HomeMy WebLinkAbout04.24.2024 Board Correspondence - FW_ Government Agency Submittal submitted in FERC P-7242-000,et al. by California State Water Resources Control Board,et al.From:Clerk of the Board
To:Bennett, Robin; Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Hancock, LeAnne; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa;
Lee, Lewis; McDonnell, Susan; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug; Zepeda, Elizabeth; Loeser, Kamie
Cc:Nevers, Dawn
Subject:Please see Board Correspondence - FW: Government Agency Submittal submitted in FERC P-7242-000,et al. by California State Water Resources Control Board,et
al.
Date:Thursday, April 25, 2024 8:33:23 AM
Please see Board correspondence -
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Subject: Government Agency Submittal submitted in FERC P-7242-000,et al. by California State Water Resources Control Board,et al.
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On 4/24/2024, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.:
Filer: California State Water Resources Control Board
State Water Resources Control Board (CA) (as Agent)
Docket(s): P-7242-000
P-7242-060
Lead Applicant: STS HydroPower,
Ltd.
Filing Type: Government Agency Submittal
Description: California State Water Resources Control Board submits s Notice of Application for Water Quality Certification for the Removal and
Decommissioning of the Kanaka Powerhouse for the Kanaka Hydroelectric Project under P-7242.
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State Water Resources Control Board
April 23, 2024
Ms. Melissa Rondou
Licensing and Compliance Manager
STS Hydropower, LLC – Affiliates of Eagle Creek Renewable Energy
7315 Wisconsin Avenue, Suite 1100W
Bethesda, MD 20814
Sent via Email: melissa.rondou@eaglecreekre.com
Kanaka Hydroelectric Project License Surrender
Federal Energy Regulatory Commission Project No. 7242
Butte County
Sucker Run Creek
DENIAL WITHOUT PREJUDICE OF REQUEST FOR WATER QUALITY
CERTIFICATION FOR REMOVAL AND DECOMMISSIONING OF KANAKA
POWERHOUSE FOR KANAKA HYDROELECTRIC PROJECT LICENSE
SURRENDER
Dear Ms. Rondou:
On May 12, 2023, the State Water Resources Control Board (State Water Board)
received a water quality certification (certification) application from STS Hydropower,
LLC (STS) for the Removal and Decommissioning of the Kanaka Powerhouse for the
Kanaka Hydroelectric Project (FERC Project No. 7242) License Surrender (License
Surrender Project) pursuant to section 401 of the federal Clean Water Act (CWA)
(33 U.S.C. § 1341). The Kanaka Hydroelectric Project is located on private property
along Sucker Run Creek in Butte County, approximately 15 miles from Oroville,
California. The State Water Board provided public notice of the request for certification
pursuant to California Code of Regulations, title 23, section 3858 on May 26, 2023, by
posting information describing the License Surrender Project to the State Water Board’s
website.
After review of the certification application and other relevant information, the State
Water Board must either: (1) issue an appropriately conditioned certification; or
(2) deny certification. (Cal. Code Regs., tit. 23, § 3859.) The State Water Board may
issue certification if the State Water Board determines that an activity will comply with
applicable water quality standards and other appropriate requirements of state law. The
State Water Board may deny a certification application if compliance with water quality
standards and other appropriate requirements is not determined, but the application
suffers from some procedural inadequacy. (Cal. Code Regs., tit. 23, § 3837,
subd. (b)(2).) The State Water Board may also deny a certification application if the
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Ms. Melissa Rondou April 23, 2024
2
State Water Board has requested supplemental information and the federal period for
certification will expire before the State Water Board has time to receive and properly
review the supplemental information. (Cal. Code Regs., tit. 23, § 3836, subd. (b).)
Additionally, under federal regulations, the certifying authority may grant certification,
grant certification with conditions, deny certification, or expressly waive certification.
(40 C.F.R. § 121.7, subd. (a).) A denial of certification should include a statement
explaining why the certifying authority cannot certify that the activity will comply with
water quality requirements, including but not limited to a description of any missing
water quality-related information if the denial is based on insufficient information.
(40 C.F.R. § 121.7, subd. (e).)
STS has not provided sufficient information to inform a determination that the Project as
proposed will comply with water quality objectives in the Water Quality Control Plan for
the Sacramento River Basin and the San Joaquin River Basin (SR/SJR Basin Plan),
which are designated to protect beneficial uses. The federal review period, which
concludes on May 12, 2024, does not provide adequate time to receive and review the
supplemental information that is needed to inform Project water quality impacts.
(Cal. Code Regs., tit. 23, § 3836, subd. (b).) Consistent with federal regulations, the
certifying authority (State Water Board) cannot certify that the Project will comply with
water quality requirements at this time. (40 C.F.R. § 121.7, subd. (e).)
Background
In 2017, the Ponderosa Fire severely damaged the Kanaka Hydroelectric Project’s
substation, interconnection transmission line and associated power poles, and
powerhouse. As a result, on May 20, 2020, STS decided to surrender the Project’s
Federal Energy Regulatory Commission (FERC) license and to permanently remove the
Project’s hydroelectric generation.
The License Surrender Project, as proposed, includes: (1) removal of remaining Project
infrastructure at the Kanaka powerhouse and substation (i.e., powerhouse structure and
slab, generator and turbine, electrical equipment, substation slab, fencing, etc.);
(2) abandonment of the Kanaka Diversion Dam intake, penstock, and tailrace; and
(3) abandonment of the Kanaka Diversion Dam, including installation of a sand and
gravel plug in the dam’s wet well to prevent dam operations (i.e., diversions to the
penstock) and allow creek flows to flow over the dam or drain through a water level
regulation gate.
Additional Information Requests – Federal Energy Regulatory Commission
On February 14, 2024, FERC issued an Additional Information Request (AIR) to STS
requesting STS: (1) clarify if and when the intake valve and flap gate to the penstock
was closed following the 2017 Ponderosa Fire; (2) clarify the number of penstock leaks;
(3) quantify the extent of erosion caused by penstock leaks as well as the environmental
effect of associated erosion; (4) describe any plans STS may have to remediate erosion
areas; (5) describe any measures taken to prevent petroleum-based products from
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Ms. Melissa Rondou April 23, 2024
3
escaping the powerhouse following the Ponderosa Fire; and (6) provide a plan and
schedule for removal of accumulated sediment from the intake wet well and assurance
that the flap gate remains in the closed position.
With respect to water quality protections, State Water Board staff have overlaping
information needs to those identified in FERC’s February 14, 2024, AIR and are
monitoring the Kanaka Hydroelectric Project’s FERC docket for additional information
submittals from STS.
Additional Information Requests – State Water Board
To inform the License Surrender Project’s certification action as well as environmental
analysis, on October 11, 2023, State Water Board staff attended a site visit and
observed that Sucker Run Creek was being diverted into the penstock. The penstock
had several breaks where staff observed water being discharged into the surrounding
forested area. Staff noted a recent erosion event on a hill slope adjacent to one of the
breaks in the penstock. Additionally, STS staff informed State Water Board staff that the
access road was being changed from an unnamed road located off Utility Road 3 to an
unnamed road located off Sucker Run Road.
Following the site visit, on January 31, 2024, State Water Board staff sent STS a letter
requesting information about ongoing and potential future water quality impacts to
inform the pending certification action. State Water Board staff’s January 31, 2024,
letter requested complete responses by March 1, 2024 (Attachment A: Information
Request for Kanaka Hydroelectric Project License Surrender).
On February 29, 2024, STS provided responses to the State Water Board and FERC’s
requests for additional information. STS’s responses did not provide adequate
information to address the needs identified in State Water Board staff’s
January 31, 2024, letter. In particular, STS’s responses did not provide: (1) information
on the structural integrity of the penstock or potential water quality impacts associated
with the penstock leaks; (2) new data or information related to the oil and grease
observed in the Kanaka Powerhouse maintenance pit; (3) the location of any of the
leaks in the penstock (State Water Board staff identified at least three leaks in the
penstock and it is unclear whether STS has examined the entire exposed length of the
penstock to determine if there are additional leaks); (4) any additional measures that
STS has or will implement to ensure that erosion from the failed culvert system that is
part of the existing access road does not negatively impact water quality; (5) any actions
that STS has or will implement to mitigate slope instability or sediment transport into
Sucker Run Creek; (6) a plan or measures to prevent wildlife and water from accessing
the penstock following dam and penstock abandonment; and (7) quantification of the
amount of sediment entrained in the penstock or any additional details on STS’s
proposed plan to excavate the sediment out of the wet well so that the penstock flap
gate can be closed.
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Ms. Melissa Rondou April 23, 2024
4
The License Surrender Project, as described in STS’s certification application, would
leave many aspects of the existing Kanka Hydroelectric Project in place. The
information provided by STS in its certification application is that the penstock had been
dewatered and the Project would result only in potential discharges from sealing the
intake gate, removing the Kanaka Powerhouse, and any other associated activities
required to accomplish those tasks. However, as described in an STS memo titled
Kanaka Site Work Memo – October 25-26, 2023, Memo (Work Memo), approximately
30 inches of sediment was entrained in the wet well and an unknown amount of
sediment has passed into the penstock as a result of ongoing0F
1 diversions following the
2017 Ponderosa Fire.
Questions remain about potential impacts from the unmanaged diversions and potential
ongoing hillslope instability caused by the penstock leaks. Specifically, State Water
Board staff are unable to determine the structural integrity of the penstock and if
penstock leaks would continue following the License Surrender Project. During the
October 11, 2023 site visit, State Water Board staff and representatives from STS
identified three penstock leaks but were unable to access two of the leaks and did not
walk the entire length of the penstock. In addition, the weight of sediment entrained in
the penstock, which is currently proposed to be abandoned in place, could jeopardize
the structural integrity of the penstock bridge crossing Sucker Run Creek. The penstock
leaks appear to have resulted in erosion with associated water quality impacts and have
the potential to contribute to hillslope instability that could result in ongoing discharges
of sediment, settleable material, suspended material, and turbidity to Sucker Run Creek
that could exceed water quality objectives in the SR/SJR Basin Plan. Increased
sediment inputs from the Kanaka Hydroelectric Project’s remaining unmanaged
infrastructure following decommissioning and license surrender have the potential to
impact aquatic resources and other beneficial uses of Sucker Run Creek. Additional
information regarding existing and potential future discharges from the penstock and
any repairs or other actions proposed to address such discharges are needed to inform
a certification action for the License Surrender Project.
In summary, as described in Attachment A (Board’s January 31, 2024 Information
Request), State Water Board staff requested supplemental information related to
potential ongoing discharges from penstock leaks, access road culvert, and the oil and
grease identified in the Kanaka Powerhouse maintenance pit. This information request
also conveys concerns with sediment remaining in the penstock following
decommissioning that could lead to penstock breaks along the penstock bridge that
could lead to additional discharges. This additional information is needed to inform a
certification action for the License Surrender Project. With consideration of the
outstanding information and review of the information provided in STS’s
February 29, 2024 submittal there remains insufficient information and time remaining
1 In its February 29, 2024 response to a State Water Board information request, STS
states that the consulting firm Northbrook Power Management confirmed that the wet
well intake valve was closed as of September 13, 2017. This was while the Ponderosa
Fire was still active. STS has provided no explanation for how State Water Board staff
found the wet well intake locked in the open position on October 11, 2023.
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Ms. Melissa Rondou April 23, 2024
5
for an informed certification action in the federal review period, which ends on
May 11, 2024. (Cal. Code Regs., tit. 23, § 3836, subd. (b).) Consistent with federal
regulations, the certifying authority (State Water Board) cannot certify that the discharge
from the proposed Project will comply with water quality requirements. (40 C.F.R.
§ 121.7, subd. (a).)
Water Quality Certification Action
Based on available information and the ongoing need for additional information to
inform License Surrender Project related impacts to water quality, STS is hereby
notified that STS’s May 12, 2023 request for certification for the License Surrender
Project is denied without prejudice, effective the date of this letter. The State Water
Board encourages STS to submit a new request for certification once STS has
adequately addressed the Project’s potential to exceed SR/SJR Basin Plan water
quality objectives, which may be accomplished through additional information and/or a
revised project description.
State Water Board staff look forward to working with STS to resolve the State Water
Board’s water quality concerns. Staff will continue to review materials and work with
STS on addressing potential discharges of sediment and other chemical constituents
associated with the Project towards the goal of acting on a future certification request
for the License Surrender Project once the additional information noted in this letter and
its attachment (Attachment A: Information Request for Kanaka Hydroelectric Project
License Surrender) are provided.
If you have questions regarding this letter, please contact Glenn Hoffmann, Kanaka
Hydroelectric Project Manager, by email to: Glenn.Hoffmann@waterboards.ca.gov or
phone call to: (916) 319-9943. Written correspondence should be directed to: State
Water Resources Control Board; Division of Water Rights - Water Quality Certification
Program; Attn: Glenn Hoffmann; P.O. Box 2000; Sacramento, CA 95812-2000.
Sincerely,
Eric Oppenheimer
Executive Director
Enclosure: Attachment A: Information Request for Kanaka Hydroelectric Project
License Surrender (January 31, 2024)
Attachment B: Certificate of Service
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Ms. Melissa Rondou April 23, 2024
6
ec: Debbie-Anne Reese, Acting Secretary
Federal Energy Regulatory Commission
Via efile to FERC Docket
U.S. Environmental Protection Agency
Region 9, Water Division
Email: R9cwa401@EPA.gov
Ms. Taylor Powell, Project Manager
United States Army Corps of Engineers
Email: Taylor.M.Powell@usace.army.mil
Patrick Pulupa, Executive Officer
Central Valley Regional Water Quality Control Board
Email: Patrick.Pulupa@waterboards.ca.gov
Stephanie Tadlock, Senior Environmental Scientist
Central Valley Regional Water Quality Control Board
Email: Stephanie.Tadlock@waterboards.ca.gov
Beth Lawson, Senior Hydraulic Engineer
California Department of Fish and Wildlife
Email: Beth.Lawson@wildlife.ca.gov
Michael Maher, Senior Environmental Scientist
California Department of Fish and Wildlife
Email: Michael.Maher@wildlife.ca.gov
Ms. Emily Moghaddas, Deputy Supervisor
United States Forest Service
Email: Emily.Moghaddas@usda.gov
Mr. Richard Kuyper, Branch Chief Southern Sierra
United States Fish and Wildlife Service
Email: Richard.Kuyper@fws.gov
Mr. Sean Noonan, Program Manager
Psomas
Email: sean.noonan@psomas.com
Ms. Shannon Luoma, Licensing and Regulatory Section Manager
Kleinschmidt Associates
Email: shannon.luoma@kleinschmidtgroup.com
ebc: Interested Parties List
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT A: INFORMATION REQUEST FOR KANAKA HYDROELECTRIC
PROJECT LICENSE SURRENDER
ENCLOSURES:
ATTACHMENT A-1: ADDITIONAL INFORMATION REQUESTS FOR
KANAKA HYDROELECTRIC PROJECT LICENSE
SURRENDER WATER QUALITY CERTIFICATION
APPLICATION
ATTACHMENT A-2: SITE VISIT PHOTOS
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
State Water Resources Control Board
1
January 31, 2024 Ms. Melissa Rondou Licensing and Compliance Manager STS Hydropower, LLC Affiliates of Eagle Creek Renewable Energy 7315 Wisconsin Avenue , Suite 1100W Bethesda, MD 20814 Sent via Email : melissa.rondou@eaglecreekre.com Kanaka Hydroelectric Project License Surrender Federal En ergy Re gulatory Commission Project No. 7242 Butte County Sucker Run Creek INFORMATION REQUEST FOR KANAKA HYDROELECTRIC PROJECT LICENSE
SURRENDER Dear Ms. Rondou: On October 11, 2023, State Water Resources Control Board (State Water Board) staff, representatives from STS Hydropower, LLC (STS), and Psomas1 attended a site visit of the Kanaka Hydroelectric Project License Surrender (Project). The purpose of the site
visit was to assess the Project’s existing environmental conditions as part of the State
Water Board’s California Environmental Quality Act (CEQA) process. During the site
visit, State Water Board staff were informed of access road changes and identified ongoing water diversions and associated leaks in the Project’s penstock along with an
eroded hillslope. Field observations raised potential water quality concerns that must
be addressed as part of the federal Clean Water Act water quality certification
(certification) process. The current deadline for the Project’s certification action is May 11, 2024. As such,
State Water Board staff request STS provide responses to State Water Board staff’s
information request (see Attachments A: Additional Information Requests for Kanaka Hydroelectric Project License Surrender Water Quality Certification Application) by
March 1 , 2024 Late responses may result in the State Water Board not hav ing adequate time to evaluate STS’s responses and assess potential water quality impacts associated
with the Project. Additionally, please see Attachment B: Site Visit Photos for photos
taken by State Water Board staff during the October 11, 2023 site visit or provided by
STS of conditions during other site visits . 1 Psomas is the State Water Board’s California Environmental Quality Act consultant. Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Ms. Melissa Rondou January 31 , 2024 2
If you have questions regarding this letter, please contact Glenn Hoffmann, Project
Manager, by email to: Glenn.Ho ffmann@waterboards.ca.gov. Written correspondence
should be directed to: State Water Resources Control Board Division of Water Rights – Water Quality Certification Program Attn: Glenn Hoffmann P.O. Box 2000 Sacramento, CA 95812-2000 Sincerely, Glenn Hoffmann Engineering Geologist Division of Water Rights Enclosures: Attachment A: Additional Information Requests for Kanaka Hydroelectric
Project License Surrender Water Quality Certification
Application Attachment B: Site Visit Photos ec (with enclosures): Ms. Debbie-Anne Reese, Acting Secretary Federal Energy Regulatory Commission Via e-filing to Docket for Project No. 7242 Mr. Michael Maher, Senior Environmental Scien tist Specialist California Department of Fish and Wildlife Email: Michael.Maher@wildlife.ca.gov Ms. Emily Moghaddas , Deputy Supervisor United States Forest Service Email: Emily.Moghaddas@usda.gov Mr. Richard Kuyper , Branch Chief Southern Sierra United States Fish and Wildlife Service Email: Richard.Kuyper@fws.gov Mr. Sean Noonan , Program Manager Psomas Email: sean.noonan@psomas.com Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Ms. Melissa Rondou January 31 , 2024 3
Ms. Shannon Luoma , Licensing and Regulatory Section Manager Kleinschmidt Associates Email: shannon.luoma@kleinschmidtgroup.com Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT A: ADDITIONAL INFORMATION REQUESTS FOR KANAKA HYDROELECTRIC
PROJECT LICENSE SURRENDER WATER QUALITY CERTIFICATION
APPLICATION 1 Pursuant to section 401 of the Federal Clean Water Act (33 U.S.C. § 1341), STS Hydropower, LLC (STS) submitted a water quality certification (certification) application
to the State Water Resources Control Board (State Water Board) on May 12, 2023 . STS is requesting to surrender its Federal Energy Regulatory Commission (FE RC) license for the Kanaka Hydroelectric Project. Actions associated with the surrender
include a proposal to demolish the Kanaka Powerhouse and Substation, and permanently decommission the penstock by installing a cement plug in the intake pipe at Kanaka Diversion Dam. The Project does not include remova l of the Kanaka
Diversion Dam2. State Water Board staff attended a site visit on October 11, 2023 , and observ ed that
Sucker Run Creek was being diverted into the Project’s penstock3 . The penstock had
several breaks where staff observed water being discharg ed into the surrounding
forested area (Attachment B: October 11, 2023, State Water Board Staff Site Visit Photos 1&2. Additionally, staff not ed a recent erosion event (see Photos 1-3 in
Attachment B) on a hillslope adjacent to one of the breaks in the penstock. On October 23, 2023, State Water Board staff met with STS staff to discuss the ongoing water diversion at Kanaka Diversion Dam. STS confirmed that the intake valve at the
Kanaka Diversion Dam was locked in the open position and that STS had learned that
the valve was open and diverting water a few weeks prior. On October 27, 2023 and
October 31, 2023, STS confirmed that Kanka Di version Dam diversions had ceased.
The October 31, 2023 correspondence stated that STS was able to partially drain the
penstock and divert water away from the wet well intake to reveal the bottom of the wet
well. STS found that the wet well was filled with approximately 30 inches of sediment that prevent ed the penstock flap gate from fully closing. On December 28, 2023, STS
filed a supplement to the Kanaka Hydroelectric Project Surrender Application briefly describing the se inadvertent diversions. STS also stated that the exact date when water
began entering the penstock is unknow n. While State Water Board staff appreciate that diversions have now ceased, questions
remain about the potential impacts from the unmanaged diversions and any potential
hillslope instability caused by the leaks from the Project’s penstock. The penstock leaks ha ve and may continue to contribute to hillslope instability and discharges of sediment,
settleable material, suspended material, and turbidity to Sucker Run Creek that could
exceed water quality objectives in the Water Quality Control Plan for the Sacrame nto
River Basin and the San Joaquin River Basin (SR/SJR Basin Plan). State Water Board
2 Per email on July 6, 2023 , STS states that the Kanka Diversion Dam is owned by the
landowner (currently Texcell Inc.) and will remain in place following license surrender. 3 STS’s FERC License Surrender Application (LSA page 1-9, 2-1, 4-3, and 4-13) and
certification application (page 1) state that there have been no diversions at the Kanaka
Diversion Dam into the penstock since the Ponderosa Fire in 2017.
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT A: ADDITIONAL INFORMATION REQUESTS FOR KANAKA HYDROELECTRIC
PROJECT LICENSE SURRENDER WATER QUALITY CERTIFICATION
APPLICATION 2 staff request add itional opportunities to confirm diversions have ceas ed and further
assess the impacts of penstock leaks. Based on field observations and information from STS staff about Project design
changes associated with Diversion Dam road access, State Water Board staff has the
following questions: 1. Please clarify when STS first closed the intake valve to the wet well following the 2017 Ponderosa Fire. If STS collected inform ation to confirm that diversions
ceased or check ed the integrity of the penstock at the time of closure or in
subsequent years , please provide that information. 2. On October 27 , 2023, STS provided a summary of a site visit that EcoKai Environmental, Inc conducted in mid-September 2023 that included a water
sample taken from one of the maintenance pits within the burned remnants of the
Kanaka Powerhouse. The sample results did not find any numeric exceedances within the maintenance pit. However, oil and grease were observed in the
maintenance pit during the October 27, 2023 site visit4. Was any upstream data
collected to provide the background condition of Sucker Run Creek or
downstream of the Kanaka Powerhouse to determine if the powerhouse remnants impact ed heavy metals or oil and grea se in Sucker Run Creek? See Attachment B, Figures 5 to 7. 3. During the October 27, 2023 site visit, State Water Board staff identified at least
three penstock leaks from the access road. Plea se clarify the total number of
penstock leaks and their locations . 4. During the site visit, State Water Board staff identified failed culverts on the
existing access road. Is STS proposing any additional measures to ensure the
Kanaka Hydroelectric P roject-related facilities left in place following the FERC
license surre nder are not contributing sed iment to Sucker Run Creek? 5. During the field investigation, hillslope instability was obser ved at one of the
penstock leaks (see Attachment B , Photos 2 and 3). Given that slope instability
has been observed in close proximity to leaks from the penstock , will STS
propose any slope stability or restoration actions at these locations to pr event
sediment discharges to surface waters ? Additionally, will STS propose any actions to seal or secure penstock leaks to prevent wildlife entrainment and/or
ongoing water infiltration? 6. How much sediment does STS estimate has been entrained in the penstock?
Addit ionally, d oes sediment entrainment affect the Project’s proposal to cut and plug the penstock at the powerhouse? Based on STS’s December 28, 2023 , letter to FERC, STS is working to develop a plan to remove sediment from inside
4 The SR/SJ R basin plan states that “Waters shall not contain oils, greases, waxes, or
other materials in concentrations that cause nuisance, result in a visible film or coating
on the surface of the water or on objects in the water, or otherwise adversely affect
ben eficial uses.” Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT A: ADDITIONAL INFORMATION REQUESTS FOR KANAKA HYDROELECTRIC
PROJECT LICENSE SURRENDER WATER QUALITY CERTIFICATION
APPLICATION 3 the wet well to allow the penstock flap gate to fully close . Will this plan be
circulated to the State Water Board and does STS plan to supplement its water
quality certification application with this information?
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 1 Photo 1 Failed pressure release system and erosion on down hill side of the
Diversion Dam access road. Water discharges are associated with
ongoing penstock diversions. Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 2 Photo 2 Failed pressure release system and erosion on down hill side of the
Diversion Dam access road. Hillslope instability shown in the background. Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 3 Photo 3 Hillslope instability near penstock leak on downhill side of the road. Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 4 Photo 4 Penstock i ntake valve locked in the open position. Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 5 Photo 5 Powerhouse operational material left in place since the 2017 Ponderosa
Fire. Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 6 Photo 6 Maintenance pit full of water and penstock actively leaking . Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 7 Photo 7 Water actively leaking from power generation equipment. Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 8 Photo 8 Sediment buildup in the wet well . (Photo taken from STS Hydropower, LLC memo summarizing field work provided to State Water Board staff on
October 11, 2023) Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B: SITE VISIT PHOTOS (unless otherwise noted, photos taken by State Water Board staff during
October 11, 2023 site visit) 9 Photo 9 Aerial of hillslope instability near penstock leak . (Photo taken from Google
Earth dated May 11, 2021)
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
ATTACHMENT B:
Certificate of Service
Certificate of Service
I hereby certify that I have this day filed electronically with the Federal Energy
Regulatory Commission and served the foregoing document upon each person
designated on the official service list compiled by the Secretary in this proceeding.
Dated this 23rd day of April 2024.
___________________________________
Glenn Hoffmann
Engineering Geologist
Division of Water Rights
State Water Resources Control Board
Glenn.Hoffmann@waterboards.ca.gov
Document Accession #: 20240424-5023 Filed Date: 04/24/2024
Document Content(s)
kanaka-wqc-denial-april-2024-final-w-attach-signed.pdf ....................1Document Accession #: 20240424-5023 Filed Date: 04/24/2024