November 3, 2008). 3.0 Earthquake Rattles North Texas.

Retrieved on June 16, 2010 from

http://www.nbcdfw.com/news/local-beat/30_Earthquake_Rattles_North_Texas.html

North Central Texas Council of Governments. (2007). Denton County Local Mitigation

Strategy. Arlington, TX.

Negraru, Petru T. and Blackwell, David D., Heat Flow in Texas. (2006). Southern

Methodist University. Dallas, TX

Texas Commission on Environmental Quality, (TCEQ). (2009). Guidelines for

Developing Emergency Action Plans for Dams in Texas. (Dam Safety

Program) Austin, TX.

Texas Commission on Environmental Quality (TCEQ). (2008). Guidelines for Operating

and Maintenance of Dams in Texas. Austin, TX.

http://fema.gov/hazard/damfailure/df_before.shtm�

http://foxsnews.com/story/0,2933,445567,00.html�

http://www.latrobe.vic.gov.au/WebFiles/Emergency%20Info/flood-response-web.pdf�

http://www.latrobe.vic.gov.au/WebFiles/Emergency%20Info/flood-response-web.pdf�

http://www.nbcdfw.com/news/local-beat/30_Earthquake_Rattles_North_Texas.html�


Texas Commission on Environmental Quality (TCEQ). (2006). Texas Guide to Local

Floodplain Management. Austin, TX.

Texas Department of Public Safety. (2009). State of Texas Mitigation Plan. Department

of Emergency Management. Retrieved on May 30, 2010 from

ftp://ftp.tdps.state.tx.us/dem/mitigation/tx_mitigation_plan_2009.pdf

US Geological Survey. (2008). Texas: Seismic Hazard Map. Retrieved on 5/28/2010 from

http://earthquake.usgs.gov/earthquakes/states/texas/hazards.php

ftp://ftp.tdps.state.tx.us/dem/mitigation/tx_mitigation_plan_2009.pdf�

http://earthquake.usgs.gov/earthquakes/states/texas/hazards.php�


Appendix A

Heat Flow In Texas

Denton


Appendix B TEXAS Seismic Hazard Map


Appendix C

AED Program Survey

Department name: __________________________________________________

Size of population served: ____________________________________________

Your name: ________________________________________________________

Does your department or city have an emergency action plan (EAP) prepared in the event of a

failure of the Lake Ray Roberts dam? Y__0__ N__4__

Does your EAP address an early warning system for the public? Y__1__ N__3__

Does your EAP list evacuation routes for the public? Y____ N____ N/A __4___

Does your EAP have a contact list for additional resources? Y____ N____ N/A _4__

How often do they receive training on your plan?

Annually ____ Two years_____ Every 5 years______ N/A __4_

dam failure response plan - hsdl

Documents