20120900 Ver 2_Notice of Completion_20210602

Cube Hydro Carolinas LLC
293 Highway 740
PO Box 575
Badin, NC 28009-0575

1

June 2, 2021

Chonticha McDaniel
NC Department of Environmental Quality
Division of Water Resources
401 & Buffer Permitting
512 N. Salisbury Street, Suite 942-E,
Raleigh, NC 27604

Via E-Mail

Subject: Yadkin Hydroelectric Project (FERC No. 2197)
401 Water Quality Certification Implementation and Compliance

Dear Ms. McDaniel:

The purpose of this letter is to inform and update the North Carolina Department of
Environmental Quality (“NCDEQ”), Division of Water Resources (“DWR”) on the status of
Cube Yadkin Generation, LLC (“Cube Yadkin’s”) construction of the planned improvements
and upgrades that are required by the North Carolina 401 Water Quality Certification - #4035
(the “Certification”), which was reissued by NCDEQ to Cube Yadkin on February 3, 20171. Any
capitalized term used but not otherwise defined in this letter shall have the meaning ascribed to it
in the Certification.

As explained in greater detail in the Improvements and Upgrades table set forth below, Cube
Yadkin is hereby providing NCDEQ with written notice that “all of the improvements and
upgrades required by [the] Certification are complete[]” (Certification Condition No. 11.F) and is
therefore proceeding with immediate cancellation of the Surety Bond, which Cube Yadkin has
maintained in accordance with Condition No. 11.A of the Certification. The chart references
each Notice of Completion Cube Yadkin filed in connection with each required improvement
and upgrade.

For the avoidance of doubt, Cube Yadkin intends to continue maintaining the Monitoring Bond
in accordance with Certification Condition No. 11.A because there are ongoing monitoring
requirements. For your convenience, the status of Cube Yadkin’s monitoring efforts is
summarized in the table of Monitoring Obligations set forth below.

Improvements and Upgrades

Condition No. Update/Status
No. 11 Surety Bond / Monitoring Bond Secured 2017-2021. NCDWR approved the
reduction of the total bond amounts in 2018.
No. 12A FERC Approval for DO Enhancements Complete. All required FERC approvals have
been received.

1 The Certification was originally issued to Alcoa Power Generating Inc. Yadkin Division on October 23, 2015.
Cube Hydro Carolinas LLC
293 Highway 740
PO Box 575
Badin, NC 28009-0575

2

Condition No. Update/Status
No. 12B Installation of Upgrades to Generators at
High Rock and Narrows (Unit 3)
Complete. Through-the-blade aeration has been
installed at each of the three turbines at High
Rock. An aerating turbine was installed and
commissioned at High Rock Unit 1 by April
2019. The aerating turbine at High Rock Unit 2
and High Rock Unit 3 were completed and
commissioned in February 2020 and December
20202, respectively. In late 2017, two draft tube
air valves were installed on Narrows Unit 3.
No. 12C Cone Valves at High Rock, Tuckertown,
and Narrows
Complete. Dedekind cone valves (1 each) were
installed at High Rock and Tuckertown.
Monitoring was conducted to test effectiveness of
the cone valves and report was filed with FERC n
4/30/2018. By letter dated 10/7/2019, NCDWR
approved the use of the linear cone valves at High
Rock and Tuckertown to satisfy the requirements
under Condition 12.C. The installation of an
aerating valve at Narrows has not been required
because the DO standard has consistently been
met since license issuance (99-100% compliance).
No. 12D Assess Need for Installation of DO
Enhancement Technology at Falls
Complete. The Falls 90-day report was included
in the 2018 Annual DO/Temperature Monitoring
Report submitted via email to NCDWR on
3/1/2019. The report concluded that no additional
DO enhancements at Narrows and/or Falls are
necessary at this time.
No. 12E Upgrade Tailwater DO Monitoring
Equipment
Complete. DO/temp monitors collect data from
each of the four tailwaters May 1 – November 30
annually.
No. 12F Update DO Monitoring Plan and QAPP Complete. Revised drafts of the Plan and QAPP
submitted to NCDWR in February 2018.
NCDWR approved the Plan and QAPP by letter
dated 4/18/2018.
No. 12I Notices to the Division Ongoing. Provided as needed and noted herein.
No. 13C Shoreline Management Complete. Stakeholder meeting on 4/6/2017;
FERC approved modifications to SMP appendices
on 10/23/2017; updated SMP filed with FERC on
9/24/2018 and was approved by FERC on
2/4/2019

2 By email dated December 17, 2020, Cube Yadkin notified NCDEQ that Cube Yadkin completed the installation of
the through-the-turbine dissolved oxygen enhancing technology at all three High Rock generating units, and all three
units are operational.

Cube Hydro Carolinas LLC
293 Highway 740
PO Box 575
Badin, NC 28009-0575

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Monitoring Obligations

Condition No. Update/Status
No. 8 Sediment Removal at City of Salisbury
Water Supply Intake

Ongoing. In cooperation with Cube Yadkin,
Carolina Sand Inc. mines sand at the intakes (most
recently spring of 2021) and within 1,000 ft
upstream and downstream of the intakes
continuously.
No. 10A Fish Tissue Sampling Ongoing. Fish tissue samples were collected from
Narrows Reservoir during Fall 2017 and a report
with the results was submitted to NCDWR on
2/2/2018. Per its 2/20/2018 response, NCDWR
did not require addition immediate sampling and
required additional sampling on a 10-year
interval, with the next sampling scheduled to
occur in 2027.
No. 10B Priority Pollutant Discharge Monitoring Ongoing. Monitoring was conducted annually
2017-2020. Results were provided to NCDWR
by email on 11/6/2017; 10/3/2018; 9/23/2019; and
10/4/2020. Data was also filed with FERC. Five
years of monitoring are required, at a minimum;
2021 is the fifth year.
No. 10C Narrows Sediment Sampling Ongoing. Sediment samples were collected
annually, and annual reports were filed with
FERC and NCDWR on 12/6/2017, 10/3/2018,
11/1/2019, and 10/21/2020. Data was also filed
with FERC. Five years of monitoring are
required; 2021 is the fifth year.
No. 12G Optimization of Electrical Generation for
DO Enhancement Using Information from
Upgraded DO Monitoring Equipment
Ongoing. Cube Yadkin has implemented a new
program in the High Rock PLC to control the DO
valves for the 3 units at High Rock. The program
monitors the downstream DO levels at High Rock
and Tuckertown, along with water temperature, to
determine how high to offset the High Rock DO
output to raise the DO levels discharged from
High Rock high enough above the required level
to allow the DO enhanced water to maintain its
DO level in Tuckertown Reservoir until it is
discharged at Tuckertown Dam.

No. 12H DO Annual Report / Provide Data
Quarterly / Every 5 Years include in Annual
Report Assessment of Placement of DO Monitors
Ongoing. Annual reports have been submitted to
NCDWR on 3/1/2017; 3/1/2018; 3/1/2019;
3/1/2020; and 2/26/2021. The reports were also
filed with FERC. DO/temperature data has been
provided to NCDWR on quarterly basis since
2019 (when the license became final and non-
appealable).
Cube Hydro Carolinas LLC
293 Highway 740
PO Box 575
Badin, NC 28009-0575

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Condition No. Update/Status
No. 13A Project Operations / LIP Ongoing. The LIP Stage is calculated the first of
every month and provided to NCDEQ staff and
posted online at Low Inflow Protocol – Cube
Hydro Carolinas (cubecarolinas.com).

Thank you for your support and collaboration as Cube Yadkin has worked to construct and
implement the various project identified in the Certification. Please contact me at [phone]
or [e-mail] if you have questions or need additional information.

Sincerely,

Jody J. Smet, AICP
VP Regulatory Affairs
Eagle Creek Renewable Energy
Cube Yadkin Generation, LLC