20030180 Ver 5_Other Agency Comments_20080908

North Carolina Wildlife Resources Commission 9
Gordon S. Myers, Executive Director
September 5, 2008
Via Email
Mr. John Dorney
North Carolina Division of Water Quality
2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604
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Subject: 401 Water Quality Certifications
Franklin Hydroelectric Project - FERC No. 2603; DWQ #2003-0180 v.
Mission Hydroelectric Project - FERC No. 2619; DWQ #2003-0181 v.
Bryson Hydroelectric Project - FERC No. 2601; DWQ #2004-1101 v. 4
Dear Mr. Dorney:
This correspondence is in reference to the August 8, 2008 public notices by the North Carolina
Division of Water Quality requesting public comment on the water quality certifications for the
relicensing of the referenced hydroelectric projects by owned by Duke Energy Carolinas LLC.
The North Carolina Wildlife Resources Commission is concerned about the operation of these
projects and their potential adverse effects to the aquatic resources of the State, including
federally and state listed aquatic species. In the vicinity of the Franklin project, these species
include Appalachian Elktoe, Littlewing Pearlymussel, Rainbow, Slippershell, Tennessee Pigtoe,
Wavyrayed Lampmussel, Spotfin Chub, Sicklefin Redhorse, Olive Darter, and Wounded Darter.
The Mission project may affect Rainbow, Spike, Tennessee Clubshell, Tennessee Pigtoe,
Wavyrayed Lampmussel, Hellbender, Sicklefin Redhorse and Banded Sculpin. Near the Bryson
project, listed species include Appalachian Elktoe, Sicklefin Redhorse, Olive Darter, and
Wounded Darter.
The North Carolina Wildlife Resources Commission recommends the following as conditions of
the 401 Water Quality Certification for the three referenced projects to protect the aquatic
resources and habitats of the State. These conditions are designed to ensure that adequate water
is maintained downstream of these projects at all times and that sediment and other materials
discharged from the projects do not degrade water quality in downstream reaches.
Mailing Address: 645 Fish Hatchery Road • Marion, NC 27652
Telephone: [phone] • Fax: [phone]
Duke Hydro 401 Certifications Page 2 September 5, 2008
Franklin
The Licensee shall operate the project in a run-of-river mode of operation. "Run-of-river"
operation is defined as instantaneous inflow upstream of the dam coming into the project
reservoir is equal to instantaneous outflow downstream of the dam. This is necessary to
protect downstream flows and the uses of those flows such as aquatic habitat, water quality,
recreation, and aesthetics.
2. The impoundment level in Franklin Reservoir (Lake Emory) shall be maintained within 0.1-
foot of the full pool elevation (2000.2 feet MSL) at least 99.5% of the time with an allowance
variable to be within 0.3-foot of full pond less than 0.5% of the time on an annual basis. The
specifics of the 0.5% variance allowance criteria for the 0.3-foot water level will be
developed for the project in the Lake Level and Flow Monitoring Plan (LLFMP).
Maintenance of these reservoir water levels will reduce impacts to run-of-river operation
should the project go off line and downstream flows through the generators stop abruptly.
With a near full pond, spill would occur more quickly over the crest and re-establish run-of-
river flows downstream. A stable reservoir water level also provides benefits to aquatic
resources in the reservoir. Exceptions to this condition will be permitted according to
condition #5 below.
The Licensee shall develop a LLFMP for the project in consultation with the N.C. Division
of Water Resources (NCDWR), the North Carolina Wildlife Resources Commission
(NCWRC), and the U.S. Fish and Wildlife Service (USFWS) and submit it to the NC
Division of Water Quality (NCDWQ) for approval. The LLFMP will provide the details of
notification, compliance monitoring and documentation of run-of-river operations (inflow ad
outflow) and reservoir levels requirements, as well as annual reporting requirements.
4. If required by the LLFMP, the Licensee shall install and maintain a USGS gage on the Little
Tennessee River near Iotla to document compliance with run-of-river operation. The
existing USGS gage at Needmore is located too far downstream of the project to be useful for
compliance monitoring.
During periods when the reservoir level is lowered for scheduled maintenance or due to
unforeseen circumstances, the September median flow of 309 cfs will be released from the
project to provide adequate downstream flows from the project during reservoir refill
periods. The Licensee will notify NCDWR, NCWRC, NCDWQ and USFWS at least 60
days before any planned drawdown or within 10 days after an operating emergency event
starts. The Licensee will consult with NCDWR, NCWRC, NCDWQ and USFWS if
operational circumstances preclude the release of the September median flow during
reservoir refill periods.
6. If the Licensee finds that maintaining a downstream flow of 309 cfs during refill periods is
difficult, the Licensee may initiate a study to determine an alternate downstream flow regime
to be used during these periods. The Licensee shall prepare a study plan in consultation with
NCDWR, NCWRC and USFWS to be approved by NCDWQ prior to study initiation. After
completion of the study, the Licensee may develop an alternate downstream flow regime for
refill periods with consensus of the NCDWR, NCWRC, NCDWQ and USFWS.
Duke Hydro 401 Certifications Page 3 September 5, 2008
7. The Licensee shall develop a long-term sediment management plan for the project in
consultation with NCDWR, NCWRC and USFWS and submit it to NCDWQ for approval.
The sediment management plan shall provide details of trashrack maintenance, debris
management and removal, sediment management and removal and agency notification.
Mission
The Licensee shall operate the project in a run-of-river mode of operation. "Run-of-river"
operation is defined as instantaneous inflow upstream of the dam coming into the project
reservoir is equal to instantaneous outflow downstream of the dam. This is necessary to
protect downstream flows and the uses of those flows such as aquatic habitat, water quality,
recreation, and aesthetics.
2. The impoundment level in Mission Reservoir shall be maintained within 0.1-foot of the full
pool elevation (1,658.17 feet MSL) at least 99.5% of the time with an allowance variable to
be within 0.3-foot of full pond less than 0.5% of the time on an annual basis. The specifics
of the 0.5% variance allowance criteria for the 0.3-foot water level will be developed for the
project in the Lake Level and Flow Monitoring Plan (LLFMP). Maintenance of these
reservoir water levels will reduce impacts to run-of-river operation should the project go off
line and downstream flows through the generators stop abruptly. With a near full pond, spill
would occur more quickly over the crest and re-establish run-of-river flows downstream. A
stable reservoir water level also provides benefits to aquatic resources in the reservoir.
Exceptions to this condition will be permitted according to condition 95 below.
The Licensee shall develop a LLFMP for the project in consultation with the N.C. Division
of Water Resources (NCDWR), the North Carolina Wildlife Resources Commission
(NCWRC), and the U. S. Fish and Wildlife Service (USFWS) and submit it to the NC
Division of Water Quality (NCDWQ) for approval. The LLFMP will provide the details of
notification, compliance monitoring and documentation of run-of-river operations (inflow ad
outflow) and reservoir levels requirements, as well as annual reporting requirements.
4. If required by the LLFMP, the Licensee shall install and maintain a USGS gage on the
Mwassee River near Murphy to document compliance with run-of-river operation.
During periods when the reservoir level is lowered for scheduled maintenance or due to
unforeseen circumstances, the September median flow of 341 cfs will be released from the
project to provide adequate downstream flows from the project during reservoir refill
periods. The Licensee will notify NCDWR, NCWRC, NCDWQ and USFWS at least 60
days before any planned drawdown or within 10 days after an operating emergency event
starts. The Licensee will consult with NCDWR, NCWRC, NCDWQ and USFWS if
operational circumstances preclude the release of the September median flow during
reservoir refill periods.
6. If the Licensee finds that maintaining a downstream flow of 341 cfs during refill periods is
difficult, the Licensee may initiate a study to determine an alternate downstream flow regime
to be used during these periods. The Licensee shall prepare a study plan in consultation with
NCDWR, NCWRC and USFWS to be approved by NCDWQ prior to study initiation. After
Duke Hydro 401 Certifications Page 4 September 5, 2008
completion of the study, the Licensee may develop an alternate downstream flow regime for
refill periods with consensus of the NCDWR, NCWRC, NCDWQ and USFWS.
7. The Licensee shall develop a long-term sediment management plan for the project in
consultation with NCDWR, NCWRC and USFWS and submit it to NCDWQ for approval.
The sediment management plan shall provide details of trashrack maintenance, debris
management and removal, sediment management and removal and agency notification.
Bryson
The Licensee shall operate the project in a run-of-river mode of operation. "Run-of-river"
operation is defined as instantaneous inflow upstream of the dam coming into the project
reservoir is equal to instantaneous outflow downstream of the dam. This is necessary to
protect downstream flows and the uses of those flows such as aquatic habitat, water quality,
recreation, and aesthetics.
2. The impoundment level in Bryson Reservoir (Lake Ela) shall be maintained within 0.1-foot
of the full pool elevation (1,828.41 feet MSL) at least 99.5% of the time with an allowance
variable to be within 0.3-foot of full pond less than 0.5% of the time on an annual basis. The
specifics of the 0.5% variance allowance criteria for the 0.3-foot water level will be
developed for the project in the Lake Level and Flow Monitoring Plan (LLFMP).
Maintenance of these reservoir water levels will reduce impacts to run-of-river operation
should the project go off line and downstream flows through the generators stop abruptly.
With a near full pond, spill would occur more quickly over the crest and re-establish run-of-
river flows downstream. A stable reservoir water level also provides benefits to aquatic
resources in the reservoir. Exceptions to this condition will be permitted according to
condition #5 below.
3. The Licensee shall develop a LLFMP for the project in consultation with the N.C. Division
of Water Resources (NCDWR), the North Carolina Wildlife Resources Commission
(NCWRC), and the U.S. Fish and Wildlife Service (USFWS) and submit it to the NC
Division of Water Quality (NCDWQ) for approval. The LLFMP will provide the details of
notification, compliance monitoring and documentation of run-of-river operations (inflow ad
outflow) and reservoir levels requirements, as well as annual reporting requirements.
4. If required by the LLFMP, the Licensee shall maintain the USGS gage on the Oconaluftee
River near Birdtown to document compliance with run-of-river operation.
During periods when the reservoir level is lowered for scheduled maintenance or due to
unforeseen circumstances, the September median flow of 204 cfs will be released from the
project to provide adequate downstream flows from the project duri ng reservoir refill
periods. The Licensee will notify NCDWR, NCWRC, NCDWQ and USFWS at least 60
days before any planned drawdown or within 10 days after an operating emergency event
starts. The Licensee will consult with NCDWR, NCWRC, NCDWQ and USFWS if
operational circumstances preclude the release of the September median flow during
reservoir refill periods.
Duke Hydro 401 Certifications Page 5
September 5, 2008
6. If the Licensee finds that maintaining a downstream flow of 204 cfs during refill periods is
difficult, the Licensee may initiate a study to determine an alternate downstream flow regime
to be used during these periods. The Licensee shall prepare a study plan in consultation with
NCDWR, NCWRC and USFWS to be approved by NCDWQ prior to study initiation. After
completion of the study, the Licensee may develop an alternate downstream flow regime for
refill periods with consensus of the NCDWR, NCWRC, NCDWQ and USFWS.
7. The Licensee shall develop a long-term sediment management plan for the project in
consultation with NCDWR, NCWRC and USFWS and submit it to NCDWQ for approval.
The sediment management plan shall provide details of trashrack maintenance, debris
management and removal, sediment management and removal and agency notification.
If you have any questions concerning these comments, please call me at 828-652-4360 ext. 223.
Sincerely,
Christopher Goudreau
Hydropower Licensing Coordinator
copy via email: Steve Reed, NCDWR
Mark Cantrell, USFWS
Steve Johnson, Duke Power