HomeMy WebLinkAbout07.06.21 FW_ Project Operations Compliance Report submitted in FERC P-803-000 by Pacific Gas and Electric Company,et al.
From:Clerk of the Board
To:Alpert, Bruce;Bennett, Robin;Clerk of the Board;Connelly, Bill;Cook, Holly;Cook, Robin;Hironimus, Patrizia;Kimmelshue, Tod;Lucero, Debra;Paulsen, Shaina;Pickett, Andy;Reaster, Kayla;Ring,
Brian;Ritter, Tami;Sweeney, Kathleen;Teeter, Doug
Subject:FW: Project Operations Compliance Report submitted in FERC P-803-000 by Pacific Gas and Electric Company,et al.
Date:Tuesday, July 6, 2021 4:00:07 PM
Please see below correspondence.
Kayla Reaster, MBA, MAED
Associate Clerk of the Board
Butte County Administration
25 County Center Drive, Suite 200, Oroville, CA 95965
T: 530.552.3308 | F: 530.538.7120
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From: 'FERC eSubscription' <eSubscription@ferc.gov>
Sent: Tuesday, July 6, 2021 3:55 PM
Subject: Project Operations Compliance Report submitted in FERC P-803-000 by Pacific Gas and Electric Company,et al.
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On 7/6/2021, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.:
Filer: Pacific Gas and Electric Company
Pacific Gas & Electric Company (as Agent)
Docket(s): P-803-000
Lead Applicant: Pacific Gas and Electric Company
Filing Type: Project Operations Compliance Report
Description: Pacific Gas and Electric Company submits Follow-up Report on Minimum Instream Flow Deviation at Philbrook Reservoir for DeSabla-Centerville Hydroelectric Project
under P-803.
To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20210706-
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July 6, 2021
Via Electronic Submittal (E-File)
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N. E.
Washington, D.C. 20426
RE: DeSabla-Centerville Hydroelectric Project, FERC No. 803
Report on Minimum Instream Flow Deviation at Philbrook Reservoir
Dear Secretary Bose:
This letter provides the Federal Energy Regulatory Commission (FERC) with Pacific Gas
-up report of a minimum instream flow (MIF)
deviation that occurred downstream of PG&E's DeSabla-Centerville Hydroelectric Project
(Project), FERC No. 803. The deviation occurred from May 13, 2021 through June 1, 2021,
as measured below the Philbrook Reservoir. The deviation was reported to FERC's San
Francisco Regional Office via email to John Aedo on June 3, 2021 (Enclosure A).
License Requirements
Philbrook Reservoir License Article 39 requires that the licensee (PG&E) maintain
instantaneous minimum flows of two cubic feet per second (cfs) from Philbrook Reservoir
during standard asset operation.
Event and Discussion
Philbrook Reservoir releases provide essential inter-basin water transfer from the West
Branch Feather River to Butte Creek, which harbors the largest remaining population of
Central Valley spring-run Chinook salmon (CVSRCS) (Oncorhynchus tshawytshca) listed
as threatened under the state and federal endangered species acts. PG&E has
maintained an agreement with several interested government and environmental
agencies to annually plan water management activities to benefit the CVSRCS population
in Butte Creek. PG&E regularly coordinates water releases, actions for addressing water
year classification needs, water storage requirements, etc. in support of the CVSRCS in
Butte Creek and in collaboration with the DeSabla Area interested agencies.
and
was attended by interested government agencies. Agreement on minimum instream flow
changes to Philbrook Reservoir, Hendricks Head Dam, and Butte Creek Head Dam were
outcomes from this meeting. Hendricks Head Dam and Butte Creek Head Dam minimum
Kimberly D. Bose, Secretary
July 6, 2021
Page 2
instream flow (MIF) changes were a result of dry water year classification requirements
and do not need FERC approval prior to implementation. Changes to Philbrook Reservoir
MIF requires submission of a variance request and FERC approval prior to
implementation.
Due to an internal communications error, on May 13, 2021 all three of the flow changes
discussed during the annual DeSabla Area Operations meeting were implemented,
including the water year classification changes at Hendricks and Butte Creek Head Dams
and the proposed MIF variance at Philbrook Reservoir.
PG&E personnel identified the unapproved MIF rate reduction on June 1, 2021 during
normal data collection/review processes. Review of the Philbrook Reservoir MIF data
confirmed that flow rates were reduced on May 13, 2021 through June 1, 2021. Table 2
below provides an overview of the Philbrook Reservoir discharge in cfs from May 2, 2021
through June 3, 2021.
Table 1: Philbrook Reservoir Discharge in cfs from 5/2/2021 through 6/3/2021:
Root Cause and Corrective Action
When it was discovered that a communication error led to this under-release, PG&E
implemented an apparent cause evaluation (ACE). The ACE team has interviewed staff
and reviewed internal correspondence. A requirement to route FERC-approved variances
throug
implemented before this process is complete. The ACE is scheduled to be completed on
July 15, 2021.
Biological Evaluation
A qualified PG&E biologist has reviewed this deviation and evaluated the potential for
adverse effects to aquatic resources in the reach downstream of Philbrook Reservoir. After
a review of available information, the PG&E biologist has concluded that it is unlikely the
event had any significant impact given the under release was less than one cfs and the
Kimberly D. Bose, Secretary
July 6, 2021
Page 3
channel remained wetted sufficient to support aquatic life. Furthermore, the MIF reduction
from Philbrook Reservoir was supported by DeSabla Area interested agencies in the
proposed variance request to FERC and is intended to support the large population of
CVSRCS in Butte Creek. The MIF reduction would conserve water for release later in the
summer months when naturally higher ambient air and water temperatures in Butte Creek
increase stress and mortality before the CVSRCS population has an opportunity to
complete their life cycle.
On June 10, 2021, PG&E held the 2021 DeSabla-Centerville Operations and Maintenance
Plan Meeting with California Department of Fish and Wildlife (CDFW), the United States
Fish and Wildlife Service (USFWS), the United States Forest Service (USFS), and
National Marine Fisheries Service (NMFS), and the State Water Resources Control Board
(SWRCB) (Hereafter Agencies). At this meeting it was shared that the potential MIF
deviation described in this report had occurred, the agencies had no questions or concerns
that were shared with PG&E.
Summary
PG&E has created safeguards in the current Project flow compliance interface to prevent
such errors in the future. PG&E personnel took actions to increase flows at Lake Philbrook
as soon as the deviation was discovered. Due to the short duration of the deviation and the
small under release (less than 1 cfs), no adverse effects to aquatic species were noted nor
expected.
license coordinator, Jackie Pope, at
530-254-4007.
Sincerely,
Teri Smyly
Manager, FERC and DSOD Compliance
Enclosure:
1. June 3, 2021 Email to FERC regarding potential minimum instream flow deviation
ENCLOSURE 1
From:Prentice, Russell
To:Frank Blackett; "John Aedo - FERC SFRO"; Vinh Tran; John Onderdonk
Cc:Nimick, Jan; Zawalick, Maureen; Baldwin, Thomas; Prentice, Russell; Rossi, Elisabeth; Smyly, Teri; Ritzman,
Dave; Van Deuren, Eric; Weber, Ryan; Lindblom, Kelly; Pope, Jackie
Subject:DeSabla Centerville Project (FERC No. 803) - Potential Minimum Instream Flow Deviation
Date:Thursday, June 3, 2021 5:37:25 PM
Dear Mr. Aedo,
As a follow up to our phone conversation, this email provides a courtesy notification of a potential
minimum instream flow (MIF) deviation from Philbrook Reservoir to Philbrook Creek on the DeSabla
Centerville Project (FERC No. 803). Initial review indicates no adverse biological impacts.
The potential deviation occurred from May 13, 2021 to June 1, 2021. PG&E will retrieve data loggers
and review flow data to confirm the MIF deviation as specified by License Article 39 which requires
that the licensee maintain instantaneous minimum flows of 2 cubic feet per second (cfs) from
Philbrook Reservoir during dry water years. Preliminary data indicate MIF from Philbrook Reservoir
dropped to 1.3cfs during this time period. PG&E has initiated a cause evaluation to understand the
causes and establish corrective actions. PG&E plans to file a follow up report with the FERC
Secretary within 30 days from the date of this notification. Please reach out to me if you have any
questions concerning this matter.
Thank you,
Russ Prentice
Pacific Gas and Electric Company
Director, Generation Risk and Compliance
805.550.3775 cell | rnpz@pge.com