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12.01.20 Board Correspondence - FW_ DOCKET CHANGE- Application To Amend License or Exemption submitted in FERC P-619-171 by Pacific Gas and Electric Company,et al.
From:Schuman, Amy To:Alpert, Bruce;Bennett, Robin;Clerk of the Board;Connelly, Bill;Cook, Holly;Lambert, Steve;Lucero, Debra;McCracken, Shari;Paulsen, Shaina;Pickett, Andy;Ring, Brian;Ritter, Tami;Rodas, Amalia;Sweeney, Kathleen;Teeter, Doug Subject:Board Correspondence - FW: DOCKET CHANGE- Application To Amend License or Exemption submitted in FERC P-619- 171 by Pacific Gas and Electric Company,et al. Date:Tuesday, December 1, 2020 12:23:15 PM Please see the email below from FERC. Amy Schuman Associate Clerk of the Board Butte County Administration 25 County Center Drive, Suite 200, Oroville, CA 95965 O: 530.552.3300 |D: 530.552.3308 | F: 530.538.7120 Twitter | Facebook | YouTube | Pinterest -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Tuesday, December 1, 2020 12:20 PM Subject: DOCKET CHANGE- Application To Amend License or Exemption submitted in FERC P-619-171 by Pacific Gas and Electric Company,et al. .ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying.. On 11/24/2020, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: Pacific Gas and Electric Company Pacific Gas and Electric Company (as Agent) Docket(s): P-619-171 Lead Applicant: Pacific Gas and Electric Company Filing Type: Application To Amend License or Exemption Description: Pacific Gas and Electric Company submits a Non-Capacity Amendment of License to reduce the length of a primary line by 900 feet at the Bucks Creek-Grizzly Hydroelectric Project under P-619. To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist? accession_num=20201124-5054__;!!KNMwiTCp4spf!VXzKjgaaNeiM0exL8VQ5- Y4l5yqddZ6kj8gBM6h4dVJgHs3MX3kjwDRTn2UJMxMQUEfJr_nP2M8$ To modify your subscriptions, click here: https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!VXzKjgaaNeiM0exL8VQ5- Y4l5yqddZ6kj8gBM6h4dVJgHs3MX3kjwDRTn2UJMxMQUEfJVgtPVN8$ ------------------------------------------------------------------------ Please do not respond to this email. Online help is available here: https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!VXzKjgaaNeiM0exL8VQ5- Y4l5yqddZ6kj8gBM6h4dVJgHs3MX3kjwDRTn2UJMxMQUEfJViXYca8$ or for phone support, call 866-208-3676. 245 Market Street Power Generation San Francisco, CA 94105 Mailing Address: Mail Code N11D P.O. Box 770000 San Francisco, CA 94177 November 23, 2020 Via Electronic Submittal (E-Filing) Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C., 20426 RE: Bucks Creek-Grizzly Hydroelectric Project, FERC No. 619 Grizzly Powerhouse Reconnection Project Dear Secretary Bose: Request Relating to Grizzly Tap Conductor Removal, Pacific Gas and Electric Company on behalf of itself and joint licensee, the City of Santa Clara, California, applies to the Commission for a Non-Capacity Amendment of License to reduce the length of a primary line by 900 feet at the Bucks Creek Hydroelectric Project, FERC No. 619 (Project). Background The Project consists of two developments Bucks Creek Development and Grizzly Powerhouse Development. As relevant to this Application, the Bucks Creek Development includes a powerhouse and an adjacent Bucks Creek substation yard, which includes Project equipment and non- transmission systems. Power generated at the Bucks Creek Powerhouse is delivered to the grid at the Bucks Creek-Cresta 230 kV non-Project transmission line, which is located within the adjacent substation yard. As relevant to this Application, the Grizzly Powerhouse Development consists of a powerhouse, a 115 the grid interconnection at the non-Project Caribou-Palermo transmission line (formerly referred to as the Caribou-Sycamore line), and ancillary facilities. The existing Project license describes the Grizzly Tap as approximately 4.2 miles long. At approximate milepost 4.0, the Grizzly Tap enters the Bucks Creek substation yard, and then continues across the North Fork Feather River and up a hill for approximately 0.2 miles (900 feet) to its interconnection point with the Caribou-Palermo line. Ms. Kimberly D. Bose, Secretary November 23, 2020 Page 2 In November 2018, the Caribou-Palermo line was deenergized as a result of damage from the Camp Fire, which forced the Grizzly Powerhouse out of service. While the Grizzly Tap remained functional, it could not be returned to service until the Caribou-Palermo line returned to service or an alternative interconnection point was identified. As part of the resolution of disputes related to the Camp Fire, PG&E committed to permanently deenergizing the Caribou Palermo line, which meant that an alternative means of reconnecting the Grizzly Powerhouse to the grid needed to be arranged. PG&E determined that the most expeditious means to reconnect the Grizzly Powerhouse to the grid would be to interconnect the Grizzly Tap at the existing, non-Project, 230-kV Bucks Creek-Cresta transmission line, which begins in the Bucks Creek substation yard. PG&E is targeting to have all testing complete and the Grizzly Powerhouse reconnected to the grid by June 2021. Non-Capacity Amendment Application In order to facilitate the modifications necessary to return the Grizzly Powerhouse to service, the Application proposes to amend the Project license to reduce the length of the Grizzly Tap by 900 feet to connect the Grizzly Tap to the existing, non-Project Bucks Creek-Cresta 230 kV transmission line in the Bucks Creek substation yard. This Application does not propose to enlarge the generating, hydraulic, or nameplate capacity of the Project; therefore, it constitutes a non-capacity amendment under 18 C.F.R. § 4.201(c) and contains only those exhibits that require revision in light of the nature of the proposed amendment. Accordingly, the Application proposes revisions to Exhibit A to reduce the length of the Grizzly Tap from 4.2 to 4.0 miles, and revisions to Exhibit L and Exhibit G drawings to remove the depiction of the 900-foot-long span of line between the 1 Bucks Creek substation yard and the non-Project Caribou-Palermo transmission line. from the public version of the Application. Additional figures and attachments that include CEII information also are omitted from the public version of the Application. In addition, the Application includes Exhibit C and Exhibit E describing additional modifications to Project works and activities that are required to facilitate the reconnection of the Grizzly Powerhouse. All activities proposed in the Application would occur entirely within the boundary of the existing substation, access road, and transmission right of way. PG&E requests concurrent review of its construction plan and schedule described in these exhibits to avoid the need for supplemental filings requesting authorization to begin the work described as Phases 2 and 3 in the Application. 1 Under the existing license, the approved drawings associated with the Bucks Creek Development are referred to as Exhibit K and L drawings and the approved drawings associated with the Grizzly Powerhouse Development are referred to as Exhibit F and G drawings. See, e.g., Pacific Gas and Elec. Co., 52 F.P.C. 1898 (1974) (order issuing new license for the features now referred to as the Bucks Creek Development and approving Exhibits K and L); Pacific Gas and Elec. Co., 43 FERC ¶ 62,136 (1988) (order amending license to add the Grizzly Powerhouse Development and approving Exhibits F and G associated with this development). Ms. Kimberly D. Bose, Secretary November 23, 2020 Page 3 This Application does not proposeto modify the Project boundary at this time. The 900- foot-long span of the Grizzly Tap is partially located on lands managed by the U.S. DepTherefore, PG&E must consult with the USFS regarding the final disposition of Project features on USFS lands, any remediation required by the USFS, and the need for permits to accommodate remaining facilities, if any. PG&E will request to amend the Project license to remove the lands underlying the 900-foot-long span after these discussions have occurred. The activities proposed in the Application affect both PG&E and USFS lands within the Plumas National Forest. PG&E notified the USFS of preliminary work associated with the Grizzly Reconnection Project on October 6, 2020, and supplemented this material with a project description that encompassed all phases of the Grizzly Reconnection Project on October 23, 2020. Once concurrence is received, PG&E will file the consultation record with FERC. The limited activities completed to date on USFS lands (e.g., the conductor removal discussed below) have been implemented in accordance with the USFS Plumas Master Programmatic Easement, which includes standard best management practices and notification requirements for any utility work conducted on USFS lands. In addition, PG&E submitted a letter to FERC on October 20, 2020 requesting to be designated as the non- federal representative for Section 106 consultation for the Grizzly Powerhouse Reconnection Project. PG&E requests expedited action on this pending request to allow PG&E to consult with the California State Historic Preservation Officer as soon as possible. As described in the Application, no resources other than USFS lands and potential historic properties would be affected by the proposed Grizzly Powerhouse Reconnection Project and therefore PG&E does not propose to consult with any other agencies. Given the minimal modifications proposed in this Application and limited associated ground- disturbing activity, PG&E requests waiver of any other applicable requirements of 18 C.F.R. § 4.38(a)(7), to the extent necessary to facilitate the expeditious processing of this Application. application that encompasses all phases of the Grizzly Powerhouse Reconnection Project and to provide information -foot-long conductor. Specifically, FERC requested the following information: A specific description of what has taken place regarding the work proposed; what other options were available to you; and an explanation of why the work was done without waiting for Commission approval of a license amendment or a response to your September 14 letter. Ms. Kimberly D. Bose, Secretary November 23, 2020 Page 4 On September 14, 2020, PG&E filed with FERC a notification of its intent to modify Project works in order to remove the 900-foot-long conductor located between the Caribou- Palermo line and a tower in the Bucks Creek substation yard. As explained in the September 14 notification, in preparation for filings in July 2020 for the court overseeing PG&E identified a potential residual public safety risk associated with the Caribou-Palermo line. PG&E determined that energized lines, such as the Grizzly Tap, in the vicinity of the Caribou-Palermo line may have the potential to induce voltage and current on the Caribou-Palermo line through induction. PG&E immediately began preparations to mitigate this risk by grounding sections of the Caribou-Palermo line and preparing plans to remove the conductor. In addition, because sections of the line in the vicinity of the Grizzly Tap could not be removed immediately, PG&E determined that the most effective way to mitigate the induction risk in this area was to remove the single span of the Grizzly Tap most proximate to the Caribou-Palermo line. PG&E communicated with Commission staff regarding this concern and immediately began coordinating to prepare the September 14 notification. After the September 14 notice was filed, PG&E personnel responsible for safety risks associated with the transmission and distribution system believed that the single span of conductor most proximate to the Caribou-Palermo line could be removed immediately after the notice for emergency modifications to project works had been submitted. Consequently, on September 16, 2020, PG&E transmission and distribution personnel removed the 900-foot-long conductor adjacent to the Caribou-Palermo line. As a result of this incident, PG&E has implemented efforts to transmission and distribution system are aware that safety and maintenance activities on the portions of transmission lines that are located within the boundaries of FERC-licensed projects require additional approvals from FERC before safety or maintenance activities may be implemented. In the September 14 notice, PG&E described its plan to remove the conductor and to cut the wooden poles and remove the top sections via helicopter. Due to heavy smoke caused by nearby fires, PG&E could not use a helicopter to remove the upper sections of the wooden poles. plan described in the September 14 notification, all other activities that occurred on September 16 were described in the September 14 notification. As described therein, PG&E transmission line crews climbed the poles and or used bucket trucks to access the conductor and lower it to the ground by hand. One crew walked up the hill to wooden poles 004/003A, B and C (on the Caribou- Palermo line), a second crew set up a bucket truck at Interstate 70 to cut the conductor clear of the road, and a third crew set up a bucket at tower 004/002 in the Bucks Creek substation yard. Once traffic had been stopped and the conductor was clear of the highway, crews at the wooden poles and tower 004/002 rolled the conductor by hand from each end. Insulators were stripped off the poles and tower and hauled in. PG&E did not remove any poles (or sections of poles) or engage in any ground-disturbing activity to remove this single span of conductor. Ms. Kimberly D. Bose, Secretary November 23, 2020 Page 5 From a public safety perspective, no other options were available to PG&E other than to remove the single span of conductor proximate to the Caribou-Palermo line as soon as possible. Upon learning of the removal of the conductor, PG&E licensing personnel immediately reported the removal of the conductor to Commission staff via telephone. To avoid similar occurrences in the future, PG&E has implemented internal measures to ensure that transmission and distribution system personnel do not complete emergency safety work on transmission lines within FERC project boundaries until after approval has been received from FERC. If you have any questions regarding this Application, please contact PG&E's senior license coordinator, Jamie Visinoni, at JNVS@pge.com. Sincerely, Elisabeth Rossi Hydro Licensing Supervisor cc: FERC San Francisco Regional Office Enclosure (2 versions: one public, one CEII) G RIZZLY P OWERHOUSE R ECONNECTION P ROJECT A PPLICATION FOR N ON-C APACITY A MENDMENT B UCKS C REEK H YDROELECTRIC P ROJECT FERC P ROJECT N O.619 San Francisco, California November 2020 CONTENTS 1.0EXHIBIT C: PROPOSED CONSTRUCTION AND SCHEDULE ................................................ 9 1.1Proposed Construction Activity ...................................................................................... 9 1.1.1Phase 1 ...................................................................................................................... 12 1.1.2Phase 2 ...................................................................................................................... 13 1.1.3Phase 3 ...................................................................................................................... 14 1.1.4Access and Staging Areas ................................................................................. 18 1.1.5Traffic Control ......................................................................................................... 18 1.1.6Fire Hazard Prevention ....................................................................................... 18 1.1.7Disposal Cleanup and Demobilization ......................................................... 19 1.1.8Work Shift ................................................................................................................ 19 2.0EXHIBIT E: ENVIRONMENTAL ASSESSMENT ......................................................................... 19 2.1Biological Resources .......................................................................................................... 22 2.2Cultural Resources .............................................................................................................. 23 2.3Erosion Control, Fugitive Dust Abatement, and Water Quality ....................... 24 2.4Hazardous Materials .......................................................................................................... 24 2.5Permits and Approvals ...................................................................................................... 24 2.5.1Permits ...................................................................................................................... 25 2.6Agency Consultation and Approvals .......................................................................... 25 2.6.1FERC ........................................................................................................................... 25 2.6.2USFS ........................................................................................................................... 27 2.6.3SHPO .......................................................................................................................... 28 3.0EXHIBIT A ............................................................................................................................................. 29 3.1Existing Language in Exhibit A ...................................................................................... 29 3.2Proposed Changes to Project Description ................................................................ 29 3.3Lands of the United States .............................................................................................. 29 4.0EXHIBIT L: PROJECT DESIGN DRAWINGS ............................................................................... 30 5.0EXHIBIT G: PROJECT BOUNDARY ............................................................................................... 31 November 2020 i U NITED S TATES O F A MERICA B EFORE THE F EDERAL E NERGY R EGULATORY C OMMISSION Bucks Creek Hydroelectric Project FERC Project No. 619 G RIZZLY P OWERHOUSE R ECONNECTION P ROJECT A PPLICATION F OR N ON-C APACITY L ICENSE A MENDMENT 1. Pacific Gas & Electric Company, on behalf of itself and joint licensee, the City of Santa Clara, dba, Silicon Valley Power (collectively, ÑApplicantsÒ), applies to the Federal Energy Regulatory Commission (FERC) for a Non-Capacity Amendment of License for the Bucks Creek Hydroelectric Project (FERC No. 619). 2. The exact name, business address, and telephone number of the Applicant are: Pacific Gas and Electric Company 77 Beale Street San Francisco, CA 94105-1814 (415) 973-8400 City of Santa Clara 1500 Warburton Avenue Santa Clara, CA 95050 (408) 615-6601 The exact name and business address of each person authorized to act as agents for the Applicant in this application are: Elisabeth Rossi, Hydro Licensing Supervisor Pacific Gas & Electric Company 245 Market Street San Francisco, CA 94105 Phone: (415) 531-5186 Email: Elisabeth.Rossi@pge.com Chris Karwick, Assistant Director, Utility Operations Silicon Valley Power/City of Santa Clara 1705 Martin Avenue November 2020 1 Santa Clara, CA 95054 Phone: (408) 615-6554 The Applicant requests that copies of all correspondence pertaining to this application be provided to: Elisabeth Rossi, Hydro Licensing Supervisor Pacific Gas & Electric Company 245 Market Street San Francisco, CA 94105 Phone: (415) 531-5186 Email: Elisabeth.Rossi@pge.com Chris Karwick, Assistant Director, Utility Operations Silicon Valley Power/City of Santa Clara 1705 Martin Avenue Santa Clara, CA 95054 Phone: (408) 615-6554 3. PG&E is a corporation of the State of California, and the City of Santa Clara, California is a city, chartered municipal corporation under the laws of the State of California. The Applicants are joint licensees for the Bucks Creek Hydroelectric Project (Project), designated as FERC Project No. 619 in the records of the Federal Energy Regulatory Commission, issued on December 19, 1974 (52 F.P.C. 1898), as amended on April 29, 1988 (43 FERC ¶ 62,136), to add the Grizzly Development, and on July 10, 1990 (52 FERC ¶ 61,017), to add the City of Santa Clara as a joint licensee. The Project license expired on December 31, 2018, and the Applicants have been operating pursuant to an annual license issued on December 12, 2018, authorizing continued Project operation. As relevant to the revised exhibits and other modifications to the license proposed herein, the currently effective version of Ordering Paragraph (B)(ii) was approved by the Commission by order dated October 25, 2005 (113 FERC ¶ 62,064). The currently effective versions of relevant exhibits were approved as follows: Exhibit A was approved by order dated March 20, 2008 (122 FERC ¶ 62,239); Exhibit L (FERC Drawing No. 619-189) was approved on February 1, 1995 (70 FERC ¶ 62,064); and Exhibit G (FERC Drawing No. 619-204) was approved on October 23, 2007 (121 FERC ¶ 62,048). November 2020 2 4. The proposed non-capacity amendment of license and the reason(s) why the Project changes are necessary are described below: The Bucks Creek Project includes two developments: the Bucks Creek Development and the Grizzly Powerhouse Development. As relevant to this application, the Bucks Creek Development includes the Bucks Creek Powerhouse, and an adjacent substation referred to as the Bucks Creek substation yard. Electricity generated at the Bucks Creek Powerhouse is delivered to the grid at PG&EÔs Bucks Creek-Cresta 230-kV line, which begins in the Bucks Creek substation yard. As relevant to this application, the Grizzly Powerhouse Development consists of the Grizzly Powerhouse, a 6.9/115 kV step up transformer, a 115 kV transmission line (the ÑGrizzly TapÒ), which connects the Grizzly Powerhouse to the grid at PG&EÔs non-Project, Caribou-Palermo transmission line (formerly referred to as the Caribou-Sycamore line). The Grizzly Tap is approximately 4.2 miles long. At approximate milepost 4.0, the Grizzly Tap enters the Bucks Creek substation yard, and then continues across the North Fork Feather River and up a hill for approximately 0.2 additional miles (900 feet) to its interconnection with the Caribou-Palermo line. In November 2018, the Caribou-Palermo line was deenergized as a result of damage from the Camp Fire, which forced the Grizzly Powerhouse out of service. While the Grizzly Tap remained functional, it could not be returned to service until the Caribou-Palermo line returned to service or an alternative interconnection point was identified. As a result of the Camp Fire, PG&E committed to permanently deenergizing the Caribou-Palermo line. PG&E also determined that the most expeditious means to reconnect the Grizzly Powerhouse to the grid is to interconnect the Grizzly Tap at the existing, non- Project, 230 kV Bucks Creek-Cresta transmission line, which begins in the Bucks Creek substation yard. In order to facilitate the reconnection of the Grizzly Powerhouse to the grid, PG&E proposes the following activities: Phase 1 (Complete): November 2020 3 o Remove a 900-foot-long span of the conductor from the Bucks Powerhouse substation yard to the de-energized Caribou-Palermo line. Phase 2 (early January 2021): o Add guy wires to three existing poles (004/001A, B and C) located in the existing right-of-way for the Grizzly Tap to allow those structures to become temporary dead-ends; o Temporarily remove an approximately 300-foot-long span of conductor extending from the existing lattice tower to the three existing poles; o Remove an existing lattice tower (004/002) supporting the conductor within the substation yard; o Reinforce an existing access bridge by welding additional steel plates to support the weight of vehicles transporting new electrical equipment. Phase 3 (February 2021-March 2021): o Demolition or removal of additional non-Project features within the Bucks Creek substation yard, including temporary removal of a 12 kV station service line, a telecom cabinet, an 11 kV bus section, 12 kV current transformers, and certain abandoned foundations, concrete culverts, trenches, conduits, cables, and fencing o Installation of new 115/230 kV transformer; o Reinstallation of 300-foot-long span of conductor; o Reconfiguration of conductor within the substation yard; o Installation of ancillary facilities such as new foundations and oil spill containment, breakers, and switches; o Installation of additional non-Project features such as the 12 kV station service line and related equipment, a new weather station, fencing, etc. A schematic depicting the areas within the Bucks Creek substation yard where demolition activities will occur is provided in Attachment A. A schematic depicting the areas within the substation yard where new facilities will be installed or reinstalled is provided in Attachment B. A depiction of the Project and non-Project features affected by this amendment application and the general November 2020 4 work areas are shown below as Figure a-1 (a larger version of the figure is also included as Attachment C). Figure a-1 Features Associated with Amendment PG&E is filing this application for a non-capacity amendment of license with FERC in order to reflect these minor modifications to the length of the Grizzly Tap and ancillary facilities needed to reconnect the Grizzly Powerhouse to the grid. For purposes of this application, only those exhibits applicable to the proposed changes to Project structures are being provided, in accordance with 18 C.F.R. § 4.201(c), as outlined and described below: Exhibit A, Project description: Page 4 of the approved Exhibit A is proposed to be modified as follows and as shown in blackline/strikeout in Attachment D: Grizzly Addition Transmission: A 4.2 4.0 mile long 115 kV transmission line extending from Grizzly Powerhouse to the 230 kV Rock Creek-Cresta line (non- Project)Caribou-Sycamore Creek 115 kV transmission line (FERC November 2020 5 2105) near Bucks Creek Powerhouse (FERC 619). The structures are H-frame wood poles supporting 4/0 ASCR conductor. Exhibit L, Project design drawings: Drawing L-7 (FERC drawing no. 619- 189) is proposed to be modified as shown in Attachment E to reflect changes to the general outdoor arrangement near the Bucks Powerhouse due to the shortening and reconfiguring of the Grizzly Tap within the Bucks Creek substation yard. Exhibit G, Project boundary: Drawing G-11 (FERC drawing no. 619-204) is proposed to be modified as shown in Attachment F to reflect the reduction in the length of the Grizzly Tap. No changes to the Project boundary are being proposed at this time. Exhibit E, Environmental report: An analysis of potential environmental impacts associated with the activities proposed herein is provided in Section 2.0, Exhibit E: Environmental Assessment. In addition, the following modification to the existing Project license is proposed: Ordering Paragraph (B)(ii)(16), as approved on October 25, 2005 (113 FERC ¶ 62,064), is proposed to be modified as follows: . . . (16) a 4.2 4.0 mile-long, 115-kV transmission line interconnecting the development to PG&EÔs 230 kV Rock Creek- Cresta line (non-Project)115kV Caribou-Sycamore Creek line and 2.8 miles of road; An application for a new license for the Project was filed by the Applicants on December 16, 2016, as supplemented on May 22, 2018, and remains pending before the Commission. Upon approval of this amendment application, PG&E will request to amend Exhibits A, F, and G of the pending license application to reflect the updated exhibits approved by the Commission. As explained in the transmittal letter to this application, PG&E has removed the 900-foot-long span of conductor between the Bucks Creek substation yard and the Caribou-Palermo line for public safety reasons. Thus, while this application November 2020 6 requests approval of the reduction in the length of the Grizzly Tap identified in the Project license, this span of the conductor has been removed already to address safety concerns associated with PG&EÔs non-Project, Caribou-Palermo line (referred to herein as ÑPhase 1Ò). As described in Exhibit E, PG&E did not remove any poles associated with this span of conductor and did not engage in any ground-disturbing activity to remove the conductor. This application does not propose to remove these poles or the lands within the existing Project boundary that encompass these poles. PG&E plans to initiate Phase 2 of the Grizzly Powerhouse Reconnection Project in January 2021. As described herein, none of the activities associated with Phase 2 involve the permanent modification of Project works itemized in the license. On October 9, 2020, PG&E separately submitted a work plan for approval of Phase 2 activities. The information included in the October 9 filing has been incorporated into the applicable sections of this application, including Exhibit C and Exhibit E. No modifications to the license or approved exhibits in the license are required for Phase 2 activities. Accordingly, PG&E requests contemporaneous review and approval of this application and the work plan for Phase 2 activities to ensure the schedule is maintained to timely reconnect the Grizzly Powerhouse. PG&E plans to complete the remaining Phase 3 activities between February 2021 and March 2021. As with Phase 2 activities, Exhibit C and Exhibit E of this application include the detailed work plan to complete Phase 3 activities and PG&E requests contemporaneous review and approval of this application and the associated work plan. The goal is to complete all necessary testing and have the Grizzly Powerhouse reconnected to the grid by June 2021. 5. The statutory or regulatory requirements of the State of California, in which the Project is located that affect the Project with respect to bed and banks and to the appropriation, diversion and use of water for power purposes are: None. The activities associated with this non-capacity amendment application do not affect the bed and banks of any river or the appropriation, diversion, and use of water for power purposes. All activities associated with this non-capacity amendment application would occur within the existing footprint of previously November 2020 7 disturbed areas of the Bucks Creek substation yard, the adjacent parking areas and adjacent roads, and the Grizzly Tap transmission right of way. November 2020 8 1.0 EXHIBIT C: PROPOSED CONSTRUCTION AND SCHEDULE 1.1 Proposed Construction Activity The Bucks Creek Project includes two developments: the Bucks Creek Development and the Grizzly Powerhouse Development. As relevant to this application, the Bucks Creek Development includes the Bucks Creek Powerhouse and a substation referred to as the Bucks Creek substation yard. Electricity generated at the Bucks Creek Powerhouse is delivered to the grid at the Bucks Creek-Cresta 230-kV line, which begins in the Bucks Creek substation yard. As relevant to this application, the Grizzly Powerhouse Development consists of the Grizzly Powerhouse, a 6.9/115 kV step up transformer, a 115 kV transmission line (the ÑGrizzly TapÒ), which connects the Grizzly Powerhouse to the grid at the non-Project, Caribou-Palermo transmission line (formerly referred to as the Caribou-Sycamore line). The Grizzly Tap is approximately 4.2 miles long. At approximate milepost 4.0, the Grizzly Tap enters the Bucks Creek substation yard, and then continues across the North Fork Feather River and up a hill for approximately 0.2 additional miles (900 feet) to its interconnection with the Caribou-Palermo line. In November 2018, the Caribou-Palermo line was deenergized as a result of damage from the Camp Fire, which forced the Grizzly Powerhouse out of service. While the Grizzly Tap remained functional, it could not be returned to service until the Caribou-Palermo line returned to service or an alternative interconnection point was identified. As a result of the Camp Fire, PG&E committed to permanently deenergizing the Caribou-Palermo line. PG&E also determined that the most expeditious means to reconnect the Grizzly Powerhouse to the grid is to interconnect the Grizzly Tap at the existing, non- Project, 230 kV Bucks Creek-Cresta transmission line, which begins in the Bucks Creek substation yard. In order to facilitate these modifications, PG&E proposes the following activities: Phase 1 (Complete): November 2020 9 o Remove a 900-foot-long span of the conductor from the Bucks Creek substation yard to the de-energized Caribou-Palermo line. Phase 2 (early January 2021): o Add guy wires to three existing poles (004/001A, B and C) located in the existing right-of-way for the Grizzly Tap to allow those structures to become temporary dead-ends; o Temporarily remove an approximately 300-foot-long span of conductor extending from the existing lattice tower to the three existing poles; o Remove an existing lattice tower (004/002) supporting the conductor within the substation yard; o Reinforce an existing access bridge by welding additional steel plates to support the weight of vehicles transporting new electrical equipment. Phase 3 (February 2021-March 2021): o Demolition or removal of additional non-Project features within the Bucks Creek substation yard, including temporary removal of a 12 kV station service line, a telecom cabinet, an 11 kV bus section, 12 kV current transformers, and certain abandoned foundations, concrete culverts, trenches, conduits, cables, and fencing. o Installation of new 115/230 kV transformer; o Reinstallation of 300-foot-long span of conductor; o Reconfiguration of conductor within the substation yard; o Installation of ancillary facilities such as new foundations and oil spill containment, breakers, and switches; o Installation of additional non-Project features such as the 12 kV station service line and related equipment, a new weather station, fencing, etc. November 2020 10 A schematic depicting the areas within the Bucks Creek substation yard where demolition activities will occur is provided in Attachment A. A schematic depicting the areas within the substation yard where new facilities will be installed or reinstalled is provided in Attachment B. A depiction of the Project and non-Project features affected by this amendment application and the general work areas are shown below as Figure a-1 (a larger version of the figure is also included as Attachment C). Figure 1-1 Features Associated with Amendment November 2020 11 1.1.1 Phase 1 As described in the transmittal letter to this application and depicted on Figure 1-2 below, a 900-foot-long span of the Grizzly Tap conductor from the Bucks Creek substation yard to the Caribou-Palermo line has been removed for public safety reasons. As described in a September 14, 2020 letter to your office (Accession No. 20200914-5150), PG&E originally intended to perform the work with helicopter assistance. Due to heavy smoke caused by nearby fires, PG&E transmission line crews instead removed the single span of conductor between towers 004/002 (in the Bucks Creek substation yard) and wooden poles 004/003A, B and C (on the Caribou-Palermo line) by hand. One crew walked up the hill to the wooden poles 004/003A, B and C; a second crew set up a bucket truck at the highway to cut the conductor clear of the road; and a third crew set up a bucket truck at tower 004/002. Once traffic had been stopped and the conductor cut clear of the highway, crews at both wooden poles 004/003A, B and C and tower 004/002 rolled the conductor by hand at both ends. Insulators were stripped off the poles and tower and hauled in. PG&E did not remove any poles or engage in any ground-disturbing activity to remove the short spur of the conductor. An environmental assessment of the work is provided in Section 2.0. Figure 1-2 Depiction of Phase 1 Features November 2020 12 1.1.2 Phase 2 In preparation for the larger demolition and construction work scheduled for February 2021 Ï March 2021, the following actions are proposed to commence in early January 2021: Add guy wires to three existing poles (004/001A, B and C) located in the existing right-of-way for the Grizzly Tap to allow those structures to become temporary dead-ends; Temporarily remove an approximately 300-foot-long span of conductor extending from the existing lattice tower to the three existing poles; Remove an existing lattice tower (004/002) supporting the conductor within the substation yard; Reinforce an existing access bridge by welding additional steel plates to support the weight of vehicles transporting new electrical equipment. Figure 1-3 below (full drawing provided as Attachment G) provides a schematic of the proposed guy wire installation, which will consist of two to four workers hiking up the existing transmission right-of-way, hand digging new holes, and manually installing 3/4Ò x 30Ò long anchors with expanding grout backfill. This design drawing is considered to be 65% completed. A negligible amount of ground disturbance is expected to remove the existing lattice tower (within the previously disturbed substation yard) and to install the guy wires (within previously disturbed transmission right-of-way). See Figure 1-2 above for a depiction of the Grizzly Tap and these associated features. November 2020 13 Figure 1-3 Guy Wire Installation at Structures 004/001A, B, and C (65% design) 1.1.3 Phase 3 Once all Phase 2 activities have been completed, the following demolition and construction actions will be taken in February 2021 Ï March 2021, with a more detailed description provided in Sections 1.1.3.1 and 1.1.3.2 (activities completed in Phase 1 or to be completed in Phase 2 are noted): Demolition or removal of additional non-Project features within the Bucks Creek substation yard, including temporary removal of a 12 kV station service line, a telecom cabinet, an 11 kV bus section, 12 kV current transformers, and certain abandoned foundations, concrete culverts, trenches, conduits, cables, and fencing. Installation of new 115/230 kV transformer; Reinstallation of 300-foot-long span of conductor; Reconfiguration of conductor within the substation yard; Installation of ancillary facilities such as new foundations and oil spill containment, breakers, and switches; Installation of additional non-Project features such as the 12 kV station service line and related equipment, a new weather station, fencing, etc. November 2020 14 1.1.3.1 Demolition As described below, certain features within the existing Bucks Creek substation yard footprint will be demolished and removed prior to new installations and re-configuring of the yard. A drawing depicting these features has been filed with FERC as CUI/CEII information and is not included in this public filing. Major features to be demolished include: the existing 115 kV lattice tower (004/002), partial overhead line (to be run underground), a telecom cabinet, an 11 kV bus section, 12 kV CTs, and certain abandoned foundations, concrete culverts, trenches, conduits, cables, and fencing. A more detailed list of demolition/removal/modification actions is provided below. Unless otherwise noted, each action will be conducted as part of Phase 3. Detailed list of Demolition/Removal/Modification Work Remove 115kV Grizzly Tap line (~900-foot span) from tower 004/002 crossing Hwy 70 to structures 004/003A, B, and C (Removed 9/16/2020) (Phase 1). Demolish and remove existing 115kV tower (Phase 2). Remove 115kV ÑGrizzly TapÒ overhead line from 115kV tower to transmission pole 004/001 (Phase 2). Demolish three (3) existing 230kV insulator supports (Possibly 4 depending on reuse evaluation). Modify Bucks Creek Powerhouse (PH) Oil Containment curb, as necessary. o Spill Prevention Control and Countermeasure (SPCC) plan revision will be required. Modify North American Electric Reliability Corporation (NERC) fencing to accommodate new control building, minimizing spillway interference, considering equipment maintenance access. Remove mechanical drainage piping and trench next to new 230kV breaker installation. Animal abatement mitigation must be required per TD-3350P-10. Demolish and remove existing unused 11kV overhead lattice and foundations as necessary to make room for new 115kV Breaker CB142, capacitor voltage transformers (CCVTs), dead-end structureÔs, turning TSPÔs (Tubular Steel Poles), & new 230/115kV transformer. Demolish existing substation telecom/storage cabinet to make way for dead-end structure. Remove abandoned foundations in 12kV & 230kV yard. Containment curbs to be partially demolished and extended in north 12kV yard & 230kV yard. 11kV bus and control house foundation removal evaluation. Re-locate weather station to a new site-specific foundation on the North side of the 12kV yard, outside of the re-located fence. Remove conductor from Feeder 1101 on 12kV bus to dead-end tower that crosses over the river. Remove existing regulators and dead-end tower on West side of substation. November 2020 15 1.1.3.2 Construction As described below, the Bucks Creek substation yard will be reconfigured, largely to incorporate a new transformer so that the 115 kV Grizzly Tap may be stepped up to 230 kV and connected to the existing Bucks Creek-Cresta 230 kV within the same yard. A drawing depicting these features has been filed with FERC as CUI/CEII information and is not included in this public filing. Major items to be installed within the existing yard footprint include: new foundations and oil spill containment, new 230kV/115kV transformer, new 115kV and 230kV breakers, and related equipment. The only work not constrained to the existing Bucks Creek substation yard and access road footprint will be the installation of guy wires for enhanced support to three existing poles (004/001), as discussed in Section 1.1.2; a 70Ô light duty steel pole at the base of the hill and end of the transmission right-of-way adjacent to the substation; and a new weather station just north of existing substation yard fencing. A more detailed list of demolition, removal, and modification actions is provided below. Detailed list of Phase 3 Construction Work Install one (1) 230kV Circuit Breaker (CB212) underneath existing structure. Install two (2) 230kV disconnect switches on existing overhead structure (SW 211 and SW 213). Install new 230kV bus supports and foundations. Replace existing broken 230kV CCVT (B Phase). Modify 11kV Bus as required to allow C Phase 230kV conductor/breaker clearances. Modify Bucks Creek PH Oil Containment curb, as necessary, including SPCC plan. Modify NERC fencing to accommodate new control building, minimizing spillway interference, considering equipment maintenance access. Modify station grounding for new equipment (grounding evaluation to be required). Install new conduit to existing high voltage circuit breaker 232 & line CCVTÔs to route to new control building. Install single phase station service on the South side of the 11kV GSU Bus. 1 Ï 1¯ 50kVA HV: 7.2 kV; LV: 240/120 VAC. This will be the backup station service supply. Install one (1) 42Ô-0Ò X 15Ô-4Ò new control building with a battery enclosure. Install new 5ÔX5Ô pull box at the Powerhouse wall and penetrate the basement wall for conduit installation. Install cables from main comm room in PH to new control building and use diverse paths once in the substation yard. Install one (1) 230/115kV transformer and foundation. o Install overhead dead-end Steel Transformer Structure for line support. Install new transition from Bucks Creek PH Yard underground 11kV cable to existing switching station 11kV/12kV transformer overhead. November 2020 16 Reroute 12kV Feeder 1101 to Bucks Creek PH ÑAlternate Source Station Service Bk#3Ò currently running overhead across new CB142 location. Transition from overhead to underground infrastructure required. Route protection/control cables for new 115kV equipment back to new control building. Install one (1) 115kV Circuit Breaker (CB142) with maintenance outlets. Install two (2) 115kV switches (SW 141 and SW 143). Install new 3¯ TSP dead end structure with three (3) CCVTÔs. Install new BØ CCVT between the XFMR bank & 115kV breaker. Modify Non-NERC substation fencing to accommodate new breaker & transformer while minimizing spillway interference. Install 44Ô-0Ò X 8Ô-0Ò new SPCC basin. Modify station grounding for new equipment (grounding evaluation to be required). Install conduit for fiber to all 3 phases of regulator bank #4. Install new lighting per PG&E standard. Install 3 current transformers (CTÔs) on the 12kV side of Transformer Bank #4 and remove existing CTÔs on the low side Transformer Bank #4. Install single phase station service on the North side of the 12kV Main Bus. This will be the primary station service supply. Transfer all circuits from existing 12kV Station Service panel 5 to the new station service panel installed on the North side of the 12kV bus. Install new LAN capable EI Nexus meter for Transformer Bank 4. Install new 4/C fiber to each of the Transformer 4 regulator controllers (qty. 3) in 12kV yard. Install new DNPC board & Dymec 5846HRT-L in Transformer 4 Cabinet. Install 115kV overhead line to connect new Bucks Creek - Grizzly feed to existing pole 004/001. Install new underground ducts/hand holes for underground 11kV line from Bucks Creek PH yard to 12kV substation. Install/modify new underground ducts/hand holes for underground control & communication lines from Bucks Creek PH yard to 12kV substation and 115kV equipment (protection/control/SCADA etc.). Install 115kV 70Ô light duty steel pole (LDSP) on hill towards pole 004/001. Install guy wires on first 3 poles (structures 004/001A, B, C) up mountain to the east. Install lightning protection as required. Evaluations for tower grounding and mitigation may be required. Install new dead-end structure in same place with a switch mounted on top. Anchor structure directly outside of substation fence. Install riser structure under Bucks Creek-Bucks Lake (Feeder 1103) 12kV line on the load side of the regulators on the East end of the yard (on north side of distribution pole that heads east up the mountain). Install underground conduit path from new riser structure (east side of yard) to new dead-end structure (west side of yard). Make overhead terminations to tie in customers on Big Bend line to Feeder 1103. November 2020 17 1.1.4 Access and Staging Areas All labor, materials and tools/equipment will be transported via established roadways and maintained on hard surfaces, and all proposed work will be conducted within the previously disturbed Bucks Creek substation yard, existing parking area, or along an existing transmission right-of-way. See Figure a-1 above for a depiction of work areas associated with this project. Given the weight associated with transport of a new transformer to the Bucks Creek substation yard, PG&E will reinforce the existing access bridge by welding steel plates to the underside of the bridge. This bridge is within the FERC project boundary and is not an historic feature. The proposed bridge maintenance work will be included in PG&EÔs annual summary of work conducted under the Standard Land Use Article 40, paragraph (c). 1.1.5 Traffic Control No traffic control will be necessary because the proposed project is at the end of the Bucks Creek Powerhouse Road. Intermittent traffic delays are possible along Highway 70 only during equipment arrival and construction material deliveries. The normal daily construction traffic will be limited to the necessary project vehicles for construction personnel and light construction vehicles. PG&EÔs personnel and its contractors will be required to reduce speed when traveling along these roads. On-site signage will be installed, as necessary, to address any potential conflicts with recreational uses of the area outside the project footprint. 1.1.6 Fire Hazard Prevention During construction, crews will take appropriate measures to eliminate the potential for fire. If any cutting or welding is required at the jobsite, fire prevention and suppression tools (including backpack-type water pumps, shovels, etc.) will be made available on site. Welding, air-arc gouging, oxy-acetylene cutting, and grinding of pipe, steel or rebar is referred to as Ñhot workÒ. Hot work will be monitored at all times. Areas where hot work is being performed will be cleaned to mineral soil, and all brush, duff and other organics will be cleared a minimum of 10 feet away. Work pieces will be allowed to cool before being moved and will be cooled before the site is closed each night. Extinguishers will be maintained at all sites where hot work is being performed. Project November 2020 18 vehicles will be equipped with appropriate fire response equipment and fire prevention and suppression tools. 1.1.7 Disposal Cleanup and Demobilization Following completion of construction activities, the job site will be returned, as much as is reasonably practical, to its original condition. Any environmental mitigation measures stipulated by agency approvals and permits will be implemented in a timely manner. All equipment and surplus materials will be removed from the construction site. All construction debris and environmentally deleterious material will be removed and disposed of at an appropriate waste collection site. 1.1.8 Work Shift In general, the work will be performed on a four-day week, 10-hour days, scheduled Monday through Thursday starting at 7:00 a.m. However, additional work hours or days may be required due to unforeseen circumstances (such as scheduling, staffing, or resource constraints). 2.0 EXHIBIT E: ENVIRONMENTAL ASSESSMENT PG&E is proposing to amend the Project license to reduce the length of the Grizzly Tap from 4.2 to 4.0 miles long, and to reconfigure ancillary facilities within the Bucks Creek substation yard and transmission line right of way. As described in the application, the reconnection of the Grizzly Powerhouse involves the following three phases of activities: Phase 1 (Complete): o Remove a 900-foot-long span of the conductor from the Bucks Powerhouse substation yard to the de-energized Caribou-Palermo line. Phase 2 (early January 2021): o Add guy wires to three existing poles (004/001A, B and C) located in the existing right-of-way for the Grizzly Tap to allow those structures to become temporary dead-ends; November 2020 19 o Temporarily remove an approximately 300-foot-long span of conductor extending from the existing lattice tower to the three existing poles; o Remove an existing lattice tower (004/002) supporting the conductor within the substation yard; o Reinforce an existing access bridge by welding additional steel plates to support the weight of vehicles transporting new electrical equipment. Phase 3 (February 2021 - March 2021): o Demolition or removal of additional non-Project features within the Bucks Creek substation yard, including temporary removal of a 12 kV station service line, a telecom cabinet, an 11 kV bus section, 12 kV current transformers, and certain abandoned foundations, concrete culverts, trenches, conduits, cables, and fencing. o Installation of new 115/230 kV transformer; o Reinstallation of 300-foot-long span of conductor; o Reconfiguration of conductor within the substation yard; o Installation of ancillary facilities such as new foundations and oil spill containment, breakers, and switches; o Installation of additional non-Project features such as the 12 kV station service line and related equipment, a new weather station, fencing, etc. Phase 1 As described in the transmittal letter to this application and depicted on Figure 2-1 below, a 900-foot-long span of the Grizzly Tap conductor from the Bucks Creek substation yard to the Caribou-Palermo line has been removed for public safety reasons. As described in PG&EÔs September 14, 2020 letter (Accession No. 20200914-5150), PG&E originally intended to perform the work with helicopter assistance. Due to heavy smoke caused by nearby fires, PG&E transmission line crews instead removed the single span of conductor between towers 004/002 (in the Bucks Creek substation yard) and wooden poles 004/003A, B and C (on the Caribou-Palermo line) by hand. One crew walked up the hill to the wooden poles 004/003A, B and C; a second crew set up a bucket truck at the highway to cut the conductor clear of the road; and a third crew set up a bucket truck at tower 004/002. Once traffic had been stopped and the conductor November 2020 20 cut clear of the highway, crews at both wooden poles 004/003A, B and C and tower 004/002 rolled the conductor by hand at both ends. Insulators were stripped off the poles and tower and hauled in. PG&E did not remove any poles or engage in any ground-disturbing activity to remove the short spur of the conductor. Figure 2-1 Depiction of Phase 1 Features The single span affects both PG&E-owned lands and lands managed by the U.S. Department of Agriculture, Forest Service, in the Plumas National Forest. Even though the conductor removal did not involve ground-disturbing activity, prior to removal, PG&E conducted a desktop review of biological and cultural resources in the right of way. No resources of concern were identified that might be affected by the removal of the conductor. The conductor was removed during a period that is outside of nesting bird season. In addition, PG&E voluntarily complied with applicable standard best management practices set forth in the Plumas Master Programmatic Easement (Plumas MPE) (Attachment H). Phases 2 and 3 November 2020 21 PG&E is currently finalizing the design of the reconnection, and has contracted with a Design, Procure, and Construction vendor to complete the reconnection expeditiously. The proposed work associated with Phases 2 and 3 of the reconnection project will be performed by PG&E transmission line crews and overseen by a PG&E Construction Manager. All labor, materials and tools/equipment will be transported via established roadways and maintained on hard surfaces, and all proposed work will be conducted within the previously disturbed Bucks Creek substation yard, existing parking area or road, or along an existing transmission right-of-way. The work will not require any adjustments to normal dam or powerhouse operations. The following sections discuss potential effects of the proposed work on relevant environmental resources. The proposed work affects both PG&E and Plumas National Forest lands. Therefore, PG&E has also been coordinating with the Plumas National Forest and will implement applicable standard best management practices in accordance with the Plumas MPE in addition to the license-specific measures outlined below. 2.1 Biological Resources The project was reviewed for potential to impact special status biological resources and to comply with the Project requirements. The proposed work is scheduled to be conducted primarily outside of nesting season and will be contained within the previously disturbed footprint of the existing substation yard, parking area, existing road, and right-of-way (guy wire installations) at structure 004/001A, B, and C upslope of the substation yard. All work areas are outside of any bald eagle nest management zones, outside of the range of Sierra Nevada yellow legged frog, and not within habitat for willow flycatcher. Relicensing studies conducted in 2015 did not identify any special status plants or wildlife species in proximity to the work areas. There are known occurrences of the invasive weeds yellow starthistle, Himalayan blackberry, and stinkwort near the bridge, along Bucks Creek Powerhouse Road, and near Bucks Creek substation yard. Therefore, in accordance with the Bucks Creek Noxious Weed Management Plan (PG&E 2006) as required by Article 103 of the license, the following measures will be implemented to limit the spread and introduction of invasive weeds: The Licensee or its contractor will ensure that all off-road equipment brought into the area from outside the watershed is free of soil, seeds, vegetative material, or other debris that could contain or hold seeds of noxious weeds. ÑOff Road EquipmentÒ includes all logging, construction, and brushing machinery/equipment (brush hogs, masticators, chippers) except log trucks, chip November 2020 22 vans, service vehicles, water trucks, pickup trucks, and similar vehicles not intended for off-road use. Equipment will be considered clean when a visual inspection does not disclose soil, seed, plant material, and other such debris. Disassembly of equipment components or specialized inspection tools will not be required. The Forest Service will be notified at least 5 working days prior to moving off- road equipment onto National Forest System land, unless otherwise agreed. In the case of emergency, the Licensee will notify the Forest Service as soon as possible of the need to bring off-road equipment onto National Forest System lands from outside the watershed. Notification will include: the location of the equipmentÔs most recent operations, the type of equipment cleaning to be used prior to entry into the watershed, and the location where cleaning will be performed. 2.2 Cultural Resources The project meets the criteria of a federal undertaking as defined in 36 CFR § 800.16(y). As a result, the undertaking must comply with Section 106 of the National Historic Preservation Act of 1966, as amended, to consider the effect of the undertaking on any sites, buildings, structures, or objects that are included in or may be eligible for inclusion in the National Register of Historic Places (NRHP). The Bucks Creek Hydroelectric Project Historic District, which contains a number of contributing features, is within the proposed Area of Potential Effect (APE). In the proposed APE, the powerhouse is eligible for inclusion in the NRHP. The transmission yard and access bridge are not eligible for inclusion in the NRHP. A review of PG&EÔs confidential Geographic Information System (GIS) database, which includes subscription data from the Northeast Information Center (NEIC) in Chico, California, identified three additional cultural resources within the APE, the Feather River Highway District, P-32-002664, and FS 05- 11-56-1043. The Feather River Highway District is eligible for the NRHP. P-32-002664 consists of an isolated telephone pole with ceramic insulators. Isolated resources are not considered eligible for the NRHP. FS 05-11-56-1043 is the unevaluated remains of Camp 1, which supported the construction of the Bucks Creek powerhouse and penstock. No alterations will be made to the Feather River Highway District or FS 05-11-56-1043. A roughly 18Ò x 30Ò hole will be cut below grade in the powerhouse basement wall for conduit installation. Additionally, the proposed APE was surveyed for archaeological November 2020 23 resources in 2015 during relicensing activities; no additional archaeological resources were identified during the survey. By letter dated October 20, 2020, PG&E filed with FERC a request for designation as non-federal representative for Section 106 Consultation for this proposed work. Once PG&E has been designated, it will submit a consultation package for review to the State Historic Preservation Officer (SHPO), pursuant to 36 CFR § 800. 2.3 Erosion Control, Fugitive Dust Abatement, and Water Quality Temporary impacts to soils will occur during the demolition of existing features and burying of new features within the Bucks Creek substation yard footprint, as well as with the installation of new guy wires for existing wooden poles within an existing transmission right-of-way. As described below, a soil disturbance analysis was performed for the proposed work. A drawing depicting this analysis has been filed with FERC as CUI/CEII information and is not included in this public filing. The soil disturbance calculation resulted in approximately 0.8 acres of disturbance, which is less than the stateÔs (1.0 acres) and PG&EÔs (0.9 acres) minimum threshold of disturbance that triggers the need for a Stormwater Pollution Prevention Plan (SPPP). Therefore, an SPPP will not be required for this project. The proposed work does not include any in-water work or expected discharges; however, due to the proximity of the river to the work site, a Site-Specific Sediment and Erosion Control Plan will be prepared by PG&EÔs storm water contractor, which will outline the best management practices and avoidance and minimization measures. 2.4 Hazardous Materials Material such as fuel (gasoline/diesel), hydraulic oil, and motor oil, will be used at the work site. Construction crews will employ spill prevention equipment such as absorbent pads and secondary containment systems on fuel or oil containing equipment to ensure that hazardous materials or hazardous waste does not negatively impact the environment. 2.5 Permits and Approvals All necessary permits and approvals will be obtained prior to construction. The Licensee will comply with the conditions or measures required by the responsible permitting/authorizing agencies. November 2020 24 2.5.1 Permits A PG&E Land Planner has reviewed the proposed activity (project) and confirms that potentially applicable discretionary permits or authorizations from resource agencies are not applicable for the following reasons: Project activity and impacts are outside of the jurisdiction of the Clean Water Act Section 404/401 as no fill or dredge material will be discharged into Waters of the U.S. and therefore US Army Corps of Engineers and Regional Water Quality Control Board permits (under Clean Water Act Sections 404 and 401 respectively) are not required. Project activities will not entail ground disturbance of over 1 acre in area, therefore a National Pollution Discharge Elimination System (NPDES) Construction Storm Water permit is not required from the State Water Board (under CWA 402). The project will implement standard PG&E Best Management Practices for dust, erosion, and sediment control. 2.6 Agency Consultation and Approvals The following approvals are being sought for the proposed work, discussed in more detail below: FERC review and approval. The United States Forest Service- Plumas National Forest (PNF) consultation. California State Historic Preservation Officer (SHPO) consultation. 2.6.1 FERC PG&E and FERC staff have recently engaged in multiple calls to discuss the proposed phased project to reestablish the transmission of power from the Grizzly Powerhouse. Before PG&E and FERC had an opportunity to discuss the project phases, FERC requested on October 9, 2020, that an amendment be prepared and filed for all phases of the proposed work. November 2020 25 Table 2-1 below provides a summary of PG&E and FERC correspondence to date, and the full text of each correspondence is found in Attachment J. November 2020 26 Table 2-1 FERC Correspondence Date From To Description 10/20/2020 PG&E FERC Request for Designation as Non-Federal Representative for Section 106 Consultation for the Grizzly Powerhouse Reconnection Project 10/9/2020 FERC PG&E Additional Information Request 10/9/2020 PG&E FERC Notice of Proposed Modification to Project Works to modify a portion of the Grizzly Tap, part of the Bucks Creek Project, FERC No. 619, by removing temporarily an approximately 300-foot span of the Grizzly Tap conductor, removing an existing lattice tower in the Bucks Creek substation yard, and installing temporary guy wires to prepare for an upcoming project to re- establish the transmission of power from the Grizzly Powerhouse (i.e., Phase 2 activities). 9/14/2020 PG&E FERC Notification of emergency removal of single span (~900 ft) that posed a potential public safety risk pursuant to 18 CFR 12.10 and 12.11(b). 2/21/2019 PG&E FERC Notification of Grizzly Powerhouse outage as a result of damage to the non-Project Caribou-Palermo 115 kv transmission line from the Camp Fire. 2.6.2 USFS The proposed work affects both PG&E and Plumas National Forest lands. Therefore, PG&E has also been coordinating with the Plumas National Forest and will implement applicable standard best management practices in accordance with the Plumas MPE (Attachment H) in addition to the license-specific measures outlined in Section 2.0. PG&E provided a project notification to the USFS of preliminary work associated with this project on October 6, 2020, supplemented by a project description of the project as a whole on October 23, 2020. Once USFS concurrence is received, PG&E will file the necessary consultation record with FERC. November 2020 27 2.6.3 SHPO The project meets the criteria of a federal undertaking as defined in 36 CFR § 800.16(y). As a result, the undertaking must comply with Section 106 of the National Historic Preservation Act of 1966, as amended, to consider the effect of the undertaking on any sites, buildings, structures, or objects that are included in or may be eligible for inclusion in the NRHP. The Bucks Creek Hydroelectric Project Historic District, which contains a number of contributing features, is within the proposed APE. In the proposed APE, the powerhouse is eligible for inclusion in the NRHP. The transmission yard and access bridge are not eligible for inclusion in the NRHP. A review of PG&EÔs confidential Geographic Information System (GIS) database, which includes subscription data to the Northeast Information Center (NEIC) in Chico, California, identified three additional cultural resources within the APE, the Feather River Highway District, P-32-002664, and FS 05-11-56-1043. The Feather River Highway District is eligible for the NRHP. P-32- 002664 consists of an isolated telephone pole with ceramic insulators. Isolated resources are not considered eligible for the NRHP. FS 05-11-56-1043 is the unevaluated remains of Camp 1, which supported the construction of the Bucks Creek powerhouse and penstock. No alterations will be made to the Feather River Highway District or FS 05-11- 56-1043. A roughly 18Ò x 30Ò hole will be cut below grade in the powerhouse basement wall for conduit installation. Additionally, the proposed APE was surveyed for archaeological resources in 2015 during relicensing activities; no additional archaeological resources were identified during the survey. By letter dated October 20, 2020, PG&E filed with FERC a request for designation as non-federal representative for Section 106 Consultation for this proposed work. Once PG&E has been designated, it will submit a consultation package for review to the State Historic Preservation Officer (SHPO), pursuant to 36 CFR § 800. November 2020 28 3.0 EXHIBIT A 3.1 Existing Language in Exhibit A Exhibit A (Project Description) for the Project was most recently approved by order dated March 20, 2008 (122 FERC ¶ 62,239). Exhibit A currently provides a narrative description of both Project and non-Project features. As it relates to features affected by this proposed amendment, Exhibit A describes the following: Grizzly Addition Transmission: A 4.2 mile long 115 kV transmission line extending from Grizzly Powerhouse to Caribou-Sycamore Creek 115 kV power circuit breaker and structure and related equipmentÉ 3.2 Proposed Changes to Project Description As described in Exhibit A, the Grizzly Powerhouse Development currently includes Ña 4.2 mile-long, 115-kV transmission line interconnecting the development to PG&EÔs 115-kV Caribou-Sycamore Creek line as a feature of the Grizzly Powerhouse Development. As a result of the re-routing of the Grizzly Tap, the length of the current line will be shortened and will no longer cross the North Fork Feather River. Instead, it will end in the Bucks Creek substation yard and interconnect to PG&EÔs existing Bucks Creek-Cresta 230 kV transmission line. The applicant proposes to amend page 4 of Exhibit A to read as follows: Grizzly Addition Transmission: A 4.2 4.0 mile long 115 kV transmission line extending from Grizzly Powerhouse to the 230 kV Rock Creek-Cresta line (non-Project)Caribou-Sycamore Creek 115 kV transmission line (FERC 2105) near Bucks Creek Powerhouse (FERC 619). The structures are H-frame wood poles supporting 4/0 ASCR conductor. Applicants are also attaching both a marked and clean version (Attachment D) of the proposed changes to Exhibit A. 3.3 Lands of the United States Applicants are proposing no changes to the current Project boundary at this time; therefore, there will be no change to Plumas National Forest acreage within the current boundary. November 2020 29 4.0 EXHIBIT L: PROJECT DESIGN DRAWINGS The only approved project design drawing that would be affected by this amendment is Exhibit L-7 (FERC Drawing No. 619-189; Plans and Section of Powerhouse). While its intent is to describe powerhouse features, the ancillary and non-project features discussed in this application are depicted in the General Arrangement Outdoors section of the exhibit. On the drawing, minor changes would be needed to reflect the shortening of the Grizzly Tap and reconfiguration of certain ancillary and non-project features. A mark-up of proposed changes to Exhibit L-7 (current) to reflect the reconfiguration proposed in this amendment has been filed with FERC as CUI/CEII information and is not included in this public filing. PG&E filed a Final Application for New License (FLA) for the Project on December 16, 2016, as supplemented on May 22, 2018. Upon approval of the revised Exhibit L-7 proposed herein, PG&E will request to amend proposed Exhibit F-5 (Proposed PG&E Drawing No. 701165-1; Plan and Section of Bucks Creek Powerhouse) to reflect the approved depiction of Project features. November 2020 30 5.0 EXHIBIT G: PROJECT BOUNDARY The only current project boundary drawing that would be affected by this amendment is Exhibit G-11 (FERC Drawing No. 619-204; Penstock, Power House and Transmission Lines). On the drawing, minor changes are proposed to shorten the length of the Grizzly Tap and to note that the non-Project Caribou-Palermo 115 kV transmission line is out of service. Error! Reference source not found. below provides a mark-up of proposed changes to Exhibit G-11 (current) to reflect the reconfiguration proposed in this amendment. A mark-up of the full drawing is provided in Attachment F. No changes to the Project boundary are being proposed at this time. PG&E filed a Final Application for New License (FLA) for the Project on December 16, 2016, as supplemented on May 22, 2018. Upon approval of the revised Exhibit G-11 proposed herein, PG&E will request to amend proposed Exhibit G-10 (Proposed PG&E Drawing No. 701160-1; Penstock, Power House and Transmission Lines) to reflect the approved depiction of Project features. Figure 5-1 Proposed Changes to Exhibit G-11 (Current) November 2020 31 A TTACHMENT A P ROPOSED D EMOLITION A CTIVITIES (F ILED AS CUI/CEII; N OT I NCLUDED IN P UBLIC F ILING) A TTACHMENT B P ROPOSED C ONSTRUCTION A CTIVITIES (F ILED AS CUI/CEII; N OT I NCLUDED IN P UBLIC F ILING) A TTACHMENT C F IGURE OF F EATURES A SSOCIATED WITH A MENDMENT A TTACHMENT D P ROPOSED E XHIBIT A R EVISIONS M ARK-UP V ERSION OF P ROPOSED E XHIBIT A R EVISIONS GeneraldescriptionoftheprincipalworksaddedtotheProjectaspartoftheGrizzly Powerhouse addition Grizzly Addition Structures: A.A tunnel intake structure of reinforced concrete and consisting of an entrance transition sectionwith a fish screen about 42 feet wide and about 20 feet high; tower section about 18 by 18 feet in plan and 58 feet high; and a gate house about 16 by 16 feet in plan and 23 feet high. B. A pressure tunnel consisting of a TBM section 11 feet in diameter and approximately 11,868 feet long, mostly unlined, and a lined horseshoe-shaped section approximately 13 by 12 feet and 82 feet long. C. A surge chamber consisting of a 212 feet tall by 10 to 15 feet in diameter reinforced concrete-lined vertical shaft with a steel-lined orifice. D. A steel penstock approximately 4,761 feet long with a diameter varying from 96 to 56 inches and buried for most of its length. E. A reinforced concrete powerhouse about 65 feet by 54 feet in plan. Grizzly Addition Turbine-Generator: The powerhouse contains a single 26,400 HP vertical Francis turbine directly coupled to a 22,000 kVA generator. The powerhouse is designed for unattended operation with supervisory control from an attended Licensee operating station in the vicinity. Grizzly Addition Transmission: A4.2 4.0 milelong115kvtransmissionlineextendingfromGrizzlyPowerhouse to the 230 kV Rock Creek-Cresta line (non-Project)Caribou-Sycamore Creek 115 kv transmission line (FERC 2105) near Bucks Creek Powerhouse (FERC 619). The structures are H-frame wood poles supporting 4/0 ASCR conductor. Grizzly Addition Miscellaneous Equipment and Facilities: The switchyard, located adjacent to the powerhouse, contains the generator step-up transformer and a 115 kv power circuit breaker and structure and related equipment. Other features include an approximately 1.7 mile long access road to the Grizzly Powerhouse, a new communications facility with an approximately 0.7 mile long access road and a new recreation facility at Sandy Point on Bucks Lake with an approximately 0.4 mile long access road. 4 C LEAN V ERSION OF P ROPOSED E XHIBIT A R EVISIONS GeneraldescriptionoftheprincipalworksaddedtotheProjectaspartoftheGrizzly Powerhouse addition Grizzly Addition Structures: A.A tunnel intake structure of reinforced concrete and consisting of an entrance transition sectionwith a fish screen about 42 feet wide and about 20 feet high; tower section about 18 by 18 feet in plan and 58 feet high; and a gate house about 16 by 16 feet in plan and 23 feet high. B. A pressure tunnel consisting of a TBM section 11 feet in diameter and approximately 11,868 feet long, mostly unlined, and a lined horseshoe-shaped section approximately 13 by 12 feet and 82 feet long. C. A surge chamber consisting of a 212 feet tall by 10 to 15 feet in diameter reinforced concrete-lined vertical shaft with a steel-lined orifice. D. A steel penstock approximately 4,761 feet long with a diameter varying from 96 to 56 inches and buried for most of its length. E. A reinforced concrete powerhouse about 65 feet by 54 feet in plan. Grizzly Addition Turbine-Generator: The powerhouse contains a single 26,400 HP vertical Francis turbine directly coupled to a 22,000 kVA generator. The powerhouse is designed for unattended operation with supervisory control from an attended Licensee operating station in the vicinity. Grizzly Addition Transmission: A 4.0 mile long 115 kv transmission line extending from Grizzly Powerhouse to the 230 kV Rock Creek-Cresta line (non-Project) near Bucks Creek Powerhouse (FERC 619). The structures are H-frame wood poles supporting 4/0 ASCR conductor. Grizzly Addition Miscellaneous Equipment and Facilities: The switchyard, located adjacent to the powerhouse, contains the generator step-up transformer and a 115 kv power circuit breaker and structure and related equipment. Other features include an approximately 1.7 mile long access road to the Grizzly Powerhouse, a new communications facility with an approximately 0.7 mile long access road and a new recreation facility at Sandy Point on Bucks Lake with an approximately 0.4 mile long access road. 4 A TTACHMENT E P ROPOSED E XHIBIT L R EVISIONS (F ILED AS CUI/CEII; N OT I NCLUDED IN P UBLIC F ILING) A TTACHMENT F P ROPOSED E XHIBIT G R EVISIONS bƚƷğƷźƚƓƷƚĬĻ ğķķĻķƷƚķƩğǞźƓŭ {źƓŭƌĻƭƦğƓƷƚĬĻ ƩĻƒƚǝĻķŅƩƚƒķƩğǞźƓŭ A TTACHMENT G G UY W IRE I NSTALLATION AT S TRUCTURES 004/001A, B, AND C A TTACHMENT H A TTACHMENT 3 OF THE P LUMAS M ASTER P ROGRAMMATIC E ASEMENT Attachment 3 Best Management Practices to be used in protection of all species outside the informal FWS consultation species in all eleven Forest Service boundaries with PG&E infrastructure. 1. Worker Environmental Awareness Training 4§¤ 5³¨«¨³¸ ¶¨«« ¯±¤¯ ±¤ ¤µ¨±®¬¤³ « ¶ ±¤¤²² ³± ¨¨¦ ±¤¦ ±£¨¦ ²¯¤¢¨ «-²³ ³´² ²¯¤¢¨¤² ³§ ³ ¢®´«£ ¡¤ ¤¢®´³¤±¤£ £´±¨¦ ¶®±ª ¢³¨µ¨³¨¤²ȁ 4§¤ ³± ¨¨¦ ¶¨«« ¨¢«´£¤ ¨¥®±¬ ³¨® ¡®´³ §®¶ ³® ¨£¤³¨¥¸ ¯¤±³¨¤³ ²¯¤¢¨¤²Ǿ ³§¤¨± § ¡¨³ ³ ±¤°´¨±¤¬¤³²Ǿ £ ±¤²®´±¢¤ ¯±®³¤¢³¨® ¬¤ ²´±¤² Ȩ20-²ȩ ³® ¡¤ ¨¬¯«¤¬¤³¤£ȁ 4 ¨«¡® ±£ ³± ¨¨¦² «²® ¶¨«« ¡¤ ¢®£´¢³¤£ ² ¤¢¤²² ±¸ȁ '¤¤± « ±¤²³±¨¢³¨®² £ ¦´¨£¤«¨¤² ³§ ³ ¶¨«« ¡¤ ¥®««®¶¤£ ¡¸ ¯±®©¤¢³ ¯¤±²®¤« ±¤ «¨²³¤£ ¡¤«®¶ȁ 4§¤ ¯±®©¤¢³ ¥®±¤¬ ¶¨«« ¡¤ ±¤²¯®²¨¡«¤ ¥®± ¤²´±¨¦ ³§ ³ ¢±¤¶ ¬¤¬¡¤±² £§¤±¤ ³® ³§¤²¤ ¦´¨£¤«¨¤² £ ±¤²³±¨¢³¨®²ȁ 0¤±²®¤« £±¨µ¨¦ µ¤§¨¢«¤² ¨ ³§¤ ¢³¨® ±¤ ¶¨«« ®¡²¤±µ¤ ³§¤ ¯®²³¤£ ²¯¤¤£ «¨¬¨³ ® § ±£- ²´±¥ ¢¤£ ±® £² £ ® «« ´¯ µ¤£ &®±¤²³ 3¤±µ¨¢¤ ±® £²ȁ Off-±® £ ³± µ¤« ¶¨«« ¡¤ ±¤²³±¨¢³¤£ ³® ³§¤ £¤²¨¦ ³¤£ ¶®±ª ±¤ ²ȁ !«« ³± ²§ ¶¨«« ¡¤ £¨²¯®²¤£ ®¥ £ ±¤¬®µ¤£ ¥±®¬ ³§¤ ¶®±ª ±¤ £ ¨«¸ȁ !² ¤¢¤²² ±¸Ǿ ³¤¬¯®± ±¸ ²¨¦²Ǿ ²³ ª¨¦Ǿ ®± ¥« ¦¦¨¦ ¶¨«« ¡¤ ´²¤£ ³® ¨£¤³¨¥¸ ²´¨³ ¡«¤ ®± ¯®³¤³¨ « § ¡¨³ ³ ¥®± ²¯¤¢¨ «-²³ ³´² ²¯¤¢¨¤²ǿ £ ¯±®©¤¢³ ¯¤±²®¤« ¶¨«« ¡¤ £µ¨²¤£ ³® min¨¬¨¹¤ £¨²³´±¡ ¢¤ ¨ ³§¤²¤ ±¤ ²ȁ !¸ ¶®±ª¤± ¶§® ¨ £µ¤±³¤³«¸ ¨©´±¤² ®± ª¨««² ²¯¤¢¨ «-²³ ³´² ²¯¤¢¨¤² ®± ¥¨£² ®¤ £¤ £Ǿ ¨©´±¤£Ǿ ®± ¤³± ¯¯¤£Ǿ ¶¨«« ¨¬¬¤£¨ ³¤«¸ ±¤¯®±³ ³§¤ ¨¢¨£¤³ ³® ³§¤ ¯±®©¤¢³ ¥®±¤¬ Ǿ ¶§® ¶¨«« ¨¬¬¤£¨ ³¤«¸ ±¤¯®±³ ³§¤ ¨¢¨£¤³ ³® ³§¤ 5³¨«¨³¸ ¡¨®«®¦¨²³ȁ 4§¤ 5³¨«¨³¸ ¡¨®«®¦¨²³ ¶¨«« ®³¨¥¸ ³§¤ &®±¤²³ ¶¨³§¨ ΑΓ §®´±²Ǿ £ ³§¤ &®±¤²³ ¶¨«« ¯±®µ¨£¤ ®± « ®³¨¥¨¢ ³¨® ³® ³§¤ ¯¯±®¯±¨ ³¤ 5ȁ3ȁ &¨²§ £ 7¨«£«¨¥¤ 3¤±µ¨¢¤ Ȩ53&73ȩ ®± . ³¨® « /¢¤ ¨¢ £ !³¬®²¯§¤±¨¢ !£¬¨¨²³± ³¨® &¨²§¤±¨¤² 3¤±µ¨¢¤ Ȩ./!!ȩ ®¥¥¨¢¤ £ «®¢ « # «¨¥®±¨ $¤¯ ±³¬¤³ ®¥ &¨²§ £ 7¨«£«¨¥¤ (CDFW) ¶ ±£¤ ®± ¡¨®«®¦¨²³ ¶¨³§¨ ΐ ¶®±ª¨¦ £ ¸ȁ 4§¤ &®±¤²³ ¶¨«« ¥®««®¶ ´¯ ¶¨³§ ¶±¨³³¤ ®³¨¥¨¢ ³¨® ³® 53&73Ǿ ./!!Ǿ £ #$&7 Ȩ¨¥ ¤¢¤²² ±¸ȩ ¶¨³§¨ Δ ¶®±ª¨¦ £ ¸²ȁ 2¤¥´¤«¨¦ ®± ¬ ¨³¤ ¢¤ ®¥ µ¤§¨¢«¤² £ ¤°´¨¯¬¤³ ¶¨«« ®¢¢´± ®´³²¨£¤ ®¥ ¶ ³¤± ¢®´±²¤² £ ±¨¯ ±¨ § ¡¨³ ³ȁ !«« ¯±®©¤¢³ ¤°´¨¯¬¤³ ¶¨«« ¡¤ ¤°´¨¯¯¤£ ¶¨³§ § ¹ ±£®´² ²¯¨«« ¯±¤µ¤³¨® £ ¢®³ ¨¬¤³ ¤°´¨¯¬¤³ ³® ¬¨¨¬¨¹¤ ³§¤ ¤¥¥¤¢³² ®¥ ¥´¤« ²¯¨«« ®± §¸£± ´«¨¢ «¤ ªȁ 2. Introduction or Spread of Invasive Plant Species /¤ ®± ¬®±¤ ®¥ ³§¤ ¥®««®¶¨¦ ¬¤ ²´±¤² ¶¨«« ¡¤ ¨¬¯«¤¬¤³¤£ ³® ¯±¤µ¤³ ³§¤ ¨³±®£´¢³¨® ®± ²¯±¤ £ ®¥ ¨µ ²¨µ¤ ¯« ³ ²¯¤¢¨¤²ȁ 0±®µ¨£¤ ¯±¤-¶®±ª ¶ ±¤¤²² ³± ¨¨¦ ³® ¯¯±®¯±¨ ³¤ ¯¤±²®¤« ¡®´³ ³§¤ ¨£¤³¨¥¨¢ ³¨® ®¥ ®·¨®´² ¶¤¤£²Ǿ ³§¤ ¨¬¯®±³ ¢¤ ®¥ ®·¨®´²-¶¤¤£ ¢®³±®«Ǿ £ ¬¤ ²´±¤² ³® ¬¨¨¬¨¹¤ ³§¤ ²¯±¤ £ ®¥ ²´¢§ ¶¤¤£²ȁ #®²´«³ ¶¨³§ ³§¤ &®±¤²³ ®± 2 ¦¤± $¨²³±¨¢³ ´ ««¸ £ ¬®±¤ ®¥³¤ ² ¤¢¤²² ±¸ ³® dis¢´²² ¶¤¤£ ¯±¤µ¤³¨® £ ¬ ¦¤¬¤³ ¤¤£²ȁ 3¢§¤£´«¤ ¢³¨µ¨³¨¤² ³® ¬¨¨¬¨¹¤ ¯®³¤³¨ « ¥®± ¨³±®£´¢³¨® £ ²¯±¤ £ ®¥ ¶¤¤£²ȁ 0« ³± µ¤« ±®´³¤² ³® µ®¨£ ±¤ ² ¨¥¤²³¤£ ¶¨³§ ¶¤¤£² ¶§¤ ¥¤ ²¨¡«¤ȁ #«¤ «« ³®®«²Ǿ ¢®²³±´¢³¨® ¤°´¨¯¬¤³Ǿ £ §¤ µ¸-£´³¸ µ¤§¨¢«¤² ¡¤¥®±¤ ¤³¤±¨¦ .&3 lands. 0±¤¯ ±¤ ¶®±ª²¨³¤² ³® ±¤²³±¨¢³ ³§¤ ¨³±®£´¢³¨® £ ²¯±¤ £ ®¥ ¶¤¤£²ȁ 5²¤ ¶¤¤£-¥±¤¤ ²®´±¢¤² ¥®± ¨¬¯®±³¤£ ¯±®©¤¢³ ¬ ³¤±¨ «² Ȩ¤ȁ¦ȁǾ ¦± µ¤«Ǿ ²³± ¶Ǿ £ ¥¨««ȩ ³® ³§¤ ¤·³¤³ ¯± ¢³¨¢ ¡«¤ Ȩ¤ȁ¦ȁǾ ¶§¤±¤ £ ¶§¤ ²®´±¢¤² ±¤ µ ¨« ¡«¤ȩȁ M ¨³ ¨ ¥ ¢¨«¨³¨¤² £ ¨¥± ²³±´¢³´±¤ Ȩ¤ȁ¦ȁ ²¯´± ±® £²Ǿ ³®¶¤±²Ǿ ²³ ¦¨¦ ±¤ ²Ǿ ¤³¢ȁȩ ³® «¨¬¨³ ³§¤ ¨³±®£´¢³¨® £ ²¯±¤ £ ®¥ ¶¤¤£²ȁ Facility Construction and Stormwater Control 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² FAC-2. %²³ ¡«¨²§ £¤²¨¦ ³¤£ ±¤ ² ¥®± ¤°´¨¯¬¤³ ²³ ¦¨¦Ǿ ²³®¢ª¯¨«¨¦ ¬ ³¤±¨ «²Ǿ £ ¯ ±ª¨¦ ³® ¬¨¨¬¨¹¤ ³§¤ ±¤ ®¥ ¦±®´£ £¨²³´±¡ ¢¤ Ȩ²¤¤ Road-9 Ȭ0 ±ª¨¦ £ 3³ ¦¨¦ !±¤ ²ȭ £ Road- 10 Ȭ%°´¨¯¬¤³ 2¤¥´¤«¨¦ £ 3¤±µ¨¢¨¦ȭȩȁ 2¤¥¤± ³® 3³ ³¤ ®± «®¢ « ¢®²³±´¢³¨® £ ²³®±¬¶ ³¤± "-0 ¬ ´ «²Ǿ ¦´¨£¤¡®®ª²Ǿ £ ³± £¤ ¯´¡«¨¢ ³¨®² ¥®± ¤¥¥¤¢³¨µ¤ ³¤¢§¨°´¤² ³®Ȁ o Apply soil protective cover on disturbed areas where natural revegetation is inadequate to prevent accelerated erosion during construction or before the next growing season. o Maintain the natural drainage pattern of the area wherever practicable. o Control, collect, detain, treat, and disperse stormwater runoff from the site. o Divert surface runoff around bare areas with appropriate energy dissipation and sediment filters. o Stabilize steep excavated slopes. )²³ «« ²¤£¨¬¤³ £ ²³®±¬¶ ³¤± ¢®³±®«² ¡¤¥®±¤ ¨¨³¨ ³¨¦ ²´±¥ ¢¤-£¨²³´±¡¨¦ ¢³¨µ¨³¨¤² ³® ³§¤ ¤·³¤³ ¯± ¢³¨¢ ¡«¤ȁ 3¢§¤£´«¤Ǿ ³® ³§¤ ¤·³¤³ ¯± ¢³¨¢ ¡«¤Ǿ ¢®²³±´¢³¨® ¢³¨µ¨³¨¤² ³® µ®¨£ £¨±¤¢³ ²®¨« £ ¶ ³¤± £¨²³´±¡ ¢¤ £´±¨¦ ¯¤±¨®£² ®¥ ³§¤ ¸¤ ± ¶§¤ §¤ µ¸ ¯±¤¢¨¯¨³ ³¨® £ ±´®¥¥ ±¤ «¨ª¤«¸ ³® occur. o Limit the amount of exposed or disturbed soil at any one time to the minimum necessary to complete construction operations. o Limit operation of equipment when ground conditions could result in excessive rutting, soil puddling, or runoff of sediments directly into waterbodies. - ¨³ ¨ ¤±®²¨® £ ²³®±¬¶ ³¤± ¢®³±®«² ² ¤¢¤²² ±¸ ³® ¤²´±¤ ¯±®¯¤± £ ¤¥¥¤¢³¨µ¤ functioning. o Prepare for unexpected failures of erosion control measures. o Implement corrective actions without delay when failures are discovered to prevent pollutant discharge to nearby waterbodies. 2®´³¨¤«¸ ¨²¯¤¢³ ¢®²³±´¢³¨® ²¨³¤² ³® µ¤±¨¥¸ ³§ ³ ¤±®²¨® £ ²³®±¬¶ ³¤± ¢®³±®«² ±¤ ¨¬¯«¤¬¤³¤£ £ ¥´¢³¨®¨¦ ² £¤²¨¦¤£ £ ±¤ ¯¯±®¯±¨ ³¤«¸ ¬ ¨³ ¨¤£ȁ 5²¤ ²´¨³ ¡«¤ ¬¤ ²´±¤² ¨ ¢®¬¯«¨ ¢¤ ¶¨³§ «®¢ « £¨±¤¢³¨® ³® ¯±¤µ¤³ £ ¢®³±®« ¨µ ²¨µ¤ species. 5. Solid Waste Management 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² FAC-5. $¨²¯®²¤ ®¥ ¢®««¤¢³¤£ ¦ ±¡ ¦¤ ³ ¯±®¯¤±«¸ £¤²¨¦¤£ £ ®¯¤± ³¤£ ¬´¨¢¨¯ «-Ǿ ¢®´³¸-Ǿ ®± 3³ ³¤ ´³§®±¨¹¤£ ² ¨³ ±¸ « £¥¨««² ®± ¶ ²³¤ ±¤¢¸¢«¨¦ ²¨³¤² ¶§¤±¤ ¦±®´£¶ ³¤± £ ²´±¥ ¢¤ ¶ ³¤± ±¤ £¤°´ ³¤«¸ ¯±®³¤¢³¤£ȁ 6. Hazardous Materials 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² FAC-6. - ¦¤ ³§¤ ´²¤Ǿ ²³®± ¦¤Ǿ £¨²¢§ ±¦¤Ǿ ®± £¨²¯®² « ®¥ ¯®««´³ ³² £ § ¹ ±£®´² ®± ³®·¨¢ ²´¡²³ ¢¤² ¦¤¤± ³¤£ ¡¸ ³§¤ ¥ ¢¨«¨³¸ ¨ ¢®¬¯«¨ ¢¤ ¶¨³§ ¯¯«¨¢ ¡«¤ ±¤¦´« ³¨®² £ requirements. %²´±¤ ³§ ³ «« ¤¬¯«®¸¤¤² ¨µ®«µ¤£ ¨ ³§¤ ´²¤Ǿ ²³®± ¦¤Ǿ ³± ²¯®±³ ³¨®Ǿ £ £¨²¯®² « ®¥ § ¹ ±£®´² ¬ ³¤±¨ «² ±¤¢¤¨µ¤ ¯±®¯¤± ³± ¨¨¦ȁ ,¨¬¨³ ³§¤ ¢°´¨²¨³¨®Ǿ ²³®± ¦¤Ǿ £ ´²¤ ®¥ § ¹ ±£®´²Ǿ ³®·¨¢Ǿ £ ¤·³±¤¬¤«¸ § ¹ ±£®´² ²´¡²³ ¢¤² ³® ®«¸ ³§®²¤ ¤¢¤²² ±¸ £ ¢®²¨²³¤³ ¶¨³§ ¬¨²²¨® ±¤°´¨±¤¬¤³²ȁ 2¤²¯®£ ³® § ¹ ±£®´² ¬ ³¤±¨ «² ±¤«¤ ²¤² ®± ²¯¨««² ´²¨¦ ³§¤ ¤²³ ¡«¨²§¤£ ²¨³¤-²¯¤¢¨¥¨¢ ¢®³¨¦¤¢¸ ¯« ¥®± ¨¢¨£¤³ « ±¤«¤ ²¤² £ %¬¤±¦¤¢¸ 2¤²¯®²¤ 0« Ǿ ¶§¤±¤ ¯¯«¨¢ ¡«¤Ǿ ¥®± « ±¦¤± ±¤«¤ ²¤²ȁ 4± ¨ ¤¬¯«®¸¤¤² ³® ´£¤±²³ £ ³§¤²¤ ¯« ²ǿ ³§¤ ¬ ³¤±¨ «² ¨µ®«µ¤£ǿ £ ³§¤¨± ±¤²¯®²¨¡¨«¨³¨¤² ¥®± ² ¥¤³¸Ǿ ®³¨¥¨¢ ³¨®Ǿ ¢®³ ¨¬¤³Ǿ £ ±¤¬®µ «ȁ 0±®µ¨£¤ £¤°´ ³¤ ¢®¬¬´¨¢ ³¨® ³® «« £®¶²³±¤ ¬ ¶ ³¤± ´²¤±²Ǿ ²´¢§ ² ¬´¨¢¨¯ « £±¨ª¨¦ ¶ ³¤± ¯±®µ¨£¤±² £ ¥¨²§ § ³¢§¤±¨¤²Ǿ ² ¤¢¤²² ±¸ȁ %²´±¤ ³§ ³ § ¹ ±£®´² ²¯¨«« ª¨³² ±¤ £¤°´ ³¤«¸ ²³®¢ª¤£ ¶¨³§ ¤¢¤²² ±¸ ²´¯¯«¨¤² £ ±¤ ¬ ¨³ ¨¤£ ¨ ¢¢¤²²¨¡«¤ «®¢ ³¨®²ȁ Stream Crossings 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² Road-7. 5²¤ ²´¨³ ¡«¤ ¬¤ ²´±¤² ³® µ®¨£Ǿ ¬¨¨¬¨¹¤Ǿ ®± ¬¨³¨¦ ³¤ £ ¬ ¦¤ ³® ³§¤ ¶ ³¤±¡®£¸ £ ¡ ª² ¶§¤ ³± ²¯®±³¨¦ ¬ ³¤±¨ «² ¢±®²² ³§¤ ¶ ³¤±¡®£¸ ®± !-: £´±¨¦ ¢®²³±´¢³¨® ¢³¨µ¨³¨¤²ȁ 2¤¦´« ±«¸ ¨²¯¤¢³ ¢´«µ¤±³² £ ¢«¤ ² ¤¢¤²² ±¸ȁ 0±®µ¨£¤ ¥®± ²´¥¥¨¢¨¤³ ¢±®²² £± ¨ ¦¤ ³® ¬¨¨¬¨¹¤ ¢§ ¦¤² ³®Ǿ £ µ®¨£ ±¤²³±¨¢³¨¦Ǿ ³´± « ²´±¥ ¢¤ £ ²´¡²´±¥ ¢¤ ¶ ³¤± ¥«®¶ ®¥ ³§¤ ¶¤³« £ ´£¤± ³§¤ ±® £ ³® ³§¤ ¤·³¤³ ¯± ¢³¨¢ ¡«¤ȁ o Avoid or minimize actions that would significantly alter the natural drainage for flow patterns on lands immediately adjacent to wetlands. 10. Low-Water Crossings 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² Road-7. #®²¨£¤± «®¶-¶ ³¤± ¢±®²²¨¦² ® ±® £² ¶¨³§ «®¶ ³± ¥¥¨¢ µ®«´¬¤ £ ²«®¶ ²¯¤¤£²Ǿ £ ¶§¤±¤ ¶ ³¤± £¤¯³§ ¨² ² ¥¤ ¥®± µ¤§¨¢«¤ ³± µ¤«ȁ )²³ «« £ ±¤¬®µ¤ ³¤¬¯®± ±¸ ¢±®²²¨¦ ²³±´¢³´±¤² ¨ ³¨¬¤«¸ ¬ ¤± ² ¤¤£¤£ ³® ¯±®µ¨£¤ ¢¢¤²² £´±¨¦ ´²¤ ¯¤±¨®£² £ ¬¨¨¬¨¹¤ ±¨²ª ®¥ ¶ ²§®´³ȁ #®²¨£¤± ´²¨¦ ³¤¬¯®± ±¸ ¢±®²²¨¦² ® ±® £² ³§ ³ ¯±®µ¨£¤ ²§®±³-³¤±¬ ®± ¨³¤±¬¨³³¤³ ¢¢¤²² ³® µ®¨£Ǿ ¬¨¨¬¨¹¤Ǿ ®± ¬¨³¨¦ ³¤ ¤±®²¨®Ǿ £ ¬ ¦¤ ³® ²³±¤ ¬¡¤£ ®± ¢§ ¤«Ǿ £ ¥«®®£¨¦ȁ #®²¨£¤± «®¶-¶ ³¤± ¢±®²²¨¦² ³® ¢±®²² ¤¯§¤¬¤± « ²³±¤ ¬²Ǿ ²³±¤ ¬² ¶¨³§ ±¤« ³¨µ¤«¸ «®¶ ¡ ²¤¥«®¶ £ ²§ ««®¶ ¶ ³¤± £¤¯³§ ®± ²³±¤ ¬² ¶¨³§ §¨¦§«¸ µ ±¨ ¡«¤ ¥«®¶² ®± ¨ ±¤ ² ¯±®¤ ³® « £²«¨£¤² ®± £¤¡±¨² ¥«®¶²ȁ 11. Parking and Staging Areas 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² Road-9. ,¨¬¨³ ³§¤ ²¨¹¤ £ ¤·³¤³ ®¥ ³¤¬¯®± ±¸ ¯ ±ª¨¦ ®± ²³ ¦¨¦ ±¤ ²ȁ o Take advantage of existing openings, sites away from waterbodies, and areas that are apt to be more easily restored to the extent practicable. o Use temporary stormwater and erosion control measures as needed. o Use applicable practices of Fac-10 (Facility Site Reclamation) to rehabilitate temporary parking or staging areas as soon as practicable following use. o If feasible, do not stage or park equipment in areas with invasive plant species. 12. Equipment Refueling and Servicing 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² Road-10. 0« ¥®± ²´¨³ ¡«¤ ¤°´¨¯¬¤³ ±¤¥´¤«¨¦ £ ²¤±µ¨¢¨¦ ²¨³¤² £´±¨¦ ¯±®©¤¢³ £¤²¨¦ȁ o Allow temporary refueling and servicing only at approved locations, located well away from the AMZ, groundwater recharge areas, and waterbodies. 0±®µ¨£¤ ³± ¨¨¦ ¥®± «« ¦¤¢¸ ¯¤±²®¤« § £«¨¦ ¥´¤«² £ ¢§¤¬¨¢ «² ¨ ³§¤¨± ¯±®¯¤± ´²¤Ǿ § £«¨¦Ǿ ²³®± ¦¤Ǿ £ £¨sposal. o Ensure that contractors and permit holders provide documentation of proper training in handling hazardous materials. 5²¤ ²´¨³ ¡«¤ ¬¤ ²´±¤² ³® µ®¨£ ²¯¨««¨¦ ¥´¤«²Ǿ «´¡±¨¢ ³²Ǿ ¢«¤ ¤±²Ǿ £ ®³§¤± ¢§¤¬¨¢ «² £´±¨¦ § £«¨¦ £ ³± ²¯®±³¨¦ȁ Prohibit¤·¢¤²² ¢§¤¬¨¢ «² ®± ¶ ²³¤² ¥±®¬ ¡¤¨¦ ²³®±¤£ ®± ¢¢´¬´« ³¤£ ¨ ³§¤ ¯±®©¤¢³ ±¤ ȁ #«¤ ´¯ £ £¨²¯®²¤ ®¥ ²¯¨««¤£ ¬ ³¤±¨ «² ¢¢®±£¨¦ ³® ²¯¤¢¨¥¨¤£ ±¤°´¨±¤¬¤³² ¨ ³§¤ ¯¯±®¯±¨ ³¤ ¦´¨£¨¦ £®¢´¬¤³ȁ 0±¤¯ ±¤ £ ¨¬¯«¤¬¤³ ¢¤±³¨¥¨¤£ 3¯¨«« 0±¤µ¤³¨®Ǿ #®³±®«Ǿ £ #®´³¤±¬¤ ²´±¤ 0« ¥®± ¤ ¢§ ¥ ¢¨«¨³¸Ǿ ¨¢«´£¨¦ ¬®¡¨«¤ £ ¯®±³ ¡«¤ ¥ ¢¨«¨³¨¤²Ǿ ² ±¤°´¨±¤£ ¡¸ ¥¤£¤± « ±¤¦´« ³¨®²ȁ 2¤¯®±³ ²¯¨««² £ ¨¨³¨ ³¤ ²´¨³ ¡«¤ ¢«¤ ´¯ ¢³¨® ¨ ¢¢®±£ ¢¤ ¶¨³§ ¯¯«¨¢ ¡«¤ 3³ ³¤ £ ¥¤£¤± « « ¶²Ǿ ±´«¤²Ǿ £ ±¤¦´« ³¨®²ȁ o Remove contaminated soil and other material from NFS lands and dispose of this material in a manner consistent with controlling regulations. Erosion Prevention and Control 4§¨² ¬¤ ²´±¤ ¨² ±¤¥¤±±¤£ ³® ¨ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ¦´¨£ ¢¤ ² Veg-2. %²³ ¡«¨²§ £¤²¨¦ ³¤£ ±¤ ² ¥®± ¤°´¨¯¬¤³ ²³ ¦¨¦ £ ¯ ±ª¨¦ ³® ¬¨¨¬¨¹¤ ³§¤ ±¤ ®¥ ¦±®´£ £¨²³´±¡ ¢¤ Ȩ²¤¤ Road-9 Ȭ0 ±ª¨¦ 3¨³¤² £ 3³ ¦¨¦ !±¤ ²ȭȩȁ 0±®µ¨£¤ £ ¯¯«¸ ³§¤ ¤±®²¨® ¢®³±®« ¬ ³¤±¨ «²Ǿ ¨¢«´£¨¦ ²¤¤£Ǿ ¯« ³¨¦²Ǿ ¬´«¢§Ǿ ¶ ³³«¤²Ǿ £ ¥¨¡¤± ¬ ³²Ǿ ² ²¯¤¢¨¥¨¤£ ¡¸ ³§¤ &®±¤²³ 3¤±µ¨¢¤ ®± ¯¯±®µ¤£ ¨ ´ « ¬¤¤³¨¦²ȁ #®¥®±¬ ³® ¯¯«¨¢ ¡«¤ ¬ ´¥ ¢³´±¤±Ȍ² ²³ £ ±£² ¨ ¯¤±¥®±¬¨¦ µ¤¦¤³ ³¨® ¤²³ ¡«¨²§¬¤³ ³±¤ ³¬¤³² ¶§¤ ³§¤ ¦±®´£ ¨² ®³ ¥±®¹¤ ®± ¤·¢¤²²¨µ¤«¸ £±¸ȁ 4§¤ 5³¨«¨³¸ ¶¨«« ²´²¯¤£ ¯¯«¨¢ ³¨® ®¯¤± ³¨®² £´±¨¦ ¯¤±¨®£² ¶§¤ ¶¨£Ǿ ¯±¤¢¨¯¨³ ³¨®Ǿ ®± ®³§¤± ¥ ¢³®±² ±¤ «¨ª¤«¸ ³® ¢ ´²¤ ¨¢®²¨²³¤³ ³±¤ ³¬¤³ ± ³¤² ®± ¨¤¥¥¤¢³¨µ¤ µ¤¦¤³ ³¨® ¤²³ ¡«¨²§¬¤³ȁ 5²¤ ²´¨³ ¡«¤ ²¯¤¢¨¤² £ ¤²³ ¡«¨²§¬¤³ ³¤¢§¨°´¤² ³® ¢®µ¤± ®± ±¤µ¤¦¤³ ³¤ £¨²³´±¡¤£ ±¤ ² ¨ ¢®¬¯«¨ ¢¤ ¶¨³§ &®±¤²³ £¨±¤¢³¨® £ ±¤°´¨±¤¬¤³² ¯¤± &3- ΑΏΖΏ £ &3- ΑΏΗΏ ¥®± µ¤¦¤³ ³¨® ¤¢®«®¦¸ £ ¯±¤µ¤³¨® £ ¢®³±®« ®¥ ¨µ ²¨µ¤ ²¯¤¢¨¤²ȁ 5²¤ ²´¨³ ¡«¤ ¬¤ ²´±¤² ¨ ¢®¬¯«¨ ¢¤ ¶¨³§ &®±¤²³ £¨±¤¢³¨® ³® ¯±¤µ¤³ £ ¢®³±®« ¨µ ²¨µ¤ species. )²³ «« ²¤£¨¬¤³ £ ²³®±¬¶ ³¤± ¢®³±®«² ¡¤¥®±¤ ¨¨³¨ ³¨¦ ²´±¥ ¢¤-£¨²³´±¡¨¦ ¢³¨µ¨³¨¤² ³® ³§¤ ¤·³¤³ ¯± ¢³¨¢ ¡«¤ȁ 2¤¥¤± ³® 3³ ³¤ ®± «®¢ « ¥®±¤²³±¸ ®± ²¨«µ¨¢´«³´±¤ "-0 ¬ ´ «²Ǿ ¦´¨£¤¡®®ª²Ǿ £ ³± £¤ ¯´¡«¨¢ ³¨®² ¥®± ¤¥¥¤¢³¨µ¤ ²³±´¢³´± « £ ®²³±´¢³´± « ¬¤ ²´±¤² ³®— o Apply soil protective cover on disturbed areas where natural revegetation is inadequate to prevent accelerated erosion before the next growing season. o Maintain the natural drainage pattern of the area wherever practicable. o Control, collect, detain, treat, and disperse stormwater runoff from disturbed areas. o Divert surface runoff around bare areas with appropriate energy dissipation and sediment filters. o Stabilize steep excavated slopes. /¯¤± ³¤ ¤°´¨¯¬¤³ ¶§¤ ²®¨« ¢®¬¯ ¢³¨®Ǿ £¨²¯« ¢¤¬¤³Ǿ ¤±®²¨®Ǿ £ ²¤£¨¬¤³ ±´®¥¥ ¶®´«£ ¡¤ ¬¨¨¬¨¹¤£ȁ o Avoid ground equipment operations on unstable, wet, or easily compacted soils and on steep slopes unless operation can be conducted without causing excessive rutting, soil puddling, or runoff of sediments directly into waterbodies. o Evaluate site conditions frequently to assess changing conditions. !£©´²³ ¤°´¨¯¬¤³ ®¯¤± ³¨®² ² ¤¢¤²² ±¸ ³® ¯±®³¤¢³ ³§¤ ²¨³¤ ¶§¨«¤ ¬ ¨³ ¨¨¦ ¤¥¥¨¢¨¤³ ¯±®©¤¢³ ®¯¤± ³¨®²ȁ - ¨³ ¨ ¤±®²¨® £ ²³®±¬¶ ³¤± ¢®³±®«² ² ¤¢¤²² ±¸ ³® ¤²´±¤ ¯±®¯¤± £ ¤¥¥¤¢³¨µ¤ functioning. 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Box 770000 San Francisco, CA 94177 September 14, 2020 Via Electronic Submittal (E-File) Mr. Frank Blackett, P.E., Regional Engineer Federal Energy Regulatory Commission Division of Dam Safety and Inspections 100 First Street, Suite 2300 San Francisco, CA 94105-3084 RE: Bucks Creek-Grizzly Hydroelectric Project, FERC No. 619-CA Notification of Grizzly Tap Conductor Removal Dear Mr. Blackett: This letter notifies the Federal Energy Regulatory Commission (FERC) of Pacific Gas and plans to remove asingle span of the Grizzly Tap conductor, part of the Bucks Creek-Grizzly Project, FERC No. 619, to address a potential residual public safety risk associated with the line. PG&E and the City of Santa Clara, aka Silicon Valley Power (SVP), are joint licensees of the Bucks Creek-Grizzly Project (FERC No. 619). The 22 MW Grizzly Powerhouse is owned by SVP and connects to Caribou-Palermo 115 kV line via the 4.2-mile- long, 115 kV Grizzly Tap. Shortly after the Camp Fire in December 2018, PG&E committed to de-energize the 56-mile-long Caribou-Palermo line. That de-energization is now permanent. Since that time, PG&E has identified a potential residual public safety risk associated with the de-energized line, determining that energized lines in the same vicinity as the Caribou-Palermo line may have the potential to induce voltage and current on to the Caribou-Palermo line through induction, despite its de-energized state. Given the potential for the out-of-service Caribou-Palermo line to carry voltage induced by nearby energized lines, PG&E has taken immediate steps to mitigate this risk by isolating and grounding sections of the line itself and working towards removing the conductor altogether. PG&E has notified the court overseeing its probation, its Federal Monitor, the California Public Utilities Commission, and the Butte County District Attorney of the situation and mitigation efforts underway. Mr. Frank L. Blackett, P.E., Regional Engineer September 14, 2020 Page 2 As part of this process, it was determined that the interconnection of the Grizzly Tap with the Caribou-Palermo line may also have the potential to induce voltage and current on the Caribou-Palermo line. To remediate this risk, PG&E will remove the single span (~900 feet) of the Grizzly Tap conductor between tower 004/002 (in the Bucks Creek Substation Yard) and wooden poles 004/003A, B and C (on the Caribou-Palermo line). Helicopters will be utilized in order to avoid ground disturbance. Once the conductor has been removed, the tops of the interconnect poles (004/003A, B and C) will be flown to an off-site landing zone. The bases will be removed during the decommissioning of the Caribou- Palermo line. Similarly, the lattice tower at the Bucks Creek Substation Yard will also remain in place at this time and is scheduled to be removed as part of a future construction project within the Bucks Creek Substation. Therefore, there will be no ground disturbance associated with the removal of the single span of conductor. The following provides a more detailed workplan for the removal of the Grizzly Tap conductor, as depicted on Figure 1 below; the FERC boundary is marked in red: 1) De-energize Bucks Creek 1101 distribution line and ground at Bucks Creek Substation Yard. 2) Report on the Caribou-Palermo 115-kV and ground at tower 004/002 (lattice tower on east side of river in Bucks Creek Substation Yard). 3) Fly to tower structures :018/148 and :018/149 (located on the Caribou-Palermo line near the interconnection with the Grizzly Tap) and ground 115-kv. 4) Using a helicopter long line, remove jumpers at 004/003A, B, and C (wooden poles located at the interconnection of Grizzly Tap and the Caribou-Palermo line). 5) Set up flagging on Highway 70 and close one lane. 6) Set up a bucket truck in the other lane and let conductor off from 004/002 with rope. 7) Stop traffic when conductor gets close to the bucket and cut it down both ways, one wire at a time. 8) Climb the poles at 004/003A, B, and C and let the remaining wire to the ground. 9) Connect a long sling to the tops of the old poles, climb down, and hook the sling to a helicopter. 10) Cut the old pole five feet above ground and let the helicopter take it off site to the landing zone. 11) Roll up wire down the hill and across the river. 12) Remove grounds and energize the Bucks Creek 1101 distribution line. Mr. Frank L. Blackett, P.E., Regional Engineer September 14, 2020 Page 3 Figure 1 Grizzly Tap Removal and Associated Features Removal of the Grizzly Tap conductor will be performed by PG&E transmission line crews and overseen by a PG&E Construction Manager. All labor, materials and tools/equipment will be transported via established roadways and maintained on hard surfaces. The work will not require any adjustments to normal dam or powerhouse operations. Due to the safety concerns discussed above, PG&E plans to expedite and perform this work as soon as possible and should be completed within one day. The single span affects both PG&E and Plumas National Forest lands. Therefore, PG&E has also been coordinating with the Plumas National Forest in accordance with its Master Programmatic Easement (Plumas MPE) on all mitigation work performed on Forest Service lands. In accordance with the Plumas MPE, PG&E conducted a desktop review of biological and cultural resources. Plumas MPE data layers did not identify any resources of concern that might be affected by the removal of a single span of conductor with no associated ground disturbance. The work will occur outside of nesting bird season. In accordance with the Plumas MPE, Attachment 3 (enclosed), applicable standard best management practices will be included in the release to construction. Mr. Frank L. Blackett, P.E., Regional Engineer September 14, 2020 Page 4 Based on , PG&E believes that the proposed work does not require formal FERC review and authorization to proceed. However, if the FERC needs additional information or has concerns regarding this work, please inform PG&E immediately. Otherwise, PG&E will proceed with the work as planned. continued support of this work. Should you have any questions concerning this matter, please contact PG&E's senior license coordinator, Jamie Visinoni, at JNVS@pge.com. Sincerely, Elisabeth Rossi Supervisor, Hydro Licensing Enclosure: Plumas MPE Best Management Practices O CTOBER 9, 2020 PG&E TO FERC 245 Market Street tƚǞĻƩ DĻƓĻƩğƷźƚƓ San Francisco, CA 94105 Mailing Address: Mail Code N11D P.O. Box 770000 San Francisco, CA 94177 October 9, 2020 Via Electronic Submittal (E-File) Mr. Frank Blackett, P.E., Regional Engineer Federal Energy Regulatory Commission Division of Dam Safety and Inspections 100 First Street, Suite 2300 San Francisco, CA 94105-3084 RE: Bucks Creek-Grizzly Project, FERC No. 619-CA 18 CFR § 12.11 Report of Modifications of Project Works Dear Mr. Blackett: This letter notifies the Federal Energy Regulatory Commission (FERC) of Pacific Gas and plans to modify a portion of the Grizzly Tap, part of the Bucks Creek Project, FERC No. 619, by removing temporarily an approximately 300-foot span of the Grizzly Tap conductor, removing an existing lattice tower in the Bucks Creek substation yard, and installing temporary guy wires to prepare for an upcoming project to re-establish the transmission of power to the City of Santa Clara. Background PG&E and the City of Santa Clara, aka, Silicon Valley Power (SVP), are joint licensees of the Bucks Creek Project (FERC No. 619). The 22 MW Grizzly Powerhouse is owned by SVP and previously delivered power to the grid at Caribou-Palermo 115 kV line via the 4.2-mile-long, 115 kV Grizzly Tap. Shortly after the Camp Fire in December 2018, PG&E committed to de-energize the 56-mile-long, Caribou-Palermo line. PG&E has determined that the most expeditious plan to reconnect the Grizzly Powerhouse to the grid is to interconnect the Grizzly Tap to the existing, non-Project Bucks Creek-Cresta 230-kV line located in the Bucks Creek substation yard. The activities proposed herein facilitate preliminary work associated with this reconnection. Project Scope To re-establish the transmission of power , PG&E plans to: 1) add guy wires to three existing poles (004/001A, B and C) located in the existing right- of-way for the Grizzly Tap, to allow those structures to become a temporary dead-ends; 2) temporarily remove an approximate 300-foot-long span of conductor extending from the Mr. Frank L. Blackett, P.E., Regional Engineer October 9, 2020 Page 2 existing lattice tower (004/002) at the Bucks Creek substation yard to the three existing poles (004/001A, B and C); and 3) demolish the existing lattice tower (004/002). Enclosure A provides a schematic of the proposed guy wire installation, which will consist of two to four workers hiking up the existing transmission right-of-way, hand digging new holes, and manually installing anchors with expanding grout backfill. A negligible amount of ground disturbance is expected toremove the existing lattice tower (within the previously disturbed substation yard) and to install the guy wires (within previously disturbed transmission right-of-way). Figure 1 provides a depiction of the Grizzly Tap and associated features discussed above; the FERC boundary is marked in red. CźŭǒƩĻ Њ DƩźǩǩƌǤ ğƦ ğƓķ wĻƌğƷĻķ {ƷƩǒĭƷǒƩĻƭ Environmental Review Temporary removal of the Grizzly Tap conductor will be performed by PG&E transmission line crews and overseen by a PG&E Construction Manager. All labor, materials and tools/equipment will be transported via established roadways and maintained on hard surfaces. The work will not require any adjustments to normal dam or powerhouse operations. The project meets the criteria of a federal undertaking as defined in 36 CFR §800.16(y). As a result, the undertaking must comply with Section 106 of the National Historic Mr. Frank L. Blackett, P.E., Regional Engineer October 9, 2020 Page 3 Preservation Act of 1966, as amended, to consider the effect of the undertaking on any sites, buildings, structures, or objects that are included in or may be eligible for inclusion in the National Register of Historic Places (NRHP). The Bucks Creek Hydroelectric Project Historic District, containing a number of contributing features, is within the Area of Potential Effect (APE). In the proposed APE, the powerhouse and penstock are eligible for inclusion in the NRHP. The transmission yard, garage, and incline are not eligible for inclusion in the NRHP. Additionally, the APE was surveyed for archaeological resources in 2015 during relicensing activities, and there are no archaeological resources within the APE. No alterations will be made to the powerhouse or penstock structures during this work, and thus PG&E has determined, on behalf of FERC, that the proposed work will have no adverse effect to historic properties in the Bucks Creek Hydroelectric Project Historic District. PG&E is currently preparing a consultation package for submission to the State Historic Preservation Officer (SHPO), pursuant to 36 CFR § 800. The proposed work is scheduled to be conducted outside of nesting season and will be contained within the previously disturbed footprint of the existing substation yard and existing right-of-way (guy wire installations) at structure 004/001A, B, and C upslope of the substation yard. All work areas are outside of any bald eagle nest management zones, outside of the range of Sierra Nevada yellow legged frog, and not within habitat for willow flycatcher. Relicensing studies conducted in 2015 did not identify any special status plants or wildlife species in proximity to the work areas. There are known occurrences of the invasive weeds yellow starthistle, Himalayan blackberry, and stinkwort near the bridge, along the access road to Bucks Powerhouse, and near Bucks Powerhouse substation yard. Therefore, in accordance with the Bucks Creek Noxious Weed Management Plan (PG&E 2006), as required by Article 103 of the license, the following measures will be implemented to limit the spread and introduction of invasive weeds: The Licensee or its contractor will ensure that all off-road equipment brought into the area from outside the watershed is free of soil, seeds, vegetative material, or other debris that could contain or hold seeds of noxious weeds. includes all logging, construction, and brushing machinery/equipment (brush hogs, masticators, chippers) except log trucks, chip vans, service vehicles, water trucks, pickup trucks, and similar vehicles not intended for off-road use. Equipment will be considered clean when a visual inspection does not disclose soil, seed, plant material, and other such debris. Disassembly of equipment components or specialized inspection tools will not be required. The Forest Service will be notified at least 5 working days prior to moving off-road equipment onto National Forest System land, unless otherwise agreed. In the case of emergency, the Licensee will notify the Forest Service as soon as possible of the need to bring off-road equipment onto National Forest System lands from outside the watershed. Mr. Frank L. Blackett, P.E., Regional Engineer October 9, 2020 Page 4 operations, the type of equipment cleaning to be used prior to entry into the watershed, and the location where cleaning will be performed. U.S. Forest Service Coordination The single span to be removed temporarily affects both PG&E and Plumas National Forest lands. Therefore, PG&E has also been coordinating with the Plumas National Forest and will implement applicable standard best management practices in accordance with the Plumas Master Programmatic Easement (Plumas MPE) (Enclosure 2). Summary This has been a significant financial burden to the City of Santa Clara and thus is also a high priority for PG&E to re-establish the transmission of power powerhouse by June 2021. Due to this urgency and the tight construction timeline to complete these actions, PG&E respectfully requests that FERC accelerate its review process, under 18 CFR § 12.11, to allow for this work to begin by November 9, 2020. continued support of this work. Should you have any questions concerning this matter, please contact PG&E's senior license coordinator, Jamie Visinoni, at JNVS@pge.com. Sincerely, Elisabeth Rossi Supervisor, Hydro Licensing Enclosures: A: Schematic of Guy Wire Installation B: Plumas MPE Best Management Practices O CTOBER 9, 2020 FERC TO PG&E FEDERAL ENERGY REGULATORY COMMISSION Washington, DC 20426 OFFICE OF ENERGY PROJECTS Project No. 619-169 –California Bucks Creek Hydroelectric Project Pacific Gas and Electric Company October 9, 2020 VIA FERC Service Mr. Jan Nimick, Vice President- Power Generation Pacific Gas and Electric Company 245 Market Street Mail Code: N11E San Francisco, CA 94105 Subject: Information Request Relating to Grizzly Tap Conductor Removal Dear Mr. Nimick: On September 14, 2020, and supplemented October 6, 2020, you filed a letter with the Commission’s Division of Dam Safety and Inspections – San Francisco Regional Office (SFRO) discussing your plans to remove a single span of the Grizzly Tap 12 conductor, part of the Bucks Creek Hydroelectric Project No. 619. You state that following the Camp Fire in 2018, PG&E committed to de- energizing the 56-mile-long Caribou-Palermo line, which has now been completed. The Grizzly Powerhouse connects to the Caribou-Palermo line via the 4.2-mile-long Grizzly Tap. You explain that since de-energizing the Caribou-Palermo line, you have identified a potential public safety risk associated with the de-energized line, determining that energized lines in the same vicinity as the Caribou-Palermo line may still have the potential to induce voltage and current on to the Caribou-Palermo line through induction. Given this risk, you state that you took immediate mitigation steps by isolating and grounding sections of the Caribou-Palermo line itself. 1 Your September 14 and October 6, 2020 filings are also available on the Commission’s eLibrary system (FERC Accession Numbers: 20200914-5150, and 20201006-5144). 2 Pacific Gas and Electric Company, 52 FPC 1898 (1974). Project No. 619-169 - 2 - To remediate the risk specifically associated with the Grizzly Tap interconnection, you state in your September 14 filing that you plan on removing a single span of the Grizzly Tap conductor, stretching approximately 900 feet, between the Bucks Creek Substation Yard and wooden poles on the Caribou-Palermo line. In your September 14 filing you provide a detailed proposed workplan for the removal of the single span of the Grizzly Tap conductor and explain that there would be no ground disturbance associated with the removal because you will use helicopters to perform the removal. In your October 6 filing you describe how you will re-establish the transmission of power from the Grizzly Powerhouse, which will involve ground disturbing activities. We are aware that prior to your September 14, 2020 filing, you were in communication with Commission staff via email and phone, regarding the steps that would be required to complete the transmission line removal. On July 31, and August 7, 2020, Commission staff informed you that removal of the transmission line would require an application for amendment of the project license. This is because the transmission line is a project feature, and as such, the proposed action would require an amendment pursuant to 18 C.F.R. §4.200 (2020). However, in your September 14, 2020 filing, you state that you do not believe that the proposed work requires formal Commission review and authorization. Nevertheless, you failed to notify and report the emergency to the San Francisco Regional Engineer as required under part 12.10(a) of the Commission’s regulations. You state that if the Commission needs additional information or has concerns regarding this work, that you should be informed. th It has come to our attention that the work proposed in your September 14letter has since been mostly completed, unauthorized by neither the Commission’s SFRO or Division of Hydropower Administration and Compliance; as such, it may be considered a 3 violation of your license and made part of the compliance history of the project. Given the initial steps you describe taking to mitigate the potential risk, and the previous indication by Commission staff that such work would require an amendment, within 45 days from the date of this letter, please file: an amendment application, for Commission approval, for the work described in the September 14 and October 6, 2020 letters; a specific description of what has taken place regarding the work proposed; what other options were available to you; and an explanation of why the work was done without waiting for Commission approval of a license amendment or a response to your th September 14 letter. 3 On September 17, 2020, Commission staff spoke with your Supervisor of Hydro licensing, who informed staff that the aforementioned electrical line had been removed. Project No. 619-169 - 3 - Thank you for your cooperation. If you have any questions regarding this letter, please contact Korede Olagbegi at (202) 502-6268 or Korede.Olagbegi@ferc.gov. Sincerely, Kelly Houff Chief, Engineering Resources Branch Division of Hydropower Administration and Compliance O CTOBER 20, 2020 PG&E TO FERC tƚǞĻƩ DĻƓĻƩğƷźƚƓ 245 Market Street San Francisco, CA 94105 Mailing Address: Mail Code N11D P.O. Box 770000 San Francisco, CA 94177 October 20, 2020 Via Electronic Submittal (E-File) Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission st 888 1 Street NE Washington, DC 20426 RE: Bucks Creek-Grizzly Hydroelectric Project (FERC No. 619) Request for Designation as Non-Federal Representative for Section 106 Consultation for the Grizzly Powerhouse Reconnection Project Dear Secretary Bose: Pacific Gas and Electric Company (PG&E) operates the Bucks Creek-Grizzly Hydroelectric Project (FERC No. 619) (Project) located within Plumas County, CA. In accordance with 36 C.F.R. 800.2(c)(4), PG&E requests the Federal Energy Regulatory Commission (FERC) designate PG&E as the non-federal representative for purposes of consultation pursuant to Section 106 of the National Historic Preservation Act to allow PG&E to consult with the California State Historic Preservation Office (SHPO), federal agencies, and tribes, as appropriate, with respect to proposed activities associated with the Grizzly Powerhouse Reconnection Project. Proposed activities include installation of guy wires to three existing poles (004/001A, B and C) located in the existing right-of-way for the Grizzly Tap; temporary removal of approximately 300-ft of conductor extending from lattice tower (004/002) to the three existing poles (004/001A, B and C); demolition of the existing lattice tower (004/002), a telecom cabinet, an 11 kV bus section, 12 kV CTs; demolition of abandoned foundations, concrete culverts, trenches, conduits, cables, and fencing; and construction of new foundations, oil spill containment equipment, and placement of new 230kV/115kV transformer, new 115kV and 230kV breakers, the new conductor, and related equipment. PG&E proposes to begin preliminary work (installation of guy wires, temporary removal of a 300-foot span of wire, and removal of tower 004/002) on November 9, 2020, and anticipates demolition of the remaining foundations and fencing by mid-December. Foundation and underground work is scheduled for thewinter of 2021 in expectation of the arrival and installation of the new 115/230 kV transformer in February 2021. Conductor and other electrical installations will be completed in the spring of 2021 with the goal of having all testing complete and the Grizzly Powerhouse reconnected to the grid by June 2021. Ms. Kimberly D. Bose, Secretary October 20, 2020 Page 2 Given the anticipated schedule for proposed activities associated with the Grizzly Powerhouse Reconnection Project, PG&E respectfully requests expeditious consideration of this request. Should you have any questionsSenior Cultural Resources Specialist, Kathleen Forrest, at (916) 899-1365. Sincerely, Elisabeth Rossi Supervisor, Hydro Licensing