20030147 Ver 2_WRC Comments_20070712

~ North Carolina Wildlife Resources Commission ~
Richard B. Hamilton, Executive Director
12 July 2007
Mr. John Dorney
Division of Water Quality - 401 Unit
N.C. Department of Environment & Natural Resources
1650 Mail Service Center
Raleigh, NC 27699-1650
Subject: Application for 401 Water Quality Certification
Yadkin-Pee Dee Hydroelectric Project (FERC No. 2206)
Progress Energy, Stanly, Montgomery, Anson, and Richmond Counties
Dear Mr. Dorney:
The North Carolina Wildlife Resources Commission has reviewed Progress Energy's application
for 401 water quality certification in conjunction with the license application submitted to the
FERC. We provide these comments in accordance with provisions of the Clean Water Act (33
U.S.C. 466 et seq.), the Federal Power Act (16 U.S.C. 791a et seq.) and the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.). We recommend that the
following conditions be included in the 401 certification. They are based on the Comprehensive
Settlement Agreement (CSA) soon to be filed with the FERC by Progress Energy.
Instream Flows
Releases from Blewett Falls Reservoir
From February 1 through May 15 of each year, the continuous minimum flow will be
2,400 cfs, as measured at the existing USGS gage at Rockingham, to enhance spawning habitat
in the Pee Dee River downstream of the Blewett Falls Development. From May 16 through May
31 of each year, a continuous minimum flow will be 1,800 cfs and for the remainder of the year,
June 1 through January 31, the continuous minimum flow will be 1,200 cfs, all subject to
allowable variances described below. This Agreement establishes a higher priority on the
Mailing Address: Division of Inland Fisheries 1721 Mail Service Center Raleigh, NC 27699-1721
Telephone: [phone] Fax: [phone]

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12 JULY 2007
maintenance of minimum flows than the maintenance of reservoir water levels. Therefore,
infrequently, events may require the prioritization of maintaining minimum flows over the
reservoir water levels.
Progress Energy shall operate its Blewett Falls facility during certain times of the year in a
manner intended to enhance fish spawning conditions downstream of the Blewett Falls
Development as described and defined below. These time periods are referred to herein as "flow
adjustment operations" and they shall occur each year as either (a) one 14-day and one 10-day
period or (b) five 5-day periods. In any event, these periods of flow adjustment to enhance
spawning will be characterized by the following:
• Flow adjustment operations shall occur between February 1 and May 15.
• The specific time periods in each year will be decided upon by resource agencies, Progress
Energy, and APGI (collectively, the "Spawning Flow Management Team"). Other entities able
to demonstrate relevant fisheries expertise may participate in these discussions. If the option of
one 14-day period and one 10-day period is chosen, Progress Energy must be notified of the
specific dates at least 14 days prior to the start of each period. If the option of five 5-day periods
is chosen, Progress Energy must be notified of the entire schedule at least 10 days in advance of
the start of the first of the 5-day periods.
• Periods of flow adjustment operations shall be chosen by the Spawning Flow Management
Team based on interpretation of relevant factors that might include, but are not limited to, water
temperature and weather data, projected inflow conditions, and observations of fish spawning
behavior. If the option of five 5-day periods is implemented, two of these periods must occur
between April 15 and May 15.
• Because of concerns regarding the predictability of inflows over longer periods of time, the
individual flow adjustment periods must be separated by at least one week, unless otherwise
approved by Progress Energy.
• If a period of unusually low inflow to Blewett Falls Reservoir or a Low Inflow
Protocol ("LIP") period occurs during a previously selected flow adjustment operation period,
the release of the required minimum continuous flow (or in the case of an LIP event, the LIP
flow) will still be considered a flow adjustment period.
• If a period of higher inflow to Blewett Falls Reservoir occurs during a selected flow adjustment
operation period, wherein there is a continuous operation of all commercially available turbines
in the Blewett Falls powerhouse, possibly accompanied by additional spillage over the dam crest,
this period will count as a flow adjustment period so long as any interruptions in the continuous
operation of all commercially available turbines are infrequent and unscheduled.
• If a period of intermediate inflow to the Blewett Falls Reservoir occurs (flows in the range of
3,000 to 6,000 cfs), Progress Energy will manage releases at the Blewett Falls powerhouse as
follows:
(1) If unregulated tributary inflow to the Pee Dee River above Blewett Falls (particularly from
the Rocky River) changes significantly during a designated flow adjustment operation period,
Progress Energy can respond to these changes in flow as needed to manage reservoir operations
by increasing or reducing the number of turbines in operation without consideration to the limits
described below in (2) through (5). This would still be considered a flow adjustment period.
(2) Except as identified in (1) above, the up-ramp time of each turbine at Blewett Falls will be no
less than 30 minutes from off-line to full gate.

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(3) Except as identified in (1) above, the down-ramp time of each turbine at Blewett Falls from
full gate to off-line will be in accordance with the following guidelines:
i. After the first operating unit is taken off-line, the second operating unit to be taken off-line
shall not be taken off-line for at least two hours after the first operating unit was taken off-line.
ii. After the second operating unit is taken off-line, the third operating unit to be taken off-line
shall not be taken off-line for at least four hours after the second operating unit was taken off-
line.
iii. After the third operating unit is taken off-line, the fourth operating unit to be taken off-line
shall not be taken off-line for at least six hours after the third operating unit was taken off-line.
(4) On the first day of any flow adjustment operation period, Blewett Falls must commence such
related operations no later than 8 a.m. to still be considered as a full day of flow adjustment
operation.
(5) On the last day of any flow adjustment operation period, Blewett Falls units can begin to be
taken off-line no earlier than 4 p.m. By example, the schedule below would be considered a full
day of a designated flow adjustment operation period if it were the last day of such period:
(i) 4 PM -- go from 5 units to 4 units
(ii) 6 PM -- go from 4 units to 3 units
(iii) 10 PM -- go from 3 units to 2 units
(6) If the five 5-day flow adjustment operation periods are chosen in any given year, each period
shall begin on a Monday morning and end on a Friday evening.
(7) If the one 14-day and one 10-day period is chosen in any given year, the actual dates shall be
such as to minimize the number of weekend days within the 14-day period. For the 10- day
period, there will be no more than 2 weekend days. All decisions to be made by the Spawning
Flow Management Team as outlined in this section shall require consensus as specifically
defined under Section 1.3.8.2 of this Comprehensive Settlement Agreement. Progress Energy
will prepare an annual report of the operations of the Blewett Falls Development during the Flow
Adjustment Operation periods consisting of meeting notes, flow records from stream flow gages,
and plant operations. The operations of the Tillery Plant during the Flow Adjustment Period will
be coordinated by Progress Energy and subject to dispatch by Progress Energy in accordance
with its system needs. Progress Energy anticipates that APGI will provide a good faith effort to
define its daily release schedule during these periods at least one week in advance of the
scheduled time periods and provide updates to the release schedule once every other day until the
cessation of the specific flow adjustment operation period.
The first year of implementation of the Flow Adjustment Operations shall be the calendar year
following the year of license issuance. After five years of Flow Adjustment Operations, the
Spawning Flow Management Team shall evaluate the Flow Adjustment Operations and develop
recommended changes for consideration by the resource agencies and Progress Energy.
Reevaluation at 5-year intervals may occur if determined necessary and if agreed to by the
Spawning Flow Management Team.
The new minimum flow regime will allow a variance for two 5-hour periods each year to reduce
the minimum flow release to just leakage flow for testing black-start capability of turbines at the
Blewett Falls powerhouse. These black-start tests will be restricted to occur only in October,
November, December, or January, when environmental effects of low flow fora 5- hour period

PAGE 4 12 JULY 2007
are expected to be minimal. Further, these tests shall not be conducted in October if a Stage 1 or
greater Low Inflow Protocol event has been triggered.
In an effort to properly manage water during unusually low flow conditions, Progress
Energy shall participate in a Low Inflow Protocol (LIP)as presented in the APGI and Progress
Energy 401 Certification applications. Minimum instream flows may be reduced during these
LIP periods in order to conserve water resources during periods of low flow in the watershed.
Progress Energy will maintain to the standards established by the USGS a continuous flow
monitoring gage at the site of the current Rockingham USGS gage and will provide flow data to
the public, via the Internet or other appropriate means, to be updated no less than every two (2)
hours. For the first ten (10) years after issuance of the New License, Progress Energy will
contract with the USGS for operation and maintenance of this gage. Annual reporting of flows
will be in accordance with normal USGS practices and procedures. Compliance with minimum
flows for the Blewett Falls facility will be measured at the Rockingham gage.
Progress Energy will maintain to the standards established by the USGS a continuous flow
monitoring gage at the site of the current Rocky River gage near the mouth of the Rocky River.
Progress Energy currently pays a portion of the cost of the maintenance of this gage. If for any
reason the funding of this gage by others is lost, then Progress Energy will be responsible for the
additional funding necessary to maintain the gage. Progress Energy reserves the right to
reconsider whether or not to continue to use the USGS as the provider of this service after the
first ten (10) years following the issuance of the new license.
Minimum releases required at the Blewett Falls Development shall be presumed to have been
met if flows recorded at the stream flow gage at Rockingham are within 5% of the required
minimum release, so long as the "true-up" procedure described below is implemented. Progress
Energy will prepare an annual report documenting its compliance with minimum releases
including any "true-up" periods. To the extent practicable, Progress Energy will "true-up"
minimum flows monthly; that is, flows falling below the minimum shall be offset by flows
greater than the minimum (during minimum release periods) in the same month for a reasonably
equivalent amount of time. If any instances of recorded lower-than-required minimum flows are
not properly compensated for in the month they occur, such compensation will occur as soon as
practicable in the next month, but no later than the 15th day of that month. Progress Energy's
annual report shall indicate all periods where a "true-up" was required and show how and when
the actual "true-up" occurred. The annual report shall be filed with the NCDENR, SCDNR,
SCDHEC and FERC by March 31 of the following year. If any of the resource agencies have
significant concerns or comments on the report, a consultation meeting will be convened to
discuss these concerns. Such meeting shall be held within 45 days of the issuance of the report.
There shall be no "gaming" of the minimum flow variance allowed under this compliance
standard; that is, under no circumstance shall Progress Energy intentionally or willfully use the
existence of the variance and true-up mechanism to deliberately manipulate minimum flow
releases to coincide with demand for electricity. For example, a consistent record of lower-than
required minimum flows during periods of high electrical demand shall be considered "gaming."

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Certain LIP events require the release of 925 cfs as the "critical flow." The Licensee shall
endeavor to maintain this target flow; however, compliance will have been achieved if the flow
recorded during this event is between 900 and 950 cfs at the Rockingham gage.
Releases from Tillery Reservoir
Progress Energy will provide a continuous year-round minimum flow at the Tillery Development
of 330 cfs except for a period of eight continuous weeks commencing as early as March 15, but
no later than March 22, when a minimum flow of 725 cfs shall be provided to enhance American
shad spawning. This release of 725 cfs will start in 2010, or at the first passage of American shad
above Blewett Falls Dam, whichever is later.
Progress Energy shall release for the purposes of enhancing recreational boating flows below
the Tillery Development an additional 1,750 acre-feet of water per year above and beyondthe
required minimum releases specified in Section 2.1.4.2. This recreational release volume can be
increased to 1,950 acre-feet per year if releases for recreation purposes are made for at least four
days within the period May 16 to May 31 or September 1 to September 15. These four days can
occur in the designated May time period or the designated September time period or any
combination thereof.
Within twelve (12) months of the New License becoming final and Non-Appealable,
Progress Energy will prepare in coordination with NCDENR and NCWRC a Recreation Release
Plan for submittal to FERC. Following the first three years of Plan implementation, the Plan
shall be evaluated and modified as appropriate; however, any modification shall not consider
increasing the amount of water above 1,950 acre-feet. After the first evaluation, re-evaluation
and modification of the Recreation Release Plan at 5-year intervals may occur if determined
necessary and if agreed upon by NCDENR, NCWRC, and Progress Energy, however, any
modification shall not consider increasing the amount of water above 1,950 acre-feet. Any
decision arrived at by this group shall require consensus of the licensee, NCDENR, and the
NCWRC.
Flows released at the Tillery Development for the purpose of meeting minimum flow
requirements will be done in such a way as to avoid skimming high temperature surface water
from the uppermost surface of Lake Tillery if high temperature gradients are found to occur in
the upper six inches of the lake.
Within 12 months of the New License becoming Final and Non-Appealable, Progress Energy
will install and maintain to the standards established by the USGS a continuous flow monitoring
gage below the Tillery Development near the State Highway 731 Bridge and will provide flow
data to the public, via the Internet or other appropriate means, to be updated no less than every
two (2) hours. For the first ten (10) years after issuance of the New License, Progress Energy
will contract with the USGS for operation and maintenance of this gage. Annual reporting of
flows will be in accordance with normal USGS practices and procedures.
Minimum releases required at the Tillery Development are presumed to have been met if flows
recorded at the stream flow gage near the Highway 731 Bridge are within 5% of the required

t
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minimum, as long as the "true-up" procedure described below is implemented. Progress Energy
will prepare an annual report documenting its compliance with minimum releases including any
"true-up" period. To the extent practicable, Progress Energy will "true up" minimum flows
monthly; that is, flows falling below the minimum shall be offset by flows greater than the
minimum (during minimum release periods) in the same month and for a reasonably equivalent
amount of time. If any instances of recorded lower-than-required minimum flows are not
properly compensated for in the month they occur, such compensation will occur as soon as
practicable in the next month, but no later than the 15th day of that month. Progress Energy's
annual report shall indicate all periods where a "true-up" was required and show how and when
the actual "true-up" occurred.
Reservoir Water Levels
Blewett Falls Development
When inflows to Blewett Falls Reservoir are greater than approximately 7,400 cfs (about 40
percent of the time), the plant is operated in a near run-of--river fashion, and water levels are
controlled by inflows. When inflows to Blewett Falls Reservoir are less than approximately
7,400 cfs (about 60 percent of the time), Progress Energy shall maintain ayear-round water level
regime at Blewett Falls Lake that allows for fluctuations of up to 6 ft, between elevation 172.1
and 178.1 ft, except for system emergencies and LIP. Under this water level regime, typical daily
water level changes will be in the range of 2 to 4 ft. When flashboards are down, an additional 2
ft of drawdown to elevation 170.1 ft is necessary to safely replace the flashboards.
During the bass spawning season, April 15 to May 15, Progress Energy will limit water level
changes to 2 ft to enhance bass spawning except when additional reservoir storage is necessary
to meet minimum flow release obligations (minimum flow releases will have priority over lake
elevations) or if the flashboards fail. In either of the exceptions noted above, Progress Energy
will endeavor to return to normal operations as soon as reasonably practical.
Tillery Development
Progress Energy will follow aseasonally-based lake level management schedule at Lake Tillery
during the term of the New License. From December 15 through March 1, lake level
fluctuations will be limited to 3 ft between 274.3 and 277.3, unless use of reservoir storage is
needed to meet demand for electricity. If storage is needed for electrical generation purposes
during this period, Progress Energy may use the storage available between elevations 272.3 ft
and 277.3 ft, resulting in a maximum fluctuation of 5 ft. When used for these power-related
purposes, Progress Energy will normally cycle the reservoir within these elevation limits on a
daily or multi-daily basis. Water fluctuations up to 8 ft may occur during system emergencies,
and potentially be greater during LIP periods.
From April 15 to May 15, Progress Energy will limit lake level changes to 1.5 ft below the water
surface elevation of the reservoir as measured on April 15 for bass spawning (higher elevations
are acceptable).

+ + PAGE 7 12 JULY 2007
During all other periods of the year (except flood flow conditions), Progress Energy will
maintain lake level fluctuations to generally within 2.5 ft of full pool (elevation 277.3 ft
measured at Tillery Dam) on weekdays, and generally 1.5 ft of full pool on weekends and
holidays.
Once in every 5-year period, Progress Energy will schedule a maintenance drawdown of up to 15
ft to occur on Lake Tillery within the September 15 to December 15 timeframe. This drawdown
will allow Progress Energy to perform routine periodic maintenance and gate testing that cannot
be accomplished when the lake level is higher.
Progress Energy will add a projection of the expected daily water levels for the day on their
existing 800-899-4435 public messaging service. For the first five years of the New License,
Progress Energy will also provide an annual notice on November 15 alerting the public to the
drawdown limits that apply between December 15 and March 1.
In the case of an LIP event, Lake Tillery and the other larger reservoirs in the basin will be called
upon to use some of their storage to augment downstream flows in a coordinated manner.
Management of flows and water levels during LIP events are contained in Progress Energy and
APGI 401 Certification applications.
Water Quality
Water quality monitoring has shown that tailwater dissolved oxygen (DO) levels can periodically
fall below North Carolina water quality standards. This is a seasonal problem, occurring during
some summer months when reservoirs stratify and deeper waters in the vicinity of the plant
turbine intakes lose some, or nearly all, of their oxygen content. This causes low DO water to be
discharged to the tailrace when generation takes place. The duration and frequency of these low
DO episodes depends largely upon reservoir inflow, weather, reservoir mixing forces, and
reservoir outflow. Water quality data collection at the Tillery and Blewett Falls developments
indicate that these low DO events occur more frequent at Tillery than at Blewett Falls.
Additionally, preliminary trials of turbine venting suggest that venting with existing equipment
alone may eliminate the problem at Blewett Falls, while additional venting equipment or other
DO enhancing strategies may be required at Tillery.
Progress Energy is following a DO implementation plan that will have both Blewett Falls and
Tillery tailrace DO levels in compliance with current state water quality standards by the end of
2011. Progress Energy will operate the Project in accordance with its 401 Certification to meet
applicable water quality standards. If at any time during the term of the New License, after all
required water quality enhancement modifications have been completed, state water quality
standards are not being met as a result of Progress Energy's hydroelectric operations; Progress
Energy will immediately consult with NCDWQ to develop, if appropriate, a plan to implement
corrective actions. Progress Energy will implement the plan as approved by NCDWQ and/or
FERC.
Progress Energy will provide continuous monitoring of water temperature and dissolved oxygen.
Temperature and DO monitoring will occur below the Tillery Plant as required by the 401

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Certificate issued by NCDWQ with equipment installed by the Licensee. The final location of
DO monitoring near the Highway 731 Bridge will be determined based upon further testing of
DO enhancement technologies and resulting patterns of DO concentrations in the Tillery
tailwater. Annual compliance reports will be prepared by Progress Energy and submitted to
NCDWQ and FERC by April 15th of the following year in accordance with the requirements of
the 401 Water Quality Certificate.
Progress Energy will conduct post-licensing monitoring of aquatic life below Tillery Dam. The
purpose of the monitoring is to document the condition of the aquatic community in the Pee Dee
River from Tillery Dam to its confluence with the Rocky River. The extent of this testing will be
in accordance with the NCDWQ Water Quality Certificate.
Five years following the issuance of the New License that is final and Non-Appealable, Progress
Energy will conduct a sediment survey in Blewett Falls Lake and a gravel recruitment survey in
the Blewett Falls tailwater. The gravel recruitment survey will repeat the study conducted by
Progress Energy during the relicensing process. If results indicate that there is still no significant
problem related to gravel recruitment, then Progress Energy will conduct another survey after an
additional 10 years.
If you have questions please contact me at [e-mail] or 1721 Mail Service
Center, Raleigh, NC 27699-1721.
Sincerely,
~~~~~~
. G~
Todd D. Ewing
Hydropower Relicensing Coordinator
ec: Jim Mead and Steve Reed (NCDWR)
Ben West (USEPA)
Mark Bowers (USFWS)
Mike Lawyer (NCDWQ)
Larry Mann (Progress Energy)