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HomeMy WebLinkAbout20080915 Ver 3_Response to NCDWR WQC Amendment Application_20161027& DUKE ENERGY October 27, 2016 Ms. Karen Higgins 401 & Buffer Permitting Branch Supervisor Division of Water Resources Department of Environmental Quality 512 N. Salisbury Street, Suite 942-E Raleigh, NC 27604 Re: Amendment of Water Quality Certification No. 3767 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project 2232 Request for Additional Information Dear Ms. Higgins: Water Strategy, Hydro Licensing, and Lake Services Duke Energy 526 S. Church Street/ EC12Y Charlotte, NC 28202 Duke Energy Carolinas, LLC ("Duke Energy"), licensee for the Catawba-Wateree Hydroelectric Project ("Project"), has received the NC Division of Water Resources' ("NCDWR") Request for Additional Information ("RAI") dated October 24, 2016 regarding the subject Water Quality Certification ("WQC") amendment application filed by Duke Energy on September 9, 2016. Duke Energy responds to the six requested items as follows: Duke Energy will incorporate the typographical corrections and other edits described in RAI items 2., 4., 5., and 6. as well as any changes agreed to below into a revised application and resend to NCDWR via electronic delivery. RAI item 1. states on application page numbers 5 through 7 the present and proposed pool elevations throughout the year are misleading in that most of October the elevation is at a different level than is communicated by the tables and the tables should include specific dates that the elevations are in effect. Duke Energy Response Duke Energy discussed this item with NCDWR staff on October 25, 2016. On application page number 5 paragraph (A) Reservoir Elevations contains the necessary information to interpret the reservoir elevation charts that follow. Specifically, the last sentence of this paragraph states: "The elevations included in the tables are for the first day of the given month; elevations for other days of the month are determined by linear interpolation." NCDWR staff agreed this information is sufficient to interpret the reservoir IIs. Karen Higyins Page 2 October 27, 2016 elevation charts but requested the last sentence of parayraph (A) be highlighted by bold font to make it more noticeable. Duke Energy ayrees to this change_ RAI item 3. requests an explanation of measures to minimize risk of vandalism to water quality monitors and what procedures will be implemented it data is lost. Dukefrrergy Response These monitors will not be intentionally located in risk -prone areas, but vandalism is a common risk regardless of locatiun_ Locating monitoring equipment on Duke Energy property provides additional security due to restricted access and security camera coverage. However, to assure representative data is collected, some monitors will be located either on a highway or rail bridge, or from a shore location further downstream of the hydro development, where public access cannot be controlled. Duke Energy is taking advantage of the U5 Geological Survey's (USGS) expertise in locating and designing munitur stations to reduce vandalism risks. USGS water quality monitoring sites generally employ the following standard approaches in an attempt to discourage vandalism: 1) control center cabinets are of heavy aluminum and kept locked; 2) instrument cabling is routinely shielded within conduit; 3) solar panels and transmitting antennae are mounted considerably higher than might be reached by anyone at ground level; 4) deployments with equipment located on bridge decks on heavily traveled bridyes will discourage vandalism due to the increased level of visibility by other members of the public, law enforcement, etc.; 5) selected deployments at most at -risk sites may be protected by an elevated mounting position, fences topped with concertina wire, and/or or use of lockable shields or doors at key access points. Duke Energy's contractual arranyement with the USGS for maintaininy the water quality monitoring sites will cover the replacement of instrument losses. I he USGS generally maintains a supply of instrument spares and other key components that would facilitate a relatively rapid replacement of damaged or lost equipment. Because the USGS staff generally performs a daily (remote) check of each site, lost data from aii equipment outage should be minimized. Data recovery and/or filling data gaps will be perffarmed by USGS to the extent possible. It there are questions or if further intormation is required, please contact me (704-382-5776; IVIark.Oakley@ duke-eneryy.com). Sincerely, E_ Mark Oakley, E. Catawba-Wateree Relicensing Project Manayer Water Strategy, Rydro Licensing, and Lake Services Duke Energy cc: Secretary Kimberly D. Bose, Federal Energy Regulatory Commission Fred Tarver, NC Division of water Resources Cory Larsen, NC Division of Water Resources Corey Basinyer, IAC Division of Water Resources Landon Davidson, NC Division of Water Resources Chris Gaudreau, NC Wildlife Resources Commission Ms. Karen Higgins Page 3 October 27, 2016 Jeff Lineberger, Duke Energy Garry Rice, Duke Energy Randy Herrin, Duke Energy George Galleher, Duke Energy Lynne Dunn, Duke Energy Keith Finley, Duke Energy Phil Fragapane, Duke Energy