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HomeMy WebLinkAbout20080915 Ver 3_10-27-16 AI Response_20161027& DUKE ENERGY October 27, 2016 Ms. Karen Higgins 401 & Buffer Permitting Branch Supervisor Division of Water Resources Department of Environmental Quality 512 N. Salisbury Street, Suite 942-E Raleigh, NC 27604 Re: Amendment of Water Quality Certification No. 3767 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project 2232 Request for Additional Information Dear Ms. Higgins: Water Strategy, Hydro Licensing, and Lake Services Duke Energy 526 S. Church Street/ EC12Y Charlotte, NC 28202 Duke Energy Carolinas, LLC ("Duke Energy"), licensee for the Catawba-Wateree Hydroelectric Project ("Project"), has received the NC Division of Water Resources' ("NCDWR") Request for Additional Information ("RAI") dated October 24, 2016 regarding the subject Water Quality Certification ("WQC") amendment application filed by Duke Energy on September 9, 2016. Duke Energy responds to the six requested items as follows: Duke Energy will incorporate the typographical corrections and other edits described in RAI items 2., 4., 5., and 6. as well as any changes agreed to below into a revised application and resend to NCDWR via electronic delivery. RAI item 1. states on application page numbers 5 through 7 the present and proposed pool elevations throughout the year are misleading in that most of October the elevation is at a different level than is communicated by the tables and the tables should include specific dates that the elevations are in effect. Duke Energy Response Duke Energy discussed this item with NCDWR staff on October 25, 2016. On application page number 5 paragraph (A) Reservoir Elevations contains the necessary information to interpret the reservoir elevation charts that follow. Specifically, the last sentence of this paragraph states: "The elevations included in the tables are for the first day of the given month; elevations for other days of the month are determined by linear interpolation." NCDWR staff agreed this information is sufficient to interpret the reservoir IIs. Karen Higyins Page 2 October 27, 2016 elevation charts but requested the last sentence of parayraph (A) be highlighted by bold font to make it more noticeable. Duke Energy ayrees to this change_ RAI item 3. requests an explanation of measures to minimize risk of vandalism to water quality monitors and what procedures will be implemented it data is lost. Dukefrrergy Response These monitors will not be intentionally located in risk -prone areas, but vandalism is a common risk regardless of locatiun_ Locating monitoring equipment on Duke Energy property provides additional security due to restricted access and security camera coverage. However, to assure representative data is collected, some monitors will be located either on a highway or rail bridge, or from a shore location further downstream of the hydro development, where public access cannot be controlled. Duke Energy is taking advantage of the U5 Geological Survey's (USGS) expertise in locating and designing munitur stations to reduce vandalism risks. USGS water quality monitoring sites generally employ the following standard approaches in an attempt to discourage vandalism: 1) control center cabinets are of heavy aluminum and kept locked; 2) instrument cabling is routinely shielded within conduit; 3) solar panels and transmitting antennae are mounted considerably higher than might be reached by anyone at ground level; 4) deployments with equipment located on bridge decks on heavily traveled bridyes will discourage vandalism due to the increased level of visibility by other members of the public, law enforcement, etc.; 5) selected deployments at most at -risk sites may be protected by an elevated mounting position, fences topped with concertina wire, and/or or use of lockable shields or doors at key access points. Duke Energy's contractual arranyement with the USGS for maintaininy the water quality monitoring sites will cover the replacement of instrument losses. I he USGS generally maintains a supply of instrument spares and other key components that would facilitate a relatively rapid replacement of damaged or lost equipment. Because the USGS staff generally performs a daily (remote) check of each site, lost data from aii equipment outage should be minimized. Data recovery and/or filling data gaps will be perffarmed by USGS to the extent possible. It there are questions or if further intormation is required, please contact me (704-382-5776; IVIark.Oakley@ duke-eneryy.com). Sincerely, E_ Mark Oakley, E. Catawba-Wateree Relicensing Project Manayer Water Strategy, Rydro Licensing, and Lake Services Duke Energy cc: Secretary Kimberly D. Bose, Federal Energy Regulatory Commission Fred Tarver, NC Division of water Resources Cory Larsen, NC Division of Water Resources Corey Basinyer, IAC Division of Water Resources Landon Davidson, NC Division of Water Resources Chris Gaudreau, NC Wildlife Resources Commission Ms. Karen Higgins Page 3 October 27, 2016 Jeff Lineberger, Duke Energy Garry Rice, Duke Energy Randy Herrin, Duke Energy George Galleher, Duke Energy Lynne Dunn, Duke Energy Keith Finley, Duke Energy Phil Fragapane, Duke Energy Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Introduction Duke Energy Carolinas, LLC (Duke Energy) submits this Application for Amendment of the Water Quality Certification (WQC) issued for the Catawba-Wateree Hydroelectric Project. For consistency and simplicity, this application is being filed with both the North Carolina Department of Environmental Quality (NCDEQ) to amend North Carolina Certification No. 3767 issued November 14, 2008 and the South Carolina Department of Environmental Control (SCDHEC) to amend South Carolina Certification DHEC 08-C-001 issued February 12, 2015. Most revisions apply to both states and one applies to South Carolina only. The applicability of each revision to each state is clearly identified within the descriptions of the individual revisions. Duke Energy acknowledges each state will process this application independently and are under no constraint to synchronize their processing of this application with the other state. Background This amendment is necessary due to the changes to the changes listed below. These changes affect certain sections and appendices of the Catawba-Wateree Comprehensive Relicensing Agreement (CRA) dated December 22, 2006 which are also incorporated by reference as conditions of the original WQCs. CRA Parties have found it to be beneficial to improve regional drought resiliency 1. by raising reservoir summer target elevations on Lakes James, Norman, and Wylie by an additional 6” from May 1 – October 1 and to make a public safety improvement by modifying the 6,000 cubic feet per second (cfs) recreation flow release from the Wylie Development to 3,000 cfs. Duke Energy voluntarily initiated revisions to update the Low Inflow Protocol 2. (LIP) and the Maintenance and Emergency Protocol (MEP) in accordance with 1 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 the CRA based on experience gained during voluntary implementation of these protocols since 2006. 3.The license issued for the Catawba-Wateree Hydroelectric Project on November 25, 2015 requires Duke Energy to file both a Water Quality Monitoring Plan (WQMP) and a Flow and Water Quality Implementation Plan (FWQIP). These plans are presented in CRA Appendices F and L respectively. During the time since these CRA provisions were developed in 2006, some of these provisions, their status and implementation schedule have changed. Affected WQC Conditions The affected WQC conditions are: Condition 1; CRA - Appendices Appendix A A-1.0 Reservoir Elevation Articles; Reservoir Elevations (applies to NC and SC) A-2.0 Flow Articles; Recreation Flows (applies to SC only) Appendix C: Low Inflow Protocol (LIP) Article (applies to NC and SC) Appendix D: Maintenance and Emergence Protocol (MEP) Article (applies to NC and SC) Appendix F: Water Quality Monitoring Plan (WQMP) (applies to NC and SC) Appendix L: Flow and Water Quality Implementation Plan (FWQIP) (applies to NC and SC) Detailed Description of Revisions Revisions to each of the affected WQC Conditions previously listed are described in detail in the following sections of this application and include: Statement of revision;  Background information explaining the need for the revision;  2 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Actual text of the revision - for ease of identification, text modified from  the December 22, 2006, Signature Copy of the CRA, Revision 1 is shown in bold italics (with only the exception of the revised Water Quality Monitoring Plan); Identification and assessment of any incremental environmental impacts of  the revision compared to the original WQC; and Consultation Summary.  Consultation On July 15, 2016 Duke Energy submitted this Application for Amendment in draft form to state and federal resource agencies and the Catawba Indian Nation for consultation. All consultation comments received for each revision are summarized, including Duke Energy’s responses, which have been incorporated into this application. All consultation documentation for all revisions is included in Attachment A. 3 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix A, A-1.0 Reservoir Elevation Articles; Reservoir Elevations (applies to NC and SC) Statement of Revision Add six inches to James, Norman, and Wylie summer Normal Target Elevations. Background information explaining the need for the revision This revision was evaluated as part of the Catawba-Wateree Water Management Group’s (CWWMG) Water Supply Master Plan (WSMP) development (http://www.catawbawatereewmg.org/water-supply-master-plan/read-the-report/). The Catawba-Wateree Water Management Group (CWWMG) is a 501C-3 non-profit organization established “to identify, fund, and manage projects that will help preserve, extend, and enhance the capabilities of the Catawba-Wateree River Basin to provide water resources for human needs while maintaining the ecological integrity of the waterway.” The CWWMG has 19 members, one member representing each of the eligible 18 public water utilities in North and South Carolina that operate water intakes on either a reservoir or regulated river reach of the main stem, and one member representing Duke Energy. The organization was born out of the Catawba-Wateree Hydroelectric Project relicensing process completed by Duke Energy. The purpose of this WSMP is to protect, preserve, and extend the available water supply in the Catawba-Wateree River and its 11 reservoirs. The work effort, results, and recommendations presented were developed by the CWWMG, regulatory officials from North and South Carolina, and a Stakeholder Advisory Team (SAT). This specific revision involves raising the summer target operating levels six inches in three of the larger Catawba-Wateree reservoirs (Lake James, Lake Norman and Lake Wylie). This modification has been approved by all CRA Parties. Pending successful amendment of the WQC, this modification will be filed with the FERC as a license amendment. Actual text of the revision (For ease of identification, text modified from the December 22, 2006, Signature Copy of the CRA, Revision 1 is shown in bold italics) 4 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix A, pages A-1 and A-2: ARTICLE – Reservoir Elevations (A) Reservoir Elevations – Within 60 days following the issuance of this license, to protect and enhance the Project’s values that may be affected by reservoir level fluctuations, the Licensee shall maintain the elevations of the Project reservoirs between the Normal Minimum and Normal Maximum Elevations indicated in the tables below and shall endeavor in good faith to achieve the Normal Target Elevations in the tables. All elevations in the tables below are relative to the top of the dam (including floodgates and flashboards where The elevations included in the applicable) with 100.0 ft. = Full Pond Elevation. tables are for the first day of the given month; elevations for other days of the month are determined by linear interpolation . Lake James (Full Pond is 1200.0 ft. above Mean Sea Level (MSL)) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January 93 96 100 February 92 94 100 March 92 95 100 April 92 96 100 98 (98.5 after Wateree Dam is modified to improve flood May - October 95 100 management or 12/31/2025 whichever is later) November - December 93 96 100 5 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Lake Rhodhiss (Full Pond is 995.1 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January - December 94 97 100 Lake Hickory (Full Pond is 935.0 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January - February 94 96 100 March – December 94 97 100 Lookout Shoals Lake (Full Pond is 838.1 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January - December 94 97 100 Lake Norman (Full Pond is 760.0 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January 93 96 100 February 91 94 100 March 92.26 95.26 100 April 93.65 96.65 100 98 (98.5 after Wateree Dam is modified to improve flood May - October 95 100 management or 12/31/2025 whichever is later) 6 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 November 93.98 97 100 December 93 96 100 Mountain Island Lake (Full Pond is 647.5 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January - December 94.3 96 100 Lake Wylie (Full Pond is 569.4 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January - April 94 97 100 97 (97.5 after Wateree Dam is modified to improve flood May - October 94 100 management or 12/31/2025 whichever is later) November - December 94 97 100 Fishing Creek Reservoir (Full Pond is 417.2 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January - December 95 98 100 Great Falls Reservoir (Full Pond is 355.8 ft. MSL) Normal Minimum Normal Target Normal Maximum Month (ft.)(ft.)(ft.) January - December 95 97.5 100 7 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Identification and assessment of any incremental environmental impacts of the revision compared to the original WQC. As recommended in the WSMP, an operating level increase in these reservoirs would represent access to a greater volume of water during typically drier summer months than is currently available under the existing target elevations. Modeling results indicate that this strategy, alone, could extend the water yield of the Catawba-Wateree lake system by one decade beyond the baseline conditions. When coupled with other strategies recommended in the WSMP, this strategy will help extend the system water yield by an additional 40 to 50 years beyond baseline conditions, for an adequate water supply lasting into the next century. This will provide additional water volume for water supply, recreational uses and environmental resources during periods of extreme drought. This operational modification was modeled for any significant risk of exacerbating downstream high-water events. Both the number of spill events and the duration of spill events (days over local elevation 100.2 ft and days over local elevation 103 ft) are summarized below. Out of a base analysis period of record of 29,330 days (82 years), the modeling predicts the change in the number of spill days at any location without spill gates to not exceed 0.06% of the analysis period. This operational modification creates no significant increase in the risk of high-water events. CHEOPS Model Results (Notes 1, 2) Period of Record 1929 to Number of Spill Events Days Over Elevation 100.2 ft Days Over Elevation 103 ft 2010 (29,950 days) 6" Summer 6" Summer 6" Summer Target Increase Target Increase Target Increase at James, at James, at James, Ungated Dam Locations Baseline Baseline Baseline Norman, and Norman, and Norman, and Wylie Wylie Wylie Lake James 63 70 160 177 6 7 Lake Rhodhiss 255 260 604 605 26 29 Lookout Shoals Lake 817 810 1,075 1,086 42 43 Mountain Island Lake 140 134 183 190 41 36 Great Falls Reservoir 209 213 2,952 2,904 828 837 Lake Wateree 280 282 266 267 26 25 Note 1 - Baseline Scenario uses New License requirements, projected water withdrawals. Note 2 - Six-inch Summer Target Increase applies May 1 to October 1. 8 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Consultation Summary No comments received for this revision. 9 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix A, A-2.0 Flow Articles; Recreation Flows (applies to SC only) Statement of Revision Change 6,000 cfs recreation flow release at Wylie Hydro Station to 3,000 cfs Background information explaining the need for the revision Appendix A-2.0 in the CRA lists a series of recreational flows for five sections of the Catawba- Wateree River. These flow rates are based on actual flow studies, which were carried out in 2004. Duke Energy made a series of different flow releases and groups of canoeists and kayakers of varying skill levels made an assessment of what was considered to be a suitable level. The flow tables in the CRA reflect the outcome of these assessments. Duke Energy made the decision to follow the CRA recreational flows voluntarily as soon as the original CRA was signed, rather than wait for the license to be issued. With the delay in FERC issuing the license, this has given us seven full seasons of experience with recreational flows. With one exception these flows have worked out as anticipated. The area of concern is the recreation flow releases from Lake Wylie. At this location the CRA calls for 3,000 cubic foot per second (cfs) recreation flow releases in the spring and fall and 6,000 cfs recreation flow releases during the summer. The 6,000 cfs recreation flow was included because it was thought that the higher water level gave the paddling trip an added experience value. During the past seven years paddlers, including the Carolina Canoe Club, have been able to assess the flows and also to get a feel for the type of boater using this section. Paddlers have found 3,000 cfs provides a perfectly satisfactory experience, but the 6,000 cfs level has proved to be a challenge to the skill levels of the more typical paddlers using this section. In fact, for safety reasons Catawba River Expeditions – one of the few outfitters running commercial trips on this section of the river – has chosen not to run river trips at the 6,000 cfs level. Tubing has increased in popularity and this adds to the need to drop back to 3,000 cfs throughout the season. 10 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 This modification has been approved by all CRA Parties. Pending successful amendment of the WQC, this modification will be filed with the FERC as a license amendment. Actual text of the revision (for ease of identification, text modified from the December 22, 2006, Signature Copy of the CRA, Revision 1 is shown in bold italics) 11 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix A, page A-6: (C) Wylie Development – Within 60 days following issuance of this license, the Licensee shall provide recreational flow releases at the Wylie Development in accordance with the following schedule in the table below. In addition, the Licensee shall, from May 1 to July 15 inclusive, release at least 1,300 cfs for six hours prior to the recreational flow release scheduled start times shown in the table below to ensure suitable water levels at Landsford Canal State Park. Wylie Development Recreational Flow Schedule Flow (at or Dates above) Days / Description Hour Start Hour End (inclusive) (cfs) Last full weekend – Saturday Apr 1-Apr 30 3,000 10:00 am 4:00 pm and Sunday Each Friday, Saturday and May 1-Jun 15 3,000 10:00 am 4:00 pm Sunday plus Memorial Day Each Friday, Saturday and Jun 16-Jul 15 3,000 10:00 am 4:00 pm Sunday plus Independence Day Jul 16-Aug Each Saturday and Sunday 3,000 10:00 am 4:00 pm 31 Sep 1-Sep Each Friday, Saturday and 3,000 10:00 am 4:00 pm 30 Sunday plus Labor Day Oct 1-Oct 31 Each Saturday and Sunday 3,000 10:00 am 4:00 pm 12 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Identification and assessment of any incremental environmental impacts of the revision compared to the original WQC This change will improve paddling and tubing safety for a broader range of public skill and experience levels while still providing scheduled recreational flow releases. Consultation Summary No comments received for this revision. 13 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix C: Low Inflow Protocol (LIP) Article (applies to NC and SC) Statement of Revision General revisions to the LIP to incorporate experience to-date, to be consistent with the preceding two CRA revisions, and to implement improvements resulting from the Water Supply Master Plan (WSMP). Background information explaining the need for the revision The LIP was evaluated as part of the Catawba-Wateree Water Management Group’s (CWWMG) Water Supply Master Plan (WSMP) development (http://www.catawbawatereewmg.org/water- supply-master-plan/read-the-report/). Through this revision, Duke Energy is implementing items identified in and determined to be beneficial via the development of the WSMP. Some LIP revisions are necessary to make the LIP consistent with previously discussed revisions to reservoir target elevations and recreation flow releases. In addition, the CRA requires that during the term of the New License, the Catawba- Wateree Drought Management Advisory Group (CW-DMAG) will review and update the LIP periodically to ensure continuous improvement of the LIP and its implementation. The LIP established the CW- DMAG to work with Duke Energy when the LIP is initiated to foster a basin-wide response to a Low Inflow Condition. These evaluations and modifications are to be considered at least once every five years during the term of the license recently issued on November 25, 2015. Even though the license has been issued for less than five years, experience gained from voluntarily implementing the LIP since 2006 has yielded revisions for clarifications and improvements. The CW-DMAG has concurred in these revisions. Actual text of the revision (for ease of identification, text modified from the December 22, 2006, Signature Copy of the CRA, Revision 1 is shown in bold italics) 14 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 APPENDIX C: LOW INFLOW PROTOCOL (LIP) FOR THE CATAWBA-WATEREE PROJECT PURPOSE The purpose of this Low Inflow Protocol (LIP) is to establish procedures for reductions in water use during periods of low inflow to the Catawba-Wateree Project (the Project). The LIP was developed on the basis that all parties with interests in water quantity will share the responsibility to establish priorities and to conserve the limited water supply. OVERVIEW This LIP provides trigger points and procedures for how the Project will be operated by the Licensee, as well as water withdrawal reduction measures and goals for other water users during periods of low inflow (i.e., periods when there is not enough water flowing into the Project reservoirs to meet the normal water demands while maintaining Remaining Usable Storage in the reservoir system at or above a seasonal target level). The Licensee will provide flow from hydro generation and other means to support electric customer needs and the instream flow needs of the Project. During periods of normal inflow, reservoir levels will be maintained within prescribed Normal Operating Ranges. During times that inflow is not adequate to meet all of the normal demands for water and maintain reservoir levels as normally targeted the Licensee will progressively reduce hydro generation. If hydrologic conditions worsen until trigger points outlined herein are reached, the Licensee will declare a Stage 0 - Low Inflow Watch and begin meeting with the applicable agencies and water users to discuss this LIP. If hydrologic conditions continue to worsen, the Licensee will declare various stages of a Low Inflow Condition (LIC) as defined in the Procedure section of this document. Each progressive stage of the LIC will call for greater reductions in hydro station water releases and water withdrawals, and allow additional use of the available water storage inventory. The goal of this staged LIP is to take the actions needed in the Catawba-Wateree River Basin to delay the point at which the Project’s usable water storage inventory is fully depleted. While there are no human actions that can guarantee the Catawba-Wateree River Basin will never experience operability limitations at water intake structures due to low reservoir levels or low streamflows, this LIP is intended to provide additional time to allow precipitation to restore streamflow, reservoir levels, and groundwater levels to normal ranges. The amount of additional time gained during the LIP depends primarily on the diagnostic accuracy of the trigger points, the amount of regulatory flexibility the Licensee has to operate the Project, and the effectiveness of the Licensee and other water users in working together to implement their required actions and achieve significant water use reductions in a timely manner. To ensure continuous improvement regarding the LIP and its implementation throughout the term of the New License, the LIP will be re-evaluated and modified periodically. These re-evaluations and modifications will be as determined by the Catawba-Wateree Drought Management Advisory Group (CW-DMAG). 15 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 KEY FACTS AND DEFINITIONS 1.Human Health and Safety and the Integrity 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, protect the equipment of the Large Water Intake Owners 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 LIP will limit the states of North Carolina and South Carolina from taking any and all lawful actions necessary within their jurisdictions to protect human health and safety. It is recognized that North Carolina and South Carolina may also take the steps necessary to protect these things without prior consultation or notification. 2.No Abrogation of Statutory Authority – It is understood the South Carolina Department of Natural Resources (SCDNR) must operate under the statutory authority of its drought response statutes, and nothing in this LIP will require the SCDNR to take any action that exceeds its authority under their drought response statute. 3.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 Full Pond Elevation for all of its reservoirs as equal to 100.0 ft. relative. The Full Pond Elevations for the Project reservoirs are as follows: Full Pond Elevation Reservoir (ft. above Mean Sea Level) Lake James 1200.0 Lake Rhodhiss 995.1 Lake Hickory 935.0 Lookout Shoals Lake 838.1 Lake Norman 760.0 Mountain Island Lake 647.5 Lake Wylie 569.4 Fishing Creek Reservoir 417.2 Great Falls Reservoir 355.8 Cedar Creek Reservoir 284.4 Lake Wateree 225.5 16 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 4.Net Inflow – The cumulative inflow into a reservoir, expressed in acre-feet (ac-ft) per month. Net inflow is the sum of tributary stream flow, inflow from upstream hydro development flow releases (where applicable), groundwater inflow, precipitation falling on the reservoir surface, land surface runoff, and on-reservoir point-source return flows, less the sum of on-reservoir water withdrawals, groundwater recharge, hydro development flow releases, evaporation, and other factors. 5.Normal Minimum Elevation – The level of a reservoir (measured in feet above Mean Sea Level (MSL) or feet relative to the full pond contour with 100.0 ft. corresponding to full pond) that defines the bottom of the reservoir’s Normal Operating Range for a given day of the year. If inflows and outflows to the reservoir are kept within some reasonable range of the average or expected amounts, hydroelectric project equipment is operating properly and no protocols for abnormal conditions have been implemented, reservoir level excursions below the Normal Minimum Elevation should not occur. 6.Normal Maximum Elevation – The level of a reservoir (measured in feet above MSL or feet relative to the full pond contour with 100.0 ft. corresponding to full pond) that defines the top of the reservoir’s Normal Operating Range for a given day of the year. If inflows and outflows to the reservoir are kept within some reasonable range of the average or expected amounts, hydroelectric project equipment is operating properly, and no protocols for abnormal conditions have been implemented, reservoir level excursions above the Normal Maximum Elevation should not occur. 7.Normal Target Elevation – The level of a reservoir (measured in feet above MSL or feet relative to the full pond contour with 100.0 ft corresponding to full pond) the Licensee will endeavor in good faith to achieve, unless operating in this LIP, the Maintenance and Emergency Protocol (MEP), the Spring Reservoir Level Stabilization Program (Lakes James, Norman, Wylie and Wateree only), a Spring Stable Flow Period (Lake Wateree only) or a Floodplain Inundation Period (Lake Wateree only). Since inflows vary significantly and outflow demands also vary, the Licensee will not always be able to maintain actual reservoir level at the Normal Target Elevation. The Normal Target Elevation falls within the Normal Operating Range, but it is not always the average of the Normal Minimum and Normal Maximum Elevations. 8.Normal Operating Range for Reservoir Levels – The band of reservoir levels within which the Licensee normally attempts to maintain a given reservoir that it operates on a given day. Each reservoir has its own specific Normal Operating Range, and that range is bounded by a Normal Maximum Elevation and a Normal Minimum Elevation. If inflows and outflows to the reservoir are kept within some reasonable range of the average or expected amounts, hydro project equipment is operating properly and no protocols for abnormal conditions have been implemented, reservoir level excursions outside of the Normal Operating Range should not occur. The New License for the Project includes the Normal Operating Ranges for reservoir levels (i.e., Normal Minimum, Normal Maximum, and Normal Target Elevations) as listed in the Reservoir Elevations License Article. 9.Large Water Intake – Any water intake (e.g., public water supply, industrial, agricultural, power plant, etc.) having a maximum instantaneous capacity greater than or equal to one Million Gallons per Day (MGD) that withdraws water from the Catawba-Wateree River Basin. 10.Public Water Supply (PWS) – Any water delivery system owned and/or operated by any governmental or private entity that utilizes waters from the Catawba-Wateree River Basin for 17 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 the public interest including drinking water; residential, commercial, industrial, and institutional uses; irrigation, and/or other public uses. 11.Critical Reservoir Elevation – Unless it is otherwise stated as applying only to a specific intake or type of intake, the Critical Reservoir Elevation is the highest level of water in a reservoir (measured in feet above MSL or feet relative to the full pond contour with 100.0 ft. corresponding to full pond) below which any Large Water Intake used for PWS or industrial uses, or any regional power plant intake located on the reservoir will not operate at its Licensee-approved capacity. The Critical Reservoir Elevations, as of December 31, 2016, are defined below: Critical Reservoir Elevation Reservoir (ft. relative to local datum) Type of Limit (100 ft = Full Pond) Lake James 50.0 Power Production Lake Rhodhiss 89.4 Municipal Intake Lake Hickory 94.0 Municipal Intake Lookout Shoals Lake 74.9 Municipal Intake Lake Norman 90.0 Power Production Mountain Island Lake 90.5 Municipal Intake Lake Wylie 92.6 Industrial Intake Fishing Creek Reservoir 95.0 Municipal Intake Great Falls Reservoir 87.2 Power Production Cedar Creek Reservoir 80.3 Power Production Lake Wateree 92.5 Municipal Intake 12.Total Usable Storage (TUS) – The sum of the Project’s volume of water expressed in ac-ft contained between each reservoir’s Critical Reservoir Elevation and the Full Pond Elevation. 13.Remaining Usable Storage (RUS) – The sum of the Project’s volume of water expressed in ac-ft contained between each reservoir’s Critical Reservoir Elevation and the actual reservoir elevation at any given point in time. 14.Storage Index (SI) – The ratio, expressed in percent, of RUS to TUS at any given point in time. 15.Target Storage Index (TSI) – The ratio of RUS to TUS based on the Project reservoirs being at their Normal Target Elevations. The following table lists the TSIs for the first day of each month: 18 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Month Target Storage Index for 1 Day of Target Storage Index for 1 Day stst Month (%) of Month (%) (Modified) 112 Jan 63 63 Feb 54 54 Mar 63 63 Apr 70 70 May 77 80 Jun 77 80 Jul 77 80 Aug 77 80 Sep 77 80 Oct 77 80 Nov 71 71 Dec 64 64 1 Target Storage Indices for other days of the month are determined by linear interpolation. 2 Future modified Comprehensive Relicensing Agreement (CRA) values for Normal Target Elevation for Lake James, Lake Norman and Lake Wylie shall become effective after Wateree Dam is modified to improve flood management or after December 31, 2025, whichever is later. 16.U.S. Drought Monitor – A synthesis of multiple indices, outlooks, and news accounts that represents a consensus of federal and academic scientists concerning the drought status of all parts of the United States. Typically, the U.S. Drought Monitor indicates intensity of drought as D0-Abnormally Dry, D1-Moderate, D2-Severe, D3-Extreme, and D4-Exceptional. The website address is http://droughtmonitor.unl.edu. The following federal agencies are responsible for maintaining the U.S. Drought Monitor: Joint Agricultural Weather Facility (U.S. Department of Agriculture and Department of  Commerce/National Oceanic and Atmospheric Administration\[DOC/NOAA\]) Climate Prediction Center (DOC/NOAA/National Weather Service)  National Centers for Environmental Information (DOC/NOAA)  17.U.S. Drought Monitor Three-Month Numeric Average – If the U.S. Drought Monitor has a reading of D0-D4 for any part of the Catawba-Wateree River Basin that drains to Lake Wateree, the Basin will be assigned a numeric value for the current month. This monthly numeric value will equal the area-weighted average Drought Monitor designation (e.g., D0 = 0, D4 = 4) for the Catawba-Wateree River Basin that drains to Lake Wateree. A normal condition in the Basin, defined as the absence of a Drought Monitor designation, would be assigned a numeric value of negative one (-1). A running average numeric value of the current month and the previous two months will be monitored and designated as the U.S. Drought Monitor Three-Month Numeric Average. 18.Critical Flows – The minimum flow releases from the hydro developments that may be 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; 19 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 b.provide some basic level of operability for Large Water Intakes located on the affected stream reaches; and, c.provide some basic level of water quality maintenance in the affected stream reaches. For the purposes of this LIP, the Critical Flows are as follows: a.Linville River, below the Bridgewater Development (Lake James): 75 cubic feet per second (cfs). b.Catawba River Bypassed Reach below the Bridgewater Development (Lake James): 25 cfs. c.Oxford Regulated River Reach below the Oxford Development (Lake Hickory): 100 cfs. d.Lookout Shoals Regulated River Reach below the Lookout Shoals Development: 80 cfs. e.Wylie Regulated River Reach below the Wylie Development: 700 cfs. f.Great Falls Bypassed Reaches (Long and Short) at the Great Falls-Dearborn Development: 450 cfs and 80 cfs respectively. g.Wateree Regulated River Reach below the Wateree Development: 800 cfs. h. Leakage flows at the remaining Project structures. Leakage flows are defined as the flow of water through wicket gates when the hydro units are not operating and seepage through the Project structures at each development. 19.Recreation Flow Reductions – Since all recreation flow releases must be made by either releasing water through hydroelectric generation or through flow releases that bypass hydro generation equipment, reductions in Project Flow Requirements will impact recreation flow releases. 20.Organizational Abbreviations – Organizational abbreviations include the North Carolina Department of Environmental Quality (NCDEQ), North Carolina Wildlife Resources Commission (NCWRC), SCDNR, South Carolina Department of Health and Environmental Control (SCDHEC), Federal Energy Regulatory Commission (FERC), National Marine Fisheries Service (NMFS), United States Bureau of Indian Affairs (BIA), United States Fish and Wildlife Service (USFWS) and the United States Geological Survey (USGS). 21.CW-DMAG – The CW-DMAG will be tasked with working with the Licensee when the LIP is initiated. This team will also meet as necessary to foster a basin-wide response to a LIC (see Procedure section of this LIP). Members of the CW-DMAG agree to comply with the conditions of this LIP. Membership in the CW-DMAG is open to the following organizations, of which each organization may have up to two members, with one vote per organization for making decisions: a.NCDEQ b.NCWRC c.NMFS d.SCDNR e.SCDHEC f.USFWS g.USGS 20 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 h.Each Owner of a Large Water Intake located on one of the Project reservoirs or the main stem of the Catawba-Wateree River i.Each Owner of a Large Water Intake located on any tributary stream within the Catawba-Wateree River Basin that ultimately drains to Lake Wateree j.Licensee (CW-DMAG Coordinator) The CW-DMAG will meet at least annually (typically during the month of May) beginning in 2007 and continuing throughout the term of the New License, regardless of the LIC status, to review prior year activities, discuss data input from Large Water Intake Owners, and discuss other issues relevant to the LIP. The Licensee will maintain an active roster of the CW-DMAG and update the roster as needed. The Licensee will prepare meeting summaries of all CW- DMAG meetings and will make these meeting summaries available to the public by posting on its Web site. 22.Revising the LIP – D uring the term of the New License, the CW-DMAG will review and update the LIP periodically to ensure continuous improvement of the LIP and its implementation. These evaluations and modifications will be considered at least once every five (5) years during the New License term. Modifications must be approved by a consensus of the participating CW-DMAG members. If the participating members cannot reach consensus, then the dispute resolution procedures set forth in Section 31.0 of the CRA will apply. Approved modifications will be incorporated through revision of the LIP and the Licensee will file the revised LIP with the FERC. If any modifications of the LIP require amendment of the New License, the Licensee will: (i) provide notice to all Parties to the CRA advising them of the proposed license article submit the modification amendment and the Licensee’s intent to file it with the FERC; (ii) request to the NCDEQ and/or the SCDHEC for formal review and approval as may be required by any reopener conditions of the respective state's 401 Water Quality Certification for the Project ; and (iii) file a license amendment request for FERC approval. During this process, the CW-DMAG may appoint an ad hoc committee to address issues and he filing of a revised LIP by the Licensee will not constitute or revisions relevant to the LIP. T require modification to the CRA and any Party to the CRA may be involved in the FERC’s public process for assessing the revised LIP. Issues such as sediment fill impact on reservoir storage volume calculations, revising the groundwater monitoring plan and substitution of a regional drought monitor for the U.S. Drought Monitor, if developed in the future, are examples of items that may be addressed. 23.Water Withdrawal Data Collection and Reporting – The Licensee will maintain information on cumulative water use from Project reservoirs beginning in 2006 and continuing throughout the term of the New License and will make the information available to water intake owners and governmental agencies upon their request. The Licensee will require a ll owners of Large Water Intakes located within the FERC Project Boundaries to report to the Licensee, on an annual basis in MGD, their average monthly water withdrawals from and flow returns to the Project or its tributary streams that drain to Lake Wateree. The Licensee will maintain a database of this information including the Licensee’s own non-hydro water use records (i.e., water uses due to thermal power generation). These annual withdrawal summaries will be in writing, certified for accuracy by a professional engineer or other appropriate official, and will be provided to the Licensee by January This information may 31 of each year for the preceding calendar year beginning in 2007. be used to determine if future increased water withdrawals would be within the projections of 21 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 the Water Supply Study conducted during the relicensing process and filed with the FERC as part of the Licensee’s Application for New License for the Project or subsequent updates to the projections. 24.Reclaimed Water – Wastewater that has been treated to reclaimed water standards and is re- used for a designated purpose (e.g., industrial process, irrigation). Reclaimed Water will not be subject to the water use restrictions outlined in this LIP. 25.Drought Response Plan Updates – All Large Water Intake Owners will review and update their Drought Response Plans or Ordinances (or develop a plan or ordinance if they do not have one) by June 30, 2007 and as necessary within 180 days following the acceptance by the FERC of any future LIP revisions during the term of the New License to ensure compliance and coordination with the LIP, including the authority to enforce the provisions outlined herein, provided that the requirements of the LIP are consistent with state law. 26.Relationship Between the LIP and the MEP – The MEP outlines the response the Licensee will take under certain emergency and equipment failure and maintenance situations to continue practical and safe operation of the Project, to mitigate any related impacts to license conditions, and to communicate with resource agencies and the affected parties. Under the MEP, temporary modifications of prescribed flow releases and the reservoir level Normal Operating Ranges are allowed. Lowering levels of Project reservoirs caused by situations addressed under the MEP will not invoke implementation of this LIP. Also, if the LIP has already been implemented at the time that a situation covered by the MEP is initiated, the Licensee will typically suspend implementation of the LIP until the MEP situation has been eliminated. The Licensee may, however, choose to continue with the LIP if desirable. 27.Consensus – Consensus is reached when all CW-DMAG members in attendance can ‘live with’ the outcome or proposal being made. The concept of consensus is more fully described in the Catawba-Wateree Hydroelectric Project Relicensing Stakeholder Teams Charter (dated October, 2005). 28.Monitored USGS Streamflow Gages – The Monitored USGS Streamflow Gages are identified as USGS streamflow gage #s 02145000 (South Fork Catawba River at Lowell, NC), 02137727 (Catawba River near Pleasant Gardens, NC), 02140991 (Johns River at Arney’s Store, NC), and 02147500 (Rocky Creek at Great Falls, SC). 29.Instream Flows for Recreation – The New License for the Project includes recreational flow releases as listed in the Recreational Flows License Article. 30.Minimum Flows – The New License for the Project includes the minimum flow requirements as listed in the Minimum Flows License Article, the Wylie High Inflow Protocol License Article, and the Flows Supporting PWS and Industrial Processes License Article. 31.Project Flow Requirements – These flow requirements include the Minimum Flows and the portion of the Recreational Flows that is greater than the Minimum Flows for Normal Conditions (i.e., conditions outside of this LIP or MEP). 32.Public Information System – The New License for the Project includes the requirement to provide information to the public as specified in the Public Information License Article. 22 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 33.Spring Reservoir Level Stabilization Program – The New License for the Project includes the reservoir level requirements in the Spring Reservoir Level Stabilization Program License Article. PROCEDURE During periods of normal inflow, reservoir levels will be maintained within prescribed Normal Operating Ranges. During times when inflow is not adequate to meet all of the normal demands for water and maintain reservoir levels as normally targeted, the Licensee will progressively reduce hydro generation while meeting Project Flow Requirements. During a Low Inflow Watch or a LIC (as defined below), the Licensee and other water users will follow the protocol set forth below for the Project regarding communications and adjustments to hydro station flow releases, bypassed flow releases, minimum reservoir elevations, and other water demands. The adjustments set forth below will be made on at least a monthly basis and are designed to equitably allocate the impacts of reduced water availability in accordance with the purpose statement of this LIP. Trigger points that demonstrate worsening hydrologic conditions will define various stages of the LIC. A summary of trigger points for various stages is provided in the table below. The specific triggers required to enter successive stages are defined in the procedure for each stage. Summary of LIP Trigger Points Drought Monitor (3-Monitored USGS 23 Stage Storage Index 1 month average) Streamflow Gages 0 90% < SI < 100% TSI 3mo Ave DM ≥ 0 AVG ≤ 85% LT 6mo Ave 4 1 75% TSI < SI ≤ 90% TSI and 3mo Ave DM ≥ 1 or AVG ≤ 78% LT 6mo Ave 2 57% TSI < SI ≤ 75% TSI and 3mo Ave DM ≥ 2 or AVG ≤ 65% LT 6mo Ave 3 42% TSI < SI ≤ 57% TSI and 3mo Ave DM ≥ 3 or AVG ≤ 55% LT 6mo Ave 4 SI ≤ 42% TSI and 3mo Ave DM = 4 or AVG ≤ 40% LT 6mo Ave The ratio of RUS to TUS at a given point in time. 1 DM = The three-month numeric average of the published U.S. Drought Monitor. 2 The sum of the rolling sixth-month average for the Monitored USGS Streamflow Gages as a percentage of the 3 period of record (i.e., long-term \[LT\]) rolling average for the same six-month period for the Monitored USGS Streamflow Gages. Stage 0 is triggered when any two of the three trigger points are reached. 4 Stage 0 Actions The Licensee will monitor the SI, the U.S. Drought Monitor, and the Monitored USGS Streamflow Gages on at least a monthly basis and will declare a Stage 0 Low Inflow Watch if any two of the following conditions occur: a.On the first or sixteenth day of the month (or first business day thereafter), SI is below the TSI, but greater than 90% of the TSI, while providing the Project Flow Requirements. b.The U.S. Drought Monitor Three-Month Numeric Average has a value greater than or equal to 0. 23 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 c.The sum of the actual rolling six-month average streamflows at the Monitored USGS Streamflow Gages is equal to or less than 85% of the sum of the period of record rolling average streamflows for the same six-month period. When a Low Inflow Watch has been declared, the Licensee will activate the CW-DMAG, including the initiation of monthly meetings or conference calls to occur on the second Tuesday of each month. These monthly discussions will focus on: a.Proper communication channels between the CW-DMAG members. b.Information reporting consistency for CW-DMAG members, including an SI history and forecast (at least a 90-day look back and look ahead) from the Licensee, a water use history and forecast (at least a 90-day look back and look ahead) from each water user on the CW-DMAG, streamflow gage and groundwater monitoring status from the state agencies and USGS, and state-wide drought response status from the state agencies. c.Refresher training on this LIP. d.Overview discussions from each CW-DMAG member concerning their role and plans for responding if a Stage 1 or higher LIC is subsequently declared. Stage 1 Actions 1.The Licensee will declare a Stage 1 LIC and notify the CW-DMAG if: a.On the first or sixteenth day of the month (or first business day thereafter), the SI is at or below 90% of the TSI, but greater than 75% of the TSI, while providing the Project Flow Requirements, and either of the following conditions exists: b.The U.S. Drought Monitor Three-Month Numeric Average has a value greater than or equal to 1. c.The sum of the actual rolling six-month average streamflows at the Monitored USGS Streamflow Gages is equal to or less than 78% of the sum of the period of record rolling average streamflows for the same six-month period. 2.The Licensee will complete the following activities after the Stage 1 LIC declaration: Within 1 day: a.Reduce the Project Flow Requirements by 60% of the difference between the normal Project Flow Requirements and the Critical Flows. These reduced Project Flow Requirements are referred to as Stage 1 Minimum Project Flows. b.Reduce the Normal Minimum Elevations by two feet at Lake James and Lake Norman and by one foot at each of the other Project reservoirs, but not to levels at any reservoir below the applicable Critical Reservoir Elevation. These elevations are referred to as the Stage 1 Minimum Elevations. 24 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Within 5 days: c.Update its Web site and Interactive Voice Response (IVR) messages to account for the impacts of the LIP on reservoir levels, usability of the Licensee’s public access areas, and recreation flow schedules. d.Notify the FERC, the USFWS, the BIA, NMFS, and the Catawba Indian Nation of the Stage 1 LIC declaration. e.Provide bi-weekly (once every two weeks) information updates to owners of Large Water Intakes about reservoir levels, meteorological forecasts, and inflow of water into the system. f.In addition the Licensee may, at its sole discretion, modify or suspend its use of selected operating procedures that are designed for periods of normal or above normal inflow to optimize the water storage capabilities of the Project, including the Normal Maximum Elevations and Normal Target Elevations for reservoir levels; the Spring Reservoir Level Stabilization Program; the Wylie High Inflow Protocol and at Lake Wateree, the Spring Stable Flow Periods and Floodplain Inundation Periods. These modifications and suspensions may be used at the Licensee’s sole discretion in any LIC (Stages 1 through 4). 3.Owners of PWS intakes and owners of intakes used for irrigation with a capacity greater than 100,000 gallons per day will complete the following activities within 14 days after the Stage 1 LIC declaration: a.Notify their water customers and employees of the LIC through public outreach and communication efforts. b.Request that their water customers and employees implement voluntary water use restrictions, in accordance with their drought response plans, which may include: Reduction of lawn and landscape irrigation to no more than two days per week  (i.e., residential, multi-family, parks, streetscapes, schools, etc.) Reduction of residential vehicle washing.  At this stage, the goal is to reduce water usage by 3-5% (or more) from the amount that would otherwise be expected. The baseline for this comparison will be generated by each entity and will be based on existing conditions (i.e., drought conditions). For the purposes of determining ‘the amount that would otherwise be expected’, each entity may give consideration to one or more of the following: Historical maximum daily, weekly, and monthly flows during drought conditions.  Increased customer base (e.g., population growth, service area expansion) since  the historical flow comparison. Changes in major water users (e.g., industrial shifts) since the historical flow  comparison. Climatic conditions for the comparison period.  Changes in water use since the historical flow comparison.  25 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Other system specific considerations.  c. Provide a status update to the CW-DMAG on actual water withdrawal trends. Discuss plans for moving to mandatory water use restrictions, if required. 4.Owners of Large Water Intakes, other than those referenced in Item 3 above, will complete the following activities within 14 days after the Stage 1 LIC declaration: a.Notify their customers and employees of the LIC through public outreach and communication efforts. b.Request that their customers and employees conserve water through reduction of water use, electric power consumption, and other means. c.Provide a status update to the CW-DMAG on actual water withdrawal trends. Stage 2 Actions 1.The Licensee will declare a Stage 2 LIC and notify the CW-DMAG if: a.On the first or sixteenth day of the month (or first business day thereafter), the SI is at or below 75% of the TSI, but greater than 57% of the TSI, while providing the Stage 1 Minimum Project Flows, and either of the following conditions exists: b.The U.S. Drought Monitor Three-Month Numeric Average has a value greater than or equal to 2. c.The sum of the actual rolling six-month average streamflows at the Monitored USGS Streamflow Gages is equal to or less than 65% of the sum of the period of record rolling average streamflows for the same six-month period. 2.The Licensee will complete the following activities after the Stage 2 LIC declaration: Within 1 day: a.Eliminate prescribed recreation flow releases at this stage and all subsequent stages. Reduce the Project Flow Requirements by 95% of the difference between the normal Project Flow Requirements and Critical Flows. These reduced flows are referred to as Stage 2 Minimum Project Flows. b.Reduce the Stage 1 Minimum Elevations by one additional foot at Lake James (three feet total below Normal Minimum Elevation) and two additional feet at Lake Norman (four feet total below Normal Minimum Elevation) and by one additional foot (two feet total below Normal Minimum Elevations) at each of the other Project reservoirs but not to levels at any reservoir below the applicable Critical Reservoir Elevation. These elevations are referred to as the Stage 2 Minimum Elevations. Within 5 days: c.Update its Web site and IVR messages to account for the impacts of the LIP on reservoir levels, usability of the Licensee’s public access areas, and recreation flow schedules. 26 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 d.Notify the FERC, the USFWS, the BIA, NMFS, and the Catawba Indian Nation of the Stage 2 LIC declaration. e.Provide bi-weekly information updates to owners of Large Water Intakes about reservoir levels, meteorological forecasts, and inflow of water into the system. f.In addition the Licensee may, at its sole discretion, modify or suspend its use of selected operating procedures that are designed for periods of normal or above normal inflow to optimize the water storage capabilities of the Project, including the Normal Maximum Elevations and Normal Target Elevations for reservoir levels; the Spring Reservoir Level Stabilization Program; the Wylie High Inflow Protocol; and at Lake Wateree, the Spring Stable Flow Periods and Floodplain Inundation Periods. These modifications and suspensions may be used at the Licensee’s sole discretion in any LIC (Stages 1 through 4). 3.Owners of PWS intakes and owners of intakes used for irrigation with a capacity greater than 100,000 gallons per day will complete the following activities within 14 days after the Stage 2 LIC declaration: a.Notify their water customers and employees of the continued LIC and movement to mandatory water use restrictions through public outreach and communication efforts. b.Require that their water customers and employees implement mandatory water use restrictions, in accordance with their drought response plans, which may include: Limiting lawn and landscape irrigation to no more than two days per week (i.e.,  residential, multi-family, parks, streetscapes, schools, etc.) Eliminating residential vehicle washing.  Limiting public building, sidewalk, and street washing activities except as required  for safety and/or to maintain regulatory compliance. At this stage, the goal is to reduce water usage by 5-10% (or more) from the amount that would otherwise be expected (as discussed in Stage 1 above). c.Enforce mandatory water use restrictions through the assessment of penalties. d.Provide a status update to the CW-DMAG on actual water withdrawal trends. 4.Owners of Large Water Intakes, other than those referenced in Item 3 above, will complete the following activities within 14 days after the Stage 2 LIC declaration: a.Continue informing their customers and employees of the LIC through public outreach and communication efforts. b.Request that their customers and employees conserve water through reduction of water use, electric power consumption, and other means. c.Provide a status update to the CW-DMAG on actual water withdrawal trends. 27 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Stage 3 Actions 1.The Licensee will declare a Stage 3 LIC and notify the CW-DMAG if: a.On the first or sixteenth day of the month (or first business day thereafter), the SI is at or below 57% of the TSI, but greater than 42% of the TSI, while providing the Stage 2 Minimum Project Flows, and either of the following conditions exists: b.The U.S. Drought Monitor Three-Month Numeric Average has a value greater than or equal to 3. c.The sum of the actual rolling six-month average streamflows at the Monitored USGS Streamflow Gages is equal to or less than 55% of the sum of the period of record rolling average streamflows for the same six-month period. 2.The Licensee will complete the following activities after the Stage 3 LIC declaration: Within 1 day: a.Reduce the Project Flow Requirements to Critical Flows. These reduced flows are referred to as Stage 3 Minimum Project Flows. b.Reduce the Stage 2 Minimum Elevations by seven additional feet at Lake James (ten feet total below Normal Minimum Elevation) and one additional foot at Lake Norman (five feet total below Normal Minimum Elevation) and by one additional foot (three feet total below Normal Minimum Elevations) at each of the other Project reservoirs but not to levels at any reservoir below the applicable Critical Reservoir Elevation. These elevations are referred to as the Stage 3 Minimum Elevations. Within 5 days: c.Update its Web site and IVR messages to account for the impacts of the LIP on reservoir levels, usability of the Licensee’s public access areas, and recreation flow schedules. d.Notify the FERC, the USFWS, the BIA, NMFS, and the Catawba Indian Nation of the Stage 3 LIC declaration. e.Provide bi-weekly information updates to owners of Large Water Intakes about reservoir levels, meteorological forecasts, and inflow of water into the system. f.In addition the Licensee may, at its sole discretion, modify or suspend its use of selected operating procedures that are designed for periods of normal or above normal inflow to optimize the water storage capabilities of the Project, including the Normal Maximum Elevations and Normal Target Elevations for reservoir levels; the Spring Reservoir Level Stabilization Program; the Wylie High Inflow Protocol; and at Lake Wateree, the Spring Stable Flow Periods and Floodplain Inundation Periods. These modifications and suspensions may be used at the Licensee’s sole discretion in any LIC (Stages 1 through 4). 3.Owners of PWS intakes and owners of intakes used for irrigation with a capacity greater than 100,000 gallons per day will complete the following activities within 14 days after the Stage 3 LIC declaration: 28 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 a.Notify their water customers and employees of the continued LIC and movement to more stringent mandatory water use restrictions through public outreach and communication efforts. b.Require that their water customers and employees implement increased mandatory water use restrictions, in accordance with their drought response plans, which may include: Limiting lawn and landscape irrigation to no more than one day per week (i.e.,  residential, multi-family, parks, streetscapes, schools, etc.) Eliminating residential vehicle washing.  Limiting public building, sidewalk, and street washing activities except as required  for safety and/or to maintain regulatory compliance. Limiting construction uses of water such as dust control.  Limiting flushing and hydrant testing programs, except to maintain water quality  or other special circumstances. Eliminating the filling of new swimming pools.  At this stage, the goal is to reduce water usage by 10-20% (or more) from the amount that would otherwise be expected (as discussed in Stage 1 above). c.Enforce mandatory water use restrictions through the assessment of penalties. d.Encourage industrial/manufacturing process changes that reduce water consumption. e.Provide a status update to the CW-DMAG on actual water withdrawal trends. 4.Owners of Large Water Intakes, other than those referenced in Item 3 above, will complete the following activities within 14 days after the Stage 3 LIC declaration: a.Continue informing their customers and employees of the Low Inflow Condition through public outreach and communication efforts. b.Request that their customers and employees conserve water through reduction of water use, electric power consumption, and other means. c.Encourage industrial/manufacturing process changes that reduce water consumption. d.Provide a status update to the CW-DMAG on actual water withdrawal trends. Stage 4 Actions 1.The Licensee will declare a Stage 4 Low Inflow Condition (LIC) and notify the CW-DMAG if: a. On the first or sixteenth day of the month (or first business day thereafter), the SI is at or below 42% of the TSI, while providing the Stage 3 Minimum Project Flows. and either of the following conditions exists: b.The U.S. Drought Monitor Three-Month Numeric Average has a value of 4. 29 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 c.The sum of the actual rolling six-month average streamflows at the Monitored USGS Streamflow Gages is equal to or less than 40% of the sum of the period of record rolling six-month average streamflows for the same six-month period. 2.The Licensee will: a.Continue to provide Critical Flows as long as possible. b.Reduce the Stage 3 Minimum Elevations to the Critical Reservoir Elevations within 1 day following the Stage 4 LIC declaration. c.Establish a meeting date and notify the CW-DMAG within 1 day following the Stage 4 LIC declaration. d.Notify the FERC, the USFWS, the BIA, NMFS, and the Catawba Indian Nation of the Stage 4 LIC declaration within 5 days following the Stage 4 LIC declaration. e.Continue to update its Web site and IVR messages to account for the impacts of the LIP on reservoir levels, usability of the Licensee’s public access areas, and recreation flow schedules within 5 days following the Stage 4 LIC declaration. f.Provide bi-weekly information updates to owners of Large Water Intakes about reservoir levels, meteorological forecasts, and inflow of water into the system. g.In addition the Licensee may, at its sole discretion, modify or suspend its use of selected operating procedures that are designed for periods of normal or above normal inflow to optimize the water storage capabilities of the Project, including the Normal Maximum Elevations and Normal Target Elevations for reservoir levels; the Spring Reservoir Level Stabilization Program; the Wylie High Inflow Protocol, and at Lake Wateree, the Spring Stable Flow Periods and Floodplain Inundation Periods. These modifications and suspensions may be used at the Licensee’s sole discretion in any LIC (Stages 1 through 4). Note: Once a Stage 4 LIC is declared, the RUS in the reservoir system is small and can be fully depleted in a matter of weeks or months. Groundwater recharge may also contribute to declining reservoir levels. For these reasons, in the Stage 4 LIC, the Licensee may not be able to ensure that flow releases from its hydro developments will meet or exceed Critical Flows or that reservoir elevations will be greater than or equal to the Critical Reservoir Elevations. 3.Owners of PWS intakes and owners of intakes used for irrigation with a capacity greater than 100,000 gallons per day will complete the following activities within 14 days after the Stage 4 LIC declaration: a.Notify their water customers and employees of the continued LIC and movement to emergency water use restrictions through public outreach and communication efforts. b.Restrict all outdoor water use. c.Implement emergency water use restrictions in accordance with their drought response plans, including enforcement of these restrictions and assessment of penalties. 30 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 d.Prioritize and meet with their commercial and industrial large water customers to discuss strategies for water reduction measures including development of an activity schedule and contingency plans. e.Prepare to implement emergency plans to respond to water outages. f.Provide a status update to the CW-DMAG on actual water withdrawal trends. At this level, the goal is to reduce water usage by 20-30% (or more) from the amount that would otherwise be expected (as discussed in Stage 1 above). 4.Owners of Large Water Intakes on the CW-DMAG, other than those referenced in Item 3 above, will complete the following activities within 14 days after the Stage 4 LIC declaration: a. Continue informing their customers and employees of the LIC through public outreach and communication efforts. b. Request that their customers and employees conserve water through reduction of water use, electric power consumption, and other means. c.Encourage industrial/manufacturing process changes that reduce water consumption. d.Provide a status update to the CW-DMAG on actual water withdrawal trends. 5.The CW-DMAG will: a.Meet within 5 days after the declaration of the Stage 4 LIC and determine if there are any additional measures that can be implemented to: (1) reduce water withdrawals without creating more severe regional problems; (2) reduce water releases from the Project without creating more severe regional problems; or (3) use additional reservoir storage without creating more severe regional problems. b.Work together to develop plans and implement any additional measures identified above. Recovery from the Low Inflow Protocol 1.Recovery under the LIP as conditions improve will be accomplished by reversing the staged approach outlined above, except that: a.All three of the trigger points identified above for declaring the lower numbered stage must be met or exceeded before returning reservoir minimum elevations and Project flows to levels specified in that LIC stage, Low Inflow Watch, or Normal Conditions. b.In addition to the triggers used to designate LIP stages, groundwater levels must show improvement to designate less restrictive LIP stages. The wells listed in the table titled “USGS Catawba-Wateree Groundwater Network Wells” will be monitored to evaluate the condition of groundwater resources upstream of Wateree Dam. The monthly average of the daily mean water levels reported by USGS for the groundwater network wells will be used to evaluate groundwater conditions. 31 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 USGS Catawba-Wateree Groundwater Network Wells Groundwater Date Site ID Site Name Monitor Station Installed 342440080443900 KER- 433 KERSHAW COUNTY NR LIBERTY HILL (REGOLITH) 5/11/2009 #1 USGS Kershaw County near Liberty Hill 342440080443901 KER- 435 KERSHAW COUNTY NR LIBERTY HILL (BEDROCK) 5/11/2009 344333080503600 LAN- 497 LANCASTER COUNTY AIRPORT (REGOLITH) 1/12/2010 #2 USGS Lancaster County Airport 344333080503601 LAN- 498 LANCASTER COUNTY AIRPORT (BEDROCK) 1/12/2010 #3 USGS Mineral 345609080415102 UN-147 MINERAL SPRINGS RS TRANSITION ZONE WELL 3/26/2011 Springs Research Station 345609080415103 UN-148 MINERAL SPRINGS RS BEDROCK WELL 3/26/2011 345830081033100 YRK-3295 YORK COUNTY AIRPORT (BEDROCK) 9/3/2010 #4 USGS York County Airport 345830081033101 YRK-3296 YORK COUNTY AIRPORT (REGOLITH) 9/2/2010 #5 USGS Pasour 352012081154301 GS-289 PASOUR MTN RS REGOLITH WELL, PM-25 4/21/2010 Mountain Research Station 352012081154302 GS-290 PASOUR MTN RS TRANSITION ZONE WELL, PM-3 4/21/2010 353135080524201 IR-130 LANGTREE RS MW-2S NR MT MOURNE (REGOLITH) 3/3/2001 #6 USGS Langtree Peninsula Research 353135080524202 IR-131 LANGTREE RS MW-2I (TRANSITION ZONE) 3/3/2001 Station near Mount Mourne 353135080524203 IR-132 LANGTREE RS MW-2D (QUARTZ DIORITE) 3/3/2001 #7 USGS Pleasant 354133082042201 MC-107 NEAR PLEASANT GARDENS RS, NC (REGOLITH) 8/20/2010 Gardens Research Station 354133082042203 MC-109 NEAR PLEASANT GARDENS, NC (BEDROCK) 8/20/2010 #8 USGS Glen BK-126 GLEN ALPINE RS NEAR MORGANTON, NC 354302081433201 1/13/2000 (BEDROCK) Alpine Research Station near 354302081433202 BK-127 GLEN ALPINE RS NR MORGANTON, NC (REGOLITH) 11/1/2008 Morganton 354616081085101 CW-350 OXFORD RS NR CLAREMONT (TRANSITION ZONE) 3/24/2011 #9 USGS Oxford Research Station near Claremont 354616081085102 CW-351 OXFORD RS NR CLAREMONT, NC (BEDROCK) 8/1/2009 #10 USGS Granite 355031081243202 CD-101 GRANITE FALLS RS TRANSITION ZONE WELL 3/17/2011 Falls Research Station 355031081243203 CD-102 GRANITE FALLS RS BEDROCK WELL 3/17/2011 Movement between LIP stages during recovery will be determined by comparing the current monthly average water level for each well to the range of monthly average water levels for each well calculated from the period of record data through the most recent USGS approved Water Year (October-September) to determine comparative percentiles. The results of the monthly calculations will be combined and compared to the 32 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Groundwater Recovery Triggers defined below. Groundwater trigger levels will be updated annually. The following triggers will be used in combination with the three triggers used for defining LIP stages to designate improving conditions. Groundwater Recovery Triggers The following recovery steps are authorized when the groundwater network’s current combined monthly average water level meets the designated trigger. i. Recovery to Stage 3: Monthly period of record low water level or higher th ii. Recovery to Stage 2: Monthly period of record 10 percentile or higher th iii. Recovery to Stage 1: Monthly period of record 25 percentile or higher th iv. Recovery to Stage 0 and Normal: Monthly period of record 50 percentile or higher The calculations described in this Item b. above will be used for informational purposes only until ten or more years of approved USGS data are available, reflecting the range of historical hydrologic conditions in the Catawba-Wateree River Basin which ultimately drains to Wateree Dam. 2.The NCDEQ, SCDNR, SCDHEC, USGS and the Licensee will determine by consensus when the groundwater trigger points for recovery are reached. 3.The Licensee will directly notify the CW-DMAG members within 5 days following attainment of all the trigger points necessary to recover to a lower stage of the LIC, Low Inflow Watch, or Normal Conditions. 4. The Licensee will update its Web site and IVR messages within 5 days following attainment of all the trigger points necessary to recover to a lower stage of the LIC, Low Inflow Watch, or Normal Conditions to account for the impacts of the LIP on reservoir levels, usability of the Licensee’s public access areas, and recreation flow schedules. 5. Notify the FERC, the USFWS, the BIA, NMFS, and the Catawba Indian Nation within 5 days following attainment of all the trigger points necessary to recover to a lower stage of the LIC, Low Inflow Watch, or Normal Conditions. 33 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Identification and assessment of any incremental environmental impacts of the revision compared to the original WQC The LIP revisions make the LIP consistent with and supportive of the beneficial CRA provisions previously discussed (i.e., higher summer Target Elevations and reduced Lake Wyle Dam recreation flow). In addition, other revisions allow the LIP to respond more quickly to changing drought triggers which conserves water during drought periods, helping to reduce the impacts of severe drought conditions on water supply, recreational uses and environmental resources. Additionally, comparisons of the percent of time in LIP stages were completed for the various scenarios. The results of this analysis indicate little difference between the percent of time in various LIP stages for the proposed revisions as compared to the baseline scenario, but do generally indicate an improvement of less time in more severe drought stages. A summary of impacts and/or benefits determined from the assessment of proposed LIP revisions is presented in the following table. Proposed LIP Revision Impact of Revision Lower critical intake Slightly increases Total Usable Storage, with corresponding elevation revisions at minor increase to Target Storage Index. Increases are the Lake James and Mountain result of the new Bridgewater Powerhouse at Lake James and Island Lake the retirement of the Riverbend Steam Station on Mountain Island Lake. Increase summer target Provides an enhancement to basin-wide water yield and elevations by 6 inches at extends available water supply by one decade and by a total Lake James, Lake Norman of 4 decades when coupled with other CWWMG WSMP and Lake Wylie recommended strategies; minimal impact of increased flooding potential in Catawba-Wateree reservoirs based on modeled assessment. U.S. Drought Monitor Current methodology (worst case Drought Monitor condition area-weighted average in basin) is not indicative of basin-wide conditions and can calculation methodology unnecessarily prolong drought recovery; proposed methodology is more indicative of basin-wide average conditions and consistent with North and South Carolina resource agencies’ approach to use of the U.S. Drought Monitor; proposed revision more closely aligns this trigger other drought triggers (storage and streamflow). LIP Stage determination Allows faster response during rapidly intensifying drought frequency of twice per conditions. 34 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 month Expedite Duke Energy Allows faster response during rapidly intensifying drought response time to 1 day conditions. for certain LIP response actions Reduce Lake Wylie Improves recreational boating safety; no additional impact as recreational flow release this revision acknowledges the 6,000 cfs to 3,000 cfs recreation flow release previously discussed. Consultation Summary Consultation resulted in the comments summarized in the following table. Commenter Summary of Comment Duke Energy Response North Page 4, bullet #11 – Will the Lake James If a new intake is located Carolina critical elevation change with the on Lake James in the Wildlife installation of the new water intake for future, the intake would Resource McDowell County? be required to be Commission operational below the Lake James Critical Elevation resulting from the new powerhouse. Therefore, a new intake would not change the Critical Elevation. North Page 5, bullet #17 – Details of the This section of the Carolina drought index are still not clear. In proposed modified LIP Wildlife second sentence you should clarify that document has been Resource the monthly numeric value is the revised for clarification, Commission average drought value of the basin. I say based upon this comment. this because you should distinguish The monthly average will between the monthly average and the 3-be based on an area- month rolling average. More weighted average. The importantly, this bullet doesn't define area-weighted average will how the monthly average will be be determined by an Excel determined. Will it be a weighted spreadsheet tool which average (e.g., by area) or a simple imports GIS-based U.S. average (part of basin is D1 and part is Drought Monitor data and D2, so average is 1.5)? If a weighted maps overlaid by basin 35 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 average, how will you determine area boundary maps to under each designation – visual estimate calculate an exact area- from map or some other method? What weighted average. would the average be for the maps below? United Page 7 of the revision: it should be The typographical States Fish changed from USFSW to USFWS. correction will be made for and Wildlife the final document. Service 36 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix D: Maintenance and Emergency Protocol (MEP) Article (applies to NC and SC) Statement of Revision Add National Marine Fisheries Service (NMFS) to the list of resource agencies to be notified and consulted under the MEP. Background information explaining the need for the revision As included in the license issued November 25, 2015, Duke Energy is required to notify the FERC of any deviations in required flow releases in accordance with the MEP and to also notify state and federal resource agencies and determine if consultation is necessary to more fully evaluate the deviation. There have been several such incidents, some of which have prompted the FERC to inquire why the National Marine Fisheries Service (NMFS) was not notified or consulted. NMFS is not currently included for notification or consultation in the MEP. Duke Energy believes it is beneficial and appropriate to add NMFS to the MEP to be included in notifications and consultation when MEP-related events occur in South Carolina due to NMFS jurisdictional interest in endangered species shortnose and Atlantic sturgeon. This revision also incorporates general terminology updates, Critical Reservoir Elevation updates, and organization name updates to align with updates in the LIP and MEP. Actual text of the revision (for ease of identification, text modified from the December 22, 2006, Signature Copy of the CRA, Revision 1 is shown in bold italics) 37 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 APPENDIX D: MAINTENANCE AND EMERGENCY PROTOCOL (MEP) FOR THE CATAWBA-WATEREE PROJECT 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 to define the most likely situations of this type, identify the potentially impacted license conditions and outline the general approach that the Licensee will take to mitigate the impacts to license conditions and to communicate with the resource agencies and affected parties. Note: Due to the potential variability of these abnormal situations, this protocol 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 integrity 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, protect the equipment of the Large Water Intake owners 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 States of North Carolina and South Carolina from taking any and all lawful actions necessary within their jurisdictions to protect human health and safety. It is recognized that North Carolina and South 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 38 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 referring to the Full Pond Elevation for all of its reservoirs as equal to 100.0 ft. relative. The Full Pond Elevations for the Catawba-Wateree Project reservoirs are: Full Pond Elevation Reservoir (ft. above Mean Sea Level) Lake James 1200.0 Lake Rhodhiss 995.1 Lake Hickory 935.0 Lookout Shoals Lake 838.1 Lake Norman 760.0 Mountain Island Lake 647.5 Lake Wylie 569.4 Fishing Creek Reservoir 417.2 Great Falls Reservoir 355.8 Cedar Creek Reservoir 284.4 Lake Wateree 225.5 3. Normal Minimum Elevation – The level of a reservoir (measured in feet above Mean Sea Level (MSL) or feet relative to the full pond contour with 100.0 ft. corresponding to full pond) that defines the bottom of the reservoir’s Normal Operating Range for a given day of the year. If inflows and outflows to the reservoir are kept within some reasonable range of the average or expected amounts, hydroelectric project equipment is operating properly and no protocols for abnormal conditions have been implemented, reservoir level excursions below the Normal Minimum Elevation should not occur. 4. Normal Maximum Elevation – The level of a reservoir (measured in feet above Mean Sea Level (MSL) or feet relative to the full pond contour with 100.0 ft. corresponding to full pond) that defines the top of the reservoir’s Normal Operating Range for a given day of the year. If inflows and outflows to the reservoir are kept within some reasonable range of the average or expected amounts, hydroelectric project equipment is operating properly, and no protocols for abnormal conditions have been implemented, reservoir level excursions above the Normal Maximum Elevation should not occur. 5. Normal Target Elevation – The level of a reservoir (measured in ft above Mean Sea Level (msl) 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 operating in the Low Inflow Protocol, the Maintenance and Emergency Protocol, the Spring Reservoir Level Stabilization Program (Lakes James, Norman, Wylie and Wateree only), a Spring Stable Flow Period (Lake 39 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Wateree only) or a Floodplain Inundation Period (Lake Wateree only). Since inflows vary significantly and outflow demands also vary, the Licensee will not always be able to maintain actual reservoir level at the Normal Target Elevation. The Normal Target Elevation falls within the Normal Operating Range, but it is not always the average of the Normal Minimum and Normal Maximum Elevations. 6. Normal Operating Range – The band of reservoir levels within which the Licensee normally attempts to maintain a given reservoir that it operates on a given day. Each reservoir has its own specific Normal Operating Range, and that range is bounded by a Normal Maximum Elevation and a Normal Minimum Elevation. If inflows and outflows to the reservoir are kept within some reasonable range of the average or expected amounts, hydro project equipment is operating properly and no protocols for abnormal conditions have been implemented, reservoir level excursions outside of the Normal Operating Range should not occur. The New License for the Catawba-Wateree Project includes the Normal Operating Ranges for the reservoirs (i.e., Normal Minimum, Normal Maximum and Normal Target Elevations) as listed in the Reservoir Elevations License Article. 7. Returning 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. If the Licensee decides that repair is not cost-effective or that hydro station or dam retirement is necessary, the Licensee will notify the Parties to the Comprehensive Relicensing Agreement (CRA) and consult with them as well as the FERC to determine any necessary modifications of the New License and/or this Agreement. 8. Incidental Maintenance – These are maintenance activities at hydro 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 hydro project works that does not require deviation from any license conditions related to prescribed flow releases from Project structures, or the Normal Operating Ranges for reservoir levels or is less than 24 hours in duration and will not require any excursions below any Critical Flows or Critical Reservoir Elevations 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. 9. 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 in 40 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 good faith to provide as much advance notice as possible to the affected parties identified in this protocol. 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 in good faith to inform the affected parties identified in this protocol within some reasonable amount of time after the situation has been identified. 10. Relationship Between this Protocol and the Low Inflow Protocol – The Low Inflow Protocol (LIP) provides for reductions in generation flows, instream flows and recreational flow releases and modification of the Normal Operating Ranges for reservoir levels when water demands on the reservoirs substantially exceed net inflow. Lowered reservoir levels caused by situations addressed under this Maintenance and Emergency Protocol (MEP) will not invoke implementation of the LIP. Also, if the LIP has already been implemented at the time that a situation covered by this MEP is initiated, the Licensee will typically suspend implementation of the LIP until the MEP situation has been eliminated. The Licensee may however choose to continue with the LIP if desirable. 11. Peak Recreation Season – The period when recreation use on Project reservoirs is generally at the highest levels, identified by the Recreation Use and Needs st th Study as extending from April 1through September 30. 12. Critical Flows – The minimum flow releases from the hydro developments that may be 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 operability for large water intakes located on the affected stream reaches; and, c. provide some basic level of water quality maintenance in the affected stream reaches. For the purposes of the LIP and this MEP, the Critical Flows are as follows: a. Linville River, below the Bridgewater Development (Lake James): 75 cubic feet per second (cfs). b. Catawba River Bypassed Reach below the Bridgewater Development (Lake James): 25 cfs. c. Oxford Regulated River Reach below the Oxford Development (Lake Hickory): 100 cfs. d. Lookout Shoals Regulated River Reach below the Lookout Shoals Development: 80 cfs. e. Wylie Regulated River Reach below the Wylie Development: 700 cfs 41 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 f. Great Falls Bypassed Reaches (Long and Short) at the Great Falls-Dearborn Development: 450 cfs and 80 cfs respectively. g. Wateree Regulated River Reach below the Wateree Development: 800 cfs h. Leakage flows at the remaining Project structures. Leakage flows are defined as the flow of water through wicket gates when the hydro units are not operating and seepage through the Project structures at each development. 13. Critical Reservoir Elevation – Unless it is otherwise stated as applying only to a specific intake or type of intake, the Critical Reservoir Elevation is the highest level of water in a reservoir (measured in feet above Mean Sea Level (mls) or feet relative to the full pond contour with 100.0 ft. corresponding to full pond) below which any Large Water Intake used for Public Water Supply or industrial uses, or any regional power plant intake located on the reservoir will not operate at its Licensee-approved capacity. The Critical Reservoir Elevations, as of December 31, 2016, are defined below: Critical Reservoir Elevation Reservoir(ft. relative to local datum) Type of Limit (100 ft = Full Pond) Lake James 50.0 Power Production Lake Rhodhiss 89.4 Municipal Intake Lake Hickory 94.0 Municipal Intake Lookout Shoals Lake 74.9 Municipal Intake Lake Norman 90.0 Power Production Mountain Island Lake 90.5 Municipal Intake Lake Wylie 92.6 Industrial Intake Fishing Creek Reservoir 95.0 Municipal Intake Great Falls Reservoir 87.2 Power Production Cedar Creek Reservoir 80.3 Power Production Lake Wateree 92.5 Municipal Intake 14. Organizational abbreviations include the Federal Energy Regulatory Commission (FERC), the North Carolina Department of Environmental Quality (NCDEQ), North Carolina Wildlife Resources Commission (NCWRC), North Carolina State Historic Preservation Office (NCSHPO), South Carolina Department of Natural Resources (SCDNR), South Carolina Department of Health and Environmental Control (SCDHEC), South Carolina State Historic Preservation Office (SCSHPO), United States Fish & Wildlife Service (USFWS), United States Geological Survey (USGS), National Marine Fisheries Service 42 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 (NMFS), American Whitewater (AW), United States Bureau of Indian Affairs (BIA), Catawba Indian Nation (CIN) and the Eastern Band of Cherokee Indians (EBCI). 15. Voltage and Capacity Emergencies – The electric transmission system serving the Project 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 shall exist when declared by the Licensee’s SOC or TCC. 16. Large Water Intake – any water intake (e.g., public water supply, industrial, agricultural, power plant, etc.) having a maximum instantaneous capacity greater than or equal to one Million Gallons per Day (MGD) that withdraws water from the Catawba-Wateree River Basin. 17. Preparation for High Inflow Events – With modern forecasting, it is more possible than ever to predict large high inflow events and to increase generation hours to reduce reservoir levels in order to mitigate the potential for spilling and high water. Typically, this type of advance action is taken from 1 to 5 days or more before the expected arrival of the storm. It is assumed that the Normal Operating Ranges of reservoir levels may not include adequate flexibility (i.e. band width) to allow for this type of reservoir level reduction under heavy inflow circumstances, and therefore, allowances are made in this MEP to lower reservoir levels below the Normal Minimum Elevations if needed in preparation for such events. 18. Large Extended Drawdown – Any drawdown of a 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 document, a large extended drawdown is any drawdown that is expected to maintain lake elevation for at least 30 consecutive days at levels that are at least five feet below the lowest Normal Minimum Elevation for that reservoir. 43 20 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 19. Revising the MEP – The Licensee will review the requirements of this MEP each time it is used and will consult with the organizations listed in Item 14 above (except the FERC) if the Licensee determines that revisions are warranted. The Licensee will file the revised MEP with the FERC, including filing a license amendment request if the Licensee determines that the amendment is needed. If any modifications of the MEP require amendment of the New License, the Licensee will provide notice to all Parties to the CRA advising them of the proposed license article amendment prior to filing the license amendment request for FERC approval. The filing of a revised MEP by the Licensee will not constitute or require modification to the CRA and any Party to the CRA may be involved in the FERC’s public process for assessing the revised MEP. 20. Instream Flows For Recreation – The New License for the Project includes the prescribed recreational flow releases as listed in the Recreational Flows License Article. 21. Minimum Flows – The New License for the Project includes the minimum flow requirements as listed in the Minimum Flows License Article, the Wylie High Inflow Protocol License Article, and the Flows Supporting Public Water Supply and Industrial Processes License Article. 22. Public Information System – The New License for the Project includes the requirement to provide information to the public as specified in the Public Information License Article. 23. Spring Reservoir Level Stabilization Program – The New License for the Project includes the reservoir level requirements in the Spring Reservoir Level Stabilization Program License Article. Guidance for Responding to Abnormal Conditions This section provides guidance for responding to the most likely conditions identified in the table below. The table identifies the most likely abnormal conditions when this protocol will be enacted and the license requirements that would most likely be impacted. Potentially Impacted License Abnormal Condition Requirements Normal Operating Flows in Flows in Ranges and Condition Regulated Condition NameIndicationsBypassed Stabilization LetterRiver Reaches Periods for Reaches Reservoir Levels 44 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Potentially Impacted License Abnormal Condition Requirements Normal Operating Flows in Ranges and Flows in Condition Regulated Condition NameIndicationsStabilization Bypassed LetterRiver Periods for Reaches Reaches Reservoir Levels Hydro Unit Maintenance will require hydro A X X X Maintenance unit shutdown. Maintenance will require Maintenance of interruption of scheduled B X X Minimum Flow minimum releases from normal Devices locations Imminent Failure or Potential Failure condition is declared per Emergency Action Plan or Dam Safety C X X X Emergency 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 cause the Licensee’s system D Capacity reliability and safety to be at X X X Emergency risk and a voltage or capacity emergency is declared by Licensee’s System Operating Center (SOC) or Transmission Control Center (TCC). Reservoir Drawdown Below Normal Minimum Elevation due to The reservoir level is below E X X X maintenance, Normal Minimum Elevation emergency or other reasons (not due to low or high inflow) Safe access to bypasses or River Access regulated river reaches F Special requires interruption of X X Circumstances scheduled/minimum releases from normal locations 45 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Potentially Impacted License Abnormal Condition Requirements Normal Operating Flows in Ranges and Flows in Condition Regulated Condition NameIndicationsStabilization Bypassed LetterRiver Periods for Reaches Reaches Reservoir Levels Expected or The water level at a reservoir G existing high is significantly above or below X inflow event the Normal Operating Range Communication with Resource Agencies and Affected Parties General Notification As soon as possible after the Licensee determines that the response to an abnormal condition 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 condition. The Licensee will consider options suggested by the identified agencies and organizations that could lessen the impact of the abnormal condition on the environmental, cultural and human needs relative to the Project. 46 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition 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, water quality, recreation, navigation or downstream water uses during Peak Recreation Season, or during Spring Reservoir Level Stabilization Periods (Bridgewater, Cowans Ford, Wylie and Wateree developments only) or during Spring Stable Flow Periods (Wateree Development only) unless it is likely that the equipment condition will cause damage or unscheduled unit maintenance if repairs are delayed. 2. Replacing Recreational Flow Releases – If the maintenance operations affect equipment that provides the normal method of providing prescribed recreational flows, then the Licensee will endeavor in good faith to replace some or all of the missed flows that are normally scheduled for recreation. This can be accomplished by providing replacement flow releases at the Oxford Development, the Wylie Development, and the Fishing Creek Development (for the Great Falls Bypassed Reaches) through the use of spillway gates. The preferred method at all of the developments is to schedule replacement recreational flow releases for another time after the maintenance operations are completed. The replacement recreational flow releases will occur during the same calendar year as originally scheduled. An Annual Recreational Flow Schedule Planning meeting will be held each March (see Section 3.2 of the CRA) and contingency dates for make-up releases can be identified at that time. 3. 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, but not to levels below the Critical Reservoir Elevations. 4. Avoid Falling Below the Critical Flows – To the extent practical, the Licensee will avoid falling below any of the Critical Flows as noted above. If it is determined that 100 percent exceedance of the Critical Flows 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. The Licensee will also work with any affected Large Water Intake Owners or Downstream Effluent Dischargers to minimize the impacts of any reduced flow releases. 47 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition A.1 – Scheduled Hydro Unit Maintenance NotificationConsultationComments For developments in NC (including Wylie). If the maintenance will affect any required flow release or Normal Operating Range or NCDEQ Stabilization Requirements for Reservoir Levels, provide notification FERC NCWRC and initiate consultation as soon as maintenance schedules are USFWS determined (typically months in advance), but at least 10 days prior to beginning any reservoir drawdown or the hydro unit maintenance. For developments in SC. If the maintenance will affect any required SCDNR flow release or Normal Operating Range or Stabilization SCDHEC Requirements for Reservoir Levels, provide notification and initiate FERC USFWS consultation as soon as maintenance schedules are determined NMFS (typically months in advance), but at least 10 days prior to beginning any reservoir drawdown or the hydro unit maintenance. Consult at least 10 days prior to maintenance if it will affect the AW prescribed recreational flow releases. Consult at least 10 days prior to maintenance or beginning any NCSHPO reservoir drawdown if maintenance will affect Historic Properties SCSHPO (NCSHPO or SCSHPO as appropriate) and include consultation with CIN CIN and EBCI if the maintenance will result in a Large Extended EBCI Drawdown. Consult at least 10 days prior to maintenance, if it will affect normal BIA minimum flow releases from the Wylie Development. CIN Large Water 1 Intake Owners Consult with intake owners and downstream effluent dischargers at least 10 days prior to beginning maintenance or any reservoir Downstream drawdown if flow releases below Critical Flows will be required. Effluent 1 Dischargers The Licensee will conduct notification procedures for any temporary Access Area recreation facility/Access Area closures (e.g., closure due to Closure extended low reservoir levels) in accordance with the Recreation Notification Management Plan. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license conditions, General 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. Note 1 – If affected by the maintenance. 48 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition A.2 – Unscheduled Hydro Unit Maintenance Mitigating Actions 1. Replacing Recreational Flow Releases – If the maintenance affects equipment that provides the normal method of providing prescribed recreational flows, then the Licensee will endeavor in good faith to replace some or all of the missed flows that are normally scheduled for recreation. This can be accomplished by providing replacement flow releases at the Oxford Development, Wylie Development, and the Fishing Creek Development (for the Great Falls Bypassed Reaches) through the use of spillway gates. The preferred method at all the developments is to schedule replacement recreational flow releases for another time after the maintenance operations are complete. The replacement recreational flow releases will occur during the same calendar year as originally scheduled. An Annual Recreational Flow Schedule Planning meeting will be held each March (see Section 3.2 of the CRA) and contingency dates for make-up releases can be identified at that time. 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, but not to levels below the Critical Reservoir Elevations. 3. Avoid Falling Below the Critical Flows – To the extent practical, the Licensee will avoid falling below any of the Critical Flows as noted above. If it is determined that 100 percent exceedance of the Critical Flows 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. The Licensee will also work with any affected Large Water Intake Owners and Downstream Effluent Dischargers to minimize the impacts of any reduced flow releases. 49 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition A.2 – Unscheduled Hydro Unit Maintenance NotificationConsultationComments For developments in NC (including Wylie). If the maintenance will FERC affect any required flow release or Normal Operating Range or NCDEQ NCDEQ Stabilization Requirements for Reservoir Levels, perform notification NCWRC NCWRC as soon as possible after the unscheduled maintenance begins, but USFWS USFWS no longer than 5 days afterwards. Begin consultation within 10 days after the unscheduled maintenance begins. FERC For developments in SC. If the maintenance will affect any required SCDNR SCDNR flow release or Normal Operating Range or Stabilization SCDHEC SCDHEC Requirements for Reservoir Levels, perform notification as soon as USFWS USFWS possible after the unscheduled maintenance begins, but no longer NMFS NMFS than 5 days afterwards. Initiate consultation within 10 days. Notify (within 5 days) and consult (within 10 days) afterwards if AW AW maintenance will affect the prescribed recreational flow releases. NCSHPO NCSHPO Notify (within 5 days) and consult (within 10 days) afterwards with SCSHPO SCSHPO NCSHPO and SCSHPO (as appropriate) if maintenance will affect CIN CIN Historic Properties and include consultation with CIN and EBCI if the EBCI EBCI maintenance will result in a Large Extended Drawdown. Notify (within 5 days) and consult (within 10 days) afterwards if BIA BIA maintenance affects normal minimum flow releases from the Wylie CIN CIN Development. Large Water Large Water 11 Intake OwnersIntake Owners Notify (within 5 days) and consult (within 10 days) afterwards with intake owners and downstream effluent dischargers if flow releases Downstream Downstream below Critical Flows are required. Effluent Effluent 11 DischargersDischargers The Licensee will conduct notification procedures for any temporary Access Area recreation facility/Access Area closures (e.g., closure due to Closure extended low reservoir levels) in accordance with the Recreation Notification Management Plan. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license conditions, the Licensee will add appropriate messages to its public information General Web site and its reservoir level toll-free phone system to inform the general public. Note 1 – If affected by the maintenance. 50 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition B.1 – Maintenance of the Normal Means of Providing Minimum Flows (Scheduled) Mitigating Actions 1. Scheduling – To the extent practical, the Licensee will avoid scheduling maintenance that would impact the ability of the Licensee to release flows for aquatic habitat, water quality or downstream water uses, unless it is likely that the equipment condition will cause damage or an unscheduled maintenance condition if repairs are delayed. 2. Providing Minimum Flows – If the maintenance cannot avoid impacting minimum flows for aquatic habitat, water quality or downstream water uses, then the Licensee will endeavor in good faith to provide some of the minimum flows in the affected stream reaches. This can be accomplished by partially opening spillway gates at the Oxford Development, the Wylie Development and the Fishing Creek Development (for the Great Falls Bypassed Reaches). At all other sites, leakage from the dams or other means of releasing flows (e.g., pulsing of hydro units at Bridgewater) will be provided during the maintenance. Note that it would be a very unusual occurrence to not have any generation or spill control equipment available at these sites. 3. Avoid Falling Below the Critical Flows – To the extent practical, the Licensee will avoid falling below any of the Critical Flows as noted above. If it is determined that 100 percent exceedance of the Critical Flows 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. The Licensee will also work with any affected Large Water Intake Owners and Downstream Effluent Dischargers to minimize the impacts of any reduced flow releases. 51 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition B.1 – Maintenance of the Normal Means of Providing Minimum Flows (Scheduled) NotificationConsultationComments NCDEQ NCWRC USFWS For developments in NC (including Wylie). If the maintenance cannot avoid impacting minimum flows for aquatic habitat, water quality or Large Water FERC downstream water uses, provide notification and initiate consultation 1 Intake Owners as soon as maintenance schedules are determined (typically months in advance), but at least 10 days prior to beginning the maintenance. Downstream Effluent 1 Dischargers SCDNR SCDHEC USFWS NMFS For developments in SC. If the maintenance cannot avoid impacting minimum flows for aquatic habitat, water quality or downstream FERC Large Water water uses, provide notification and initiate consultation as soon as 1 Intake Owners maintenance schedules are determined (typically months in advance), but at least 10 days prior to beginning the maintenance. Downstream Effluent 1 Dischargers Consult if maintenance affects normal minimum flow releases from BIA the Wylie Development, as soon as maintenance schedules are CIN determined (typically months in advance), but at least 10 days prior to beginning the maintenance. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license conditions, General 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. Note 1 – If affected by the maintenance. 52 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition B.2 – Maintenance of the Normal Means of Providing Minimum Flows (Unscheduled) Mitigating Actions 1. Providing Minimum Flows – If the maintenance cannot avoid impacting minimum flows for aquatic habitat, water quality or downstream water uses, then the Licensee will endeavor in good faith to provide some of the minimum flows in the affected stream reaches. This can be accomplished by partially opening spillway gates at the Oxford Development, the Wylie Development and the Fishing Creek Development (for the Great Falls Bypassed Reaches). At all other sites, leakage from the dams or other means of releasing flows (e.g., pulsing of hydro units at Bridgewater) will be provided during the maintenance. Note that it would be a very unusual occurrence to not have any generation or spill control capability available at these sites. 2. Avoid Falling Below the Critical Flows – To the extent practical, the Licensee will avoid falling below any of the Critical Flows as noted above. If it is determined that 100 percent exceedance of the Critical Flows 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. The Licensee will also work with any affected Large Water Intake Owners and Downstream Effluent Dischargers to minimize the impacts of any reduced flow releases. 53 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition B.2 – Maintenance of the Normal Means of Providing Minimum Flows (Unscheduled) NotificationConsultationComments FERC NCDEQ NCDEQ NCWRC NCWRC USFWS For developments in NC (including Wylie). If the maintenance cannot USFWS avoid impacting minimum flows for aquatic habitat, water quality or downstream water uses, perform notification as soon as possible Large Water Large Water 1 after the unscheduled maintenance begins, but no longer than 5 days Intake Owners 1 Intake Owners afterwards. Begin consultation within 10 days after the unscheduled Downstream maintenance begins. Downstream Effluent Effluent 1 Dischargers 1 Dischargers FERC SCDNR SCDNR SCDHEC SCDHEC USFWS USFWS NMFS For developments in SC. If the maintenance cannot avoid impacting NMFS minimum flows for aquatic habitat, water quality or downstream water uses, perform notification as soon as possible after the Large Water Large Water 1 unscheduled maintenance begins, but no longer than 5 days Intake Owners 1 Intake Owners afterwards. Initiate consultation within 10 days. Downstream Downstream Effluent Effluent 1 Dischargers 1 Dischargers Notify if maintenance affects normal minimum flow releases from the BIA BIA Wylie Development, as soon as possible after the unscheduled CIN CIN maintenance begins, but no longer than 5 days afterwards. Initiate consultation within 10 days. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license conditions, General 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. Note 1 – If affected by the maintenance. 54 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition C – Dam Safety Emergency Mitigating Actions 1. Safety Must Come First – If an Imminent Failure or Potential Failure condition 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 Condition C – Dam Safety Emergency Notification Consultation Comments Conducted strictly in accordance with the Licensee’s Emergency Action Plan. In cases where dam safety concerns arise that are During EAP Imminent Failure or not an Imminent Failure or Potential Failure Condition per the Potential Failure Conditions 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 condition will potentially impact license Once Dam Safety Conditions Have conditions, the Licensee will add appropriate messages to its Stabilized public information Web site and/or its reservoir level toll-free phone system to inform the general public. The Licensee will conduct notification procedures for any Access Area temporary recreation facility/Access Area closures (e.g., closure Closure due to extended low reservoir levels) in accordance with the Notification Recreation Management Plan. 55 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition D – Voltage and Capacity Emergencies Mitigating Actions 1. Suspension of the Normal Operating Ranges and Spring Stabilization Periods for Reservoir Levels – 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. Reservoir levels will not be reduced below the Critical Reservoir Elevations noted above. 2. 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 Critical Flows (as defined above) and may modify or suspend any scheduled recreational flow releases, and may at Lake Wateree, modify or suspend any Spring Stable Flows or Floodplain Inundation Flows if taking those actions is necessary to maintain the water inventory in Project reservoirs for use during the Voltage and Capacity Emergency. During a Voltage and 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. 3. Replacing Lost Recreational Flow Releases – If scheduled recreational flow releases are lost, then once the emergency is over, the Licensee will endeavor in good faith to reschedule the releases during the same calendar year as originally scheduled. An Annual Recreational Flow Schedule Planning meeting will be held each March (see Section 3.2 of the CRA) and contingency dates for make-up releases can be identified at that time. 56 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition D – Voltage and Capacity Emergencies NotificationConsultationComments FERC For developments in NC (Including Wylie). Perform notification as NCDEQ NCDEQ soon as possible, but no longer than 5 days following the deviation NCWRC NCWRC from a license condition for Voltage or Capacity Emergency reasons. USFWS USFWS Initiate consultation as soon as possible. FERC SCDNR For developments in SC. Perform notification as soon as possible, SCDNR SCDHEC but no longer than 5 days following the deviation from a license SCDHEC USFWS condition for Voltage or Capacity Emergency reasons. Initiate USFWS NMFS consultation as soon as possible. NMFS Notify (within 5 days) and consult as soon as possible if maintenance AW AW will affect the prescribed recreational flow releases. NCSHPO NCSHPO Notify (within 5 days) and consult as soon as possible with NCSHPO SCSHPO SCSHPO and SCSHPO (as appropriate) if Voltage or Capacity Emergency CIN CIN will affect Historic Properties. EBCI EBCI Notify (within 5 days) and consult as soon as possible if Voltage or BIA BIA Capacity Emergency affects normal minimum flow releases from the CIN CIN Wylie Development. The Licensee will conduct notification procedures for any temporary Access Area recreation facility/Access Area closures (e.g., closure due to Closure extended low reservoir levels) in accordance with the Recreation Notification Management Plan. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license conditions, General 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. 57 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition E.1 – Reservoir Drawdown (Planned) Mitigating Actions 1. Scheduling – To the extent practical, the Licensee will avoid scheduling reservoir drawdowns (i.e., reducing water level to below the Normal Minimum Elevation) that would impact the ability of the Licensee to release the prescribed flows for aquatic habitat, water quality, recreation, navigation or downstream water uses. Also, to the extent practical, the Licensee will avoid scheduling reservoir drawdowns during the Peak Recreation Season or during Spring Reservoir Level Stabilization Periods (Bridgewater, Cowans Ford, Wylie and Wateree developments only) or during Spring Stable Flow Periods (Wateree Development only). 2. Alternative Means to Provide Minimum Flows – If the drawdown cannot avoid impacting minimum flows for aquatic habitat, water quality or downstream water uses, then the Licensee will endeavor in good faith to provide some of the minimum flows in the affected stream reaches by utilizing the generating equipment, spill gates or leakage at the developments for flows required downstream of the powerhouses. Note that it would be a very unusual occurrence to not have any generating units or spill devices available at these sites for flows required downstream of powerhouses. 3. Replacing Recreational Flow Releases – If the reservoir drawdown impacts normally scheduled recreational flows, then the Licensee will endeavor in good faith to replace some or all of the missed recreational flows. This can be accomplished by providing replacement flow releases at the Oxford Development, the Wylie Development, and the Fishing Creek Development (for the Great Falls Bypassed Reaches) through the use of spillway gates. The preferred method at all of the developments is to schedule replacement recreational flow releases for another time after the drawdown is completed. The replacement recreational flow releases will occur during the same calendar year as originally scheduled. An Annual Recreational Flow Schedule Planning meeting will be held each March (see Section 3.2 of the CRA) and contingency dates for make-up releases can be identified at that time. 4. Avoid Falling Below the Critical Flows – To the extent practical, the Licensee will avoid falling below any of the Critical Flows as noted above. If it is determined that 100 percent exceedance of the Critical Flows 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. The Licensee will also work with any affected Large Water Intake Owners and Downstream Effluent Dischargers to minimize the impacts of the reduced flow releases. 5. Avoid Falling Below Critical Reservoir Elevations – To the extent practical, the Licensee will avoid falling below any of the Critical Reservoir Elevations as noted above. If it is determined that 100 percent exceedance of the Critical Reservoir Elevations cannot reasonably be achieved, the Licensee will work with any affected Large Water Intake Owners to minimize the impacts of the drawdown. 58 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition E.1 – Reservoir Drawdown (Planned) NotificationConsultationComments For developments in NC (including Wylie). Provide notification and NCDEQ consult as soon as approximate dates are determined (typically FERC NCWRC months in advance), but at least 10 days prior to beginning USFWS drawdown. SCDNR For developments in SC. Provide notification and consult as soon as SCDHEC FERC approximate dates are determined (typically months in advance), but USFWS at least 10 days prior to beginning drawdown. NMFS NCSHPO SCSHPO Consult in the event of a Large Extended Drawdown as soon as approximate dates are determined (typically months in advance), but CIN EBCI at least 10 days prior to beginning drawdown. BIA Consult at least 10 days prior to beginning drawdown if it will affect AW the prescribed recreational flow releases. Large Water Intake If the drawdown will go below Critical Reservoir Elevations that affect 1 Owners the operations of a Large Water Intake located in a reservoir or will cause flow releases to drop below Critical Flows supporting Large Downstream Water Intakes or Downstream Effluent Dischargers, the Licensee will Effluent consult with the owner of the intake or discharge facility as soon as 1 Dischargers approximate dates are known (typically months in advance), but at least 10 days prior to beginning the drawdown. The Licensee will conduct notification procedures for any temporary Access Area recreation facility/Access Area closures (e.g., closure due to Closure extended low reservoir levels) in accordance with the Recreation Notification Management Plan. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license conditions, General 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. Note 1 – If affected by the reservoir drawdown. 59 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition E.2 – Reservoir Drawdown (Unplanned) Mitigating Actions 1. Alternative Means to Provide Minimum Flows – If the drawdown (i.e., reducing water level to below the Normal Minimum Elevation) cannot avoid impacting minimum flows for aquatic habitat, water quality, navigation or downstream water uses, then the Licensee will endeavor in good faith to provide some or all of the missed minimum flows in the affected stream reaches. This can be accomplished by using the generating equipment, spill gates or leakage at the developments for flows required downstream of the powerhouses. Note that it would be a very unusual occurrence to not have any generating units or spill devices available at these sites for flows required downstream of powerhouses. 2. Replacing Recreational Flow Releases – If the reservoir drawdown impacts normally scheduled recreational flows, then the Licensee will endeavor in good faith to replace some or all of the missed recreational flows. This can be accomplished by providing replacement flow releases at the Oxford Development, the Wylie Development, and the Fishing Creek Development (for the Great Falls Bypassed Reaches) through the use of spillway gates. The preferred method at all of the developments is to schedule replacement recreational flow releases for another time after the drawdown is completed. The replacement recreational flow releases will occur during the same calendar year as originally scheduled. An Annual Recreational Flow Schedule Planning meeting will be held each March (see Section 3.2 of the CRA) and contingency dates for make-up releases can be identified at that time. 3. Avoid Falling Below the Critical Flows – To the extent practical, the Licensee will avoid falling below any of the Critical Flows as noted above. If it is determined that 100 percent exceedance of the Critical Flows 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. The Licensee will also work with any affected Large Water Intake Owners and Downstream Effluent Dischargers to minimize the impacts of the reduced flow releases. 4. Avoid Falling Below Critical Reservoir Elevations – To the extent practical, the Licensee will avoid falling below any of the Critical Reservoir Elevations as noted above. If it is determined that 100 percent exceedance of the Critical Reservoir Elevations cannot reasonably be achieved, the Licensee will work with any affected Large Water Intake Owners to minimize the impacts of the drawdown. 60 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition E.2 – Reservoir Drawdown (Unplanned) NotificationConsultationComments FERC NCDEQ NCDEQ NCWRC NCWRC USFWS USFWS For developments in NC (including Wylie). If the drawdown cannot avoid impacting minimum flows for aquatic habitat, water quality or Large Water Intake downstream water uses, perform notification as soon as possible, Large Water 1 Owners 1 but no longer than 5 days after the drawdown begins. Begin Intake Owners consultation within 10 days after the drawdown begins. Downstream Downstream Effluent Effluent 1 Dischargers 1 Dischargers FERC SCDNR SCDNR SCDHEC SCDHEC USFWS USFWS NMFS For developments in SC. If the drawdown cannot avoid impacting NMFS minimum flows for aquatic habitat, water quality, navigation or downstream water uses, perform notification as soon as possible, Large Water Intake Large Water 1 but no longer than 5 days after the drawdown begins. Begin Owners 1 Intake Owners consultation within 10 days after the drawdown begins. Downstream Downstream Effluent Effluent 1 Dischargers 1 Dischargers If the drawdown affects releases from the Wylie Development, BIA BIA notify as soon as possible, but no longer than 5 days after the CIN CIN drawdown begins. Begin consultation within 10 days after the drawdown begins. Notify (within 5 days) and consult as soon as possible if the AW AW drawdown will affect prescribed recreational flow releases. The Licensee will conduct notification procedures for any Access Area temporary recreation facility/Access Area closures (e.g., closure Closure due to extended low reservoir levels) in accordance with the Notification Recreation Management Plan. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license General 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. . Note 1 – If affected by the drawdown 61 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition F – Special River Access Circumstances Mitigating Actions 1. Scheduling – To the extent practical, the Licensee will 1) avoid scheduling Special River Access Circumstances that would impact the ability of the Licensee to release flows for aquatic habitat, water quality, navigation, recreation or downstream water uses and 2) avoid scheduling during Peak Recreation Season. 2. Replacing Recreational Flow Releases – If scheduling Special River Access impacts normally scheduled recreational flows, then the Licensee will endeavor in good faith to replace some or all of the missed recreational flows. This can be accomplished by providing replacement flow releases at the Oxford Development, the Wylie Development, and the Fishing Creek Development (for the Great Falls Bypassed Reaches) through the use of spillway gates. The preferred method at all of the developments is to schedule replacement recreational flow releases for another time after the Special River Access Circumstance is completed. The replacement recreational flow releases will occur during the same calendar year as originally scheduled. An Annual Recreational Flow Schedule Planning meeting will be held each March (see Section 3.2 of the CRA) and contingency dates for make-up releases can be identified at that time. 3. Avoid Falling Below the Critical Flows – To the extent practical, the Licensee will avoid falling below any of the Critical Flows as noted above. If it is determined that 100 percent exceedance of the Critical Flows 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. The Licensee will also work with any affected Large Water Intake Owners and Downstream Effluent Dischargers to minimize the impacts of the reduced flow releases. 4. Avoid Falling Below Critical Reservoir Elevations – To the extent practical, the Licensee will avoid falling below any of the Critical Reservoir Elevations as noted above. If it is determined that 100 percent exceedance of the Critical Reservoir Elevations cannot reasonably be achieved, the Licensee will work with any affected Large Water Intake Owners to minimize the impacts of the drawdown. 62 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Communication with Resource Agencies and Affected Parties Abnormal Condition F – Special River Access Circumstances NotificationConsultationComments NCDEQ NCWRC For developments in NC (including Wylie). If the circumstances USFWS cannot avoid impacting minimum flows for aquatic habitat, water quality, navigation, recreation or downstream water uses, initiate Large Water Intake FERC consultation as soon as soon as the dates are known, but at least 1 Owners 10 days prior to beginning the temporary flow alteration. Initiate consultation for unplanned river access within 5 days after the Downstream temporary flow alteration. Effluent 1 Dischargers SCDNR SCDHEC USFWS For developments in SC. If the circumstances cannot avoid NMFS impacting minimum flows for aquatic habitat, water quality, navigation, recreation or downstream water uses, initiate FERC Large Water Intake consultation as soon as soon as the dates are known, but at least 1 Owners10 days prior to beginning the temporary flow alteration. Initiate consultation for unplanned river access within 5 days after the Downstream temporary flow alteration. Effluent 1 Dischargers If the flow modifications for the planned river access affect flow BIA releases from the Wylie Development, initiate consultation as soon CIN as the dates are known but at least 10 days prior to beginning the temporary flow modification. Initiate consultation for unplanned river access within 5 days after the temporary flow alteration. Notify (within 5 days) and consult as soon as possible if the AW AW drawdown will affect prescribed recreational flow releases. The Licensee will conduct notification procedures for any Access Area temporary recreation facility/Access Area closures (e.g., closure Closure due to extended low reservoir levels) in accordance with the Notification Recreation Management Plan. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license General 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. Note 1 – If affected by Special River Access Circumstances. 63 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Abnormal Condition G – Expected or Existing High Inflow Event Mitigating Actions 1. As outlined in the Key Facts and Definitions section of this protocol, the Licensee may reduce reservoir levels significantly below the Normal Minimum Elevation, but not below the Critical Reservoir Elevations in preparation for high inflow events to minimize the potential for uncontrolled spilling. Reservoir levels may also rise significantly above Normal Maximum Elevations as a result of high inflow events. The reservoir levels may be below Normal Minimum Elevations or above Normal Maximum Elevations for as long as necessary to minimize the effects of uncontrolled spilling on the Project reservoirs and downstream river reaches and to minimize reservoir elevations during high inflow events. Communication with Resource Agencies and Affected Parties Abnormal Condition G – Expected or Existing High Inflow Event NotificationConsultationComments FERC For developments in NC (including Wylie). The Licensee will perform NCDEQ notification as soon as possible following or prior to a deviation from NCWRC license requirements for an existing or expected high inflow event. USFWS FERC SCDNR For developments in SC. The Licensee will perform notification as SCDHEC soon as possible following or prior to a deviation from license USFWS requirements for an existing or expected high inflow event. NMFS The Licensee will conduct notification procedures for any temporary Access Area recreation facility/Access Area closures (e.g., closure due to Closure extended low or high reservoir levels) in accordance with the Notification Recreation Management Plan. As soon as possible after the Licensee determines that the response to an abnormal condition will potentially impact license conditions, General 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. 64 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Identification and assessment of any incremental environmental impacts of the revision compared to the original WQC This revision creates no incremental environmental impacts. It expands resource agency notification and consultation regarding flow and reservoir level deviations and potential related environmental impacts and mitigation. Consultation Summary No comments received for this revision. 65 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix F: Water Quality Monitoring Plan (WQMP) (applies to NC and SC) Statement of Revision CRA Appendix F is the WQMP and is included as a condition of both state WQCs. Appendix E; Section A-5.0 Water Quality Article; Article – Water Quality Monitoring Plan of the license issued by the FERC on November 25, 2015 requires: (A) Within 180 days following the issuance of this license, the Licensee must file with the Commission, for approval, a Water Quality Monitoring Plan (WQMP) to monitor compliance with water quality requirements. The plan must include, at a minimum, identification of compliance monitoring locations and devices at applicable Project developments as needed to accurately monitor and record flows, dissolved oxygen, and water temperatures released from Project developments and an implementation schedule. Background information explaining the need for the revision There are two reasons for these revisions. Duke Energy now plans to shift from a fully in-house implementation, operation, and maintenance of water quality monitoring equipment, as envisioned when CRA Appendix F was originally written, to a partnership in which the United States Geological Survey (USGS) locates, installs, and maintains water quality monitors. Also, in Duke Energy’s assessment, the existing CRA Appendix F may not fully comply with the requirements set forth in the license issued November 25, 2015, as it does not contain an implementation schedule (Implementation schedule is currently found in CRA Appendix M). Actual text of the revision Note that the following revision of the WQMP represents a significant update of the original WQMP that was included in the December 22, 2006, Signature Copy of the CRA. Because of the substantial revisions made to text, figures, maps, and format, individual changes are not tracked to facilitate readability. 66 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 APPENDIX F: WATER QUALITY MONITORING PLAN (WQMP) 1.0 Introduction ..................................................................................................... 69 2.0 Hydro Project Compliance Monitoring .......................................................... 69 3.0 Supplemental Trout Habitat Monitoring ...................................................... 104 4.0 Trend Monitoring of Water Quality Characteristics .................................... 106 5.0 References .................................................................................................... 108 67 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 (intentionally blank) 68 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 WATER QUALITY MONITORING PLAN (WQMP) 1.0 Introduction Duke Energy Carolinas, LLC (the “Licensee”) received a new operating license (“License”) from the Federal Energy Regulatory Commission (FERC) for the Catawba-Wateree Hydro Project (the “Project’) on November 25, 2015. Appendix E of the New License requires Duke Energy to file a Water Quality Monitoring Plan (WQMP) with the FERC for approval. The WQMP must at a minimum include identification of compliance monitoring locations, devices needed to accurately monitor flows, dissolved oxygen (DO) concentrations, and water temperature, and an implementation schedule. This WQMP, developed in consultation with natural resource agencies, has been prepared to meet these requirements. The Licensee also submitted one Quality Assurance Project Plan (QAPP) to each state water quality agency. The QAPP provides the details for project management, measurement/data acquisition procedures and calibration, data validation, and reporting requirements as specified by the United States Environmental Protection Agency (USEPA 2001). The monitoring activities described in this document will be accomplished by a combination of United States Geological Survey (USGS) stream gages, USGS-operated water quality monitoring stations, and Licensee monitoring responsibilities (i.e., supplemental trout habitat monitoring and monitoring trends in water quality for streamflows entering the Project developments). 2.0 Hydro Project Compliance Monitoring 2.1 Background The License for the Project specifies flows to be released from various Project developments. Figure 1 provides a flow routing and compliance flow schematic for the entire Catawba-Wateree Project. These required flows in the riverine reaches are designed to enhance fish and wildlife habitat (continuous flows), to meet the needs of downstream water users, to provide periodic higher flows for recreational activities (water sports) and ecological purposes, and to meet water quality standards. Water quality issues that are relevant to the Project include continuous flows, water temperature, and DO concentrations. Compliance with state DO standards in water released from all of the Project developments is a requirement for both North and South Carolina’s 401 Water Quality Certifications. 69 9 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Figure 1: Project Flow Routing Schematic Catawba River Linville River Catawba Linville Lake James Arm of Arm of Lake Lake Catawba Paddy Ck Paddy Ck Bridgewater Linville 11 DamSpillway Dam Powerhouse Dam Paddy Creek Bypassed Reach Linville River Catawba River Bypassed Reach Muddy Johns Catawba River River Lake Rhodhiss Rhodhiss Rhodhiss 1 Dam Powerhouse Lake Hickory Lower Little River Oxford Oxford 2 Dam Powerhouse Notes: Overflow spillway Spillway with gates Catawba River With flash boards Lookout Shoals Lake Lookout Lookout LEGEND 1 Shoals Dam Shoals PH Powerhouse release Recreation release Lake Norman Continuous release Cowans Cowans Regulated reach or 2 Ford Dam Ford PH tributary inflow Bypassed reach Mountain Island Lake Reservoir Lake Mountain Mountain Dam Structure 1 Island Dam Island PH (continued) 70 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 (continued) Mountain Island Lake Mountain Mountain South Fork 1 Island Dam Island PH Catawba River Lake Wylie Notes: Overflow spillway WylieWylie Spillway with gates Sugar 1,2 Dam Creek Powerhouse With flash boards Catawba River Fishing Cane Creek Creek Fishing Creek Reservoir Fishing Fishing 2 Creek Dam Creek PH Great Falls Reservoir Lower Upper Pond Pond Camp Great Falls Dearborn Great Falls Great Falls Creek 1,31,3 HeadworksDiversion PH + Dam Powerhouse Rocky Creek Short Bypass Long Bypass LEGEND Powerhouse release Cedar Creek Reservoir Recreation release Rocky Creek Cedar 1,2 PH + Dam Creek PH Continuous release Big Wateree Regulated reach or Beaver Creek Creek tributary inflow Creek Lake Wateree Bypassed reach Wateree Wateree 1 Dam Powerhouse Lake Reservoir Dam Structure Wateree River 71 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 2.2 Sensor Locations The proposed sites for compliance monitoring of the Project were based upon the various flow and reservoir level requirements and water quality requirements referenced in Table 1 and the following criteria: 1. Representative of water quality conditions at all Project flows and operations; 2. Secure (minimize probability of vandalism); 3. Safely accessible for maintenance at all flows; and; 4. Small time-lag between changes in Project operations and monitor response (minimize downstream distance of sensor). Table 1. Summary of Project Compliance Verification and Reporting Comprehensive Relicensing Developments * Agreement Requirement Flow and Reservoir Level Requirements Bypassed Reaches Minimum Continuous BW, GF Flow Release Recreational Flow Releases BW, OX, WY, GF, WA Minimum Continuous Flows BW, OX, LS, WY, GF, WA Minimum Average Daily Flows RH, CF, MI, FC, CC Reservoir Elevations All Spring Reservoir Level Stabilization BW, CF, WY, WA Compliance Monitoring All Water Quality Requirements DO Concentrations All Minimum Flows BW, OX, LS, WY, GF, WA Compliance Reporting All * BW = Bridgewater (Lake James) RH = Rhodhiss OX = Oxford (Lake Hickory) LS = Lookout Shoals CF = Cowans Ford (Lake Norman) MI = Mountain Island WY = Wylie FC = Fishing Creek GF = Great Falls-Dearborn (Great Falls Reservoir) 72 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CC = Rocky Creek-Cedar Creek (Cedar Creek Reservoir) WA = Wateree The following pages provide maps or aerial photos for each hydro development in the Project indicating existing and proposed compliance monitoring locations with amplifying information. 73 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Bridgewater (Lake James)  Reservoir Level Monitor   USGS WQ Monitor at Existing USGS Gage Valve Flow Monitor  Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Wireless Bypassed telemetry to Flow sensor at Reach Minimum Hydro Station 1 Catawba Dam n/a Flow Release Continuous Computer and Valve Flows Staff Gage for visual 74 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Minimum USGS Satellite Continuous 1 Downstream of Link to NWIS Flows Powerhouse, USGS Station Web Interface 2 Recreational 0.10 and Turbine West Bank of 02138520 Flows Linville River Generation Project Hourly Records Flows Wireless Telemetry (DO) In Situ Downstream of - Pipe and Water to Hydro Station Powerhouse, Instruments at 3 0.10 Computer, Temperature, West Bank of USGS Station DO USGS Satellite Linville River 02138520 Link to NWIS Web Interface Current Device on Wired to Hydro Bridgewater 4 Reservoir Levels n/a the Intake Station Forebay Structure Computer Device Location Rationale The ring-jet valve at the Catawba Dam is designed to supply seasonal minimum continuous flows in the Catawba River Bypassed Reach (Location 1). A sensor, calibrated for flow, provides a continuous reading of the flow being released into the Catawba River Bypassed Reach. Since the sensor is located on the dam, it should be secure from vandals. The channel configuration at USGS Gage 02138520, CATAWBA R AT SR1223 BL LK JAMES NR BRIDGEWATER, NC, located 0.10 mile below the Bridgewater Powerhouse, is ideally suited for the expected range of flows originating from the Linville Dam (Location 2 & 3). The site is located on private property providing a measure of security. A previous water quality monitoring site was located on the downstream side of the former Bridgewater Powerhouse. Given the present configuration of the new Bridgewater Powerhouse, a decision was made to place the water quality monitoring instrument at the existing USGS flow gage station. Additional downstream continuous DO monitoring conducted in 2012 for aeration characteristics of the new Bridgewater Powerhouse generating units demonstrated that at the existing USGS gage site, DO concentrations were virtually identical to those measured simultaneously at the previously proposed (WQMP version 0) site, which was located 0.05 miles further downstream at the Powerhouse Road Bridge (HDR 2012). The selected USGS gage site has been shown to represent the water quality conditions of any combination of hydro unit flow (including minimum flow). In addition, the site is accessible under all Project flows, and will 1 National Water Information System: Web Interface operated by the USGS. 75 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 facilitate a rapid response at the station to water quality conditions. This gage site, originally installed in December 2008, was upgraded by the USGS in August 2015 to accommodate seasonally operated water quality instrumentation. Security from vandals is a minor concern at this site. Besides seasonal compliance monitoring for generation flow DO, water temperature will be monitored seasonally at this site to support state trout management initiatives on the downstream section of the river. 76 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Rhodhiss Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Planned USGS In Situ Station with Wireless - Pipe and Telemetry (DO) Rhodhiss Road Water Instruments to Hydro Station Bridge 1 Temperature, 0.40 Mounted on Computer, Downstream of DO Bridge in Center USGS Satellite Rhodhiss Hydro of Channel Link to NWIS (NCDOT approval Web Interface required) 77 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Current Device on Wired to Hydro Rhodhiss 2 Reservoir Levels n/a the Intake Station Forebay Structure Computer Device Location Rationale The previous water quality monitoring site was located on the south corner on the downstream side of the Rhodhiss Powerhouse. That site adequately represented the water quality of the turbine flow when all the units were identical; however, the turbine venting tests (Duke Power 2005a), indicated that this location was not representative of the combined flows from units with differing aeration capability. Therefore, the monitor should be moved to the center of the river channel at the downstream bridge (Location 1). The bridge not only provides an existing structure to place the water quality monitor in the center of the channel, but this site represents the water quality conditions of any combination of hydro unit flows (Duke Power 2005a). This site is accessible under all Project flows, and may provide a rapid response at the station to water quality conditions. Security from vandals may be a slight concern at this site. 78 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Oxford (Lake Hickory) Proposed WQ Monitor   Reservoir Level Monitor Proposed USGS-  Gage Height Sensor Proposed Modified Trash Gate  79 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Approximate Map Recommended Distance Data Comments Data Collection Location Location Downstream (miles) Planned USGS In Situ Station with Wireless - Pipe and Telemetry (DO) Highway 16 Water Instruments to Hydro Station Bridge 1 Temperature, 0.15 Mounted on Computer, Downstream of DO Bridge, South USGS Satellite Oxford Hydro Channel Link to NWIS (NCDOT approval Web Interface required) Modified Trash Minimum Gate monitored Wired to Hydro 2 Continuous Oxford Dam n/a via Reservoir Station Flows Elevation and Computer Gate Position Highway 16 USGS-Gage Gage Height Recreational Bridge height sensor at indicator and Flows 3 Downstream of 0.15 planned USGS Turbine Project Hourly Oxford Hydro, Water Quality Generation Flows Turbine Records Station Records Current Device on Wired to Hydro 4 Reservoir Levels Oxford Forebay n/a the Intake Station Structure Computer Device Location Rationale An existing trash gate will be modified to spill well-aerated reservoir near-surface water in order to provide a constant minimum continuous flow in the downstream channel (Location 2). The gate will provide the minimum continuous flow during periods of no hydro unit generation. The gate position will be adjustable and set as required to deliver the required minimum flow based on target reservoir elevation and expected reservoir elevation range. Generation and recreational flow requirements will be recorded from the generation records for each turbine. A previous water quality monitoring site was located in the corner of the Oxford Powerhouse and wingwall. That site adequately represented the water quality of the turbine flow when all the hydro units were identical, and prior to the installation of the tailrace buttresses. However, this site now is not representative of the combined flows from hydro units with differing aeration capability and the buttresses would effectively prevent Unit 2 water from reaching the sensor when Unit 1 is generating. Therefore, a decision was made to move the monitor to the Highway 16 Bridge immediately downstream of the turbines (Location 1). The bridge not only provides an existing structure to place the water quality monitor in the channel, but this site will represent the water quality conditions of any combination of hydro unit flows. This site will be accessible under all Project flows, and will provide a rapid response of the station to water quality conditions. Security from vandals may be a concern at this site, and adverse effects on equipment due to occasional high tailwater water levels is a possibility. 80 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Lookout Shoals Reservoir Level Monitor  USGS WQ Monitor  Map Data Recommended Approximate Comments Data Collection Distance LocationLocation Downstream (miles) 1 Water 0.01 In Situ - Pipe and Wired to Hydro East Wingwall - Instruments at Temperature, Tailrace Station USGS Station DO Computer (DO), 0214244102 USGS Satellite Link to NWIS Web Interface 2 Minimum Lookout Shoals n/a n/a Turbine Continuous Hydro Generation Flows Records Project Hourly Flows 3 Reservoir Levels n/a Current Device on Wired to Hydro Lookout Shoals Forebay the Intake Station Structure Computer 81 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Device Location Rationale The minimum continuous flow will be provided by either one of the small auxiliary hydro units (Location 2) during periods when the larger hydro units are not operating. The configuration of the Lookout Shoals tailrace (including a pooled area upstream of the first downstream hydraulic control, located approximately 500 ft downstream of the powerhouse) exhibits very little stage change with or without the auxiliary hydro unit generation. In addition, the elevation of the tailrace is also a function of Lake Norman’s reservoir level (at full pond, the reservoir level extends upstream of the hydraulic control). Therefore, the minimum continuous flow and hourly flow rates would be best monitored by the individual generation records of each hydro unit at Lookout Shoals Hydro. A previous water quality monitoring site was located on the east wingwall downstream of Unit 1. That site adequately represented the water quality of the turbine flow when all the hydro units were identical. The nearest downstream structure to place a monitor in the center of the channel is the I-40 Bridge, which is 1.3 miles downstream. The I-40 Bridge site is strongly influenced by Lake Norman’s reservoir level, and the long travel time to the Bridge site would influence the water quality at minimum flow. Therefore, the I-40 Bridge location is not preferred for water quality monitoring. Since no other downstream structure exists to place a monitor in the center of the river, the wingwall site (Location 1) represents the best logistical option available for water quality monitoring. This wingwall site will be accessible under all Project flows, and will provide a rapid response of the station to water quality conditions. The monitor will be secure since it is located inside the security fence. A seasonally operated USGS Water Quality Station, USGS 0214244102 CATAWBA RIVER CATAWBA RIVER BL LOOKOUT SHOALS DAM NR SHARON, NC was activated in March, 2016. 82 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Cowans Ford (Lake Norman) Reservoir Level Monitor  USGS WQ Monitor  Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Wireless Telemetry (DO) In Situ Railroad Bridge - Pipe and Water to Hydro Station Downstream Instruments at 1 Temperature, 0.50 Computer, Cowans Ford USGS Station DO USGS Satellite Hydro 0214264790 Link to NWIS Web Interface Wired to Hydro Cowans Ford Current Device on 2 Reservoir Levels n/a Station Forebay Intake Structure Computer Device Location Rationale 83 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Even though the previous monitor was placed on the tail-deck of Cowans Ford Hydro, this location probably represented the water quality of the released flow. However, under multi-unit operation, the monitor would only record data from the hydro unit flows adjacent to the monitor. In addition, security at the Cowans Ford Hydro facility is controlled by the McGuire Nuclear site (Nuclear Regulatory Commission guidelines) and is difficult to enter when operators are not present. This security issue limits maintenance accessibility. Therefore, the recommended site for the temperature and DO monitoring is at the railroad bridge 0.5 miles downstream (Location 1). This site enables the monitor to measure water quality from the high-volume hydro unit flow as well as provide a somewhat secure site. Location of the monitor just west of the downstream tip of the island ensures that the monitor remains out of the influence of the wastewater discharge from McGuire Nuclear Station. A seasonally operated USGS Water Quality Station (USGS 0214264790 CATAWBA R AT RR BRIDGE AB NC 73 AT COWANS FORD, NC) was activated at this site in June, 2016. 84 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Mountain Island Reservoir Level  Monitor USGS WQ Monitor  Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Wireless Telemetry (DO) In Situ - Pipe and Water to Hydro Station Tail Deck - Instruments at 1 Temperature, 0.00 Computer, Tailrace USGS Station USGS Satellite DO 0214267602 Link to NWIS Web Interface Wired to Hydro Mt. Island Current Device on 2 Reservoir Levels n/a Station Forebay Intake Structure Computer Device Location Rationale 85 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Even though the present monitor is on the tail-deck of the hydro (Location 1), this location probably represents the water quality of the released flow. However, under multi-unit operation, the monitor would be primarily influenced by the hydro unit flows adjacent to the monitor. Since no other structure, (e.g., bridge), exists in the center of Mountain Island’s tailrace, this tail-deck location represented the best logistical location available. The site is secure and provides ready access for maintenance. A seasonally operated USGS Water Quality Station, USGS 0214267602 CATAWBA RIVER DNSTRM DECK MTN IS DAM NR MTN IS, NC was activated at the site in May, 2015. 86 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Wylie 87 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Planned USGS In Situ Station with Pipe and Wireless Instruments Approximately Telemetry (DO) Water Deployed into 0.5 Mile to Hydro Station Temperature, Channel from 1 Downstream 0.50 Computer, West Shore off from Hydro (off USGS Satellite DO Ferrell Island Ferrell Island) Link to NWIS Web Interface (Island property, owner’s approval required) USGS Gage Small Unit Turbine Minimum Turbine 02146000, n/a, Generation Records, 2 Continuous Records, and CATAWBA RIVER 3.60 Flows Highway 21 USGS Gage NEAR ROCK USGS Gage HILL, SC USGS Gage Recreational Turbine Turbine 02146000, Flows Records, n/a, Generation 3 Records, and CATAWBA RIVER Project Hourly Highway 21 3.60 USGS Gage NEAR ROCK Flows USGS Gage HILL, SC Current Device on Wired to Hydro the Intake Station 4 Reservoir Levels Wylie Forebay n/a Structure Computer Device Location Rationale The USGS gage at the Highway 21 Bridge (Location 2/3) is well established and will be used for verification of minimum continuous flow, recreational flows, and hourly Project flows. In addition, generation records will be used to supplement the USGS data. However, as this site is 88 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 approximately 3.6 miles downstream of the Wylie Powerhouse, the distance makes it less suitable for locating water quality instruments there. A previous water quality monitoring site was located in the corner of the powerhouse and wingwall. Extensive monitoring of DO concentrations in the Wylie tailrace was conducted during the 2002 turbine venting test (Duke 2005a). These results indicated that the proposed monitoring location was the closest point to the hydro that best represented the water quality of the multi-unit flows (Location 1). This test included detailed water quality sampling along several downstream transects, as opposed to just at the monitoring site. Furthermore, the Wylie tailrace is very complicated since the island immediately downstream of the powerhouse splits the water released from the hydro. The flow, from either a single unit or multiple unit operation, moves around the island and finally merges just upstream of the small island across the channel from the proposed monitoring location. Use of this location is contingent on being able to get permission for access from the property owner and on obtaining any necessary easements. Security from vandals is of some concern at this site. 89 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Fishing Creek Reservoir Level Monitor  Buttresses USGS WQ Monitor  Approximate Recommended Distance Data Map DataComments Location LocationDownstream Collection (miles) Wireless Telemetry Highway 97/200 (DO) to Hydro In Situ - Pipe and Water Bridge Station Instruments at Temperature, 1 0.15 Computer, Downstream USGS Station USGS DO Fishing Creek 02147310 Satellite Link Hydro to NWIS Web Interface 90 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Existing Device Wired to Reservoir Fishing Creek 2 N/A Hydro Station on the Intake Levels Forebay Computer Structure Device Location Rationale A previous water quality monitoring site was located on the wingwall, west of the Fishing Creek Powerhouse. That site adequately represented the water quality (temperature and DO) of the turbine flow when all the hydro units were identical and prior to the recent installation of the tailrace buttresses. However, this site would probably not be representative of the combined flows from hydro units with differing aeration capability since the flows will be directed downstream due to the newly installed buttresses. Therefore, the best site for a new monitor is the Highway 97/200 Bridge immediately downstream of the turbines (Location 1). The bridge not only provides an existing structure to place the water quality monitor in the channel, but this site will represent the water quality conditions of any combination of hydro unit flows. This site is accessible under all Project flows, and allows for a rapid response of the station to water quality conditions. Security from vandals may be a concern at this site. A seasonally operated USGS Water Quality Station (USGS 02147310 CATAWBA RIVER AT GREAT FALLS, SC) was activated at this site in June, 2016. 91 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Great Falls-Dearborn (Diversion Dam) Proposed Staff Gage Proposed Obermeyer Gate(s); and/or Diversion Dam Notch(s)  92 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Great Falls-Dearborn (Headworks) Proposed Staff Gage   Proposed Obermeyer Gate(s); or Diversion Dam Notch(s) Proposed Pond Level  Gage 93 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Great Falls-Dearborn (Main Dam) Reservoir Level Monitor USGS WQ Monitor  Map Data Recommended Approximate Comments Data Location LocationDistance Collection Downstream (miles) Optionally, Static Bypassed Optionally, Notch Dimensions Diversion Dam Reaches Notch(s) in Used with Wired Long Bypassed Diversion Dam, Pond Elevation or Minimum 0.25 mi. from Reach or Gate Position Staff Gage Visual; 1 Continuous Fishing Creek Sensor Used in or Wireless Flows Dam Downstream Conjunction with Telemetry of Fishing Creek Pond Elevation to Actuated Gate Recreational Hydro Assure Flows Position to Hydro Flows Station Computer Optionally, Optionally, Static Bypassed 1.95 mi. from Headworks Notch(s) in Notch Dimensions Reaches 2 Fishing Creek Headworks Dam, Used with Wired Dam Short Bypassed Minimum or Gate Position Pond Elevation or 94 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Continuous Reach Sensor Used in Staff Gage Visual; Flows Conjunction with or Wireless Downstream Pond Elevation to Telemetry of Fishing Creek Recreational Assure Flows Actuated Gate Flows Hydro Position to Hydro Station Computer Wireless Telemetry In Situ - Pipe and (DO) to Hydro Water Duke Bridge 0.1 mi. from Instruments at Station Computer, Temperature, 3 Downstream of Great Falls – USGS Station USGS Satellite Link Hydros Dearborn Dam DO 021474095 to NWIS Web Interface Existing Device Reservoir Great Falls Wired to Hydro 4 N/A on the Intake Levels Forebay Station Computer Structure Device Location Rationale Ideally, measurement of the minimum continuous flows and recreational flows in the Great Falls Long and Short Bypassed Reaches would be taken directly in the respective channels. However, the irregular channel configuration in both reaches prevents accurate flow measurements from stage changes. In addition, the difficult access to the bypassed reaches poses substantial personnel safety limitations to the calibration and maintenance of the gages. Therefore, the best measurement of the flow in the bypassed reaches is at the source of the flows (Locations 1 and 2). The facilitation and measurement of recreational flows into the bypassed reaches will either be via a known relationship of stage and gate opening positions, or via the known relationship to pond elevation relative to dam notch openings. Continuous flow monitoring for the Long Bypass will be located at the Great Falls Diversion Dam immediately downstream of Fishing Creek Hydro (Location 1). The continuous flow monitoring for the Short Bypassed Reach will be provided at the Great Falls Headworks spillway, downstream of the headworks structure (Location 2). Manually read, new USGS type plate staff gages will be placed at the Great Falls Diversion Dam and upstream of the Great Falls Headworks (Locations 1 and 2). A previous water quality monitor mounted on the Duke Energy bridge immediately downstream of Great Falls and Dearborn Hydros is ideally located since it is in the center of the channel (Location 3). This position captures the water quality (temperature and DO) from both hydros and is in a secure location. A seasonally operated USGS Water Quality Station (021474095 95 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 GREAT FALLS RESERVOIR TAILRACE AT GREAT FALLS, SC) was installed at this site in March, 2016. 96 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Rocky Creek-Cedar Creek Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Planned USGS Water Downstream In Situ Station with Wired to Hydro Temperature Face of Cedar 1 0.00 - Pipe, Monitor Station Creek Location Computer DO Powerhouse Unchanged Current Device on Wired to Hydro Cedar Creek the Intake Station 2 Reservoir Levels n/a Forebay Structure Computer 97 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Device Location Rationale A previous water quality monitor was located in the center of the Cedar Creek tailrace, mounted directly on the powerhouse. Since the hydro units at Cedar Creek were identical, the temperature and DO monitor adequately measured the water quality released from Cedar Creek Powerhouse (Location 1). Unlike Great Falls-Dearborn, there is no structure downstream of Cedar Creek Powerhouse to mount a water quality monitor in the center of the channel. The water quality of the Cedar Creek hydro flow represents the overall tailrace water quality because:  Cedar Creek Powerhouse flow is significantly greater than Rocky Creek Powerhouse flow and dominates the downstream flow (capacity of Cedar Creek units is three times the capacity of the Rocky Creek units).  Rocky Creek Hydro is operated infrequently; it is operated only after Cedar Creek Reservoir pond level cannot be maintained by Cedar Creek Hydro (three Units at Cedar Creek).  Both hydros draw water from the same forebay and the water quality is similar. Thus, no water quality monitoring device is necessary at the Rocky Creek Hydro. 98 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Wateree 99 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Approximate Map Recommended Distance DataCommentsData Collection LocationLocationDownstream (miles) Wireless Planned USGS Telemetry (DO) Water West Shore In Situ Station with to Hydro Station Temperature, Platform – Computer, 1 0.02 - Pipe, Monitor Tailrace Location USGS Satellite DO Unchanged Link to NWIS Web Interface USGS Station 02148000 USGS Gage and Minimum Highway 1/601 (Wateree River Turbine 2 Continuous 7.4 near Camden, Generation USGS Gage Flows SC) Records USGS Station 02148000 Recreational Turbine Records USGS Gage and Flows (Wateree River Turbine 3 Highway 1/601 7.4 near Camden, Generation Project Hourly SC) Records USGS Gage Flows Current Device on Wired to Hydro Wateree 4 Reservoir Levels n/a the Intake Station Forebay Structure Computer Device Location Rationale The USGS gage at Highway 1/601(Location 2/3) is well-established and will be used for verification of minimum continuous flow, recreational flows, and hourly Project flows. Generation records will be used to supplement the USGS data. The Wateree tailrace is a relatively simple channel, with the flows from the various hydro units moving directly downstream. However, the tailrace does not lend itself to simple water quality 100 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 monitoring due to the various aeration capabilities of the individual hydro units and subsequent multi-unit flow patterns (Duke Power 2005a). Moving the monitor location downstream to capture a multi-unit flow is not an option because, at flows greater than provided by 2-3 unit operations, a significant volume of water flows out of the main channel to the east within a few hundred yards of the powerhouse. The existing monitor location (Location 1) was built to extend a short distance into the tailrace with the goal of obtaining more representative water quality measurements than at the face of the powerhouse. The existing monitor location is the best logistical location available to measure water quality because no structure exists in the center of the channel, nor is the east side of the channel a viable option because that area is heavily used by fisherman (creating damage and security issues) and is prone to flooding and further potential damage or loss. The next available location at the Highway 1/601 Bridge is less suitable because of its distance from the powerhouse and the presence of aquatic plants and shoals between the powerhouse and bridge that significantly influence the DO levels. 2.3 Water Quality Monitoring Implementation Plan and Schedule Per the Comprehensive Relicensing Agreement (CRA), Appendix M, all water quality monitors are to be installed within 12 months following FERC approval of the Project Flow and Water Quality Implementation Plan (FWQIP; Table 3). 101 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Table 3 Water Quality Monitoring Schedule Task Timeframe Notes At several locations, the installation of water quality monitors will precede the installation of the equipment 12 months after FERC approves modifications necessary to achieve compliance. In Water Quality the FWQIP (subject to approval these cases, the monitors will assist Duke Energy in in NC and SC 401 Water Monitor the implementation of interim measures per the Installation Quality Certification) per CRA, FWQIP. However, these monitor results are not Appendix M suitable for compliance assessments until the necessary equipment modifications have been implemented (refer to CRA Section 13.2) DO Each year for the term of the license, per Compliance April 1 – November 30 WQMP/FWQIP Monitoring Water Each year for the term of the license, per Temperature April 1- November 30 WQMP/FWQIP Compliance Monitoring Annual Report The annual report will reflect previous year’s data; June 30 Submitted annual reports submitted for the term of the license The Licensee’s plans for water quality data collection methodologies, including requirements for measuring instrumentation, calibrations and maintenance, validation, archival, reporting, and data transmittal providing real-time input for hydro compliance operations are described in the Quality Assurance Project Plans (QAPPs) filed with both the North Carolina Department of Environmental Quality (NCDEQ) and South Carolina Department of Health and Environmental Control (SCDHEC). 2.4 Reporting Requirements Historic records indicate that DO concentrations have consistently exceeded state water quality standards during the winter months. Therefore, compliance monitoring for water temperature and DO will commence on 1 April and end on 30 November each year during the term of the New License, unless additional monitoring is determined necessary by the state water quality agency (e.g., for extended low DO periods, unusual meteorological periods). Flows and reservoir levels will be recorded year-round. 102 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 2 USGS Provisional water quality datafor each monitoring site will be maintained in real time on the USGS NWIS Web Interface for as needed access by state water quality agency staffs. After compliance monitoring is initiated per Section 2.3 above, during the term of the New License, an annual report summarizing the previous water quality monitoring season will be filed with the appropriate agencies by June 30 of the following year. 2 Provisional USGS data typically include the following disclaimer: Data are provisional and subject to revision until they have been thoroughly reviewed and received final approval. Provisional data may be inaccurate due to instrument malfunctions or physical changes at the measurement site. Subsequent review based on field inspections and measurements may result in significant revisions to the data. Data users are cautioned to consider carefully the provisional nature of the information before using it for decisions that concern personal or public safety or the conduct of business that involves substantial monetary or operational consequences. 103 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 3.0 Supplemental Trout Habitat Monitoring 3.1 Monitoring The Catawba River Bypassed Reach and Bridgewater minimum continuous flows have been selected and evaluated to provide flows and water temperatures suitable for protection and enhancement of mussels in the bypassed reach and the maintenance of a stocked trout fishery downstream of Bridgewater Hydro. The volume of warmwater flows provided to the Catawba River Bypassed Reach to maintain mussel habitat are balanced against the coldwater minimum flow from the Linville Dam to maintain suitable temperatures for trout downstream of the confluence of the Catawba River Bypassed Reach and the Linville River. During Project relicensing, the flows and temperatures provided to each channel to achieve the desired, but conflicting temperature requirements were analyzed by the CE-QUAL-W2 reservoir model and the River Modeling System (RMS). The results of these computer models were evaluated by the Aquatics/Terrestrial and Water Quality Resource Committees. Bypassed Reach and Linville Dam minimum continuous flows stated in the CRA are the result of the recommendations from the evaluations by the resource committees. Due to the hydraulic complexity and trout supplemental management interests in this area, supplemental monitoring will be used seasonally (1 April through 30 November) to support future evaluations of whether trout management goals in the mainstem Catawba River continue to be supported. Results of this monitoring may be used to determine if flow reductions need to be made in the Catawba River Bypassed Reach. Per CRA agreement, this supplemental trout habitat monitoring was to commence after the Bridgewater Powerhouse had been replaced with either a new powerhouse or valve system and compliance operations had begun. Also, the study was to continue through the next full North Carolina Division of Water Resources (NCDWR) Catawba River Basinwide Assessment period, but not beyond Year 2019. Due to the extended time between the CRA signing and New License issuance, Duke Energy and the NCDWR have agreed that the study will be conducted at least from 2016 to 2019 (four years), but may be extended to additional years if the initial four sampled years are not sufficiently variable from either a meteorological or operational perspective. The general study outline for the supplemental trout habitat monitoring is provided below. 3.2 Sensor Locations The temperature and level logger placement is designed to be able to record temperatures, flow (level logger with stage-discharge relationship) from the inflows, and empirically determine the temperatures at the appropriate downstream river reaches. An additional downstream temperature and level logger and staff gage (not depicted on the map below) will be provided at the Watermill Bridge (RM 271.7) in Glen Alpine, NC which is in the middle of the primary trout habitat. 104 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Bridgewater Supplemental Trout Habitat Monitoring USGS Gage & WQ Reservoir Level Monitor (Compliance) Temperature Monitor Logger, Level Logger, & Staff Gage Valve Flow Monitor Temperature Loggers (Compliance) Temperature Loggers Level Logger, Staff Gage 3.3 System Requirements Level loggers (devices to record river stage from which a stage-discharge relationship may be developed to calculate flow) and temperature loggers will be placed in the river and periodically downloaded to obtain the respective data. Stage-discharge curves will be developed and maintained for the level logger sites. 3.4 Reporting Requirements Annual reports will be provided to the NCDEQ and North Carolina Wildlife Resources Commission (NCWRC) annually by 30 April, the calendar year following monitoring seasons, for the duration of the supplemental trout habitat monitoring study. Reports will detail the previous monitoring season’s temperatures and levels. Flow-weighted temperatures will be calculated for the downstream sites. 105 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 4.0 Trend Monitoring of Water Quality Characteristics 4.1 Background Dissolved oxygen deficits in the Project reservoirs have been shown to be related to organic and nutrient (nitrogen and phosphorus) loading (Duke Power 2005b). Increased organic and nutrient loadings to the system after the Licensee installs aeration equipment designed to meet current deficits may impose additional oxygen deficits that the equipment was not designed to treat. To provide information to assess basin-wide growth and potential increased organic and nutrient loading, the Licensee will monitor trends in organic and nutrient concentrations to supplement state water quality databases. This monitoring is not required for compliance with the Section 401 Water Quality Certifications. 4.2 Sampling Locations In cooperation with state agencies, the Licensee will identify sampling sites for future long-term organic and nutrient sample collections. Parameters collected will include total N (calculated from nitrate+nitrite and total Kjeldahl nitrogen), total P, pH, DO, and water temperature. Hydro Tailraces Samples will be collected monthly throughout the year from the immediate tailraces or alternatively in the vicinity of the continuous water quality monitors. Tributary Sites Tributary sampling will focus on stream confluences draining major sub-watersheds into the Project reservoirs and downstream river sections. Tributary samples will be collected monthly, beginning in 2017. The following tributaries will be monitored in North Carolina:  Muddy Creek at Highway 70 (Burke Co.)  Johns River at Highway 18 (Burke Co.) *  Catawba River at Highway 18 (Burke Co.) *  Lower Little River upstream of Confluence with Catawba River (Alexander Co.)  Catawba Creek at SR 2435 (Gaston Co.)  South Fork Catawba River at Goat Island Park Pier, Cramerton (Gaston Co.) * 3 (* Three storm events will be sampled each year.) The tributaries in South Carolina to be sampled will be chosen from the following list: Sugar Creek at Hwy 160 (York Co.) 3 Storm event sampling to occur within 72 hours of a tributary catchment precipitation event estimated meeting or exceeding a minimal 1.27 cm (0.5 in) precipitation accumulation. One convenient-to-access source of precipitation data currently available for this purpose is the NC CRONOS/ECONet Database, developed by the State Climate Office of North Carolina (http://climate.ncsu.edu/cronos). 106 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Catawba River at Highway 9 (Chester and Lancaster Co.) Fishing Creek at SSR 77 (Chester Co.) Cane Creek at SSR 50 (Lancaster Co.) Rocky Creek at USGS Gage (Chester Co.) Big Wateree Creek at Highway 21 (Fairfield Co.) Beaver Creek at SSR 13 (Kershaw Co.) 4.3 Sampling Requirements The samples will be collected and analyzed by state certified personnel and laboratories. 4.4 Reporting Requirements Data derived from the long-term monitoring program will be stored electronically and reports provided as needed or requested by state agencies, such as to support the NCDWR’s Catawba River Basinwide Assessment. 107 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 5.0 References Duke Power. 2005a. Catawba Hydros - Existing Aeration Capability and Downstream Aeration Tests, Technical Report Series, Catawba-Wateree License. FERC No. 2232, Charlotte, NC. Duke Power. 2005b. CE-QUAL-W2 Calibration Reports, Technical Report Series, Catawba- Wateree License. FERC No. 2232, Charlotte, NC. Duke Energy 2015. Bridgewater Supplemental Trout Habitat Monitoring Study Plan. Duke Energy Water Resources. Huntersville, NC. \[HDR\] HDR Engineering, Inc. 2012. Bridgewater Hydroelectric Station Dissolved Oxygen Report. Prepared for Duke Energy Carolinas, LLC. December 2012. Knight, Jon, 2003. Dissolved Oxygen Concentrations and Water Temperature from Bridgewater Hydroelectric Station. Duke Power Company. Mitchell, Thomas O. 2006. Luminescence Based Measurement of Dissolved Oxygen in Natural Waters. Hach Environmental. Loveland, CO. United States Environmental Protection Agency. 2001. EPA Requirements for Quality Assurance Project Plans. EPA QA/R-5, EPA/240/B-01/003. USEPA, Office of Environmental Information, Washington D.C. 108 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Identification and assessment of any incremental environmental impacts of the revision compared to the original WQC The USGS is a nationally-trusted resource whose expertise adds value in the form of personnel experience and technical capability, organizational continuity and accountability, and all facets of quality assurance and quality control in environmental monitoring. The USGS has the resources to make provisional water quality data publicly available on the internet for all monitoring locations on a real-time basis, and subsequently furnishing approved water quality data which will be used in annual compliance reports. Duke Energy will also have access to real- time water quality data via local telemetry, to be used throughout the monitoring season in managing hydro operations to meet dissolved oxygen requirements. Consultation Summary Commenter Summary of Comment Duke Energy Response NC Wildlife The map location of the USGS gage Duke Energy agrees the location of Resources and WQ monitor below the the USGS gage as shown on the Commission Bridgewater Powerhouse are Water Quality Management Plan incorrect. (WQMP) maps needs to be changed. The gage is actually located on the river between the Bridgewater Powerhouse tailrace and the Powerhouse Road bridge, just upstream of where the bridge crosses the river. We will revise the maps and will also confirm downstream distances and revise them accordingly. NC Wildlife There is a discrepancy between The USGS aerial photograph of the Resources Duke Energy’s description of the gage location is of the Bridgewater Commission USGS gage location below the Fishing Area, which is indeed open Bridgewater Powerhouse and the to the public. The lat-long location as shown by the USGS and coordinates on the USGS aerial a concern about the gage being in a photo place the gage across the river publicly-accessible area. from the fishing area adjacent to Powerhouse Road downstream of the Powerhouse Road bridge. However the gage is actually located upstream of the bridge outside the 109 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 access area. While Duke Energy may not be able to resolve all discrepancies among these references, we will confirm and revise the site description in the WQMP as necessary to be accurate. NC Wildlife It was suggested to add text Duke Energy will provide additional Resources explaining how the minimum flow explanation of how the gate at Commission release gate at the Oxford Oxford will operate and provide Powerhouse will operate and continuous minimum flow. provide continuous minimum flow. The gate position will be adjustable and set as required to deliver the required minimum flow based on target reservoir elevation and expected reservoir elevation range. 110 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 CRA Appendix L: Flow and Water Quality Implementation Plan (FWQIP) (applies to NC and SC) Statement of Revision CRA Appendix L is the FWQIP and is included as a condition of both state WQCs. Appendix E; Section A-2.0 Flow Articles; Article – Flow and Water Quality Implementation Plan of the license issued by the FERC on November 25, 2015 requires: Within 180 days following the issuance of this license, the Licensee must file with the (A) Commission, for approval, a Flow and Water Quality Implementation Plan (FWQIP) for completing the modifications necessary to satisfy the flow and water quality requirements at Project developments. The Plan shall include, at a minimum: (i) descriptions of any equipment, including flow release valves, minimum flow hydro units, or aerating hydro units to be installed; (ii) descriptions of any proposed modifications to any Project structures to provide prescribed flow releases or meet the requirements of the 401 Water Quality Certifications; and (iii) a schedule for the installations and modifications to meet the prescribed flow releases or water quality requirements stipulated in this license. Background information explaining the need for the revision One reason for the changes to FWQIP activities and schedules as originally included in both state WQCs is current timelines for vendors to design, fabricate, and deliver major components, such as the new minimum flow units at the Wylie and Wateree Developments, are different than projected in 2006. Also, Duke Energy has already implemented major items such as flow and water quality improvements at the Bridgewater Development (at both the Bridgewater Hydro Station and the Catawba Dam), the Rhodhiss Development, and the Oxford Development. More detailed design and scheduling for Great Falls minimum continuous flow and recreation flow release modifications coupled with other improvements required by the Federal Energy Regulatory Commission have resulted in modifications to implementation schedules at that development. Actual text of the revision (for ease of identification, text modified from the December 22, 2006, Signature Copy of the CRA, Revision 1 is shown in bold italics) 111 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 APPENDIX L: FLOW AND WATER QUALITY IMPLEMENTATION PLAN (FWQIP) The Flow and Water Quality Implementation Plan (FWQIP) table that follows presents an outline of:  A site-specific list of measures that the Licensee will take for providing aquatic flows, recreation flows and for meeting the applicable water quality standards;  A schedule for when these measures will be implemented; and  A schedule for any interim measures that will be taken to address flow releases or dissolved oxygen (DO) improvements prior to completing the necessary physical modifications to the Project. Dates are subject to change due to items beyond the Licensee’s control such as materials availability, manufacturing capacity, transportation schedules and installation contractor availability. The Licensee will however make every reasonable effort in its planning and implementation to minimize the chance of delays in this schedule. Timeframe for Operational Change to Timeframe for Implement Flows and/or Completing Physical Enhance DO where No Physical Modifications Modifications and Interim Measures for Providing Aquatic Physical Modifications Proposed to Meet Flow Implementing Flows Flow and/or DO Enhancement until Locationare Anticipatedand/or DO Requirements and/or DO Enhancements Physical Modifications are Complete (Note 7) (Note 8) (Note 1) (Notes 3, 7) Bridgewater Development (Notes 2, 4, 6) Completed 11/18/09 New flow valve with aerating Catawba Dam N/A N/A capability New Powerhouse with Linville Dam N/A New powerhouse N/A aerating capability on all completed 11/14/11 units or flow valve system (Note 2) 112 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Timeframe for Operational Change to Timeframe for Implement Flows and/or Completing Physical Enhance DO where No Physical Modifications Modifications and Interim Measures for Providing Aquatic Physical Modifications Proposed to Meet Flow Implementing Flows Flow and/or DO Enhancement until Locationare Anticipatedand/or DO Requirements and/or DO Enhancements Physical Modifications are Complete (Note 7) (Note 8) (Note 1) (Notes 3, 7) Rhodhiss Development Rhodhiss Dam & New aerating runner on Unit N/A Completed 12/03/13 N/A Powerhouse 3 Oxford Development - Trash gate modification - 12 months following Beginning within 60 days following the to spill forebay surface FERC approval of FWQIP date of closure of the New License, raise water. The gate position Oxford Dam N/A a flood gate during periods of no will be adjustable and generation to release and aerate the set as required to deliver Minimum Continuous Flow. the required minimum flow based on target reservoir elevation and expected reservoir elevation range. - New aerating runner on - Completed 12/23/13 one existing unit (Unit 2) 113 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Timeframe for Operational Change to Timeframe for Implement Flows and/or Completing Physical Enhance DO where No Physical Modifications Modifications and Interim Measures for Providing Aquatic Physical Modifications Proposed to Meet Flow Implementing Flows Flow and/or DO Enhancement until Locationare Anticipatedand/or DO Requirements and/or DO Enhancements Physical Modifications are Complete (Note 7) (Note 8) (Note 1) (Notes 3, 7) Lookout Shoals Development Beginning within 60 days following the date of closure of the New License, operate existing vacuum breakers (three units) as needed Lookout Shoals to meet state standard N/A N/A N/A Powerhouse s for DO while monitoring Oxford DO carry-over benefits. If necessary, add aerating capacity to auxiliary units. Operate existing large or auxiliary units as needed to provide minimum flow. Cowans Ford Development Beginning within 60 days following the date of closure Cowans Ford of the New License, operate N/A N/A N/A Powerhouse & Dam existing units as needed. No flow or DO enhancements are needed. 114 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Timeframe for Operational Change to Timeframe for Implement Flows and/or Completing Physical Enhance DO where No Physical Modifications Modifications and Interim Measures for Providing Aquatic Physical Modifications Proposed to Meet Flow Implementing Flows Flow and/or DO Enhancement until Locationare Anticipatedand/or DO Requirements and/or DO Enhancements Physical Modifications are Complete (Note 7) (Note 8) (Note 1) (Notes 3, 7) Mountain Island Development (Note 5) Beginning within 60 days following the date of closure of the New License, operate Mountain Island existing stay vane aeration N/A N/A N/A Powerhouse & Dam units as needed. No flow or DO enhancements are needed. Wylie Development Beginning within 60 days following the date of closure of the New License, pulse Replace one existing hydro an existing unit 1 hr on, 2 hrs off during 30 months following Wylie Powerhouse N/A unit with a smaller unit with periods when at least 1 unit is not running FERC approval of FWQIP aerating capability continuously. When DO is below state standards, operate two existing units with hub-venting capability on a first-on, last-off hierarchy whenever the station is being operated for flow release, reservoir level control or generation. 115 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Timeframe for Operational Change to Timeframe for Implement Flows and/or Completing Physical Enhance DO where No Physical Modifications Modifications and Interim Measures for Providing Aquatic Physical Modifications Proposed to Meet Flow Implementing Flows Flow and/or DO Enhancement until Locationare Anticipatedand/or DO Requirements and/or DO Enhancements Physical Modifications are Complete (Note 7) (Note 8) (Note 1) (Notes 3, 7) Fishing Creek Development Beginning within 60 days following the date of closure of the New License, operate Fishing Creek existing stay vanes (two N/A N/A N/A Powerhouse & Dam units) and hub venting (one unit) as needed to meet state standards for DO. Great Falls – Dearborn Development Great Falls Diversion Combination notches/gates 55 months following N/A None Dam (Long Bypass) and/ or bladder dam FERC approval of FWQIP In order to provide aquatic flow to the Short Bypass Duke Energy will Great Falls Headworks Combination existing trash 55 months following N/A (Short Bypass) gate and/or bladder dam FERC approval of FWQIP leave open the existing trash gate continuously with the exception of any time if and when it must be closed for public safety, operational emergency, to perform design reconnaissance for the permanent headworks modifications , or to begin constructing the permanent modifications. 116 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Timeframe for Operational Change to Timeframe for Implement Flows and/or Completing Physical Enhance DO where No Physical Modifications Modifications and Interim Measures for Providing Aquatic Physical Modifications Proposed to Meet Flow Implementing Flows Flow and/or DO Enhancement until Locationare Anticipatedand/or DO Requirements and/or DO Enhancements Physical Modifications are Complete (Note 7) (Note 8) (Note 1) (Notes 3, 7) Beginning within 60 days following the date of closure of the New License, operate existing vacuum breakers (three units) as needed to Dearborn Powerhouse N/A N/A N/A meet state standard s for DO while monitoring Fishing Creek DO carry- over benefits. Rocky Creek – Cedar Creek Development Beginning within 60 days following the date of closure of the New License, operate existing hub venting capability (three units) as Cedar Creek needed to meet state N/A N/A N/A Powerhouse & Dam standards for DO while monitoring the benefit of continuous flows through Great Falls Bypassed Reaches. 117 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Timeframe for Operational Change to Timeframe for Implement Flows and/or Completing Physical Enhance DO where No Physical Modifications Modifications and Interim Measures for Providing Aquatic Physical Modifications Proposed to Meet Flow Implementing Flows Flow and/or DO Enhancement until Locationare Anticipatedand/or DO Requirements and/or DO Enhancements Physical Modifications are Complete (Note 7) (Note 8) (Note 1) (Notes 3, 7) Wateree Development Beginning within 60 days following the date of closure of the New License, Beginning within 60 days approximate minimum continuous flows following the date of closure by (1) pulsing an existing unit 1 hr on, 2 of the New License, operate hrs off from May 16 thru Feb 14 during existing hydro units periods when at least 1 unit is not running Replace one existing hydro as necessary to provide 42 months following continuously and (2) running an existing Wateree Powerhouse unit with a smaller unit with downstream flow FERC approval of FWQIP hydro unit continuously from Feb 15 thru requirement. Also operate aerating capability May 15. When DO is below state existing units with auto- standards, operate existing units with venting capability as auto-venting capability on a first-on, last needed to meet state off hierarchy whenever the station is being standards for DO. operated for flow release, reservoir level control or generation. 118 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Notes: 1. The FWQIP was filed with NCDWQ and SCDHEC during the 401 Water Quality Certification processes as the recommended flow and water quality implementation plan. NCDWQ and SCDHEC took the recommended FWQIP under advisement and approved and/or modified the FWQIP in the 401 Water Quality Certification. The FERC must approve the FWQIP before the Licensee can begin construction at any location, except for Bridgewater (see Note 2 below). Also, since the FERC approval order for the FWQIP can substantially modify the Licensee’s proposed FWQIP, the Licensee will not contract for the manufacture or installation of large capital cost items until FERC approval is obtained. 2. At Bridgewater, retirement of the existing powerhouse and its replacement with a new powerhouse was performed as part of the ongoing Bridgewater Dam Upgrade Project, and FERC approval was obtained in conjunction with that project. The Licensee’s final decision was to replace the original powerhouse with a new powerhouse designed to provide the prescribed flows and meet the applicable state water quality standards. 3. The interim measures will be implemented as indicated except when the Licensee is operating under the Low Inflow Protocol (LIP) or the Maintenance and Emergency Protocol (MEP). 4. Paddy Creek Bypassed Reach: No flow releases are proposed in the Paddy Creek Bypassed Reach. Parties to this Agreement agree to recommend the provisions presented in Section 4.0 of this Agreement in lieu of flow releases into the Paddy Creek Bypassed Reach for consideration by the NCDWR and the FERC in the 401 Water Quality Certification process and the license issuance process, respectively. 5. Mountain Island Bypassed Reach: No flow releases are proposed in the Mountain Island Bypassed Reach. Parties to this Agreement agree to recommend the provisions as presented in Section 4.0 of this Agreement in lieu of flow releases into the Mountain Island Bypassed Reach for consideration by the NCDWR and the FERC in the 401 Water Quality Certification process and the license issuance process, respectively. 6. The Licensee consulted with the resource agencies to reduce resource impacts during any periods of reduced flow associated with the Bridgewater Dam Upgrade Project. 7. For the purpose of this Appendix L only, “date of closure for the New License” will mean the first day following the issuance of the New License and the closure of all rehearing and administrative challenge periods related to water quantity, including Project flow releases and reservoir levels, and water quality. 8. If a state water quality agency requires equipment modifications in addition to those listed in this Appendix L to assure compliance with applicable state water quality standards for Dissolved Oxygen (DO), the fact that such modifications are not currently specified in this Appendix L does not render those modifications inconsistent with this Agreement pursuant to Section 21.0. However, any equipment modifications necessary to assure compliance with any other applicable state water quality standard or any other regulatory requirements to provide flow releases, and/or reservoir levels other than the flow releases and reservoir levels specified in this Agreement may be inconsistent with this Agreement and may be subject to review pursuant to the provisions of Section 21.0. 119 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Identification and assessment of any incremental environmental impacts of the revision compared to the original WQC Overall, this revision to the FWQIP is an improvement to and not inconsistent with the previous FWQIP given: Four of the nine modification projects (Catawba Dam, Bridgewater Powerhouse,  Rhodhiss turbine, Oxford turbine) have been completed years ahead of schedule. The originally proposed Oxford minimum flow release valve has been changed to a  trash gate modification to 1) release forebay surface water higher in dissolved oxygen, 2) spill that water to provide additional aeration, and 3) shorten the implementation schedule. The original schedule for the Wylie Hydro Station unit replacement is unchanged.  The Wateree Hydro Station unit replacement date has extended. The Wylie and  Wateree unit replacements are unique and complicated designs required to significantly raise dissolved oxygen under reduced flow conditions while utilizing the same intake structures and turbine outlet structures. There are considerable risks associated with these unique designs. Therefore, rather than have simultaneous installations that may duplicate unexpected problems, these implementations are staggered to maximize lessons learned, correct any discovered design or manufacturing deficiencies, and make more efficient use of installation crews. The schedule for the Great Falls Long Bypass modifications has extended. The original  concept was to use notches, gates or bladder dams to release both minimum continuous and recreation flows. However, these options may not provide sufficient control to regulate flow releases precisely enough to assure compliance. Instead, additional design concepts are being developed, including possibly Obermeyer gates which require pneumatic piping, compressors, and controls that greatly increase the scope of this modification compared to the original concept. The Great Falls Short Bypass modification date has extended in order to integrate  the flow release provision (also including Obermeyer gates as described for the Long Bypass) into an overall modification to make FERC-required dam stability modifications and to replace the existing flashboards on top of a section of the short bypass spillway with bladder dams. This approach will improve Duke Energy’s ability to comply with flow releases. In addition, public safety will be improved since the existing flashboards are somewhat trouble-prone and can unpredictably break resulting in difficulty managing flow releases, unsafe flow releases, and undesired debris in the Short 120 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 Bypass reach. Consultation Summary Commenter Summary of Comment Duke Energy Response NC Wildlife It was suggested to add text Duke Energy will provide additional Resources explaining how the minimum flow explanation in both Appendix F Commission release gate at the Oxford (WQMP) and Appendix L (FWQIP) of (NCWRC) Powerhouse will operate and how the gate at Oxford will operate provide continuous minimum flow. and provide continuous minimum flow. The gate position will be adjustable and set as required to deliver the required minimum flow based on target reservoir elevation and expected reservoir elevation range. SC Department of There are no interim measures Duke Energy will revise the interim Natural Resources identified in the CRA to provide measure for the Great Falls (SCDNR) flows to the Long and Short Headworks (Short Bypass) to clarify Bypasses. SCDNR also requests Duke in order to provide aquatic flow to Energy strive to complete Great the Short Bypass Duke Energy will Falls Long and Short Bypass leave open the existing trash gate modifications ahead of schedule continuously with the exception of and consider the development of an any time if and when it must be interim measure that could be used closed for public safety, operational to provide some flow to the emergency, to perform design bypasses in the meantime. reconnaissance for the permanent headworks modifications , or to begin constructing the permanent modifications. Duke Energy will also pursue design alternatives for the Long Bypass modifications to save time while providing reasonable assurance of public safety, operational feasibility, and regulatory compliance. Duke Energy will consult with SCDNR by 02/28/17 to review design concepts, schedule, and identify potential 121 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 additional interim measures if needed based on the success of shortening the Long Bypass modification schedule. 122 Catawba-Wateree Hydroelectric Project Federal Energy Regulatory Commission Project No. 2232 Application for Amendment of Water Quality Certification South Carolina Certification DHEC 08-C-001 issued February 12, 2015 No. 3767 North Carolina Certification issued November 14, 2008 ATTACHMENT A Consultation Documentation