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HomeMy WebLinkAbout20080915 Ver 1_FERC Filing Email_20161130 Strickland, Bev From:Oakley, Mark <Mark.Oakley@duke-energy.com> Sent:Wednesday, November 30, 2016 4:20 PM To:Higgins, Karen; Tarver, Fred; Larsen, Cory; Goudreau, Chris J.; bryan_tompkins@fws.gov; Herrin, Randy C; Lewis, Greg D; Lineberger, Jeff; Fragapane, Phil; Finley, Keith A; Rice, Garry S Subject:Federal Energy Regulatory Commission Staff Request for Additional Documentation re: Advance Notification of Hydroelectric Unit Repairs at Lookout Shoals Development Attachments:Advance Notification Hydro Unit Repairs LS Dev.pdf This note copies you on the attached response to additional documentation requested by the FERC related to upcoming repairs to Lookout Shoals Hydro. Please contact me if there are any questions. Thanks to resource agency contacts for your rapid response to this request. 1 �r DUKE � : ENERGY_ November 30, 2016 The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 WATER STRATEGY, HYDRO LICENSING AND LAKE SERVICES Duke Energy Corporation 526 South Church Street Charlotte, NC 2820 RE: Advance Notification of Hydroelectric Unit Repairs Lookout Shoals Development Catawba-Wateree Hydro Project P-2232 Federal Energy Regulatory Commission Staff Request for Additional Documentation Dear Secretary Bose: On November 18, 2016, Duke Energy Carolinas, LLC (Duke Energy) submitted to the Federal Energy Regulatory Commission (Commission) advance notification of required Maintenance of the Normal Means of Providing Minimum Flow (Scheduled) under the Catawba-Wateree Project license's Maintenance and Emergency (MEP) Condition B.1. On November 29, 2016, Commission staff contacted Duke Energy 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) while the average daily flow of approximately 90 cfs will exceed the Critical Flow release. As of November 29, 2016, no agency had expressed the need for additional consultation, monitoring, or mortality replacement in this matter, but Commission staff requested a documented affirmation from resource agencies as to whether or not they agree with Duke Energy's approach to this maintenance event, and with monitoring impacts and replacing mortalities not being required. Duke Energy solicited resource agency feedback via e-mail dated November 29, 2016 and received responses representing all resource agency contacts (see Attachment A) by November 30, 2016. The latest agency responses do not require Duke Energy to monitor for impacts or to replace mortalities. The North Carolina Division of Water Resources asked Duke Energy to monitor leakage flows to assure these flows do not fail below 53 cfs. Duke Energy cannot control leakage flows, but will monitor all flow releases. Please direct questions to Mark Oakley at (704) 382-5778 (Mark.Oakley@duke-energy.com). Ms. Kimberly D. Bose November 18, 2016 Page 2 of 2 Sinc rely, V Jeffrey G. Lineberger, PE Director, Water Strategy & Hydro Licensing Duke Energy Carolinas, LLC cc: Karen Higgins, NC Department of Environmental Quality Fred Tarver, NC Department of Environmental Quality Chris Goudreau, NC Wildlife Resources Commission Bryan Tompkins, US Fish and Wildlife Service Randy Herrin, Duke Energy Greg Lewis, Duke Energy Mark Oakley, Duke Energy Phil Fragapane, Duke Energy Keith Finley, Duke Energy Garry Rice, Duke Energy ATTACHMENT A Oakley, Mark From: Goudreau, Chris J. <chris.goudreau@ncwildlife.org> Sent: Tuesday, November 29, 2016 11:37 AM To: Oakley, Mark; Higgins, Karen; Tarver, Fred; bryan_tompkins@fws.gov Cc: Lineberger, Jeff, Fragapane, Phil; Finley, Keith A; robert.ballantine@ferc.gov Subject: RE: YOUR PROMPT ATTENTION REQUESTED - Advance notification of unit repairs at C- W Project Lookout Shoals Hydro *** Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. *** Mark, The NC Wildlife Resources Commission is fine with Duke Energy's approach and doesn't see the need for monitoring impacts. Chris Goudreau Hydropower & Special Projects Coordinator Habitat Conservation Division NC Wildlife Resources Commission 645 Fish Hatchery Road Marion, NC 28752 office: 828-652-4360 ext. 223 mobile: 828-606-3977 chris.00udreau @ ncwildlife.ora ncwildlife.org © 91 ® Tite! From: Oakley, Mark [mailto:Mark.Oakley@duke-enerey.com] Sent: Tuesday, November 29, 2016 11:20 AM To: Higgins, Karen <karen.higgins@ncdenr.gov>; Tarver, Fred <fred.tarver@ncdenr.gov>; Goudreau, Chris J. <chris.goudreau@ncwildlife.org>; bryan tompkins@fws.gov Cc: Lineberger, Jeff <Jeff.Line berger@duke-energy.com>; Fragapane, Phil <Phil.Fragapane @duke-energy.com>; Finley, Keith A <Keith.Finley@duke-enerey.com>: robert.ballantine@ferc.gov 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. Thank you. Please contact me if there ae further questions. From: Oakley, Mark Sent: Friday, November 18, 2016 11:41 AM To: 'Karen. higgi ns@ncdenr.gov'; 'fred.tarver@ncdenr.gov';'chris.goudreau@ncwildlife.org'; bryan tompkins@fws.gov; Herrin, Randy C; Lewis, Greg D; Fragapane, Phil; Finley, Keith A; Rice, Garry S; Lineberger, Jeff; Dunn, Lynne; Galleher, George A (George. GaIleher@duke-energx.com) 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. Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties Oakley, Mark From: Tompkins, Bryan <bryan_tompkins@fws.gov> Sent: Tuesday, November 29, 2016 12:44 PM To: Oakley, Mark Cc: Karen.higgins@ncdenr.gov; fred.tarver@ncdenr.gov; chris.goudreau@ncwildlife.org; Lineberger, Jeff; Fragapane, Phil; Finley, Keith A; robert.ballantine@ferc.gov Subject: Re: YOUR PROMPT ATTENTION REQUESTED - Advance notification of unit repairs at C- W Project Lookout Shoals Hydro *** Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. *** Good afternoon Mark. As you requested, the USFWS has reviewed the information presented by Duke Energy regarding the upcoming repairs at the Lookout Shoals Development. The USFWS is in agreement with the project as proposed by Duke Energy and we do not foresee the need for additional monitoring for impacts at the site during the proposed maintenance activities. If you have questions or if I can be of assistance, please do not hesitate to contact me. Thanks, Bryan Tompkins US Fish and Wildlife Service 160 Zillicoa Street Asheville, North Carolina 28801 828/258-3939 ext.240 NOTE: This email correspondence and any attachments to and from this sender is subject to the Freedom of Information Act (FOIA) and may be disclosed to third parties. On Tue, Nov 29, 2016 at 11:19 AM, Oakley, Mark <Mark.Oakley@duke-enemy com> wrote: 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 13.1 — 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 F:RC so they can issue an approval letter before the scheduled start of unit repairs on Monday Dec 5. Thank you. Please contact me if there ae further questions. From: Oakley, Mark Sent: Friday, November 18, 2016 11:41 AM To: 'Karen.higgins@ncdenr.gov'; 'fred.tarverC )ncdenr.gov';'chris.goudreau@ncwildlife.org'; bryan tompkins'�fws.gov; Herrin, Randy C; Lewis, Greg D; Fragapane, Phil; Finley, Keith A; Rice, Garry S; Lineberger, Jeff; Dunn, Lynne; Galleher, George A (George. Ga I leherC&d u ke-energy.com) 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. Oakley, Mark From: Higgins, Karen <karen.higgins@ncdenr.gov> Sent: Wednesday, November 30, 2016 2:13 PM To: Oakley, Mark; Tarver, Fred; Goudreau, Chris J.; bryan_tompkins@fws.gov; Larsen, Cory Cc: Lineberger, Jeff, Fragapane, Phil; Finley, Keith A; robert.ballantine@ferc.gov; 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 Mark - Fred's response is for DWR, including Cory and me. Thanks - Karen Karen Higgins 401 & Buffer Permitting Branch Supervisor Division of Water Resources Department of Environmental Quality 919 807-6360 office karen.higgins@ncdenr.gov 512 N. Salisbury Street, Suite 942-E, Raleigh, NC 27604 1617 Mail Service Center, Raleigh, NC 27699-1617 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Oakley, Mark <Mark.Oakley@duke-energy.com> Sent: Wednesday, November 30, 2016 1:45:23 PM To: Tarver, Fred; Higgins, Karen; Goudreau, Chris J.; bryan_tompkins@fws.gov; Larsen, Cory Cc: Lineberger, Jeff; Fragapane, Phil; Finley, Keith A; robert.baIlantine@ferc.gov; 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:fred.tarver@ncdenr.gov] Sent: Tuesday, November 29, 2016 2:05 PM To: Oakley, Mark; Higgins, Karen; Goudreau, Chris J.; bryan_tompkins@fws.gov; Larsen, Cory Cc: Lineberger, Jeff; Fragapane, Phil; Finley, Keith A; robert.ballantine@ferc.gov Subject: RE: YOUR PROMPT ATTENTION REQUESTED - Advance notification of unit repairs at C -W Project Lookout Shoals Hydro *** Exercise caution. This is an EXTERNAL email. DLJ NOT open attachments or click links from unknown senders or unexpected email. *** 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. Thank you for the opportunity to respond. Fred Fred R Tarver III Instream Flow Program Supervisor Department of Environmental Quality 919-707-9029 office fred.tarver@ ncdenr.gov Division of Water Resources 1611 Mail Service Center Raleigh NC 27699-1611 C Nothing Compares �.�. 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:Mark.Oakley@duke-energy.com) Sent: Tuesday, November 29, 2016 11:20 AM To: Higgins, Karen <karen.higgins@ncdenr.gov>; Tarver, Fred <fred.tarverPncdenr.gov>; Goudreau, Chris J. <chris.goudreau@ncwildlife.org>; bryan tompkins@fws.gov Cc: Lineberger, Jeff<Jeff.LinebeMered uke-energy.com>; Fragapane, Phil <Phil.Fraeapane@duke-energy.com>; Finley, Keith A <Keith.Finley@duke-energy.com>; robert.ballantineCferc.gov 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. Thank you. Please contact me if there ae further questions. From: Oakley, Mark Sent: Friday, November 18, 2016 11:41 AM To: 'Karen.higgins@ncdenr.gov'; 'fred.tarver@ncdenr.gov'; 'chris.goudreau@ncwildlife.org'; bryan tompkinsCcLfws.gov; Herrin, Randy C; Lewis, Greg D; Fragapane, Phil; Finley, Keith A; Rice, Garry S; Lineberger, Jeff; Dunn, Lynne; Galleher, George A (George.GalleherLg)duke-energy.com) 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.