20030180 Ver 7_More Info Received_20100720 (2)

Run-of-River(ROR) Projects:
Bryson (FERC P-2601; WQC #3827)
Franklin(FERC P-2603; WQC #3828)
Mission (FERC P-2619; WQC #3826)
The legal name for the project licensee is Duke Energy Carolinas, LLC. All references to
the project licensee and the holder of the applicable WQC should be Duke Energy
Carolinas, LLC rather than Duke Energy Carolinas, Inc.
Duke requests that you make these changes where appropriate in the reissued WQCs.
Conditions 3, 5 and 7 of WQCs for Bryson (#3827) and Franklin (#3828):
• These conditions in the WQCs for the Bryson and Franklin Projects contain references to
the Mission Project that should have been Bryson and Franklin, respectively.
Duke requests that you make this change for Conditions 3, 5, and 7 of the reissued
WQCs for the Bryson and Franklin Projects.
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Condition 6 of WQCs for Mission (#3826),Bryson (#3827) and Franklin (#3828):
• Because Addendum 3 (submitted to NCDWQ on 5/27/2010) supersedes Addendum 2
(submitted to NCDWQ on 5/26/2010) in its entirety, Addendum 2 does not need to be
incorporated by reference into the respective WQCs.
Please remove the reference to Addendum 2 from Condition 6 of all 3 WQCs.
• While Addendum 3 addresses sediment management, it does not mention a"Short-term
Sediment Management Plan" as Condition 6 does. It appears that the reference to the
Short-term Sediment Management Plan in Condition 6 should be changed to the gyp%
Sediment Removal Pilot Study described in Addendum 3.
Please change all references to the "Short-term Sediment Management Plan" refer to 9,,o
the "Sediment Removal Pilot Study."
• It is our understanding that the last sentence in this Condition 6 does not mandate a
revision to Addendum 3, but rather it simply requires that if, after additional consultation
with the specified agencies and Duke, that a revision to Addendum 3 is needed, then at S
that point, Duke would need to file a revised Addendum 3 with NCDWQ for approval.
Duke requests that you clarify this statement as part of Condition 6 of the reissued
WQCs.
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Condition 7 of WQCs for Mission 03826), Bryson (#3827) and Franklin (#3828):
• We believe that requirements to consult with the identified agencies and develop and file
the Lake Level and Flow Management Plans (Addendum 1), Sediment Study Plan
(Addendum 3), the process described for developing a Long-Term Sediment

Management Plan for all three ROR Projects and processes for communication and
consultation during emergencies and routine maintenance (Nantahala Area Run-of-River
Projects Maintenance and Emergency Protocol) have already been met according to what
is described in the first part of Condition 7. It is confusing to list this as a requirement
when it has already been done.
Please clarify Condition 7 to indicate that the Lake Level and Flow Management Plan
has been completed.
• Duke understands that the Lake Level and Flow Management Plans (LLFMP) have been
incorporated into the WQC's for the ROR Projects by reference to Addendum 1 as stated
in Condition 6. Since the LUMP was developed in consultation with resource agencies
and incorporated into the WQC by reference no additional approvals by DWQ are
required.
Please remove this requirement from Condition 7 in the reissued WQC.
• The Long-Term Sediment Management Plan, as described in the Sediment Study Plan,
will not be developed until after the Sediment Removal Pilot Study has been completed
and recommendations formulated for the Long-Term Sediment Management Plan.
Please indicate in Condition 7 that the Long-Term Sediment Management Plan will not be A�A—'
developed unit after the Sediment Removal Pilot Study has been completed and approved.
• Condition 7 requires NCDWQ notification in writing within 24 hours if there are
deviations in flows or lake levels as described in the Lake Level and Flow Management
Plans (Addendum 1) for these Projects. However this requirement is inconsistent with
the Nantahala Area Run-of-River Projects Maintenance and Emergency Protocol (MEP)
(Addendum 1) and incorporated by reference into the WQCs as Condition 8 for these
Projects. The MEP identifies situation-specific notification requirements for Duke to
contact NCDWQ as well as other entities.
In order to maintain consistency with the MEP please remove the 24-hour notification
requirement from Condition 7. /
Condition 9 of WQCs for Mission 03826), Bryson 03827) and Franklin (93828):
• These Projects have a small number of pre-existing structures that provide private access.
Duke's understanding is that these private access structures will continue to be allowed
under the Land Management Plan and Shoreline Management Guidelines.
Please acknowledge that pre-existing structures that Licensee approves can remain in
place.
Condition 10 of WQCs for Mission 03826), Bryson 03827) and Franklin 03828):
• Attached is documentation that Duke has paid the cost of public notice advertisements in
local newspapers.

Duke's understanding is that based on your letter of June 24, 2010 to Steve Jester, Vice
President Hydro Strategy, Licensing, and Lake Services, Condition 10 has been satisfied. v
Please do not include this condition in the reissued WQC.
Certificates of Completion for Mission 03826),Bryson 03827) and Franklin (#3828):
Since the WQC for these Projects involves implementation of plans for managing various
aspects of ongoing Project operation, a certificate of completion would not seem to be
applicable to these Projects.
Duke requests that no requirement for a Certificate of Completion be included in the
reissued WQCs for these Projects.