20070812 Ver 2_More Info Letter_20060630 (14)

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Gene Ellis
Alcoa Power Generating, Inc.
Yadkin Division
P.O. Box 576
Badin, NC 28009-0576
Dear Mr. Ellis:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
June 30, 2006
RE: 401 Water Quality Certification for FERC relicensing
Yadkin Project upgrades
As we discussed in our May 24, 2006 meeting, the following questions still need to be
addressed by APGI in order for DWQ to make our decisions with respect to issuing a 401 Water
Quality Certification for this project. The submittal that you made in your March 31, 2006 letter
to Darlene Kucken was helpful in addressing our concerns but the following questions still
remain. These questions revolve around the timing of proposed improvements to the turbines
at your facilities in order to meet the state's dissolved oxygen water quality standard and the
monitoring that will be needed to demonstrate compliance with that standard.
1. What percent of time (approximately) is each unit operated at the Narrows and High
Rock facilities during the May to November timeframe? This information is needed
for us to determine if the sequencing for turbine upgrades is reasonable and whether
a different schedule would result in water quality improvements more quickly while
not unduly interfering with your operation of these facilities to generate electricity.
2. Please address why you need two years of engineering work and modeling on the
Narrows facility before improvements can be done to meet water quality standards.
As you know, the other hydroelectric plants are generally on a three year schedule to
meet DO standards with their pending 401 Certifications and FERC relicensing. It is
unclear to us why your schedule for the Narrows facility could not be accelerated into
year 2007 to start the needed improvements at this facility, especially since it is our
understanding that the physical fix at Narrows Units 1, 2 and 3 is rather similar to that
done for Unit 4. Therefore, we continue to believe that improvements to Narrows
Unit 2 could be moved up to 2007 and this would address your concerns and costs
over shutting down two units at once. Please be aware that during refurbishment,
APGI will continue to operate all other units that have been upgraded on a first on,
last off basis.
3. Documentation for costs of alternative improvement plans. In your March 31 letter
and at our May meeting, you refer to costs of various alternative schedules. Please
provide quantitative documentation for those conclusions. As you know, the 401
Certification considers practicable alternatives (defined as "...size, configuration or
density of the proposed activity and all alternative designs (which meet) the basic
project purpose..." (15A NCAC 2H .0506 (f)). This documentation is needed for us
to make this decision. If some of this information is proprietary, please notify us
accordingly and we will use the existing DWQ procedures to handle this information.
For instance, you have referred to the cost of Alternative 2 (as discussed in your
401 OversighUExpress Review Permits Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: http:/A12o.enr.state.nc.us/ncwetlands
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March letter) as being $2 million or 3 to 5% of the cash flow compared to your
preferred alternative while the cost of Alternative 1 would be $6 million. Please
address whether these alternatives are practicable in the context of the above
definition.
4. Please be aware that the DWQ approved Quality Assurance Performance Plan
(QAPP) must be submitted to DWQ at the time of the 401 application for our review.
Therefore, we urge you to now begin to work on this product with DWQ staff rather
than waiting for 401 application submittal. DWQ staff will require at least two months
to review the draft QAPP to work towards approval.
5. Monitoring: APGI will need to develop a Flow Monitoring and Compliance Plan for
both developments in consultation with Progress Energy (Progress), the U.S.
Geological Survey (USGS), and other resource agencies. This Plan will then need to
be part of the 401 application and filed with FERC within 12 months of the effective
date of a new license. This monitoring should begin in 2008. The following
provisions will need to be incorporated into the agreement for this project
a. Routine monthly data (hourly and daily averages in spreadsheet format) will be
supplied for information purposes to NCDWQ by the last day of the following
month, (e.g. May data due June 31) via electronic mail. Discrepancies or
deviations from required flows, reservoir levels, or state standards will be briefly
noted, evaluated and discussed. A more detailed assessment along with the
corrective actions will be supplied in the annual report. An annual report,
summarizing the monthly reports will be filed with the appropriate agencies by
March 1.
b. Alcoa will need or provide compliance monitoring of flow at two locations,
downstream of High Rock Dam and also downstream of Falls Dam. USGS has
just completed field reconnisance investigations of these two tailwater areas on
Tuesday to determine the feasibility of installing USGS gages there. Water
quality monitoring (esp. of dissolved oxygen) will be needed at or downstream of
all four APGI dams and monitoring should begin as you stated above.
6. Please provide justification for postponing the beginning of refurbishment/upgrade
work on Tuckertown until 2016, with a completion date of 2018. This appears to
provide a 3 year period of no improvements at Tuckertown.
Thank you for your attention to these matters. If you have any additional questions,
please call me at 919-733-9646.
Sincerely yours,
John Dorney
Cc: Secretary Bill Ross, DENR
Steve Reed, DWR
Jim Mead. DWR
Darlene Kucken, DWQ
Central files
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