Dams and levees are critical infrastructure across Texas. They control flooding, store water for municipal and agricultural use, and support the long-term resilience of communities throughout the state. As of June 2025, TCEQ regulates 7,384 dams in Texas, of which 4,147 are non-exempt. Among those, 1,574 are classified as high-hazard and 295 as significant-hazard, meaning that failure of any one of these structures could result in loss of life or major economic damage downstream.
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The role of a qualified dam engineer has never been more consequential. With Texas continuing to grow and downstream development pushing more dams into higher hazard classifications, proactive engineering is the line between functioning infrastructure and catastrophic failure. For Texas dam owners, that responsibility is also the law.
Texas Emergency Action Plan Requirements
In 2009, the Texas Legislature enacted a law requiring owners of all high-hazard and significant-hazard dams to file an Emergency Action Plan (EAP) with the Texas Commission on Environmental Quality (TCEQ). These plans were mandated to be completed and on file by January 1, 2011.
The requirement has since been strengthened. TCEQ guidelines were revised in December 2019, with updates to notification flowcharts, EAP templates, inundation map guidance, and a new glossary of dam safety terms. EAPs must also be reviewed and updated annually, and dam owners must conduct a tabletop exercise every five years.
Despite the longstanding requirement, TCEQ’s own data as of June 2025 shows a significant gap: of all high-hazard and significant-hazard dams in the state, 402 do not have any EAP on record with the agency. Another 896 have only a draft EAP on file. Only 566 have a complete, reviewed EAP. This compliance gap represents a real and ongoing risk to downstream communities, and it underscores how much demand still exists for qualified dam engineer services.
What Is an Emergency Action Plan for a Dam?
An Emergency Action Plan (EAP) is a formal, documented plan of action that a dam or levee owner must execute in the event of failure or imminent failure. Think of it as the infrastructure equivalent of a fire evacuation plan: it is designed, documented, and distributed well in advance so that when seconds matter, no one is guessing.
For high-hazard dams, a well-developed EAP is a life-safety document. It defines notification chains, identifies downstream populations at risk, and establishes clear decision thresholds for evacuation. TCEQ is explicit on this point: EAPs are not a substitute for proper maintenance, but they do facilitate early recognition of developing problems and establish a means of minimizing loss of life and property damage when a failure is underway.
An EAP prepared by a qualified dam engineer typically includes:
- Hydrologic and hydraulic modeling of the dam and its watershed
- Dam break analysis to determine failure scenarios and timing
- Inundation mapping showing downstream flood extents and affected properties
- Property and population identification within the inundation zone
- Emergency notification and contact charts for owners, local officials, and first responders
- Defined warning and response procedures for various threat levels
For small and intermediate-sized dams with limited downstream development, TCEQ regulations allow use of the Simplified Dam Breach method, which streamlines the modeling process without sacrificing the core protective intent. Most non-exempt Texas dams qualify under this category.
Why EAPs Matter: The Cost of Not Having One
The consequences of dam failure without an EAP in place are severe. Nationally, the FEMA National Dam Safety Program estimates there are approximately 15,600 high-hazard potential dams across the United States, with an average age exceeding 53 years. As infrastructure ages, the risk of failure grows and the need for current, tested EAPs becomes more acute.
In Texas specifically, urban expansion continues to move more dams into higher hazard classifications. When a dam is reclassified from low or significant hazard to high hazard due to new downstream development, an EAP immediately becomes required and the owner may also face mandated structural upgrades. Working with an experienced dam engineer early, before reclassification occurs, reduces both risk and long-term cost.
TCEQ conducted 302 inspections between September 2024 and June 2025 and reviewed 121 EAPs during the same period. Owners found out of compliance face formal enforcement actions, including referral to the Office of the Attorney General. Beyond regulatory penalties, the liability exposure from a dam failure without an adequate EAP on file is substantial.
What Services Does a Dam Engineer Provide?
Beyond EAP development, a dam engineer provides a full spectrum of services covering the structural integrity, regulatory compliance, and long-term performance of dam and levee assets. These include:
- Embankment stability analysis
- Seepage detection and seepage control design
- Spillway capacity evaluation and upgrade design
- Geotechnical investigation and slope stability analysis
- Hydrologic and hydraulic modeling, including 2D and 3D simulations
- Inundation mapping and flood routing
- Dam break and breach analysis
- Rehabilitation design and construction document preparation
- Regulatory permitting support and agency coordination
- Construction phase oversight and quality assurance
Proactive dam engineering is not just about compliance. It is about identifying warning signs early, including seepage, settlement, erosion, or spillway deterioration, and resolving them before they escalate into emergencies. TCEQ inspects high and significant hazard dams on a target cycle of once every five years, but that interval means problems can develop between inspections. An ongoing relationship with a qualified dam engineer provides the continuity that periodic government inspections alone cannot.
O'Brien Engineering Dam Engineers: Texas Experience, Proven Results
O’Brien Engineering’s team brings decades of hands-on experience with Texas dams, including projects for the U.S. Forest Service, the Texas Army National Guard, and municipal clients across the state. Our team uses GIS specialty software to accelerate hydraulic model preparation and inundation mapping, reducing turnaround time without compromising technical accuracy.
Recent O’Brien Engineering dam engineering projects include:
- Ratcliff Lake Dam (TX): Rehabilitation of a historic dam originally built in the 1800s in the Davy Crockett National Forest, following significant spillway damage from heavy rainfall. O’Brien Engineering delivered full feasibility analysis, hydrologic and hydraulic modeling, geotechnical analysis, civil design, and TCEQ permitting coordination.
- Camp Maxey Dam Rehabilitations (TX): Three dam rehabilitations for the Texas Army National Guard facility, following TCEQ inspections citing structural and environmental deficiencies.
- Lake Forest Park Dam (TX): Full rehabilitation design addressing slope instability, seepage, erosion, and lake siltation for the City of Denton.
- Sherando Lake Dams (VA): Rehabilitation of Upper and Lower Sherando Lake Dams, both classified High Hazard, including spillway repairs, riprap installation, embankment restoration, and inundation mapping.
Whether your dam requires a new EAP, an updated breach analysis, or a full rehabilitation design, O’Brien Engineering has the technical depth and regulatory knowledge to move your project forward efficiently.
Learn more about O’Brien Engineering’s Dam and Levee Safety services, or explore our full Water Resources capabilities to see how we support communities and agencies across Texas and beyond.
Frequently Asked Questions: EAPs and the Role of a Dam Engineer
What is a dam engineer?
A dam engineer is a licensed civil or geotechnical engineer with specialized expertise in the design, inspection, analysis, and rehabilitation of dams, levees, and related water control structures. In Texas, dam engineering work associated with regulatory submissions requires a licensed Professional Engineer (PE).
Who is required to file an EAP in Texas?
Texas law requires owners of all high-hazard and significant-hazard non-exempt dams to file an EAP with TCEQ. High-hazard dams are those where failure could result in loss of life, defined as three or more habitable structures in the breach inundation area. Significant-hazard dams are those where failure could cause appreciable economic loss or affect one to two habitable structures.
How many Texas dams currently lack a complete EAP on file?
As of June 2025, TCEQ data shows that 402 high-hazard and significant-hazard dams in Texas have no EAP on record, and an additional 896 have only a draft EAP. Only 566 have a complete, reviewed EAP on file. This represents a substantial compliance gap and ongoing liability risk for affected dam owners.
How often must a dam EAP be updated?
Under current TCEQ requirements, dam owners must review and update their EAP annually. Additionally, owners must conduct a tabletop exercise, simulating the EAP’s notification and response procedures, at least once every five years.
What happens if a dam owner does not have an EAP on file?
Failure to maintain a current, filed EAP puts the owner out of compliance with Texas state law and TCEQ regulations, creating significant liability exposure. TCEQ has referred non-compliant dam owners to the Office of the Attorney General for enforcement. In the event of a dam failure, the absence of an EAP substantially increases legal and financial risk for the owner.
Does O'Brien Engineering provide EAP services for both new and existing dams?
Yes. O’Brien Engineering develops original EAPs for dam owners who do not yet have a compliant plan on file, and also provides updates to existing EAPs when dam conditions, downstream land use, regulatory requirements, or TCEQ guidelines have changed.