20080915 Ver 1_Prompt Attention Request Response DWR Email_20161130

Strickland, Bev
From:Oakley, Mark <[e-mail]>
Sent:Wednesday, November 30, 2016 1:45 PM
To:Tarver, Fred; Higgins, Karen; Goudreau, Chris J.; [e-mail]; Larsen,
Cory
Cc:Lineberger, Jeff; Fragapane, Phil; Finley, Keith A; [e-mail]; Dunn,
Lynne; Galleher, George A; Lewis, Greg D
Subject:RE: YOUR PROMPT ATTENTION REQUESTED - Advance notification of unit repairs at
C-W Project Lookout Shoals Hydro
Thank you, Fred.

I’d like to clarify if your response also reflects feedback from Karen Higgins. If so, then your response will fulfill feedback
from all resource agency contacts.

Duke Energy will monitor all flow releases, including the leakage flow of approximately 53 cfs, but has to add we cannot
control the seepage flow and therefore cannot assure the flow does not drop below this level. Since the Catawba Basin
is in Low inflow Protocol stage 1 Duke Energy would prefer to not make large flow releases from the large units to
compensate for leakage flow excursions, which are anticipated to be small, if any.

Duke Energy will space the pulse flows at equal time intervals to distribute the flow releases throughout the day.

From: Tarver, Fred \[mailto:[e-mail]\]
Sent: Tuesday, November 29, 2016 2:05 PM
To: Oakley, Mark; Higgins, Karen; Goudreau, Chris J.; [e-mail]; Larsen, Cory
Cc: Lineberger, Jeff; Fragapane, Phil; Finley, Keith A; [e-mail]
Subject: RE: YOUR PROMPT ATTENTION REQUESTED - Advance notification of unit repairs at C-W Project Lookout
Shoals Hydro

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Mark,

The Division of Water Resource’s response is as follows:

For the record, as reported in Duke Energy’s submittal to FERC on 11-2-2016, the 53 cubic feet per second (cfs) is the
mean value based on ADCP measurements (N = 8, range = 19 to 80 cfs). Mean dam seepage is 5.0 cfs (N = 2, Range = 4.9
and 5.1 cfs). Duke should monitor the USGS gage to assure that the flow does not drop below 53 cfs, based on the
corresponding gage height of 9.25 feet. Although an average daily flow is not a suitable regime for establishing a
permanent Critical Flow, the mitigating factor is that this release schedule is planned for less than the month of
December and is higher than the instantaneous Critical Flow of 80 cfs. The two, 1-hr pulse flows, as reported in the 11-
18-2016 FERC submittal, should be equally spaced if possible to equitably distribute the daily average flow. This should
resolve DWR’s concerns.
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Thank you for the opportunity to respond.

Fred

Fred R Tarver III
Instream Flow Program Supervisor
Department of Environmental Quality

919-707-9029 office
[e-mail]

Division of Water Resources
1611 Mail Service Center
Raleigh NC 27699-1611

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

From: Oakley, Mark \[mailto:[e-mail]\]
Sent: Tuesday, November 29, 2016 11:20 AM
To: Higgins, Karen <[e-mail]>; Tarver, Fred <[e-mail]>; Goudreau, Chris J.
<[e-mail]>; [e-mail]
Cc: Lineberger, Jeff <[e-mail]>; Fragapane, Phil <[e-mail]>; Finley,
Keith A <[e-mail]>; [e-mail]
Subject: YOUR PROMPT ATTENTION REQUESTED - Advance notification of unit repairs at C-W Project Lookout Shoals
Hydro

Thank you for taking a moment to quickly reply to this note.

The Federal Energy Regulatory Commission has contacted me today to request additional agency documentation
regarding the upcoming repairs at the Lookout Shoals Development. Specifically, Maintenance and Emergency Protocol
Condition B.1 – Maintenance of the Normal Meals of Providing Minimum Flow Release (Scheduled), item 3 states if
Critical Flows cannot be exceeded 100% of the time, then Duke Energy will work with resource agencies to monitor
impacts and replace species mortalities. In this case, instantaneous minimum flows will drop below the 80 cfs Critical
Flow for this development, but not less than approximately 53 cfs (documented leakage and seepage) while the average
daily flow of approximately 90 cfs will exceed the Critical Flow release.

To-date no agency has expressed the need for additional consultation, monitoring, or mortality replacement in this
matter, but the FERC has requested a documented affirmation from resource agencies as to whether or not they agree
with Duke Energy’s approach to this maintenance event, and monitoring impacts and replacing mortalities are not
required.

With apologies for the short deadline, please send me your response as soon as possible, but no later than Wednesday
noon. I’ll then file your responses with the FERC so they can issue an approval letter before the scheduled start of unit
repairs on Monday Dec 5.

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Thank you. Please contact me if there ae further questions.

From: Oakley, Mark
Sent: Friday, November 18, 2016 11:41 AM
To: '[e-mail]'; '[e-mail]'; '[e-mail]'; [e-mail];
Herrin, Randy C; Lewis, Greg D; Fragapane, Phil; Finley, Keith A; Rice, Garry S; Lineberger, Jeff; Dunn, Lynne; Galleher,
George A ([e-mail])
Subject: Advance notification of unit repairs at C-W Project Lookout Shoals Hydro

The attached notification was filed this morning with the Federal Energy Regulatory Commission in accordance with
Maintenance and Emergence Protocol Condition B.1 – Maintenance of the Normal Means of Providing Minimum Flows
(Scheduled).

The described work is to begin December 5. Agencies are requested to please advise if further consultation is necessary.

Thanks, all.
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