20041101 Ver 5_More Info Received_20100528 (3)

I P Duke
Energya
Carolinas
May 26, 2010
Mr. John Dorney
North Carolina Division of Water Quality
2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604
0 LICENSING AND LAKE SERVICES
MIAY Z J 26 I j Duke Energy Carolinas, LLC
526 South Church St.
DENR-WATER WAUTY Charlotte, NC 28202
WETLANDS ANDSTORI`!yATERMRp)*1 ing Address:
EC12K / PO Box 1006
Charlotte, NC 28201-1006
Re: Submittal of Section 401 Water Quality Certification Application Addendum No. 1
Bryson Hydroelectric Project, FERC Project No. 2601
DWQ #H3=6i*5 o 1{ - 11 o i V Lo
Swain County, North Carolina
Dear Mr. Dorney:
On June 16, 2009, Duke Energy Carolinas, LLC (Duke) withdrew the previous Bryson Project 401 Water
Quality Certification (401 WQC) Application and simultaneously submitted a new 401 WQC Application
to the North Carolina Division of Water Quality (NCDWQ). The one-year timeframe that the Federal
Energy Regulatory Commission (FERC) allows states to process 401 WQC applications for relicensing of
hydro projects expires on June 16, 2010 (i.e., one year following the date that Duke's 401 WQC
Application was stamped accepted by NCDWQ) for the Bryson Project.
As you are aware, Duke has been engaged in consultation with the United States Fish & Wildlife Service
(USFWS), NCDWQ, North Carolina Division of Water Resources (NCDWR) and the North Carolina
Wildlife Resources Commission (NCWRC) to prepare a Lake Level and Flow Management Plan, a
Maintenance and Emergency Protocol and a Sediment Management Plan to help further define how the
hydro project could operate under a Subsequent License from the FERC. This consultation has been
productive and Duke is very grateful for the time commitment provided by these agencies over the past
several weeks.
Attached to this letter you will find the Bryson Project Lake Level and Flow Management Plan along with
the Nantahala Area Run-of-River Hydro Projects Maintenance and Emergency Protocol (as an Appendix
to the Bryson Project Lake Level and Flow Management Plan). Duke has incorporated the results of the
agency consultation into the attached documents and we are hereby submitting them as Addendum No. 1
to Duke's Bryson Project 401 WQC Application.
By separate cover, Duke will also file a proposed Sediment Study Plan as Addendum No. 2 for the
Bryson Project 401 WQC Application.
www. duke-energy. com
If there are any questions please call Steve Johnson at 704-382-4240.
Sincerely,
V
Steven D. Jester, Vice President
Hydro Strategy, Licensing and Lake Services
Duke Energy Carolinas, LLC
cc: Mr. Kevin Barnett, Asheville NCDWQ Regional office
Mr. Jim Mead, NCDWR
Mr. Chris Goudreau, NCWRC
Mr. Mark Cantrell, USFWS-Asheville
Secretary, FERC
Steve Johnson, Duke
Jeff Lineberger, Duke
Phil Fragapane, Duke
Attachment
Duke Energy Carolinas, LLC
Bryson Project (P-2601)
Lake Level and Flow Management Plan
May 26, 2010
Background
The Bryson Project (FERC No. 2601) (the Project) is located in Swain County, North Carolina
approximately 5 miles east of Bryson City. Bryson Dam is located on the Oconaluftee River
approximately 0.5 mile upstream of its confluence with the Tuckasegee River. Constructed by Bryson
City to serve the surrounding community, the Project began operation with the installation of the first
generator in 1925. Four years later a second unit was installed. Nantahala Power and Light Company
(NP&L) acquired the Project from Bryson City in 1942, and the Federal Energy Regulatory Commission
(FERC) licensed the Project on July 22, 1980. Duke Power (now Duke Energy Carolinas, LLC) (Duke)
acquired NP&L in 1988. Duke assumed operational control of NP&L hydro stations in August 2000.
The Project consists of a reservoir, dam, and powerhouse plus a small amount of land surrounding the
reservoir from just downstream of the tailrace to just upstream of the mouth of Goose Creek. The
electrical switchyard for the Project abuts the Project powerhouse. Duke owns the approximately 42
acres of land within the Project and the Bryson Reservoir (also known as Lake Ela) has approximately 4
miles of shoreline.
Major components of the Bryson Dam (also referred to herein as the Project Dam or Ela Dam) are listed
below beginning at the left abutment (facing downstream). Unless stated otherwise, all elevations are
referenced in the U.S. Geological Survey (USGS) datum and are expressed in feet above mean sea level
(AMSL). Major components of the dam include:
• A concrete, non-overflowing section with crest elevation 1838.41 ft AMSL.
• Two gravity spillway sections with crest elevation 1813.41 ft AMSL, each surmounted by a 16.5-
foot wide, 16-foot-high Tainter gate with the top of the gates at Elevation 1829.41 ft AMSL and
an opening deck with crest elevation 1838.41 ft AMSL. Both Tainter gates are operated
automatically by an independent control center located in a metal building on the deck above the
gates. Gate No. 2, located nearest the left (facing downstream) abutment, opens automatically
when the reservoir elevation in the open spillway section reaches 1828.90 ft AMSL,
approximately 0.5 foot above Normal Full Pond Elevation (Elevation 1828.41 ft AMSL). Gate
No. 1 raises automatically after Gate No. 2.
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• An uncontrolled multiple-arch spillway with four bays with crest elevation 1828.41 ft AMSL,
with buttresses on 39-foot centers.
• A 64.5-foot-wide powerhouse with a brick and concrete superstructure and concrete
substructure.
• Total distance along the dam's crest is approximately 341 feet, and the maximum height of the
dam is 36 feet.
The Bryson Project powerhouse consists of a reinforced concrete substructure and a brick superstructure.
The powerhouse contains two hydroelectric units. The unit nearest the spillway (Unit No. 1) includes a
vertical S. Morgan Smith Francis turbine with a rating of 700 horsepower at 34-foot head and 225
revolutions per minute (rpm). The turbine is located in a steel scroll case. Directly connected to the
turbine is a General Electric generator rated at 600 kilovolt-amperes (kVA) capacity at 0.80 power factor.
This unit was installed in 1925.
In the center bay (Unit No. 2) is a vertical Leffel Francis turbine with a rating of 700 horsepower at 34-
foot head and 225 rpm. The turbine is located in a steel scroll case. This generator, installed in 1929, was
manufactured by General Electric and has a 625-kVA capacity at 0.80 power factor. A directly connected
General Electric DC exciter surmounts both generators. Located adjacent to the turbine draft tube
compartments for Unit No. 2 is a third bay that contains a motorized sluice gate operated by an electric
control near the hoist. The gate is installed in the waterway of the intake serving this bay. The rated
hydraulic capacities of the turbines are 206 cfs each. The maximum and minimum hydraulic capacities
are 263 cfs and 149 cfs per unit respectively. The average annual generation for the Bryson Project over
the period of 1942 to 2002 was 5,534,230 kWh. Total maximum hydraulic capacity of the 2 units
combined at the Bryson Project is 526 cfs.
Bryson Unit No. 1 intake system is an 8.5 foot diameter steel intake pipe with 18 feet by 22 feet grated
trash rack mounted at a sloping angle in front of the intake pipe. The intake trash rack is located
approximately 10 feet in front of the intake pipe at the bottom of the pipe. The steel grating bars are 3/16-
inch thick diameter and the center-to-center spacing between the bars varies from 2.25 inches to 2.5
inches. Horizontal support bars are spaced 2 feet apart. These bars are round and have a diameter of 1.5
inches. Reservoir level is approximately 4 feet below the top of the grating during times of maximum
generation. The intake system for Bryson Unit No. 2 is identical to Bryson Unit No. 1.
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The reservoir has a length of 1.5 miles and a surface area of approximately 38 acres at Normal Full Pond
Elevation 1828.41 ft. AMSL. The drainage area upstream of the dam encompasses 188 square miles.
The average annual runoff into the Project reservoir is 534 cfs.
Flows upstream of the Project reservoir are measured at the U.S. Geological Survey (USGS) Gage
Oconaluftee River at Birdtown, NC (Gage #03512000) and can be found at the USGS web site address:
http://waterdata.usgs.gov/nc/nwis/uv?site no=03512000.
The Bryson Project operates in run-of-river mode (ROR) with an ordinary available drawdown of
approximately 6 inches. Project generation is dependent upon the availability of stream flow in the
Oconaluftee River. The Project operates semi-automatically; a float controls the wicket gates
automatically, but the units must be put on-line or taken off-line manually. The float makes the units
responsive to headwater pool levels, which are determined by variations in stream flow. Unit No. 2 uses
available stream flow up to a generator output of 500 kilowatts. Unit No. 1 uses any flows in excess of
Unit No. 2 capacity. When stream flow decreases, Unit No. 1 reduces its load first but maintains
synchronous speed by motoring. If stream flow continues to decrease, Unit No. 2 will also change mode
to synchronous speed motoring. The current license requires the Project to release a minimum flow of 82
cfs, or inflow if less, at all times from Bryson Dam.
Duke submitted an application for Subsequent License for the Project on July 17, 2003. In this License
Application Duke proposed to operate the Project in a run-of-river (ROR) manner such that outflow from
the Project is approximately equal to inflow into it at any given time. In a subsequent Environmental
Assessment (EA) issued on July 14, 2006, the FERC recommended that in order to meet the intent of
ROR operations Duke should operate the Project so that Project reservoir levels are within 0.1 ft of full
pond for 99 percent of the time and within 0.3 ft of full pond during the remaining 1 percent of the time
on an annual basis. In addition, the FERC recommended (i.e., Nantahala East Project Final
Environmental Assessment-July 14, 2006) that Duke consult with the appropriate resource agencies to
develop a Lake Level and Flow Management Plan (LLFMP) for the Project to ensure compliance with
ROR operations, as well as a Sediment Management Plan for the Project.
In 2004, Duke filed the initial Application for a Section 401 Water Quality Certification (401 WQC) with
the North Carolina Division of Water Quality (NCDWQ). Since that time, Duke has withdrawn and
resubmitted its application for a 401 WQC each year. The 401 WQC Application is currently under
review by the NCDWQ.
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Purpose
The purpose of the Bryson Project LUMP is to provide a framework for appropriate management and
monitoring of reservoir levels and flows downstream of the Project during normal operations, and
maintenance and emergency situations under the Subsequent License.
Objectives
The objectives of the LUMP are as follows:
1. Describe lake level and flow management during normal Project operations
2. Describe potential operational problems and solutions
3. Describe compliance monitoring and reporting procedures
4. Describe procedures for maintenance and emergency operations.
Normal Project Operations
The definition of ROR operations for a hydro project is that outflow is approximately equal to inflow at
any given point in time. This can be achieved by maintaining Project reservoir levels at a constant
elevation called the Normal Target Elevation. For this LUMP, Normal Target Elevation is defined as the
level of a ROR Project reservoir (measured in feet above Mean Sea Level (AMSL) or feet relative to the
full pond contour with 100.0 ft corresponding to full pond) that the Licensee will endeavor in good faith
to achieve, unless operation in the Maintenance and Emergency Protocol allows otherwise. For this
Bryson Project LUMP, Normal Target Elevation will be 99.95 ft. local datum which equates to
Elevation 1828.36 ft AMSL. In order to achieve a consistent reservoir level, control must be maintained
through operation of the Project's hydro units, Tainter gates, or both. The operating philosophy for
normal operations of Tainter gates and hydro units at the Project is described in the following:
Hydro Unit Operation
• A Programmable Logic Controller (PLC) will control each hydro unit.
• The operation of the hydro unit will be determined by lake level, electrical grid system conditions,
and amount of debris build up on trash racks.
• Lake levels will be managed to maintain the Normal Target Elevation (99.95 ft), with 100.0 ft
representing the Normal Full Pond Elevation of 1828.41 ft AMSL.
• The lake level set point for hydro unit control must be at a lower elevation than the lake level set
point for Tainter gate control such that the hydro units will operate prior to Tainter gate operation.
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Tainter Gate Operation
• For the Tainter gates with automatic controls, PLCs compare actual lake level to a lake level set point.
• The PLC will control the Tainter gate position based on the lake level set point value.
• Downstream flows are maintained through a combination of hydro generation and/or spill to maintain
reservoir levels at Normal Target Elevation (99.95 ft).
• A mobile back-up generator that will provide a redundant power source to the Project (i.e., Tainter
gates) during emergency situations (e.g., power loss) will be provided.
Based on the operations philosophy described above, the Project reservoir level control will consist of the
following components:
• A 5 psi pressure transducer secured in a stilling well and calibrated to measure lake level based on
Normal Full Pond Elevation of 100.0 ft. The transducer is accurate to within 0.01 feet. A back-up
transducer is also installed.
• A gate position transducer with a stainless steel tape connected to the top of each automatically
controlled Tainter gate. The transducer measures gate opening from fully closed to fully open with an
accuracy of 0.02 feet.
• Each automatic gate hoist has an encoder on the shaft that gives a relative position of the Tainter gate
to the position of the hoist shaft.
• Each hoist has a low limit and a high limit switch on the hoist shaft.
• A PLC is used to control Tainter gate movement through either a (1) variable frequency drive or (2)
motor contactors. Manual control is also available.
• There is a communication system between the Tainter gate controller and the plant controller. These
controllers communicate either by radio, fiber link, modem, or RS485.
• The Tainter gate PLC communicates the status of the gate position, lake level, and alarm points to the
plant PLC.
• The plant PLC communicates via wireless modem to the work station node at the Nantahala Hydro
Station (FERC Project 2692).
• The information from the Nantahala Hydro Station is sent to Hydro Central in Charlotte, North
Carolina through a secure network.
Potential Operational Issues:
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There are a number of factors that can affect the Project reservoir level control. These factors include
equipment failures, high inflow conditions, and debris build up in front of trash racks and Tainter gates.
• A PLC response to rapid changes in these reservoir level factors may result in reservoir level
variations greater than 0.1 feet.
• Since the Tainter gates at the Bryson Project are large (16.0 ft high x 16.5 ft wide), control of gate
position by the PLC to a tolerance of 0.02 feet allows for flow variances of 15 cfs or more through
each automatically controlled gate.
• There are occasional conditions, such as when there is trash or debris accumulations on the trash
racks which may create situations when one of the units cannot maintain the lake level set point. At
these times, an automated Tainter gate will support pond control.
Compliance Monitoring and Reporting
Run-of-River Compliance
Provided the Project is not operating in the Nantahala Area ROR Projects Maintenance and Emergency
Protocol (see Appendix), the Bryson Project will be considered in compliance with ROR operations under
the following conditions:
• Reservoir elevations maintained at ± 0.3 ft of Normal Target Elevation (99.95 ft) when less than 2
hydro units are operable
• Reservoir elevations maintained f 0.1 ft of Normal Target Elevation (99.95 ft) for 99% of year and f
0.3 ft of Normal Target Elevation (99.95 ft) for I% of year when 2 hydro units are operable.
• If the Licensee determines that the Project will have less than 2 hydro units operable for a period of
more than 60 consecutive days, the Licensee will consult with the agencies identified in the MEP
within 30 days of making such a determination, to develop a plan and schedule for complying with
ROR operations.
Reporting
• Reservoir elevation data will be collected no less frequently than every 15 minutes. Real-time
reservoir elevation information will be available for the Project at URL http://www.duke-
eneray.com/lakes/nantahala/nantahala-lake-levels asp
• The Licensee will provide 7-day reservoir history on its website. Any other history or period of
record is available from the Licensee upon written request.
• The Licensee will archive the 15-minute reservoir elevation data for the term of the Subsequent
License.
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• No later than March 31 of each calendar year beginning the first full calendar year after the
calendar year in which the Subsequent License is issued, the Licensee will provide to the
NCDWQ, NCDWR, the NCWRC, and the USFWS and file with the FERC a report containing a
table of the elevation of the reservoir on a daily basis (including midnight, daily minimum and
maximum elevations) during the previous calendar year, a certification by the Licensee that the
lake level requirements were met during the previous calendar year, and a discussion of each
incident during the previous calendar year where the elevation of the reservoir was above or
below the normally required levels.
• After five full calendar years of operation under the Subsequent License, the Licensee will confer
with the NCDWR, NCDWQ, NCWRC, USFWS, and the FERC to consider holding an
informational meeting, to review the operational history of the LUMP and to determine if any
operational changes are needed and agreeable to all the parties. Any such meeting will be
scheduled and held no later than October 31 of the appropriate year.
Emergency and Other Non-Routine Operations
• The Licensee will enhance remote monitoring of the Bryson Project by implementing an
expanded alert system concerning gate control failures, hydro unit trips, power failures, low
inflows, and other situations where downstream flows could be temporarily interrupted.
• Alerts will be directed to the Licensee where appropriate technical staff will be called out as
needed to respond to such situations.
• In addition the Licensee will provide a key contact individual that will be available during normal
business hours for the agencies to contact should significant Project-related issues arise.
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APPENDIX
NANTAHALA AREA RUN-OF-RIVER PROJECTS MAINTENANCE AND EMERGENCY PROTOCOL (MEP)
Introduction
Under some emergency, equipment failure, maintenance or other abnormal situations, certain license
conditions may be impractical or even impossible to meet and may need to be suspended or modified
temporarily to avoid taking unnecessary risks. The objectives of this protocol are:
1) to define the most likely abnormal situations for the Nantahala Area Run of River (ROR)
Projects (i.e., Mission, Bryson and Franklin Projects),
2) describe the operations protocol for certain abnormal situations,
3) identify the potentially impacted license conditions,
4) outline the general approach that the Licensee will take to mitigate the impacts to license
conditions, and
5) describe how these situations will be communicated to resource agencies and others.
Note: Due to the potential variability of these abnormal situations, this Maintenance and Emergency
Protocol (MEP) is not intended to give an exact step-by-step solution path. It will, however, provide
basic expectations for the Licensee's approach to dealing with the situation. Specific details will vary
and will be determined on a case-by-case basis as the protocol is being enacted.
The Licensee will review the requirements of this protocol each time it is used and may revise the MEP
from time to time as noted below.
Key Facts and Definitions
1. Human Health and Safety and the Inteerity of the Public Water Supply and Electric Systems are
of Utmost Importance - Nothing in this protocol will limit the Licensee's ability to take any and
all lawful actions necessary at the Project to protect human health and safety, protect its
equipment from major damage, and ensure the stability of the regional electric grid and public
water supply systems. It is recognized that the Licensee may take the steps that are necessary to
protect these things without prior consultation or notification. Likewise, nothing in this MEP will
limit the State of North Carolina from taking any and all lawful actions necessary in its
jurisdiction to protect human health and safety. It is recognized that North Carolina may also
take the steps necessary to protect these things without prior consultation or notification.
2. Normal Full Pond Elevation - Also referred to simply as "full pond," this is the level of a reservoir
that corresponds to the point at which water would first begin to spill from the reservoir's
dam(s) if the Licensee took no action. This level corresponds to the lowest point along the top
of the spillway (including flashboards) for reservoirs without floodgates and to the lowest point
along the top of the floodgates for reservoirs that have floodgates. To avoid confusion among
the many reservoirs the Licensee operates; it has adopted the practice of referring to the
Normal Full Pond Elevation for all of its reservoirs as equal to 100.0 ft. relative. The following
are the Normal Full Pond Elevations for the Nantahala Area ROR Projects expressed in terms of
USGS datum (ft above Mean Sea Level (AMSL)) rather than relative or local datum:
• Franklin Project - 2,000.22 ft AMSL
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• Bryson Project -1,828.41 ft AMSL
• Mission Project -1,658.17 ft AMSL
3. Normal Target Elevation - The level of a ROR Project reservoir (measured in ft above Mean Sea
Level (AMSL) or feet relative to the full pond contour with 100.0 ft corresponding to full pond)
that the Licensee will endeavor in good faith to achieve, unless operation in this MEP allows
otherwise. The Normal Target Elevation for the Franklin and Mission Projects is 99.5 ft and it is
99.95 ft local datum for the Bryson Project. These Normal Target Elevations correspond to the
following USGS elevations at each ROR Project:
• Franklin Project -1,999.72 ft AMSL
• Bryson Project -1,828.36 ft AMSL
• Mission Project -1,657.67 ft AMSL
4. Returnine to Normal - Some of the abnormal situations noted in this MEP can impact the
Licensee's ability to operate the hydro project in the most efficient and safest manner for power
production. The Licensee will therefore endeavor in good faith to repair existing hydro project
equipment and facilities and return them to service within a reasonable period of time,
commensurate with the severity of the equipment / facility repair requirements and availability
of budgeted funding. If the Licensee determines that the Project will have less than 2 hydro
units operable for a period of more than 60 consecutive days, the Licensee will consult with the
agencies identified in this MEP, within 30 days of making such a determination, to develop a
plan and schedule for complying with ROR operations.
5. Incidental Maintenance -These are maintenance activities at Project works that are very brief in
nature or that require minimal if any deviation from normal license conditions. For the purposes
of this protocol, maintenance of Project works that does not require deviation from any license
conditions related to prescribed flow releases from Project structures that is less than 24 hours
in duration and will not require any excursions below the Minimum Flow (as identified in this
MEP) is considered Incidental Maintenance and, except for the notification steps identified in
the tables below for communication with resource agencies and affected parties for conditions
that impact prescribed flow releases, Incidental Maintenance is exempt from the requirements
of this protocol.
6. Notification - Typically includes informing or providing information concerning a Project activity
or situation (e.g., scheduled maintenance drawdown) to interested parties. Notification is an
important aspect of the communication protocol for the Projects and can be used under both
scheduled and emergency situations.
7. Consultation - Typically includes meetings and/or correspondence regarding agency
deliberation, decision, or guidance concerning a Project activity (e.g., review operational
changes, review plan modifications). Consultation is also an important aspect of the
communication protocol for the Projects.
8. Notification Guidance
a. Scheduled Maintenance that Affects License Conditions - Typically, scheduled maintenance
is planned months in advance. Once a likely maintenance schedule has been established,
the Licensee will endeavor to provide as much advance notice as possible to the affected
parties identified in this protocol.
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b. Unscheduled Maintenance and Emergencies that Affect License Conditions - It is not
possible for the Licensee to assure any level of advance notice. For these situations, the
Licensee will endeavor to inform the affected parties identified in this protocol within some
reasonable amount of time after the situation has been identified.
9. Minimum Flow -The minimum flow releases from the Nantahala Area ROR Projects that maybe
necessary to:
a. prevent long-term or irreversible damage to aquatic communities consistent with the
resource management goals and objectives for the affected stream reaches;
b. provide some basic level of water quality maintenance in the affected stream reaches.
For the purpose of this MEP, the Minimum Flow will be equal to the September median flow for
the given Project. The Minimum Flows for the Nantahala Area ROR Projects are as follows:
• Little Tennessee River at Franklin Dam is 309 cfs.
• Oconaluftee River at Bryson Dam is 204 cfs.
• Hiwassee River at the Mission Dam is 341 cfs.
10. Organizational abbreviations include the Eastern Band of Cherokee Indians (EBCI), United States
Fish and Wildlife Service (USFWS), Federal Energy Regulatory Commission (FERC), United States
Geological Survey (USGS), North Carolina Department of Environment and Natural Resources
(NCDENR), North Carolina Division of Water Resources (NCDWR), North Carolina Division of
Water Quality (NCDWQ), North Carolina State Historic Preservation Office (NCSHPO), North
Carolina Wildlife Resources Commission (NCWRC), Duke System Operating Center (SOC) and
Duke Transmission Control Center (TCC).
11. Voltage and Capacity Emergencies - The electric transmission system serving the Nantahala
Area is part of the Licensee's main transmission system. The Licensee's system is connected to
other large transmission systems located in the southeast. If the Licensee's system reliability is
at risk due to Voltage and Capacity Emergencies, the ability to provide secure and continuous
electric service to the Licensee's electric customers becomes compromised. The Licensee's
System Operating Center (SOC) and Transmission Control Center (TCC) continuously monitor the
electric transmission system. Therefore, for the purposes of this protocol, a Voltage or Capacity
Emergency will exist when declared by the Licensee's SOC or TCC.
12. Large Extended Drawdown - Any drawdown of a Nantahala Area ROR Project reservoir that will
expose substantial lakebed areas for an extended period of time that are not normally exposed
during the year. For the purposes of this ROR Project MEP document, a Large Extended
Drawdown is any drawdown that is expected to maintain a ROR Project's reservoir level greater
than 1.0 foot below the Normal Target Elevation for at least 30 consecutive days.
13. Revising the MEP_- The Licensee will review the requirements of this MEP each time it is used
and will consult with the pertinent agencies if the Licensee determines that revisions are
warranted. The Licensee will file any revised MEP with the FERC, including filing a license
amendment request if the Licensee determines that the amendment is needed.
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Assumptions
1. Run-of-River Operation - The Subsequent or New Licenses for the Nantahala Area ROR Projects
are expected to require the Projects to be operated in such a manner that outflow is
approximately equal to inflow at any given time while allowing variations during maintenance,
emergencies, and equipment failures.
Guidance for Responding to Abnormal Situations
The table below identifies the most likely abnormal situations when this protocol will be enacted and
the license requirements that would most likely be impacted.
Abnormal Situation Potentially Impacted
License Requirements
Situation Situation Name Indications Run-of-River
Letter Operations

A
Hydro Unit Maintenance Maintenance will require
Yes
hydro unit shutdown.
Maintenance will require
B Maintenance of Floodgates interruption of scheduled Yes
releases from normal
locations (e.g., gates)
Condition A or B (i.e. dam
failure has occurred, is
imminent or a potentially
C Dam Safety Concerns hazardous situation exists) is Yes
declared per Emergency
Action Plan or other dam
safety concern is identified.
Voltage or capacity conditions
on the electric grid in the
Licensee's system or the
larger regional electric grid
Voltage or Capacity cause the Licensee's system
D
Emergency reliability and safety to be at Yes
risk and a voltage or capacity
emergency is declared by
Licensee's System Operating
Center (SOC) or Transmission
Control Center (TCC).
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Reservoir Drawdown Below The reservoir level is below
Normal Target Elevation due Normal Target Elevation by
E to maintenance, emergency more than is allowable for Yes
or other reasons (not due to normal operation
low or high inflow)
Safe access to regulated river
River Access Special reaches requires interruption
Y
F
Circumstances
of releases from normal es
locations
Communication with Resource Agencies and Affected Parties
General Notification
As soon as possible after the Licensee determines that the response to an abnormal situation will
potentially impact license conditions, the Licensee will add appropriate messages to its public
information Web site and/or its reservoir level toll-free phone system to inform the general public.
Specific consultation is discussed below for each identified abnormal situation.
Notification and Consultation
Notification and consultation requirements are specified for each abnormal situation. The Licensee will
consider options suggested by the identified agencies and organizations that could lessen the impact of
the abnormal situation on the environmental, cultural and human needs relative to the Project.
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Abnormal Situation A.1- Scheduled Hydro Unit Maintenance
Mitigating Actions
1. Scheduling - To the extent practical, the Licensee will avoid scheduling hydro unit maintenance that
would impact flow requirements for aquatic habitat or water quality unless it is likely that the
equipment condition will cause damage or unscheduled unit maintenance if repairs are delayed.
2. Drawing Down the Affected Reservoir -To minimize the impacts to its electric customers, the
Licensee may choose to draw down a reservoir using its hydro units to minimize spillage from the
dam during maintenance operations.
3. Avoid Falling Below the Minimum Flow - To the extent practical, the Licensee will avoid falling
below the applicable Minimum Flow as noted above. If it is determined that 100 percent
exceedance of the Minimum Flow cannot reasonably be achieved, the Licensee will work with the
resource agencies to (a) monitor any potential aquatic species impacts in the affected stream
segments and (b) replace any aquatic species mortalities that are identified.
Communication with Resource Agencies and Affected Parties
Abnormal Situation A.1- Scheduled Hydro Unit Maintenance
Notification Consultation Comments
NCDENR Provide notification, initiate consultation and provide
FERC NCWRC agencies 30 days to comment on drawdown plan as soon as
USFWS approximate dates are determined (typically months in
advance).
Consult at least 10 days prior to beginning the hydro unit
NCSHPO outage or any reservoir drawdown if maintenance will affect
EBCI Historic Properties (NCSHPO) and include consultation with
the EBCI if the maintenance will result in a Large Extended
Drawdown.
Access Area The Licensee will conduct notification procedures for any
Closure temporary recreation facility/Access Area closures (e.g.,
Notification closure due to extended low reservoir levels).
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
General license conditions, the Licensee will add appropriate
messages to its public information Web site and its reservoir
level toll-free phone system to inform the general public.
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Abnormal Situations A.2 - Unscheduled Hydro Unit Maintenance
Mitigating Actions
1. Drawing Down the Reservoir -To minimize the impacts to its electric customers, the Licensee may
choose to draw down a reservoir using its hydro units to minimize spillage from the dam during
maintenance operations.
2. Avoid Falling Below the Minimum Flow - To the extent practical, the Licensee will avoid falling
below the applicable Minimum Flow as noted above. If it is determined that 100 percent
exceedance of the Minimum Flow cannot reasonably be achieved, the Licensee will work with the
resource agencies to (a) monitor any potential aquatic species impacts in the affected stream
segments and (b) replace any aquatic species mortalities that are identified.
Communication with Resource Agencies and Affected Parties
Abnormal Situation A.2 - Unscheduled Hydro Unit Maintenance
Notification Consultation Comments
If the maintenance will affect run-of-river operations,
FERC NCDENR perform notification as soon as possible after the
NCDENR NCWRC unscheduled hydro unit outage begins, but no longer than 5
NCWRC USFWS days afterwards. Begin consultation within 10 days after the
USFWS unscheduled hydro unit outage begins.
Notify (within 5 days) and consult (within 10 days) after the
hydro unit outage or drawdown begins with NCSHPO if
NCSHPO NCSHPO maintenance will affect Historic Properties and include
EBCI EBCI consultation with EBCI if the maintenance will result in a
Large Extended Drawdown.
Access Area The Licensee will conduct notification procedures for any
Closure temporary recreation facility/Access Area closures (e.g.,
Notification closure due to extended low reservoir levels).
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
General license conditions, the Licensee will add appropriate
messages to its public information Web site and its reservoir
level toll-free phone system to inform the general public.
14
Abnormal Situation B.1- Scheduled Maintenance of the Normal Means of Providing Minimum Flows
Mitigating Actions
1. Scheduling - To the extent practical, the Licensee will avoid scheduling maintenance (e.g.,
floodgate maintenance requiring drawdown; hydro unit outage) that would impact the ability of
the Licensee to release flows for aquatic habitat or water quality unless it is likely that the
equipment condition will cause damage or an unscheduled maintenance situation if repairs are
delayed.
2. Drawing Down the Reservoir -To minimize the impacts to its electric customers, the Licensee
may choose to draw down a reservoir using its hydro units to minimize spillage from the dam
during maintenance operations.
3. Avoid Falling Below the Minimum Flow - To the extent practical, the Licensee will avoid falling
below the applicable Minimum Flow as noted above. If it is determined that 100 percent
exceedance of the Minimum Flow cannot reasonably be achieved, the Licensee will work with
the resource agencies to (a) monitor any potential aquatic species impacts in the affected
stream segments and (b) replace any aquatic species mortalities that are identified.
Communication with Resource Agencies and Affected Parties
Abnormal Situation B.1- Scheduled Maintenance of the Normal Means of Providing Minimum
Flows
Notification Consultation Comments
Provide notification, initiate consultation and provide
NCDENR agencies 30 days to comment on drawdown plan as soon as
FERC NCWRC approximate dates are determined (typically months in
USFWS advance).
Notify (within 5 days) and consult (within 10 days) after the
hydro unit outage or drawdown begins with NCSHPO if
NCSHPO NCSHPO maintenance will affect Historic Properties and include
EBCI EBCI consultation with EBCI if the maintenance will result in a
Large Extended Drawdown.
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
General license conditions, the Licensee will add appropriate
messages to its public information Web site and/or its
reservoir level toll-free phone system to inform the general
public.
15
Abnormal Situation B.2 - Unscheduled Maintenance of the Normal Means of Providing Minimum
Flows
Mitigating Actions
1. Avoid Falling Below the Minimum Flow - To the extent practical, the Licensee will avoid falling
below the applicable Minimum Flow as noted above. If it is determined that 100 percent
exceedance of the Minimum Flow cannot reasonably be achieved, the Licensee will work with
the resource agencies to (a) monitor any potential aquatic species impacts in the affected
stream segments and (b) replace any aquatic species mortalities that are identified.
Communication with Resource Agencies and Affected Parties
Abnormal Situation 6.2 - Unscheduled Maintenance of the Normal Means of Providing Minimum
Flows
Notification Consultation Comments
If the maintenance cannot avoid impacting run-of-river
FERC NCDENR operations, perform notification as soon as possible after the
NCDENR NCWRC unscheduled maintenance begins, but no longer than 5 days
NCWRC USFWS afterwards. Begin consultation within 10 days after the
USFWS unscheduled maintenance begins.
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
license conditions, the Licensee will add appropriate
General messages to its public information Web site and/or its
reservoir level toll-free phone system to inform the general
public.
16
Abnormal Situation C - Dam Safety Emergency
Mitigating Actions
Safety Must Come First - If a Condition A or B is declared per the Licensee's Emergency
Action Plan, or other dam safety concerns arise, the Licensee may modify or suspend any
license conditions immediately and for as long as necessary to restore the dam to a safe
condition.
Communication with Resource Agencies and Affected Parties
Abnormal Situation C - Dam Safety Emergency
Notification Consultation Comments
Conducted strictly in accordance with the Licensee's
Emergency Action Plan. In cases where dam safety
During EAP Condition A or B or concerns arise that are not a Condition A or B per the
Other Dam Safety Concerns Licensee's Emergency Action Plan, consultation with
resource agencies and affected parties will occur as soon as
possible, after the dam safety concern arises.
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
Once Dam Safety Conditions Have license conditions, the Licensee will add appropriate
Stabilized messages to its public information Web site and/or its
reservoir level toll-free phone system to inform the general
public.
Access Area Closure The Licensee will conduct notification procedures for any
Notification
temporary recreation facility/Access Area closures (e.g.,
closure due to extended low reservoir levels).
17
Abnormal Situation D -Voltage and Capacity Emergencies
Mitigating Actions
1. Suspension of the Normal Run-of-River Proiect Operation - If a voltage or capacity emergency
(as defined above) occurs, the Licensee may modify or suspend reservoir level operating
limitations immediately and for as long as necessary if doing so would allow additional hydro
station operation that is needed to restore the electric grid to a stable condition.
Conserving Water for Power Generation - If a voltage or capacity emergency (as defined above)
occurs and if it is expected to continue for an extended period of time (e.g. two weeks or more),
the Licensee may reduce minimum flows to the applicable Minimum Flow (as defined above).
During a Voltage or Capacity Emergency, the Licensee will not deviate from the normal license
conditions to conserve water for power generation strictly as a cost avoidance measure, but
only to assist in addressing the emergency.
Communication with Resource Agencies and Affected Parties
Abnormal Situation D -Voltage and Capacity Emergencies
Notification Consultation Comments
FERC Perform notification as soon as possible, but no longer than 5
NCDENR NCDENR days following the deviation from a license condition for
NCWRC NCWRC Voltage or Capacity Emergency reasons. Initiate consultation
USFWS USFWS as soon as possible.
Notify (within 5 days) and consult as soon as possible with
NCSHPO NCSHPO if a Voltage or Capacity Emergency will affect
NCSHPO EBCI Historic Properties and include consultation with EBCI if the
emergency will result in a Large Extended Drawdown.
Access Area The Licensee will conduct notification procedures for any
Closure temporary recreation facility/Access Area closures (e.g.,
Notification closure due to extended low reservoir levels).
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
General license conditions, the Licensee will add appropriate
messages to its public information Web site and its reservoir
level toll-free phone system to inform the general public.
18

Abnormal Situation E.1- Scheduled Reservoir Drawdown
Mitigating Actions
1. Scheduling - To the extent practical, the Licensee will avoid scheduling reservoir drawdowns that
would impact the ability of the Licensee to release the Minimum Flow for aquatic habitat and water
quality.
2. Avoid Falling Below the Minimum Flow - To the extent practical, the Licensee will avoid falling
below the applicable Minimum Flow as noted above. If it is determined that 100 percent
exceedance of the Minimum Flow cannot reasonably be achieved, the Licensee will work with the
resource agencies to (a) monitor any potential aquatic species impacts in the affected stream
segments and (b) replace any aquatic species mortalities that are identified.
Communication with Resource Agencies and Affected Parties
Abnormal Situation E.1- Scheduled Reservoir Drawdown
Notification Consultation Comments
NCDENR Provide notification, initiate consultation and provide
FERC NCWRC agencies 30 days to comment on drawdown plan as soon as
USFWS approximate dates are determined (typically months in
advance).
Consult at least 10 days prior to beginning the reservoir
NCSHPO NCSHPO drawdown if the drawdown will affect Historic Properties
EBCI EBCI (NCSHPO) and include consultation with the EBCI if the
maintenance will result in a Large Extended Drawdown.
Access Area The Licensee will conduct notification procedures for any
Closure temporary recreation facility/Access Area closures (e.g.,
Notification closure due to extended low reservoir levels).
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
General license conditions, the Licensee will add appropriate
messages to its public information Web site and its reservoir
level toll-free phone system to inform the general public.
19

Abnormal Situation E.2 - Unscheduled Reservoir Drawdown
Mitigating Actions
1. Avoid Falling Below the Minimum Flow - To the extent practical, the Licensee will avoid falling
below the applicable Minimum Flow as noted above. If it is determined that 100 percent
exceedance of the Minimum Flow cannot reasonably be achieved, the Licensee will work with the
resource agencies to (a) monitor any potential aquatic species impacts in the affected stream
segments and (b) replace any aquatic species mortalities that are identified.
Communication with Resource Agencies and Affected Parties
Abnormal Situation E.2 - Unscheduled Reservoir Drawdown
Notification Consultation Comments
If the drawdown cannot avoid impacting run-of-river
FERC NCDENR operations, perform notification as soon as possible, but no
NCDENR NCWRC longer than 5 days after the drawdown begins. Begin
NCWRC USFWS, NCSHPO, consultation within 10 days after the drawdown begins.
USFWS EBCI Include consultation with the NCSHPO if the drawdown will
affect Historic Properties and include consultation with the
EBCI if the drawdown will be a Large Extended Drawdown.
Access Area The Licensee will conduct notification procedures for any
Closure temporary recreation facility/Access Area closures (e.g.,
Notification closure due to extended low reservoir levels).
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
General license conditions, the Licensee will add appropriate
messages to its public information Web site and its
reservoir level toll-free phone system to inform the general
public.
20
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Abnormal Situation F - Special River Access Circumstances
Mitigating Actions
1. Avoid Falling Below the Minimum Flow - To the extent practical, the Licensee will avoid falling
below the applicable Minimum Flow as noted above. If it is determined that 100 percent
exceedance of the Minimum Flow cannot reasonably be achieved, the Licensee will work with the
resource agencies to (a) monitor any potential aquatic species impacts in the affected stream
segments and (b) replace any aquatic species mortalities that are identified.
Communication with Resource Agencies and Affected Parties
Abnormal Situation F - Special River Access Circumstances
Notification Consultation Comments
If the Licensee must alter outflow from the Project such
that the stream flow will be reduced to a level that is below
NCDENR the Minimum Flow, then the Licensee will initiate
FERC NCWRC consultation as soon as possible after the dates are known,
USFWS but at least 10 days prior to beginning the temporary flow
alteration. Initiate consultation for unplanned river access
within 5 days after the temporary flow alteration begins.
Access Area The Licensee will conduct notification procedures for any
Closure temporary recreation facility/Access Area closures (e.g.,
Notification closure due to extended low reservoir levels.
As soon as possible after the Licensee determines that the
response to an abnormal situation will potentially impact
General license conditions, the Licensee will add appropriate
messages to its public information Web site and its
reservoir level toll-free phone system to inform the general
public.
21