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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 Twitter | Facebook | YouTube | Pinterest -----Original Message----- 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. .ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying.. 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. 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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