20150759 Ver 2_Applicant Draft EA Comments_20160817

Cardinal Energy Service
Financial, Management, & Energy Supply Services
2308 Wheeler Rd.
Raleigh, North Carolina 27612
August 17, 2016
Federal Energy Regulatory Commission
Office of Energy Projects
Washington DC 20426
Reference: Comments regarding Draft Environmental
Assessment
Greetings;
Cell 919 602-6125
ac iven5 a cardinatcnergy.com
Project No. 9842-0006
Ward Mill Hydroelectric Project
Mr. Ray F. Ward
The Applicant has reviewed the Draft Environmental Assessment Issued by the Staff on July 18,
2016, and offers the following comments.
Section 2.0 of the draft Environmental Analysis (ED) beginning on page 8, the staff presents the
Proposed Action and Alternatives. On page I and 12 Section 2.3 included the Staff
Alternatives.
In the initial paragraph of this section, the staff indicates that they do not propose to include the
proposal to implement an erosion control plan. Mr. Ward filed the Shoreline Management Plan.
and the Sediment Management Plan to document the minimal risk and the historical operation of
the project, as well as to move the licensing process forward. Mr. Ward maintains that the
erosion risk remains low and that the operation of the project does not pose a significant risk to
the stability of the shoreline. The requirement of a specific plan is excessive and the applicant
agrees that this should not be included in the license.
Likewise, the applicant's original proposal to install a gauge at the project if the USGS gauge is
discontinued was included as a response to the other parties. The applicant agrees with the staff
alternative that the operation as a run of river project, as assured by regular monitoring and the
operation of the float switch, makes this unnecessary.
The applicant believes that the Impoundinent Drawdown and Refill Plan filed by the Applicant is
sufficient, and that the requirements of the Staff Alternative are inflexible, overly restrictive, and
not consistent with safe operation of this project. Specifically;
A. Emergency Drawdown - It may be necessary to conduct emergency drawdowns when
the flow is below 60 cfs. Emergency drawdowns may be required as a result of
equipment failure, personal injury or risk of personal injury, or a situation which causes
a risk to the risk to the project. The applicant believes that it is unreasonable to impose

the specific drawdown provisions in an emergency situation. Therefore, the applicant
proposes that the drawdown provisions exclude emergency situations.
B. Drawdown. Limit - The proposal to limit the drawdown rate to I foot per day, and the
overly restrictive refill provisions are unnecessary and improper.
In 2012 the Forest Service studied the impact of drawdown and refilling of the
impoundment at a period of low flows. This was discussed in the application and
included on page 21 of the Draft EA, as shown below.
In August 2012, during low flow conditions (i.e., inflow to the project was 42
to 45 cfs; 87 to 88 percent exceedance flows), Cantrell et a]. (2014)
conducted a demonstration impoundment drawdown and refill study at the
project to evaluate river stage and water quality (discussed below) in the
impoundment and tailrace. During the drawdown (two generators operating),
which lasted 2 hours, water depth in impoundment dropped about 3 feet, and
water depth in the tailrace increased about 0.7 feet. Impoundment refill (one
generator operating) lasted about 20 hours, during which water depth in
the impoundment increased by about 3 feet and water depth in the tailrace
decreased by about 0.7 feet.
The applicant believes that this study demonstrates that a relatively rapid controlled
drawdown of the impoundment (3 feet in 2 hours) will impact the water level in the
tailrace by only 0.7 feet with limited adverse impact in the environment of the
impoundment or the tailrace. Likewise, the impoundment was refi

conducted by the Forest Service the impoundment was dropped by 3 feet in 2 hours
and the tailrace rose only 0.7 feet. The impact of the Staff Alternative of limiting
the drawdown to 1 foot per day on the tailrace would be minimal.
In addition to the operational issues, the applicant objects to the limitation on the
drawdown for safety reasons. As discussed in the application, the drawdown
process begins with the running water through the turbines, until the water level is
approximately 4 feet below the top of the dam. At that point, it is necessary to go
onto the dam above the first gate and begin pulling the gate boards out of the gate
with a special hook for that purpose. From a safety standpoint, it is best for the
operator to stay in position and remove boards until the water level is reduced
sufficiently, rather than have to engage in this repeatedly over several days.
The applicant believes there should not be a specific limit on the daily drawdown of
the impoundment because:
1. the site experiences significantly greater natural variations in the water level
without adverse impact,
2, the studies conducted by the Forest Service did not show significant adverse
impact form much the studies with greater fluctuations in water level, and
3. The safety of the operator is at greater risk if the drawdown is prolonged.
C. Refill. The applicant believes that the operation of this project requires flexibility in the
refill of the impoundment, and points to the results of the information supplied by
Interior, and by the recent load flow information.
On pages 26 and 27 of the Draft EA states:
Cantrell et al (2014) demonstrated that the water quality was generally good in the
project impoundment and the tailrace during the demonstration drawdown and
refill study (study) conducted under very low flows. In the tailrace, DQ did not
decline below the state standard 6.- mg/L and water temperature did not exceed
the state standard 84.2°F, including during refill when no flow (other than
leafage) was released to the tailrace.
The applicant believes that this actual study by Interior shows specifically that at flows
between 42 efs and 45 efs the water quality of the water in the tailrace is within of the
state standards.
While the applicant recognizes the importance of maintaining sufficient flow in the
tailrace and operating with at least 60 efs when possible to maintain the water quality
below the dam, the applicant believes that it is also necessary to maintain or restore the
water quality in the impoundment after a drawdown. Under a restrictive refill
prevision, the impoundment could remain at the drawdown level for weeks waiting for
sufficient flow to replace the boards and raise the level of the impoundment.

As the USGS gaga graph shows,
there have been many hours and
2000
days during the summer of 2016
r
that the flow has been below 60°"
Qu 1
cfs. Under the proposed
restriction for refilling only when
the flow is at or above 60 efs,
there may be many days when
the impoundment would have to
U 100
remain drained. If the operator
0
had the flexibility to refill the
U
impoundment the water quality in
20
both the impoundment and the
tailrace could be enhanced.
USGS 03479000 MRTRUGR RIVER HEAR SUGAR GROVE,
Jun Jun Jun Jun Jul Jul Jul
04 11 18 25 02 89 16
As an example, had the impoundment been lowered on July 18 2016, as shown on the
graph, the flow would not have been sufficient to refill the impoundment for well over
a week. Thus, the boards would have remained out of the gates, the impoundment
would be drained, and the existing flow would have been going through the gates. On
the evening of July 27 a storm in another part of the watershed increased the flow at the
gage from 46 efs to over 1,100 cfs in 3 hours. There would have been no opportunity
to replace the gate boards and the flood would have -rushed through the gate, filled the
impoundment temporarily with the gates open, then drained the next day as the flood
subsided. Only after the flow returned to a flow between 60 cfs and 100 cfs; would it be
safe to replace the gate boards and refill the impoundment.
Considering the small size of the impoundment, the fact as discussed above that the
water quality is not compromised at the 45 cfs level, and benefits to the environment of
the impoundment when refilled, the applicant believes that it is appropriate for the
operator to have the flexibility to refill the project.
The applicant proposes that the license require the operator maintain an Irripoundi-nent drawdown
and Refill Plan in conjunction with the agencies, and that the plan reflect the environment of the
tailrace and well as the impoundment, as well as the functional operation of the facility. The
applicant believes that the plan previously filed does that and should be approved.
Sincerely
Andrew C. Givens
For: Ray F. Ward, applicant
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