In mid-2004, Aspen Environmental Group engaged EDM Services to perform a number of audits for the California Energy Commission (CEC) Delegate Chief Building Officials (DCBO) performing plan reviews and inspections for a number of power plants being constructed throughout the State. The intent of this effort was to insure that the actions of their delegates were acting in a manner which was:
- Consistent with the expectations of the CEC and the Conditions of Certification for each power plant,
- Resulting in compliance with the California Building Codes and other applicable laws, regulations and standards, and
- Fair and consistent regarding the interpretations of the codes and industry standards.
This consistency would provide an added benefit to any power plant developer within the State, since they would know and understand the plan review and construction inspection process and expectations of the CEC. Over the past twelve months, EDM Services has completed 10 audits of DCBO operations at 10 different power plant projects. These plants have ranged in size from 520 to 1,200 megawatts. These power plants included:
- Pico Power Plant Project,
- Malburg Generating Station Project,
- TID Walnut Energy Center Project,
- Metcalf Energy Center Project,
- Palomar Power Plant Project,
- Mountainview Power Plant Project,
- SMUD – Consumnes Power Plant Project,
- Magnolia Power Plant Project,
- Inland Empire Energy Center Project, and
- Roseville Power Plant Project.
Once the audits were fully underway, it became evident that not all DCBO operations dealt consistently on many subjects. Inconsistencies were found in a variety of the assigned DCBO duties, from administrative issues to code interpretations. EDM Services, Inc. was subsequently asked to help insure that all DCBO’s executed their duties in consistent manor. In some cases, the firm mediated disputes between applicants and other project representatives. The firm also authored Guidance Documents to address a number of issues where problems had arisen. Some of this issues included:
- Pre-Fabricated Assemblies (PFA’s),
- Professional Engineer (PE) Stamping Requirements,
- Use of Recommended Practices,
- Use and applicability of California Plumbing Code/California Mechanical Code versus ASME Piping Codes (ASME B31.1, B31.3, B31.8),
- Limits and Application of the Process Piping Codes (ASME B31.8, 31.1, 31.3) and Delegate CBO Review,
- Process Piping Hydrostatic Testing,
- Consistent Oversight of Piping Systems – Design and Construction,
- Labeling and Listing – Material Approvals versus Inspection for Compliance,
- Construction Oversight – Means and Methods versus Code Compliance,
- Plant Start-Up Responsibilities of the Delegate CBO,
- Fire Suppression California Fire Code Compliance – Special Equipment Protection,
- PE Requirements for Plan Reviewers and Delegate CBO,
- Approval of Structural Steel Fabricators,
- CBO limits of Responsibilities (Plan Reviewer versus Project Engineer),
- Chemical Spacing and Setbacks,
- Safety Responsibilities,
- CBO and Local Fire Marshal Interaction,
- ADA versus OSHA Requirements for Handrails/Platforms,
- Consistent Application of Importance Factors for Seismic Design, etc.
We anticipate renewed power plant design and construction activity in California over the next few years. We look forward to continuing our role and being a part of California’s energy solution.