Woronoco Hydro LLC - Low Impact Hydropower Institute

Transcription

Woronoco Hydro LLC
PO Box 149, Hamilton, MA 01936
January 22, 2010
VIA EFILING
The Secretary
Federal Energy Regulatory Commission
Mail Code: DHAC, PJ-12.3
888 First Street, N.E.
Washington, DC 20426
Re:
FERC Project No. 2631-MA
Filing of Plans under Article 404
Dear Secretary Bose:
The Commission’ January 11, 2010 letter rejecting the December 21, 2009 filing of Woronoco Hydro
LLC’s 2009 Comprehensive Fish Passage Plan (Plan) requesting re-submission of a detailed schedule
to address the issues listed in the Commission’s July 21, 2009 Order. The Commission’s July 21, 2009
Order Approving Downstream Atlantic Salmon Smolt Passage Effectiveness Report and Requiring
Further Actions Pursuant to License Article 404 (128 FERC ¶ 62,050) for the Woronoco Project (FERC
No. 2631) required the filing of the following plans: 1) Condition B of the Order required the plan and
schedule for the annual installation and removal of trashrack overlays. 2) Condition D of the Order
required the schedule to complete velocity testing at the intake. 3) Condition E of the Order required a
plan and schedule to conduct passage effectiveness testing. Attached is the Plan which contains the
information required by the July 21, 2009 Order. In response to the Commission’s letter, Woronoco is
re-submitting the Plan with modifications to address stakeholder comments..
Woronoco received comments on the draft Plan from the Massachusetts Division of Fisheries and
Wildlife (MDFW), the U.S. Fish and Wildlife Service (USFWS) and Trout Unlimited (TU). The
Massachusetts Department of Environmental Protection (MDEP) deferred comments to the MDFW.
The comments that have been received have been incorporated into the Plan except as discussed below.
TU comments on section 3.3 of the Plan indicates that eel passage counts should be continued.
Woronoco notes that on-going counts are the responsibility of resource agencies and the previous
counts of the Middle and South ladders in 2008 and 2009 proved those two ladders were passing
juvenile eels in large numbers and did not require additional passage efficiency testing. Woronoco
notes that the license requires providing effective and efficient eel passage and does not require
continuous counting of eel passage. The completed Phase 1 testing of the South and Middle ladders
has confirmed the installed passage systems are efficient. The proposed Phase 2 testing will confirm
the effectiveness of the passage systems. Woronoco will conduct limited counting during the 2010
season during testing of the new North ladder.
The USFWS and MDFW are in support of the proposed schedule for smolt testing at the development
in 2011. TU is opposed to the proposed test schedule based on their concerns regarding installation of
the new downstream passage system. This system remains on schedule and, as outlined in Woronoco’s
agency plan filing letter (Appendix B of the Plan), makes best use of the development’s resources and
is expected to significantly enhance passage at the development. Re-testing of the soon to be removed
current passage system in April to June 2010 would not prove the effectiveness of the proposed
relocation of the passage entrance. Re-testing an obsolete design that failed two previous tests would
not be a wise investment of stakeholder or owner resources. Woronoco has therefore retained the 2011
testing schedule in order to include tests of the redesigned passage facility that will be installed during
the 2010 construction season. Smolt are not at risk in the 2010 passage season because Woronoco will
install ¾” clear bar spaced trashrack panels in March 2010 to prevent entrainment and then test for
velocity hot-spots in early April in order to mitigate risk of impingement due to areas of the new racks
that might have approach velocities in excess of 2 fps.
The stakeholders noted that additional details are required for the modification to the downstream fish
passage system shown in Appendix A of the Plan. The engineering details are currently under
development and will be submitted for further agency consultation. The details may also be adjusted
after the results of the velocity testing are reviewed by USFWS, MDFW and TU in May 2010.
TU also provided a reference for an alternate method for marking eels during the Phase 2 upstream eel
passage testing. However, Woronoco will retain the originally recommended and equally acceptable
method of dye marking proposed by MDFW. However, the alternative method referenced by TU will
be discussed during the future on-site consultation meeting scheduled to occur in the summer of 2010.
TU indicates that a study should be conducted during the 2010 adult eel migration season. The Plan
incorporates the recommended study plan development but does not support conducting of the study
during the 2010 season that depends on finding reliable sources for Silver eels in sufficient number to
conduct effectiveness tests. Similar to the need for future studies for Kelt once present, Woronoco is
unaware of the presence of migrating eels at the site and proposes to construct on-site capture devices
to confirm the presence of migrants. The captured migrants could then potentially be used as a source
for test eels. Woronoco intends to utilize the 2010 season to develop and prepare for a study to be
conducted during the 2011 season if migrants are confirmed to be present. The impact to the resource
is anticipated to be insignificant since adult eels will typically migrate during spill conditions and
entrainment protection screens at the intake will be installed before the 2010 fall migration season.
Please contact me at (978) 468-3999 (email: pclark@swiftriverhydro.com) if you have any questions or
require additional information regarding this filing.
Sincerely,
Peter B. Clark
Manager
Attachments
WORONOCO HYDRO, LLC
Hamilton, MA
2009 COMPREHENSIVE
FISH PASSAGE PLAN
For the
WORONOCO HYDROELECTRIC PROJECT
FERC NO. 2631
January 2010
Prepared by:
Renewable Power Consulting, PA
Palmyra, ME
WORONOCO HYDRO, LLC
WORONOCO PROJECT
(FERC NO. 2631)
2009 COMPREHENSIVE FISH PASSAGE PLAN
TABLE OF CONTENTS
1.0 2.0 3.0 4.0 5.0 6.0 INTRODUCTION .............................................................................................................. 1 FISH PASSAGE FACILITY DESCRIPTION ................................................................... 3 2.1 General Project Information ................................................................................... 3 2.2 Downstream Fish Passage System .......................................................................... 3 2.3 Downstream Adult Eel Passage System ................................................................. 4 2.4 Upstream Eel Passage ............................................................................................. 5 OPERATIONS AND MAINTENANCE............................................................................ 7 3.1 Downstream Fish and Eel Passage ......................................................................... 7 3.2 Downstream Eel and Fish Protection Intake Rack Screens .................................... 8 3.3 Upstream Eel Passage ............................................................................................. 8 PREVIOUS AND PROPOSED STUDIES ...................................................................... 10 4.1 2005 Downstream Smolt Passage Effectiveness Testing ..................................... 10 4.2 2008 Downstream Smolt Passage Effectiveness Testing ..................................... 10 4.3 2011 Downstream Smolt Passage Effectiveness Testing ..................................... 11 4.4 Downstream Kelt Passage Effectiveness Testing ................................................. 13 4.5 Downstream Adult Eel Protection and Passage Effectiveness Testing ................ 14 4.6 Upstream Eel Passage System .............................................................................. 15 4.7 2010 Velocity Testing ........................................................................................... 19 SCHEDULE ...................................................................................................................... 21 5.1 Downstream Eel and Fish Protection Panels ........................................................ 21 5.2 Intake Velocity Study ........................................................................................... 21 5.3 Downstream Fish Passage Facility ....................................................................... 21 5.4 Effectiveness Testing of Smolt Passage Systems: ................................................ 21 5.5 Downstream Adult Eel Passage Testing ............................................................... 22 5.6 Effectiveness Testing of Juvenile Eel Passage Systems and North Eel Ladder: .. 22 5.7 Summary Schedule: .............................................................................................. 24 SUMMARY OF JULY 21 ORDER RESPONSE ............................................................ 25 6.1 Condition B of the Order: ..................................................................................... 25 6.2 Condition C of the Order: ..................................................................................... 25 6.3 Condition D of the Order: ..................................................................................... 26 6.4 Condition E of the Order: ..................................................................................... 26 6.5 Condition F of the Order:...................................................................................... 27 Appendix A: Conceptual Downstream Fish Passage and Intake Rack System
Appendix B: Consultation and Meeting Notes
C:\RPC Projects\403 Woronoco\Fish Passage Plan\4010-P2631 FINAL Fish Passage Plan_012210.docx
Woronoco Hydro (FERC No. 2631)
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2009 Comprehensive Fish Passage Plan
1.0
INTRODUCTION
Woronoco Hydro, LLC (Woronoco Hydro) owns and operates the Woronoco
Hydroelectric Project (Project), which is licensed by the Federal Energy Regulatory Commission
(FERC) as FERC Project No. 2631. The Project is located on the Westfield River in Hampden
County, Massachusetts. Article 404 of the Project license, issued April 30, 2002 (99 FERC ¶
62,075), required Woronoco Hydro to develop a comprehensive fish passage plan (Plan). The
Plan is required to include provisions to install, operate, maintain, and evaluate, as appropriate,
upstream and downstream fish passage facilities at the Woronoco Project for Atlantic salmon
and American eel. The Plan is required to include the following items as outlined in the original
license:
1)
A provision to continue operating and maintaining the existing downstream fish
passage facility;
2)
functional design drawings of the licensee’s proposed upstream passage measures
for American eel (in accordance with the plans filed June 6, 2000);
3)
Quantification of the flows required to operate the licensee’s proposed fish
passage facilities;
4)
An operation and maintenance plan, including a schedule for operating the
licensee’s proposed fish passage facilities;
5)
Funding support towards implementing the Massachusetts Division of Fisheries
and Wildlife’s upstream trap-and-truck program for Atlantic salmon on the
Westfield River; and
6)
A schedule for implementing the plan.
In addition, the plan is to include provisions to:
•
Evaluate the effectiveness of the downstream passage facility for passing salmon
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smolts, post-spawn adult salmon.
•
Evaluate the effectiveness of the upstream eel passage measures.
•
Evaluate American eel out-migration.
The Commission license orders on July 21, 2009 and July 23, 2009 amended the Plan
requirements. These Orders required that the Plan also include:
7)
Installation of trashrack overlays or replacement rack panels.
8)
An operational plan for overlay or panel installation and maintenance.
9)
Conduct an intake velocity testing and propose mitigation measures if required.
The Commission in an Order issued April 20, 2006 (115 FERC ¶ 62,091) originally
approved the Plan. Pursuant to the Commission’s Order issued January 17, 2008, the Plan was
revised in August 7, 2008 and the revised Plan was approved on November 25, 2008 (125 FERC
¶ 62,187). The Commission’s July 21, 2009 Order (128 FERC ¶ 62,050) and the July 23, 2009
Order (128 FERC ¶ 62,054) required changes to Plan.
The Plan incorporates the work or data collected at the site since the original license
Order. The Plan also identifies the additional studies required at the development, the schedule
of the remaining studies, and the description of the proposed new downstream passage system
(shown conceptually in Appendix A). Details of the new trashrack panels (Appendix A) were
provided to the Massachusetts Department of Environmental Protection (MDEP), the
Massachusetts Division of Fisheries and Wildlife (MDFW), the U.S. Fish and Wildlife Service
(USFWS) and Trout Unlimited (TU) on October 30, 2009. A draft of this Plan was submitted to
MDEP, MDFW, USFWS and TU on December 11, 2009. Appendix B provides a copy of the
comments received from the MDEP, MDFW and from TU. Clarifications and discussions of
comments not incorporated into this final plan are contained in the cover letter at the front of this
plan.
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2.0
FISH PASSAGE FACILITY DESCRIPTION
2.1
General Project Information
The Woronoco Project is located at river mile (RM) 18.5 on the Westfield River. The
project's principal features consist of: (1) two non-contiguous dam sections and an earthen dike;
(2) an intake area leading to a powerhouse, which contains three turbine/ generator units with an
installed capacity of 2.7 MW; (3) a downstream fish passage facility; (4) a 43-acre impoundment
at the normal pool elevation; (5) a bypassed reach with three channels, varying in length from
200 to 1,000 feet; and (6) appurtenant facilities. The project is operated in a run-of-river mode,
with a target elevation of 229.0 feet National Geodetic Vertical Datum, for the protection and
enhancement of water quality, fisheries, and aquatic resources in the Woronoco impoundment
and the Westfield River downstream from the project. The three Francis turbines and generating
units have minimum and maximum hydraulic capacities of 130 cubic feet per second (cfs) and
710 cfs, respectively with a gross head of 55 feet and a design head of 50 feet at 710 cfs. The
project is required to release a minimum flow of 35 cfs into the south channel (20 cfs through the
fish passage facility and 15 through the south dam discharge gate) and 22 cfs into the north
channel, as measured by the gate openings and staff gauges immediately downstream from the
north and south dams.
2.2
Downstream Fish Passage System
The downstream fish passage facilities at the Woronoco Project currently consist of a
surface bypass facility installed in 1997 to promote passage of fish and for passage of the
minimum flow requirements at the project. The system consists of a metal, open topped chute, a
vertical downward closing timber maintenance gate, and a natural rock and timber walled plunge
pool. The system entrance is located immediately upstream of the Project’s intake racks in a
former trash sluiceway originally used when pond level was elevation 231.5 ft NGVD (project
was formerly equipped with 30-inch boards). The lower than the originally designed
impoundment level limits the existing system to pass required attraction flows.
Previous Plans and agency recommendations included installation of an angled rack
system to guide migrants to the passage entrance. Testing in 2006 and 2008 of experimental
partial depth angled screen systems were unsuccessful and the screen system was determined to
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be ineffective at guiding migrants due to the shallow forebay level and resulting severe
turbulence. Woronoco Hydro does not intend to pursue further modification of the angled
screens or installation of a full depth angled trash rack. Stakeholders have agreed that partial
depth angled lead is not viable at this location. Full-depth intake rack panels with bar openings of
¾” to prevent smolt and adult eel entrainment will replace the angled lead. The revised intake
screen system will consist of 13 individual full height rack panels installed between permanently
attached guide bars. The panels will be installed and removed using a jib crane mounted on the
movable trash rake. Appendix A provides details of the rack panel system.
Woronoco is also proposing the installation of an intake fish bypass system and to
abandon the current bypass location. The new downstream passage system is conceptually
shown in Appendix A and would be combined with new close spaced exclusion rack panels.
The passage system will be modified, if appropriate, to incorporate the results of the intake
velocity testing. The system will be combined with the full depth intake rack panels (with a
maximum clear spaced opening of 3/4-inches). The bypass system will consist of a 3.0 feet wide
(clear) steel entrance channel and collection box approximately 7 feet in length (flow direction)
and 6 ft in width. The collection chamber will be located near the dam side of the forebay to
avoid interference with water flow into the penstock. Flow into the collection chamber is
designed to create a 3 feet deep plunge pool within the chamber. A 30-inch diameter bypass pipe
will exit the collection chamber and discharge into the existing plunge pool. Passage flow will
be controlled at the entrance channel by the use of removable stop logs or manually operated
slide gate. The final details of the bypass system will be developed in consultation with the
stakeholders.
2.3
Downstream Adult Eel Passage System
Several downstream passage routes exist for out-migrating silver eel at the development.
These include spill, passage through deep discharge gates (which are partially opened to release
minimum flows), the current fish bypass system and the proposed fish bypass system. A formal
eel bypass facility will be provided using the new fish bypass system while the alternate routes
will remain available. In addition, Woronoco will install new full depth intake protection screens
with ¾-inch clear spacing to prevent entrainment and will test intake velocities to reduce
impingement potential for migrants.
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2.4
Upstream Eel Passage
An April 20, 2006 Commission order (115 FERC ¶ 62,091) approved installation of
upstream eel passage facilities at three locations: (1) the channel adjacent to the forebay and
plunge pool (the “South ladder”), (2) below the project’s South Dam (the “Middle ladder”), and
(3) below the project’s North Dam (the “North ladder”). The facility at the North Dam was
damaged by ice in the ice out of 2008, and has been required to be repaired or relocated based
upon the results of the 2009 night observation (see draft 2009 Juvenile Eel Passage Report
currently under review by the stakeholders). The location and details of the North ladder Eel
passage at the North dam now utilizes a combination of available attraction flows through cracks
in the crest that wet the dam’s surface and fills a large resting pool in the natural ledge
outcropping where eels congregate before climbing the trace of water coming over the dam. Eel
ladders have been installed at two locations below the South dam. The eel ladders consist of
inclined wooden flumes overlaid with artificial substrate that are watered by submersible pumps.
The ladders are covered to prevent predation. A 4’x3’x2’ holding tank for eel collection, testing
and enumeration purposes has been installed at the top of each ladder section. Each ladder is
supplied with an attraction flow of 0.5 cfs (225 gpm). Attraction water is provided by a 2” siphon
line over the dams for both ladders. The Middle and South ladders are supplied with a
conveyance flow of 6 gpm from a single submersible pump and each ladder is designed with
level resting pools inside the ladder.
The 2009 test and night observation surveys confirmed that the majority of eels seen at
the North dam are attracted to the deep discharge gate flow. Because of the test and
observations, Woronoco proposes to construct a new eel passage system at the North dam where
the 22 cfs minimum flow discharge attracts upstream migrating juvenile eels to the passage
system entrance. The proposed replacement ladder will consist of a metal elevated ladder
attached to existing structures on the north end of the dam. The ladder entrance will be located
in a calm area adjacent to a natural high point within the bypass channel, slightly off from the
north shore. The ladder will be attached to the existing concrete abutment and be sheltered from
ice flows and flood debris by the north abutment. The ladder sections will be turned to follow
the exterior of the abutment and terminate approximately 5 feet upstream of the dam crest. The
exit from the ladder will be located approximately 5 feet above normal impoundment levels.
Water supply for the ladder will be supplied from a submersible pump or siphon located within
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the impoundment at the North dam north abutment. Water will flow into the ladder’s high point
to provide transport flow and a separate pipe installed to provide entrance attraction flow. The
upstream, exposed section of ladder and water supply system will be removed during the nonpassage season to prevent damage.
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3.0
OPERATIONS AND MAINTENANCE
3.1
Downstream Fish and Eel Passage
The downstream fish passage facility with the required attraction flow will be operated
from April 1 through mid-June for passage of juvenile Atlantic salmon (smolts) and from
September 1 to November 15 for passage of adult eels and post-spawn adult salmon. Future
refinement of the timing will be made as information on the behavior of migrants at the Project is
obtained and may be adjusted once post-spawn adult salmon are present. Since the bypass
system attraction flow will also provide part of the required minimum flow releases, the passage
facility will operate on a year-round basis except during the winter season. Flow through the
passage system will be annually stopped from December until “ice-out” or until the water
temperature reaches 5-degrees Celsius. During periods in which the bypass system is closed,
minimum flows will be maintained using the project’s deep gates.
35 cfs will be used for bypass attraction flow during the passage season. The attraction
flow amount may be modified based on the result of the future system effectiveness testing.
Flows in the bypass system during the passage season will be maintained through an adjustable
stop log or side gate opening and controlled by the impoundment level. Flows in the bypass
system during the non-passage season will be limited to those required to satisfy minimum flow
requirements at the project. The settings for the minimum flow requirements (22 cfs at the North
dam, 15 cfs at the South dam and 20cfs through the passage facility) will be based on USFWS
calculations of the opening necessary to provide the required minimum flow discharge when the
impoundment elevation is at the dam crest.
A Woronoco Hydro roving operator routinely visits the project a minimum of three times
per week during unit operation and once per week during non-operational periods. During the
migration season the operator will check the bypass system and plunge pool area daily for debris
clogging, proper stop log adjustment, and to clean the intakes racks when needed (in addition to
the automated cleaning cycle). During rack cleaning the unit flow may be temporarily reduced
to assist in cleaning operations. Due to the use of the open straight bypass system entrance,
debris clogging within the bypass system is anticipated to be infrequent. Maintenance of the
system will include an annual (if necessary) dewatering to remove accumulated debris within the
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bypass system and to check the structure’s integrity. Annual cleaning of the plunge pool area
will be conducted prior to the migration season and will consist of temporarily stopping flow into
the area to permit the water levels to be reduced to facilitate debris removal activities.
Woronoco Hydro will maintain minimum flow requirement releases either through flow over the
dam, by the use of two deep gates, through the former bypass system or by some combination of
the gates and former bypass system. Increased minimum flow releases of short duration (less
than a half hour) may occur to blow out and remove small debris deposits within the bypass
system by releasing larger discharges of short duration. The gates will be closed only if a
permanent obstruction must be removed by divers or by drawing down the impoundment.
3.2
Downstream Eel and Fish Protection Intake Rack Screens
The project intake will be equipped with thirteen (13) separate removable full depth rack
panels to facilitate fish protection and generation. The station’s closed spaced fish protection
panels (with 3/4th inch clear bar spaces) will be installed on or before the two migration seasons:
April 1 through June 15 and September 1 through November 15. Panels with 1 ¼-inch clear bar
spacing will be used the remainder of the year. The seasonal ¾-inch clear bar spaced panels will
be installed and removed utilizing a jib crane mounted on a traveling mechanical rack raker. The
racks will be automatically cleaned through mechanical rack raker operations and supplemented
as required during heavy debris loads.
3.3
The upstream eel passage facility will be operated from May 15 through November 15
for passage of juvenile American Eels (eels). Two of the eel passage systems will be supplied
with siphoned water for attraction and passage. The North Dam passage system’s attraction and
transport flow will be supplied from a submersible electric pump or siphon located in the
impoundment adjacent to the dam abutment. The pump and gravity flow systems will operate
continually during the passage season providing a minimum of 0.1 cfs of flow per ladder system.
A Woronoco Hydro operator routinely visits the project typically three times per week
during unit operation and once per week during non-operational periods. When eel ladders are in
operation, an operator will check each passage system daily for debris clogging, damage and
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proper flows through the system. Repairs or equipment replacement will be implemented within
one week of the discovery of damage or failure. During cleaning or repairs, the ladder flow may
be periodically reduced or stopped to assist in the operations. During the non-passage seasons
some structural portions of the ladders will be removed to prevent ice damage to the passage
systems. Maintenance to the eel passage facilities will include an annual (if necessary)
dewatering and top opening to remove accumulated debris or to repair damaged portions of the
ladder.
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4.0
PREVIOUS AND PROPOSED STUDIES
4.1
2005 Downstream Smolt Passage Effectiveness Testing
Wornoco conducted a Radio Frequency Identification (RFID) or a Passive Integrated
Transponder (PIT) tag effectiveness test during the 2005 migration season. In general the
assessment entailed releasing tagged live smolts (Atlantic salmon) upstream of the Project and
monitoring their subsequent downstream passage movements to determine the proportion of fish
using the bypass facility. The downstream passage chute was equipped with an in-water
antenna, tag reader and data logger to document the number of fish using the bypass. In
addition, the forebay stop log structure was equipped with in-water antenna, tag reader(s) and
data logger(s) to document the number of fish entering the forebay area. Woronoco calculated a
passage efficiency of 71 percent at the passage chute entrance, and 35 percent at the plunge pool.
Calculations supported by the USFWS indicated that the bypass efficiency was 55 percent and
29 percent at the plunge pool. The USFWS and MDFW found the study inconclusive regarding
smolt passage effectiveness. The licensee therefore consulted with the agencies on a second,
revised smolt passage study that would use radio-telemetry to monitor fish movements past an
angled lead device installed in the forebay.
4.2
Woronoco Hydro was dewatered and reconstructed between July 2007 and April 2008.
During that time, resource agency consultation resulted in approval of an experimental floatsupported partial depth angled lead to channel smolt away from the racks to the entrance of the
downstream passage facility. Pursuant to recommendations from the USFWS, MDFW, and in
consultation with TU, Woronoco Hydro conducted a smolt passage radio-telemetry study during
the 2008 smolt migration season. The testing began immediately after completion of the
reconstruction work resulting in the inability to test or adjust the angled lead prior to the start of
testing. The objective of the study was to determine the efficiency of the existing fishway
(including the angled lead) at passing smolts into the passage facility. In addition, the study was
designed to assess whether and to what degree smolts were entrained through the units, the fate
of smolts that may pass via spill, and overall project passage.
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During the 2008 smolt migration period, at operating flows between 350 and 730 cfs
(including 20 cfs discharge through the passage chute), the lead acted as a porous dam, causing
most of the flow to dive down under the 10-foot deep lead structure, and the rest of the flow to
accelerate along the upstream face of the lead. Upon installation, Woronoco Hydro personnel
noted that the angled lead resulted in abnormal velocity vectors throughout the forebay channel,
backwatered flow away from the entrance of the fishway, and caused a strong downward current
along the face of the lead towards the trashrack. The unusual flow patterns, velocity changes,
and turbulence in the forebay may have influenced smolts to sound under the lead and
subsequently reduced their ability to successfully find the entrance to the fishway once behind
the lead. Upon determination that, during the first weeks of testing, the angled lead was
ineffective, and, after consulting with the resource agencies, Woronoco Hydro tested three other
fishway configurations. The revised configurations included i) a deep gate test with the angled
lead in place, ii) removal of the angled lead to test of the surface fishway alone, and iii)
temporary installation of a full-depth overlay with 1-inch vertical clear bar rack spacing to screen
smolts from the penstock. The final tests with the temporary overlay configuration were tested
with the surface fishway fully opened and operational. The final tests were conducted with
partial turbine flow due to reduced river flows.
The results of the 2008 study indicated that the utilization of full-depth overlays with 1inch bar rack spacing prevented entrainment of salmon smolts and provided successful passage
past the project. In April 2009 the USFWS and the MDFW recommended that additional
effectiveness tests be conducted in 2009 to test smolt passage under full capacity flow operating
conditions with an overlay installed. In addition, the resource agencies recommend an additional
study due to the small sample size tested with the overlay in place. The Commission’s July 21,
2009 Order approved the 2008 Effectiveness Tests and required additional testing with overlays
in place. The approval order was issued after the close of the 2009 smolt migration season and
therefore the recommended additional testing was not completed in 2009.
4.3
Pursuant to recommendations from the stakeholders, Woronoco Hydro will conduct a
quantitative assessment of the downstream fish passage effectiveness following the 2010
summer installation of the downstream fish passage facility modifications at the Project. An onWoronoco Hydro (FERC No. 2631)
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site meeting will be conducted with the stakeholders to finalize the details of the testing
procedures and location of monitoring devices in the fall of 2010. In general, the effectiveness
assessment will repeat the 2008 testing procedures but include antennae downstream of the
plunge pool for positive identification of fish leaving the pool, and in the tailrace channel to
detect if any fish pass through the turbines.
During the study, the project would be operated in its normal run-of-river mode, so that
outflows equal inflows on a continuous basis. Documentation of the unit generation and river
flow will be recorded for use in the data analysis. Assuming adequate inflows, all three of the
project’s units would be operated during as much of the study as possible. If inflows are below
normal, the project would be operated at maximum capacity possible under the flow conditions.
No modifications to operation would be made during the study. All testing would be limited to
no-spill periods, if possible, to restrict downstream fish passage outside of the bypass system.
Antenna will be placed in order to detect test fish that may spill over the dam or pass through the
deep discharge gates should a spill event occur during testing. Prior to the study, stationary radio
telemetry receivers would be installed, calibrated, and tested to ensure their ability to detect
passage of radio-tagged fish. The stationary receivers would be installed at the following
locations:
1) Impoundment: near the forebay area, oriented upstream to detect fish near the
dam.
2) Forebay stoplog structure: to detect fish approaching the forebay and fish bypass
facility.
3) Fish bypass chute: an underwater dropper antenna in the bypass chute
downstream far enough to positively determine successful passage.
4) Plunge pool: an underwater dropper antenna in the plunge pool to document
delay or potential mortality associated with passage through the chute.
5) South Channel: an antenna downstream of the plunge pool to confirm passage
after exiting the plunge pool.
6) Penstock and/or Tailrace: to document any passage via turbine entrainment.
7) In the South dam bypass reach just above the entrance of the plunge pool channel
to count fish that may pass over the dam when flows exceed 767 cfs.
8) Westfield River: located approximately 1 mile downstream of the project, to
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assess total passage through the project, and fish survival.
9) A receiver/antenna would be used to manually track smolts that do not pass the
project and are not documented by the stationary receivers, and to track fish that
may pass the project through entrainment but are not detected by downstream
stationary antennae.
The study would utilize 60 Atlantic salmon smolts transported by the licensee from the
Pittsford National Fish Hatchery. Fish would be held at an on-site holding facility consisting of
a series of 150- gallon tubs with pumped river water for acclimatization. Each fish would be fit
with a small radio transmitter via esophageal transplant. Fish would be released approximately
0.25 miles upstream of the downstream fish passage chute unless Indian River is ready for smolt
passage testing, in which case the test fish would be released approximately one half mile above
the Russell Dam. The fish will be released in groups of 12, with the groups separated by 12 to 24
hours, with releases made to avoid periods of spill and inclement weather. A sixth group of 10
fish would be fitted with mock tags and held for approximately 96 hours to assess the effects of
handling and tag insertion, and also tag retention. Bypass efficiency would then be calculated
using the following formula:
E = (100) (a / b), where:
a = number of smolts detected as having successfully passed via the fish bypass, and
b = (number of smolts released) – (number of smolts proven to have passed via spill) –
(number of smolts proven not to have migrated).
4.4
Downstream Kelt Passage Effectiveness Testing
Woronoco is not proposing effectiveness studies for post-spawned Atlantic salmon (kelts)
since they are not currently present in the Westfield River. The results of the February 14 and
April 10, 2008 conference calls with the stakeholders concurred with this proposal. Woronoco
will develop an effectiveness test study if Woronoco receives notification from the resource
agencies that adult salmon are present in sufficient numbers above the Project to supply a
significant number of test fish and thus to make downstream kelt passage testing possible.
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In general, Woronoco Hydro anticipates that a PIT tag study, radio telemetry study, or
other similar tracking methodology may be necessary to document successful passage of kelts at
the site. It was noted by the stakeholders during the February 14, 2008, conference call that the
current 1.25-inch trash rack spacing would prevent entrainment of kelts through the units. As
such, likely routes of passage include the fish bypass or spill over the dam. If a study indicates
that the existing plunge pool at the proposed passage facility is not adequate for the successful
passage of kelts, Woronoco would propose additional modifications as part of its final report to
the Commission to correct observed problems.
4.5
Downstream Adult Eel Protection and Passage Effectiveness Testing
Similar to the discussion in Section 4.4, there is currently no known presence of outmigrating eels and the Project will be equipped with protection screens at the intake to prevent
entrainment should migrants be present. To confirm the presence of outmigrants, Woronoco
proposes to install an on-site capture mechanism (live box) to monitor outmigration of adult eels
by capturing them after passage in the plunge pool of the bypass facility. The live box will be
monitored daily during the eel migration season.
Visual monitoring for the presence of migrating eels at the intake and in the live box will
be conducted during the 2010 migration season. Pursuant to recommendations from the
stakeholders, Woronoco Hydro will conduct a quantitative assessment of the downstream eel
protection effectiveness following the installation of the downstream fish passage facility
modifications at the Project and confirmation that migrants are present. A source for
outmigrating eels is the main deterrent for conducting a test of the bypass system effectiveness
for the passage of adult eels. Inquiries at tackle and fishing stores in the area of Woronoco
Hydro have not identified an active American eel fishery upstream on the Westfield River.
Similarly, consultation with agency representatives did not find a confirmed reliable source for
capture of large numbers of adult silver eels in the watershed (TU has provided a potential source
that would need to be confirmed). Collection of test eels may become possible using the
proposed on-site live box in the plunge pool or may be available at MDFW supported eel
passage facilities downstream. Testing would be possible with the collection of 30 or more outmigrants.
- 14 -
An on-site meeting will be conducted with the stakeholders to finalize the details of the
testing procedures and location of monitoring devices in the summer of 2010. The meeting will
also be used to determine potential sources for eels and timing of the testing. In general, the
effectiveness assessment is anticipated to use approximately 40 marked adult eels placed
upstream of the dam and tracked through the development. Eel marking may include physical or
radio tagging of the migrants, depending upon the number of eels and the ability to obtain
sufficient numbers of outmigrating eels for testing. Testing of on-site captured eels will be
conducted through marking techniques with the release of 10 or more eels per release. The onsite captured and marked eels will be removed from the live box and placed upstream of the
forebay. Recaptured marked eels would then be used to document the effectiveness of the
formal passage system.
4.6
Upstream Eel Passage System
Woronoco Hydro monitored the performance of the installed eel ladders by counting
captured eels (in installed collection tanks) and through nighttime monitoring of eel behavior and
distribution during the 2007 through 2009 migration seasons. In the fall of 2007, no eels were
observed to have used any of the three ladders nor were eels collected in the exit tanks. In June
and July 2008, 141 juvenile eels were collected from the exit tanks of the two existing ladders
(the North Channel ladder was destroyed by ice). In 2009 there were a total of 1,278 eels
recovered, 891 from the South tank and 387 from the Middle tank. No eels were observed in the
Woronoco tailrace in 2008 or 2009.
During nighttime observations, several other avenues of passage were seen to exist along
smaller natural flowages across the dam face and existing bedrock ledges. On July 21, 2008,
several eels were observed passing naturally over the wet ledge of the North and South dams.
Specifically, in the North Channel, an existing bedrock crevice, which is kept wetted through a
small notch in the North dam, was observed to pass juvenile eels. The configuration of this
natural rock way and eel passage avenue contains steady and reliable flow because of the
notched dam, and contains resting pools. Other small natural passageways in both the Middle
and South dams also function as a means for eels to migrate past the Project. Nighttime
observation also revealed that hundreds of eels migrate up the westernmost bypass reach
(discharge from the fishway and plunge pool) and pass up over the forebay spillway. At the same
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time (July 21, 2008), one eel was documented as having used one of the installed ladders to
ascend past the Project.
The November 25, 2008 order approved the licensee’s plan to use a two-phased
assessment of the effectiveness of upstream eel passage. The schedule to conduct the testing was
modified in the July 23, 2009 Order. In Phase 1 of the study, the licensee would monitor the
performance of upstream eel passage routes by counting eels in collection tanks positioned at the
upper end of the eel ladders, and through nighttime monitoring of eel behavior and distribution.
In Phase 2, the effectiveness of the individual ladders will be studied using marked eels.
Passability is defined as the ability of juvenile eels to traverse a ladder(s) successfully
(i.e., move from the entrance to the exit). For Phase 1 testing, Woronoco Hydro proposes a
closed-system approach to assess ladder passability. Passability would then be calculated as the
percent of those eels passed successfully:
Passability = (100) a/b, where:
a = number of eels collected at top of ladder, and
b = number of eels introduced to ladder entrance.
Phase 1 study methods generally include:
•
The construction of temporary small exclusion mechanisms (e.g., box trap or
screens) at the downstream entrance of the two existing ladders to exclude
non-test eels from accessing the ladder and to prevent test eels from escaping.
To reduce the time when eels in the river cannot enter an eelway, passability
testing would be conducted sequentially on a ladder-by-ladder basis so that
the amount of time in which physical barriers are installed is minimized.
•
The placement of eels in the downstream entrance, 100 test eels per ladder (or
less if 100 eels are not available);
•
The collection of eels at the top of the ladder(s) to assess overall passability
and timing;
- 16 -
•
The calculation of passability as the ratio between fish released at the entrance
and fish collected at the exit of each ladder;
•
Upon release of test eels into the ladders, Woronoco personnel would monitor
the collection bins at the top of the ladders nightly for a period of 12 to 96
hours to determine success of passage;
•
If passage is deemed to be unsuccessful, subsequent releases would be made
with additional eels (as available), potentially with a modified flow regime.
If eels are not available at the site, Woronoco Hydro would coordinate with nearby hydro
facilities (e.g., Holyoke or West Springfield – formerly DSI) to procure juvenile eels from active
eel trapping and passage facilities. In their comments on the draft Revised Comprehensive Fish
Passage Plan, MDFW, TU, and the USFWS stated that Holyoke is the optimum site for a transfer
of juvenile eels to Woronoco personnel. Because of its length, the Middle ladder has been
modified to allow for portions of the cover to be opened so that Woronoco Hydro personnel can
periodically evaluate passage of eels while in transit to ensure that there are no major bottlenecks
or problem areas in the ladder itself.
Phase I passability testing in 2009 resulted in 100% efficiency in 18 hours from release at
the South ladder and 46% efficiency in 18 hours from time of release in the 205 foot long Middle
ladder. Continued observation of the Middle ladder resulted in 65% efficiency in 27 hours, 83%
efficiency in 42 hours and 93% efficiency in 66 hours from the time of release. While successful,
the Middle ladder test may have slower passage times because within hours after the beginning
of testing, 2 inches of rainfall fell while the test was in progress, causing the dam to overflow and
fill the area at the entrance to the ladder at least five to six feet above its normal water level. The
raised water level may have exposed ladder cover joints that allowed eels that had not progressed
far up the ladder to escape.
As part of Phase 1 testing at the North dam, Woronoco Hydro proposes to continue
nighttime visual observation of eels in the bypass reach below the North Dam and to count eels
that pass up the new North Dam passage route. Woronoco Hydro will consult with the agencies
about both the design of the North ladder and the method for managing the ladder and counting
eel passability in order to keep the operators safe during the late night tests on the rough terrain
- 17 -
below the North Dam. Nighttime survey observations will continue around the station in 2010 to
order to assess the relative abundance and distribution of eels moving upstream below the dam
and in the tailrace. Observations would take place on at least four occasions throughout the
migratory period, at night between the hours of 2200 and 2400 with use of red-bulb flashlights to
facilitate viewing. Observations would take place in all three bypassed reaches under conditions
likely conducive for eel movement; i.e., at night, under cloudy skies, during rain events, and / or
conditions that induce a minimal amount of spill and when flow conditions for nighttime
observation are safe for walking on the rocky ledges and boulder fields below the dams.
Observations would take place in the following locations:
• In the vicinity of the min flow discharge gate at each dam;
• In the vicinity of the existing ladder entrances; and,
• Along the base of each dam where there are pools fed by leaks at crest of the dam.
In addition to providing information about eel distribution, abundance, and behavior at
the Project, observation data would be used to qualitatively determine whether eels are able to
find the ladder entrance(s) and assess the relative percent of fish attracted to the outflow of the
units as compared to the ladders and other natural routes of passage.
Phase 2 would be implemented by Woronoco Hydro in 2010 to assess each ladder‘s
effectiveness. In general, ladder effectiveness will be defined as the ability of a ladder to both
attract and pass eels successfully and is calculated as the percentage of those test specimens
released below the eel ways that are documented as having passed successfully up any of the
ladders. This type of testing is experimental in nature and consideration needs to be given to the
many complicating variables that may affect passage success. Unlike salmon, eels do not home
in on any particular destination during riverine migrations and as such, their distribution and
migratory behavior can be random in nature. Research indicates that upstream migration may be
density-dependent; therefore, if eel density in the project area is low, the migratory “drive” of
eels may be limited. In addition, test specimens cannot be prevented from passing upstream of
the dam by other means (e.g., natural flow over the dam because of dam leaks, rain events, and
spillage). All of these considerations need to be documented and taken into account during
subsequent determination of what threshold delimits passage effectiveness. Woronoco Hydro
expressed concern over these issues during the April 10, 2008, conference call with the involved
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resource agencies. As such, the stakeholders are aware that this type of testing is experimental at
best.
Phase 2 testing includes conducting a mark-recapture study to assess ladder effectiveness.
To mark test animals, an infrared light detectable dye application would be applied to individual
fish prior to release. A target sample size of 100 juvenile eels would be marked and released to
test effectiveness. Test fish will be released at about midstream upstream of the Bridge Street site
at a location downstream of the three active ladders. The evening releases will be made in two
batches of 50 eels each on nights when conditions appear favorable and the count from the night
before indicates that eels are moving. All tagging and release activities would take place at night
under conditions likely to be representative of migratory conditions (e.g., precipitation or spill,
cloud cover, and appropriate water temperature). If eels are not available at the Project,
Woronoco Hydro would coordinate with the staff from the Holyoke Project on the Connecticut
River, with coordination assistance from MDFW, as necessary, to procure juvenile eels from
active eel trapping and passage facilities for testing purposes.
Ladder efficiency would then be calculated using the following formula:
E = (100) (a / b), where:
a = number of eels detected as having successfully passed all ladders combined, and
b = (number of eels released) – (number of eels proven not to have migrated).
4.7
2010 Velocity Testing
Condition D of the July 21, 2009 Order requires:
The licensee shall perform a study to determine water intake velocities at the trashrack
configuration to be used during the annual smolt migration period, through hydraulic
calculations and also through post-installation velocity measurements, and develop
detailed velocity profiles at the trashrack under varying levels of generation, including
full generation. In the study, the licensee shall identify any areas where velocities exceed
2 fps. The licensee shall plan this work, and determine measures to be taken if velocities
greater than 2 fps are found, in consultation with the U.S. Fish and Wildlife Service
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(FWS) and the Massachusetts Division of Fisheries and Wildlife (MDFW), and file a
report on the results of the study with the Commission within 90 days of the date of this
order. If the study cannot be performed within this time frame, the licensee shall instead
file a schedule with the Commission, within 90 days of the date of this order, for
completing the study and filing the report with the Commission before April 15, 2010.
The report filed with the Commission shall include copies of any correspondence with the
FWS and the MDFW regarding the study, and any measures that need to be taken as a
result of the study, and include a description of how any identified measures are being
handled.
Woronoco Hydro is also proposing to evaluate the expected water velocity through a
combination of hydraulic calculations based on screen size and open area, as well as through the
collection of post-installation velocity measurements. Velocity measurements of the intake will
occur after installation of the new protection rack panels at the start of the 2010 passage season
and, if appropriate, again after installation of the proposed bypass facility. Velocity
measurements will be taken at approximate water depths of 2, 5, 8, 11 and 13 ft. Measurements
will occur at approximately 4-foot increments across the intake area with the increment level
decreased to 2-foot at the penstock inlet area. Measurements will occur at the rack face and 3
feet upstream of the rack face.
Intake velocities will be obtained at 100%, and 80% unit gate settings with all three units
in operation. Additional velocities may also be taken at other unit operational limits, such as
two-unit operation, if initial data collection warrants or indicates the need for additional data.
Should areas of high intake velocities occur (those exceeding 2 feet-per-second); additional data
will be collected in an attempt to define the location of hot spots and the extent of these areas of
high velocity. Limited velocity measurements will also be obtained during spill conditions.
The test results will be presented to the stakeholders in graphical form to permit
reviewing staff to understand the hydraulics at the intake. In addition, the data will be provided
in tabular form for stakeholder independent analysis. If required, Woronoco will propose
appropriate measures to mitigate exceedance of the velocity criteria established for the site.
Such measures may include operational restrictions or intake reconfiguration. The results will
also be used to modify, if appropriate, the details of the new downstream fish passage system.
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5.0
SCHEDULE
5.1
Downstream Eel and Fish Protection Panels
Woronoco Hydro has begun fabrication of the removable intake screens to be installed at
the project. Screen installation is anticipated to begin by March 15, 2010 and be completed by
the April 1st start of the smolt passage season.
5.2
Intake Velocity Study
The intake velocity testing will occur after completion of the protection panel installation.
Velocity testing will occur within 7 days after installation is completed or, as soon thereafter,
that sufficient river flow exists to permit plant operation required for the test. Woronoco will
consult with USFWS and MDFW if hot spots are found and, after consultation, will implement
approved modifications to mitigate their potential impact on 2010 smolt passage. The draft test
report will be filed within one week after completion of testing and analysis. The report will
include proposed remedial measures, if required. Filing of the draft report is anticipated to occur
by April 16, 2010 with the final report filed with the Commission by May 31, 2010.
5.3
Downstream Fish Passage Facility
The new downstream fish bypass system is currently being designed. The design will be
submitted for stakeholder review by March 1, 2010. Upon receipt of the comments, the final
design details of the system will be issued for Commission approval. The bypass details may be
modified to incorporate the results of the intake velocity-testing program. Commission filing of
the final downstream passage details is anticipated to occur by May 3, 2010. Pending
Commission approval, the proposed downstream fish passage facility will be installed during the
2010 construction season. Final operational test are anticipated to occur by September 30, 2010.
5.4
Effectiveness Testing of Smolt Passage Systems:
Filing of the detailed testing plan is anticipated to occur by November 2010 after
consultation with the stakeholders. Downstream passage effectiveness testing for the successful
- 21 -
passage of smolts will occur in late April and early May of 2011 and , if possible, in conjunction
with testing at the upstream Indian River Project. Timing of release of the tagged fish would be
determined based on flows and water temperature. The licensee will consult with the USFWS,
MDFW, MDEP and TU to determine appropriate steps if the initiation of testing is determined to
be impossible because of high flows, water temperature or equipment malfunction.
Woronoco Hydro will prepare a summary report of all testing results for agency review
by July 2011. Upon receipt of the agency review comments and recommendations, the final
report will be filed with the Commission. The final report is anticipated to be filed with the
Commission by September 2011. Modifications to the passage systems or additional testing, if
required, will be implemented at earliest construction period after approval from the Commission
of the report and the report recommendations.
5.5
Downstream Adult Eel Passage Testing
Visual monitoring for the passage of out-migrating adult American eels will occur in the
fall of 2010 following the procedures described in Section 4.5 above. An on-site meeting will be
conducted with the stakeholders to finalize the details of the live box design and passage
efficiency testing procedures and location of monitoring devices in the summer of 2010. The
results of the on-site meeting will include a finalization of the schedule to conduct the passage
test.
5.6
Effectiveness Testing of Juvenile Eel Passage Systems and North Eel Ladder:
Per Condition B of the July 23, 2009 Order, a draft of the 2009 Phase 1 upstream juvenile
eel passage effectiveness study report was supplied to the stakeholders by December 31, 2009
and a final version filed with the Commission is required to be filed by February 28, 2010. The
Phase 1 report will include:
•
Details of any modifications to the methods to be used in the Phase 2 study, based
on site-specific information and comments received from the stakeholders.
•
Schedule to conduct the Phase 2 study, draft and final report filing.
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•
An assessment of the need to replace the North Channel (Dam) ladder.
•
Agency consultation and responses.
The Phase 1 report also contains the proposed schedule to install the North ladder by July
31, 2010.
Phase 2 tests will begin after installation of the North ladder and completion of the Phase 1
testing of the North ladder. Phase 2 testing will be conducted during the 2010 upstream migration
season, with final timing dependent upon observation of eel movements at other facilities. The Phase
II test data will be submitted for agency review by December 31, 2010 and a final report with agency
comments will be filed at FERC by February 28, 2011.
- 23 -
5.7
Summary Schedule:
The overall study and installation schedule for all provisions of this Plan is summarized
below:
Intake Protection Panels
Install by April 1, 2010
Intake Velocity Testing
April 2010
Velocity Draft Report
April 16, 2010
Velocity Final Report
May 31, 2010
Downstream Passage Draft Details
March 1, 2010
Downstream Passage Final Details
May 3, 2010
Downstream Passage Installation
July 2010
Downstream Passage Operational Testing
September 2010
Smolt Test Draft Plan
November 2010
Smolt Test Final Plan
January 2011
Smolt Testing
April/May 2011
Smolt Draft Test Report
July 15, 2011
Smolt Final Test Report
September 15, 2011
Adult Eel Test Program Development
June 2010
Adult Eel Monitoring
September 2010
North Eel Ladder Installation
July 2010
Phase 2 Upstream Eel Testing
Between August and October 2010
Phase 2 Eel Test Draft Report
December 31, 2010
Phase 2 Eel Test Final Report
January 28, 2011
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6.0
SUMMARY OF JULY 21 ORDER RESPONSE
Details of the information required by the July 21, 2009 Commission order has been
provided in the preceding Plan sections and are summarized below:
6.1
Condition B of the Order:
Condition B of the July 21, 2009 Order states:
The licensee shall file, within 90 days of the date of this order, for Commission approval,
a plan and schedule for the annual installation and removal of trashrack overlays, or for
the installation of new permanent trashracks, as appropriate. The licensee shall consult
with the U.S. Fish and Wildlife Service and Massachusetts Division of Fisheries and
Wildlife regarding planning and scheduling of the trashrack configuration work, and
provide copies of any comments received from the agencies, or evidence that the agencies
were given 30 days in which to provide comments and chose not to do so.
This 2009 Comprehensive Fish Passage Plan provides the materials required by this
condition. Section 3.2 provides the plan and Section 6.1 provides the schedule for the
installation and removal of the intake protection screen system. Appendix A provides details of
the trashrack protection screens. Appendix B provides copies of agency consultation comments.
6.2
Condition C of the Order:
Condition C of the July 21, 2009 Order states:
Pursuant to paragraphs 12.4, 12.11, and 12.40 of the Commission's regulations, a plans
and specifications package and a quality control and inspection program shall be
submitted to the Commission’s New York Regional Director if new trashracks are to be
permanently installed. Authorization to start construction activities will be given by the
Regional Director after all preconstruction requirements are satisfied. We encourage the
licensee to contact the regional office as soon as possible regarding these requirements.
Submittals to the Regional Director shall be made well in advance of facilities
installation. In addition, as-built drawings of any new trashrack installation shall be
filed, for Commission approval, within 90 days following installation.
The trashrack panel details were submitted for Commission approval on December 24,
2009. Woronoco continues to work with the New York Regional Office to obtain approval of
the proposed trashrack changes.
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6.3
Condition D of the Order:
Condition D of the July 21, 2009 Order states:
The licensee shall perform a study to determine water intake velocities at the trashrack
configuration to be used during the annual smolt migration period, through hydraulic
calculations and also through post-installation velocity measurements, and develop
detailed velocity profiles at the trashrack under varying levels of generation, including
full generation. In the study, the licensee shall identify any areas where velocities exceed
2 fps. The licensee shall plan this work, and determine measures to be taken if velocities
greater than 2 fps are found, in consultation with the U.S. Fish and Wildlife Service
(FWS) and the Massachusetts Division of Fisheries and Wildlife (MDFW), and file a
report on the results of the study with the Commission within 90 days of the date of this
order. If the study cannot be performed within this time frame, the licensee shall instead
file a schedule with the Commission, within 90 days of the date of this order, for
completing the study and filing the report with the Commission before April 15, 2010.
The report filed with the Commission shall include copies of any correspondence with the
FWS and the MDFW regarding the study, and any measures that need to be taken as a
result of the study, and include a description of how any identified measures are being
handled.
condition. Section 4.7 provides the plan and Section 6.1 provides the schedule for the evaluation
of the intake velocities at the project. Appendix B provides copies of agency consultation
comments. The Plan has been revised to incorporate the recommendations of the USFWS and
TU. The USFWS and MDFW support the testing schedule.
6.4
Condition E of the Order:
Condition E of the July 21, 2009 Order states:
The licensee shall file, within 90 days of the date of this order, for Commission approval,
a plan and schedule for the evaluation of the effectiveness of downstream Atlantic salmon
smolt passage at the project, with the new trashrack configuration installed, during
spring 2010. The plan shall include a description of the study methodologies to be
employed, and address the issues identified by the U.S. Fish and Wildlife Service (FWS),
Massachusetts Division of Fisheries and Wildlife (MDFW), and Trout Unlimited, as
reviewed in this order. The plan shall be written in consultation with the FWS and the
MDFW, and include copies of recommendations from these agencies on a draft version of
the plan, or evidence that the agencies were given 30 days in which to provide
recommendations and did not do so. If the licensee does not adopt an agency
recommendation, the filing shall include the licensee’s reasons, based on site specific
information. The licensee shall ensure that the plan includes a schedule for: (1)
- 26 -
implementing the proposed study; (2) consulting with the resource agencies concerning
the results of the study; and (3) filing the results of the study, resource agency comments
on the results, and the licensee’s response to agency comments. The Commission reserves
the right to require modification of the plan to ensure collection of adequate information
to ensure protection and downstream passage of Atlantic salmon smolts at the project.
condition. Section 4.3 provides the plan and Section 6.4 provides the schedule for the evaluation
of the effectiveness of downstream Atlantic salmon smolt passage at the Project. Appendix B
provides copies of agency consultation comments. The USFWS and MDFW support the testing
plan details and schedule.
6.5
Condition F of the Order:
Condition F of the July 21, 2009 Order states:
The licensee shall file, for Commission approval, an operation plan for annual
downstream smolt passage, at the same time that the results of the downstream passage
study results required above are filed. The plan shall be based upon the licensee’s
effectiveness studies and any recommendations provided by the U.S. Fish and Wildlife
Service (FWS) and the Massachusetts Division of Fisheries and Wildlife (MDFW). The
operation plan shall identify the annual period in which the downstream passage facility
will be operated, including installation and removal of trashrack overlays, if a permanent
rack with 1-inch bar spacing is not to be installed. The operation plan shall include a
schedule for inspection, adjustments, cleaning, and maintenance of each downstream fish
protection and passage component. The plan shall be accompanied by copies of
comments and recommendations from the FWS and the MDFW, or evidence that the
agencies were given at least 30 days to comment on the plan, and chose not to do so. If
the licensee does not adopt an agency recommendation, the plan shall include the
licensee’s reasons, based on site-specific information.
condition. If required the Plan will be revised based on the 2011 testing results of the passage
systems. Section 3.1 identifies the annual period in which the downstream passage facility will
be operated and the schedule for inspection, adjustments, cleaning and maintenance of each
downstream fish protection and passage component. Section 3.2 provides the installation and
removal schedule of the protection screens and the maintenance details for the new screen
system. Appendix B provides copies of agency consultation comments.
- 27 -
APPENDIX A
Conceptual Downstream Fish Passage and Intake Rack System
APPENDIX B
Consultation and Meeting Notes
Meeting Minutes
Woronoco Project (FERC No. 2631)
ATTENDEES:
William Faye, Woronoco Hydro
W. Davis Hobbs, Woronoco Hydro
Caleb Slater, MA Div. of Fish & Wildlife
Alfred Nash, Renewable Power Consulting
DATE:
December 9, 2009
A meeting was held in the MA Division of Fish and Wildlife offices to review various
project compliance items associated with the Woronoco development (FERC No. 2631) on the
Westfield River. The meeting was requested by Woronoco Hydro LLC (Woronoco) to specifically
discuss Woronoco’s application to the Low Impact Hydropower Institute (LIHI), downstream fish
passage testing, and upstream eel passage testing.
1.0
LIHI Certification Request
Woronoco explained that the new Renewable Energy Portfolio Standard Regulations require
that any hydroelectric project wishing to qualify as either a RPS I or RPS II generator first obtain
LIHI certification. LIHI requires a letter from the MA DFW indicating that the development could
be considered for certification. Caleb acknowledged that the project would be considered low
impact once the fish passage was proved effective. Caleb would not provide a letter supporting
certification until the passage testing was complete. Caleb was willing to supply a conditional letter
indicating that while not currently certifiable, upon completion of testing it could be. Woronoco
agreed to send Caleb a letter template to expedite the process.
Woronoco explained the financial structure and status of the development. Installation of
flashboards would increase development revenues by around $100,000 annually. Because of the
potential revenue increase Woronoco may explore installation of flashboards at the site. Woronoco
is applying for a grant from the Massachusetts Technology Collaborative (MTC) to perform studies
associated with flashboard installation and requested an initial brief listing of key areas of concern
for Caleb’s agency. Caleb indicated that the MA Department of Environmental Projection (DEP)
would be the lead agency in study development but that his agency would be concerned with habitat
impacts. Woronoco noted the potential fish passage enhancements and ability to better pass fish
during spill events through the use of crest gates. Caleb noted that raising the impoundment will
Page 1 of 4
negatively impact free flow and wetland areas. In addition the MADFW resist new dam
construction and installation of the flashboards would have a similar effect as new dam
construction. Caleb suggested that Woronoco make a decision on whether they wanted flashboards
or certification since they could not have both. Caleb would not support certification if flashboards
were installed at the dam.
2.0
Fish Passage Concept and Testing
Caleb expressed his concern over the Project’s passage effectiveness. He noted that since
the second and third units have been returned to service his counts of returning salmon downstream
have been reduced. Caleb did acknowledge that the reduced counts may be from other factors and
that variation in counts are not untypical and are generally unexplainable. Woronoco took
exception to Caleb’s statements (made in another forum) that Woronoco was killing stocked smolts
and that Woronoco has been non-responsive to passage testing. Woronoco noted the previous
testing occurring at the site and the on-going changes to the passage system. Caleb acknowledged
Woronoco has been working at the site but felt the progress needs to be faster since many years
have gone by without resolution.
The existing passage system was originally install as a “temporary” system and is not in the
ideal location for fish passage. Woronoco noted its financial distress at the project requiring new
loans and acknowledged Caleb’s statement that his agency was not responsible to maintain the
economic viability of a project. Woronoco indicated that the significant costs associated with
testing and the current financial strain of the project has caused Woronoco to reexamine fish
passage at the project.
The recent discussions at Indian River have led Woronoco to propose installation of a
similar system at the Woronoco development. The new system would provide a single entrance
through the racks with discharge into the existing plunge pool. Caleb would not comment on the
technical details of the proposed system but acknowledged that the system would likely be an
enhancement over the current bypass.
The expected timeline to install a new fish passage would be the summer of 2010.
Woronoco reiterated that they want to test the system with the highest probability of success and
avoid the repeated cost to conduct effectiveness testing. Testing the current system does not, in
Woronoco judgment, offer the best chance of success. Caleb was not sure that the enhanced system
would justify a delay in testing but he would discuss this with other agencies.
Woronoco agreed to not tie testing of the Woronoco site to testing at the Indian River site.
While this is Woronoco’s goal, Woronoco will not use delay in testing at Indian River as a reason to
delay testing at Woronoco. Woronoco and Caleb noted that should concurrent testing occur the
Page 2 of 4
testing protocol may need to maintain some of the test fish for a release at Woronoco should
passage delays occur at Indian River during testing. Caleb’s experience is that fish should move
through the system quickly but test results must be closely followed to allow for adjustments should
fish not pass the Indian River site.
The group also discussed the required velocity testing and trash boom design. Caleb did not
have any input regarding the velocity test methodology. Caleb felt that deep booms (with
submerged face) caused the migrants to sound under the boom and then defeated the use of a
surface sluice bypass. He noted examples of systems with booms leading directly to the bypass
often are ineffective.
3.0
The general results of the 2009 eel counts were briefly discussed. Woronoco is finalizing
the report and requested count data from the downstream project for comparison purposes. Caleb
has not seen any data but will pursue obtaining any available information. Overall Caleb was
pleased with the numbers passing the site.
Phase 2 testing. The marking technique and details of the upstream eel ladder was
discussed. Caleb noted that Holyoke uses dye to mark their eels and suggested Woronoco talk with
them to find out more information. Caleb indicated that the Phase 2 test was mostly to determine
the effectiveness of the eels locating the ladder (Phase 1 documented effectiveness of eels passing
through the ladder once they enter it). Migrants can be placed slightly downstream of the entrance
for the test. The test would be conducted during the 2010 passage season with eels from Holyoke if
available or from the on-site ladders if other sources were not available.
The North ladder was also discussed. The North Channel is required to pass a minimum
flow for habitat and therefore eels are expected to travel up this channel. Woronoco confirmed that
eels were observed in various pools near the discharge gate and exposed ledges. Eels were found
in perched pools after spill events. Caleb was open to any ladder option including from the perched
pool. The main concern with the perched pools was the potential for high water temperature and
the inability for eels to move from the pools during non-spill conditions.
Page 3 of 4
4.0
Follow-Up Actions
•
•
•
•
•
•
Caleb will attempt to provide eel count data from the downstream project.
Caleb will discuss the testing schedule with the USFWS.
Woronoco will provide Caleb with a LIHI letter template for his use.
Woronoco to determine if it will pursue the revised downstream fish passage
concept. Woronoco to begin consultation process if the plan is to proceed.
Woronoco to investigate the use of dye for the Phase 2 eel testing.
Woronoco will develop a proposal for the North eel ladder.
C:\RPC Projects\403 Woronoco\Agency Consultation\006_403001 MADFW 120909 Mtg notes_FINAL_121809.docx
Page 4 of 4
December 14, 2009
VIA EMAIL AND MAIL
Mr. Caleb Slater
Anadromous Fish Team Leader
Commonwealth of Massachusetts
Division of Fisheries and Wildlife
Field Headquarters
1 Rabbit Hill Rd
Westborough, MA 01581
John P. Warner
Energy/Hydropower Coordinator
New England Field Office
U.S. Fish and Wildlife Service
70 Commercial Street, Suite 300
Concord, NH 03301
Mr. Robert Kubit
Massachusetts Department of Environmental Protection
Division of Water Quality
67 Main Street, 2nd Floor
Worcester, MA 01608
Woronoco Project (FERC No. 2631)
Revised Comprehensive Fish Passage Plan – Article 404
Dear Sirs:
Woronoco Hydro, LLC (Woronoco Hydro) owns and operates the Woronoco
Hydroelectric Project (Project), which is licensed by the Federal Energy Regulatory Commission
(FERC) as FERC Project No. 2631. Condition E of the Order Approving Downstream Atlantic
Salmon Smolt Passage Effectiveness Report and Requiring Further Actions Pursuant to License
Article 404 issued July 21, 2009 states:
The licensee shall file, for Commission approval, an operation plan for annual
downstream smolt passage, at the same time that the results of the downstream passage
study results required above are filed. The plan shall be based upon the licensee’s
effectiveness studies and any recommendations provided by the U.S. Fish and Wildlife
Service (FWS) and the Massachusetts Division of Fisheries and Wildlife (MDFW). The
operation plan shall identify the annual period in which the downstream passage facility
will be operated, including installation and removal of trashrack overlays, if a permanent
rack with 1-inch bar spacing is not to be installed. The operation plan shall include a
P.O. Box 195 • Palmyra, ME 04965 • Phone: 207-992-3926 Shipping: 43 Spaulding Road, Palmyra, ME 04965
Mr. Slater, Mr. Warner, Mr. Kubit
December 14, 2009
2.
schedule for inspection, adjustments, cleaning, and maintenance of each downstream fish
protection and passage component. The plan shall be accompanied by copies of
comments and recommendations from the FWS and the MDFW, or evidence that the
agencies were given at least 30 days to comment on the plan, and chose not to do so. If
the licensee does not adopt an agency recommendation, the plan shall include the
licensee’s reasons, based on site-specific information. The licensee shall file, within 90
days of the date of this order, for Commission approval, a plan and schedule for the
annual installation and removal of trashrack overlays, or for the installation of new
permanent trashracks, as appropriate. The licensee shall consult with the U.S. Fish and
Wildlife Service and Massachusetts Division of Fisheries and Wildlife regarding
planning and scheduling of the trashrack configuration work, and provide copies of any
comments received from the agencies, or evidence that the agencies were given 30 days
in which to provide comments and chose not to do so.
Woronoco previously provided details of the installation schedule and details of the
proposed intake rack panels to prevent entrainment at the site on October 30, 2009. The attached
2009 Comprehensive Fish Passage Plan (Plan) is being provided for your review and comment.
The previously approved Plan has been modified to incorporate various discussions, results and
changes that have occurred since approval of the August 2008 Revised Comprehensive Fish
Passage Plan (2008 Plan). Section 2.2 has been revised to include a description of the new fish
passage system being proposed at the intake area. Section 3 of the Plan remains the same as the
2008 Plan except for the addition of the rack panel operation and maintenance section. Section 4
(Previous and Proposed Studies) has been expanded to provide a synopsis of the 2005 and 2008
effectiveness testing and details the proposed future testing, which is consistent with the
effectiveness testing conducted in 2008. Section 5 contains an updated Schedule of the proposed
studies and fish passage installation schedule.
The February 25, 2008 letter (attached for reference) outlined the financial constraints
associated with the Project. While the March 5, 2008 response from the USFWS correctly noted
that Woronoco was aware of the compliance requirements of the Project, Woronoco has
experienced significant cost overruns for items both within and beyond Woronoco’s control.
Now, the dramatic drop in 2009 energy prices has cut revenue by 60%, the cost to install ¾” bar
opening protection rack panels along with installing the Cross Machine automatic rake needed
for continuous cleaning of ¾” bar openings, plus cost of the rake and overages incurred during
the 2008 effectiveness testing have combined to strain the financial resources available for
project development. Thus, the project is applying for additional grant and bank funding.
Financial delay, combined with the time it will take for agency consultation about relocation of
the fish passage entrance into the racks and the need for other testing discussed below, requires
Woronoco to seek postponement of smolt passage testing until the 2011 migration season when
Woronoco’s passage changes will have been installed and a two-station passage effectiveness
test with Indian River (FERC No. 12462) would be possible.
Woronoco participated in the recent consultations for the passage design at the upstream
Indian River development, which suggests an enhanced passage system at Woronoco could
Mr. Slater, Mr. Warner, Mr. Kubit
December 14, 2009
3.
potentially be realized through installation of an intake passage system similar to the design
Indian River developed in collaboration with the resource agency. Woronoco also recognizes
that should its current bypass system have low effectiveness, a new passage design, such as
being proposed for Indian River may be required. Any new system would require effectiveness
testing. Given the high cost of such testing and the project’s financial constraints, Woronoco
desires to provide a fish passage system with the highest probability of satisfying stakeholder
requirements to avoid future testing beyond the currently required testing.
Based upon the Indian River discussion, Woronoco has shown USFWS and MDFW
officials a preliminary design of an intake bypass system (Appendix A of the Plan) that would be
installed during the 2010 construction season. Woronoco knows that a significant change in
design will require that the new system be tested to confirm passage efficiency and that testing of
its current system would be moot. Therefore, Woronoco does not believe testing of its
unenhanced passage facility in 2010 would be beneficial and likely would be a waste of financial
resources. Woronoco proposes to install the entrance to its fish passage system in summer 2010
and to conduct effectiveness testing during the 2011 migration season. If possible the test would
be performed in conjunction with the Indian River testing but would not be required to conduct
the testing concurrently should Indian River experience unexpected delays.
As the agencies are aware, Woronoco staff is significantly involved with construction and
redevelopment of the upstream Indian River Project. The Indian River Project has received
separate funding to redevelop and conduct passage testing. While these funds are not available
for use at the Woronoco Project, the Indian River Project funding includes the funds required to
conduct fish passage effectiveness testing in 2011 when both Indian River turbines are installed.
Woronoco proposes to conduct the next effectiveness test in conjunction with testing at the
Indian River Project, if possible, to obtain part of the funds necessary to conduct the test.
The 2008 Downstream Atlantic Salmon Smolt Passage Report (2008 Report) provided
limited and inconclusive test data with the proposed intake screening system installed. A new
design will significantly improve on the temporary, hastily installed 1-inch bar-opening screens
tested in the 2008 effectiveness test program. The new system will avoid the gaps believed to
have been present at the bottom of the hastily installed overlays during the 2008 test (and
subsequent entrainment of 2 of 16 test fish) and have an automated rack cleaner to continuously
prevent blockages that increase velocities in front of the racks. Also, Woronoco has elected to
install ¾-inch clear bar racks versus the required 1-inch clear-space bar racks to protect against
adult eel entrainment as recommended by USFWS. Although inconclusive, the 2008 Report did
note that the protection screens were a significant enhancement against entrainment. While
Woronoco maintains that test result indicated above 70% effectiveness, the resource agencies
have calculated effectiveness as slightly above 50%. Regardless of which effectiveness rate is
correct, Woronoco has implemented protection enhancements to increase future effectiveness
and will have installed racks to prevent smolt entrainment before April 1, 2010. Woronoco
requests you to include this fact during your assessment of the risk from delayed testing.
ATTACHMENT 1
February 25, 2008 Letter
20080227-5056 FERC PDF (Unofficial) 02/27/2008 05:17:29 PM
Extension of Time Request - Woronoco Hydroelectric Project (FERC No. 2631)
February 27, 2008
Woronoco Hydro LLC
PO Box 149, Hamilton, MA 01936
pclark@swiftriverhydro.com
February 25, 2008
John P. Warner
US Fish and Wildlife Service
Concord, New Hampshire 03301
Caleb Slater
Massachusetts Department of Fish and Wildlife
1 Rabbit Hill Road
Westboro, MA 01581
Robert Kubit
Massachusetts Department of Environmental Protection
Division of Water Quality
67 Main Street, 2nd Floor
Worcester, MA 01608
Donald Pugh
Trout Unlimited
Deerfield/Millers River Chapter
10 Old Stage Road
Wendell, MA 01379
Re: Woronoco Hydro’s Inability to Carry Out Downstream Smolt Passage Tests in 2008
Gentlemen:
As you know, Woronoco Hydro retained Kleinschmidt to conduct a downstream smolt
passage test this April. However, it is our understanding that the test will only be applicable if
all three turbines are generating, and if the site is fully functional and operating as it will in the
future. At our two site meetings last summer, you saw that the intake area was complete with the
automatic intake gate, plunge pool and adjustable gates at both the chute and at the discharge of
the plunge pool. You saw two of the three rafts that will support the angled lead (10’ deep
aluminum screens that hang from the rafts) to direct migrating smolt directly to the intake of the
chute. We recently found that the underwater cables for these rafts were installed incorrectly and
we are in the process of contracting divers to reinstall them with the proper tensions so we can
determine if they will effectively remain in place and function during high spring flows.
However, there are several additional problems that have come up that make the smolt passage
test this year impractical and may result in our having to abort testing at the last minute.
11.
February 27, 2008
Therefore, we are asking you to reconsider the schedule and suggest that it would be far
better to carry out the tests after construction work at Woronoco Hydro has been fully completed,
that is, in spring 2009.
First, let me give you some background and a progress report on the rehab work at
Woronoco Hydro since your last site visit. After renewing its FERC license, Woronoco Hydro
obtained a $2 million loan to refurbish the equipment and civil structures of the 90-year old
hydro plant. The work commenced in July 2006 when we dewatered the intake structures,
penstock and equipment. The plant remained off line for more than 9 months. The first task was
to locate a new substation on the powerhouse side of the river in order to decommission the
oversized transformers used previously for the Strathmore Paper mill. This took about four
months, delaying work on the intake structures and the relining of the penstock. Woronoco
Hydro also ordered a steel intake gate for emergency closure of the penstock that was finally
installed in March and April 2007. The shotcrete penstock lining did not pass its acceptance
tests, so this too delayed resuming generation, but we were able to rehab one of the two low flow
turbines in the powerhouse. Being off line for nine months seriously damaged the finances of the
project. These delays forced Woronoco Hydro to increase its debt to $2.8 million.
Construction continued during the summer of 2007 when the cables in the forebay were
installed to hold the angled lead in position. The rafts were assembled, and screens hung.
However, later in the summer, all the aluminum screens were stolen from the site. We have reordered the aluminum screens and plan to shutdown while divers change the cable lengths when
the ice flows pass. We still have to rebuild the discharge gate for the plunge pool and to adjust
the angled lead and entrance to the chute. This work is almost impossible with ice and flood
flows. We think the whole passage system and fish lead are experimental in design and thus will
need to be changed as we assemble it. Thus, we cannot risk conducting the telemetry study
without having a season to complete and fine-tune components of the passage system just
constructed, and to generate needed capital.
In July and August of 2007, construction of the three eel ladders was finished, after
modifying the work following site visits by your agencies, including changes recommended by
Alex Haro of the USGS. The test collection containers were installed in September, but we did
not collect any eels during the fall. Therefore, with your guidance, and as part of our modified
Comprehensive Fish Passage Plan (pending), Woronoco will conduct upstream effectiveness
testing for juvenile eels this year. We will bring eels from the dam immediately downstream, or
other local sources, to assess upstream efficiency by collecting them in the holding pens installed
at each ladder. Much of the 2008 summer will be devoted to perfecting the eel ladders.
Woronoco is now approximately 4 weeks from the start up of the third turbine on which
the crew has worked all winter. However, we cannot guarantee that it will be on line by the
proposed start date for the smolt passage tests. Furthermore, must shut the station down while
we wire the new unit into the substation and switchgear. Woronoco Hydro must finish its
construction program in order to get back to generating this spring because the project is in
serious financial difficulty due to construction delays and cost overruns. The project ran deficits
throughout 2007, although they are less each month. Woronoco’s February 21, 2008 Profit and
Loss statement shows a net 2008 deficit of ($111,267). This is better than last year; for example,
take the period from July 2007 to December 2007 (last half year), Net Income was ($142,612)
and if we take all of 2007 until today, Woronoco Hydro’s Net Income is ($188,546). Thus, in
12.
February 27, 2008
order to pay debt service in January 2008, Woronoco had to draw down its line of credit with the
term lender. The project no longer has any reserves left for the next debt service payment, yet
construction is still not complete. Given that the cost of the telemetry study will amount to
approximately $100,000 (Kleinschmidt’s costs of $62,000 plus our direct costs for labor and
expenses of $35,000 to $40,000), this study will clearly put Woronoco Hydro into default with
the bank that made the long term loan.
As explained above, Woronoco Hydro must still complete its construction plan that cost
it $2.8 million in debt and another $1.0 million in owner’s equity. We are about to bring the
program to completion, after which we have to ensure that all the refurbished equipment is
broken in and monitored carefully during the next six months. Committing to add another
$100,000 of cost to the project and contracting for things that we know the project cannot pay for
in its present financial condition is not responsible. Therefore, we request that the proposed 2008
downstream smolt passage tests be rescheduled for April 2009. In the meantime, we commit to
finishing all components of the passage system just as if we were going to run the test this year.
We will devote the extra staff time to making qualitative visual observations of smolt passage via
the chute to assess whether the installed components actually work. We will work to test our
angled lead, to change cable lengths when it is safe to use divers, to refine the discharge of the
plunge pool and to observe whether screening of the trash racks themselves will be necessary
close to the intake of the chute to prevent migrants from hesitating at the chute entrance. We will
also correct submergence and flow rates into the chute as impoundment levels vary during the
smolt migration season.
We recommend that 2008 be used to fine-tune all the elements of the passage system to
see that they are in balance before we undertake the proposed radio-telemetry test. If it is
apparent through observation that the modified fish passage chute works, we will commence an
efficiency study in 2009. Another advantage of postponing the test is that it makes it more likely
that Indian River Power Supply’s downstream fish passage facility will also be tested in 2009.
This will potentially allow us to test both project developments to monitor fish as they move
from above the Russell Dam to below the Woronoco Dam for a two facility test in 2009.
We are disappointed that Woronoco Hydro has not yet finished its construction and
therefore is not ready to make the proposed tests in 2008. In October 2007, we recommended a
stop-gap test using the same methodology as the 2005 PIT tag study made prior to the plant
shutting down for two years of construction and rehab work. You rejected this proposal, but we
now see the advantage that telemetry may bring in allowing us to assess fish passage, and can
commit to it in 2009 with the study design you proposed in recent consultation with
Kleinschmidt (e.g., increased sample size and additional telemetry receivers/antennas).
However, it would be irresponsible to proceed in 2008 knowing that the project would
potentially be forced to shutdown after defaulting on its debt service payments on April 1st, just
when we have to run the tests. Woronoco Hydro needs the funds saved by postponing the smolt
study to pay its quarterly debt service on April 1st.
Please let me know as quickly as possible if you will support Woronoco’s revised
schedule. We must let Peter Yarrington at FERC know what is being planned next week. This
revised schedule will also allow us to consult with you over the coming weeks to re-develop our
Comprehensive Fish Passage Plan so that we can effectively address all remaining fish passage
issues of concern at the two sites. Jesse Wechsler (Kleinschmidt) will be helping us put the
13.
February 27, 2008
Revised Comprehensive Fish Passage Plan together for submission to FERC after we request a
45-day extension to allow for consultation with the resource agencies during the month of March
2008 when you are least busy with field work. Having to revise the plan at the same time as
undertaking the changes in the passage system would put too much strain on our staff and
resources in the next month. This too is a reasonable justification for modifying the plan now
with your full input, and carrying it out in 2009.
Sincerely,
Peter B. Clark
Manager
14.
Commonwealth of Massachusetts
Wayne F. MacCallum, Director
December 29, 2009
Alfred Nash, P.E.
43 Spaulding Road
P.O. Box 195
Palmyra, ME 04965
RE:
Draft Fish Passage Plan
Woronoco Project, Westfield River
FERC Project No. 2631
Dear Mr. Nash:
The Massachusetts Division of Fisheries and Wildlife (Division) is the agency responsible for the
protection and management of the fish and wildlife resources of the Commonwealth. As such we monitor
operations at hydroelectric projects within the Commonwealth. The Division has the following comments
in response to the Revised Comprehensive Fish Passage Plan – Article 404 for the Woronoco Hydroelectric
Project, located on the Westfield River, in Russell, Massachusetts. The Division received the plan as an
attachment to an electronic mail message on December 14, 2009.
The plan proposes:
The installation of ¾ inch clear space Downstream Fish Protection Panels at the project turbine intake
starting March 15, 2010 to be completed by April 1st (start of the smolt passage season).
An Intake Velocity Study to occur after completion of the protection panel installation. Velocity testing
will occur within 7 days after installation completion or as soon thereafter, that sufficient river flow exists
to permit plant operation required for the test. The draft test report will be filed within one week after
completion of testing and analysis. The report will include proposed remedial measures, if required. Filing
of the draft report is anticipated to occur by April 16, 2010 with the final report filed with the Commission
by May 31, 2010.
Construction of a new Downstream Fish Passage Facility during the 2010 summer season.
The design of the new downstream fish passage system has been submitted for stakeholder review. Upon
receipt of the comments the final design details of the system will be developed and issued for Commission
approval. Commission filing of the final downstream passage details is anticipated to occur by April 2010.
Filing of a detailed Downstream Fish Passage Effectiveness Testing Plan is anticipated to occur by
November 2010. Downstream passage effectiveness testing for the successful passage of smolts will occur
in late April and early May of 2011 and, if possible, in conjunction with testing at the upstream Indian
River Project. Timing of release of the tagged fish would be determined based on flows and water
temperature.
Effectiveness Testing of Eel Passage Systems and North Eel Ladder: Per Condition B of the July 23,
2009 FERC Order, a draft of the 2009 Phase 1 upstream eel passage effectiveness study report will be
supplied to the stakeholders by December 31, 2009 and a final version filed with the Commission by
www.masswildlife.org
Division of Fisheries and Wildlife
Field Headquarters, One Rabbit Hill Road, Westborough, MA 01581 (508) 389-6300 Fax (508) 389-7890
An Agency of the Department of Fisheries, Wildlife & Environmental Law Enforcement
February 28, 2010. The Phase 1 report will contain the proposed schedule to install the North Channel
ladder, if required.
Division Comments
After consultation with the USFWS, MADEP, and TU the Division accepts the schedule proposed in the
fish passage plan. (3/4 inch racks to be installed by April 1, 2010. Intake velocity tests as soon as possible
after rack installation. Installation of new downstream fish passage structure- as approved by USFWS, TU,
MADEP, and the Division- during summer 2010. Effectiveness testing for the new system in spring of
2011.
The Division will comment on the eel passage plan in a separate letter, however upstream and downstream
eel passage should be included in the final comprehensive fish passage plan.
Thank you for the opportunity to comment.
Sincerely,
Caleb Slater
Anadromous Fish Project Leader
508.389.6331
DEERFIELD/MILLERS CHAPTER
10 Old Stage Road
Wendell, MA 01379
December 30, 2009
Re: Project #2631, 2009 Comprehensive Fish Plan
Peter Clark
Woronoco Hydro LLC
PO Box 149
Hamilton, MA 01936
Dear Peter,
Trout Unlimited has reviewed the 2009 Comprehensive Fish Passage Plan and has the following
comments.
General comments:
The 2009 Comprehensive Fish Passage Plan submitted to the FERC on December 18, 2009 does
not meet the consultation requirements of Article 404 of the License granted by the FERC on
April 30, 2002. In that article the FERC states:
The licensee shall prepare the comprehensive fish passage plan in consultation with the
Massachusetts Department of Environmental Protection, the MDFW, and the U.S. Fish
and Wildlife Service. The licensee shall include, with the plan, documentation of agency
consultation, copies of comments and recommendations on the completed plan after it
has been prepared and provided to the agencies, and specific descriptions of how the
agencies’ comments are accommodated by the plan. The licensee shall allow a minimum
of 30 days for the agencies to comment and to make recommendations before filing the
plan with the Commission. If the licensee does not adopt a recommendation, the filing
shall include the licensee’s reasons, based on site-specific information.
The plan was distributed to the agencies and TU on December 13, 2009. No opportunity was
provided for agency or other stakeholder comments prior to filing the plan on December 18th
with the FERC and, as such, this plan should be viewed as a draft. The final plan should be filed
after comments are received and addressed as required above.
This “comprehensive” plan does not include a plan for adult eel downstream passage evaluation.
On November 25, 2008 the FERC granted an extension of 90 days for submitting a final plan and
schedule for the evaluation of the effectiveness of downstream adult eel passage facilities. On
April 3, 2009 the FERC granted a further extension of 145 days for submittal of the plan. The
plan was due July 30, 2009. No plan has been submitted. There is sufficient time to provide a
draft plan to the agencies and a final plan to the FERC for evaluation of adult eel passage in the
fall of 2010. The Fish Passage Plan does not need a study plan but should address current
protections for outmigrating eels and the general plan and timing for evaluating downstream
passage.
TU also notes that Woronoco Hydro, LLC is in violation of the FERC Order of October 25, 2009
which granted a 60 day extension to the requirement of section E of the July 21, 2009 FERC
Order requiring a plan for the evaluation of downstream smolt passage in 2010. The present plan
ignores that requirement and proposes testing in 2011. The justification for this is a plan to
modify the downstream passage system in the summer of 2010 which has not been discussed
with all the various stakeholders and is presented in summary in section 4.3 accompanied with
the drawings in Appendix A.
The long and extensive history by Woronoco Hydro of unmet deadlines causes TU great concern
with the proposed plan for modifying the bypass system. We have minimal confidence that the
proposed modifications will be made in the summer of 2010 and that another year will pass with
insufficient progress for downstream protection for smolts.
Specific comments:
1.0 Introduction
The first paragraph states that the comprehensive fish passage plan is required to include
evaluation of upstream and downstream passage facilities for Atlantic salmon and American
eels. It then lists requirements that the plan contain based on the July 21 and July 23
Commission orders but does not include downstream passage plans for eels as noted above.
Article 404 requires that the plan address upstream and downstream passage of eels.
2.2 Downstream Fish Passage System
Installation of ¾” clear space bar racks coupled with comprehensive velocity measurements
should be a positive step toward protection of both smolts and American eel migrating past the
project. Without more information on the proposed downstream passage system it is difficult to
provide comprehensive comments as to its suitability.
2.3 Upstream Eel Passage
TU will comment separately on the upstream eel passage report for the 2009 season.
Construction of an eel passage for the north side dam is appropriate. A site visit in the spring
after the project stops spilling should be scheduled to review the proposed site of the eelway and
to view the ‘natural’ passage routes that are described in the plan. TU is concerned that the
natural routes could leave eels exposed to avian predation for eels unable to fully ascend during
the night. Natural pathways can lead to dead ends where fish cannot complete the ascent to the
top or become isolated in shallow pools as the flow over or through the dam slows or ceases.
2
Similar to the south and middle eelways, a trap will be necessary to assess passage for the north
eelway.
3.1 Downstream Fish Passage
Minimum flow for the south channel is required for the full year by the FERC license and the
Massachusetts 401 water quality certificate. If ice build up on the present bypass chute is a
concern, the chute can be removed for the winter.
Minimum flows at the dam are provided by two deep gates or “by some combination of the
available project features.” These project features should be described. If the gates need to be
shut to allow divers access, the project should spill water to maintain minimum flows. Spilling
water should be incorporated in the plan as one of the alternative ‘project features’.
Supplying the south and middle eel passes with gravity flow for attraction and passage implies
that the collection tanks will no longer be used. At present it is inappropriate to discontinue eel
passage counts at these eelways.
4.3 2011 Downstream Smolt Passage Effectiveness Testing
The specifics of any evaluation of downstream passage will be fully reviewed when that study
plan is drafted. In general the addition of antennas and receivers described in this section
appears appropriate. The sites in the bypass channel downstream of the plunge pool and at the
south channel above the confluence with the bypass channel will help eliminate some of the
detection problems that occurred in the telemetry study of 2008.
4.4 Downstream Kelt Passage Effectiveness Testing
Delay of downstream kelt passage tests is appropriate at this time.
4.5 Upstream Eel Passage System
The statement “On July 21, 2008, hundreds of eels were observed passing naturally over the wet
ledge of the north and south dams.” is not supported by the notes of Shawn Regan for July 21,
2009 in Attachment 2 of the draft 2008 upstream eel report. He states that observations were
made from 9:15 PM to around 12:30 AM the following morning. The total count of eels for the
three locations is 80 (actual numbers reported although some were minimum estimates) plus
“dozens” of eels in the pools at the base of the north dam. Of these 56 are described as actually
ascending the dam face on a wetted route to the dam crest. In addition to the eels seen on July
21, observations were made on July 25, August 6, and August 14. On July 25, 6 eels were seen
ascending the dam at the bypass reach. On both dates in August no eels were seen ascending the
dam face. Thirty eels on July 21 ascending the forebay/bypass dam plus 6 on July 25 does not
constitute the “hundreds of eels” migrating up the westernmost bypass reach.
A quick review of nighttime observations in 2009 shows only eight eels ascending the face of the
dam through ‘natural’ routes. Comments concerning the 2009 upstream eel report which is
summarized here and plans for evaluation in 2010 will be forwarded in a separate letter.
3
4.6 2010 Velocity Testing
The proposed velocity testing points are inadequate to properly evaluate the velocities at the
rack. Velocities should be taken at more points with the emphasis on the area in front of the
penstock. The diagram below shows more comprehensive velocity measurement points at the
intersection of the grid lines. Exact location of these points in the field would depend on the size
and location of the penstock. Large measurements are in feet. Small ones are in inches.
5.3 Downstream Fish Passage Facility
More details of the proposed downstream fish passage are required for review.
Appendix B
The use of a dye marker for evaluation of eels was discussed at the meeting as a part of the 2010
upstream study. An alternative technique which would be better is discussed in the Journal of
Fish Biology (2007) 71, 1546–1554, Evaluation of visible implant elastomer as a method for
tagging small European eels by Imbert et al. The availability of multiple tag colors combined
with different tagging locations would provide much greater resolution for evaluating release
location and date.
Thank you for the opportunity to comment. If you have any questions concerning this matter, I
can be reached at the above address or at 413 863 3832.
Sincerely,
Donald Pugh
4
cc: Secretary, FERC
Peter Yarrington, FERC
John Warner, USFWS
Dick Quinn, USFWS
Melissa Grader, USFWS
Caleb Slater, MADFW
Bob Kubit, MADEP
Al Nash, Renewable Power
5
Print
Page 1 of 1
From: Kubit, Robert (DEP) (Robert.Kubit@state.ma.us)
To: Alfred Nash
Date: Wed, December 30, 2009 3:31:58 PM
Subject: RE: Woronoco 2009 Comprehensive Fish Passage Plan
Dear Mr. Nash,
The MA Department of Environmental Protection will not be providing comment on the revised Comprehensive
Fish Passage Plan for the Woronoco development. The Department supports the comments provided by the MA
Division of Fisheries and Wildlife.
Robert Kubit, P.E.
MassDEP
Division of Watershed Management
627 Main Street
Worcester MA 01608
Telephone: (508) 767-2854
Email: robert.kubit@state.ma.us
Fax: (508) 791-4131
From: Alfred Nash [mailto:renewablepwr@yahoo.com]
Sent: Monday, December 14, 2009 3:34 PM
To: Kubit, Robert (DEP); John_Warner@fws.gov; Caleb Slater
Cc: 'Bill Fay'; bwhalley@swiftriverhydro.com; 'Donald Pugh'; Melissa_Grader@fws.gov;
wbailey@swiftriverhydro.com; wdhobbs@swiftriverhydro.com; Peter B Clark
Subject: Woronoco 2009 Comprehensive Fish Passage Plan
Attached for your review and comment is the revised Comprehensive Fish Passage Plan for the
Woronoco development. As outlined in the cover letter and the Plan, Woronoco is proposing a
significant change in the downstream fish passage system. The proposed change is consistent with the
approved fish passage system to be installed at the Indian River development (upstream of Woronoco)
and is believed that the proposed system will enhance passage effectiveness at the development. Please
let us know if you need additional information or have any questions regarding the attached Plan.
Alfred Nash, P.E.
43 Spaulding Road
P.O. Box 195
Palmyra, ME 04965
(207) 992-3926
email: renewablepwr@yahoo.com
http://us.mg4.mail.yahoo.com/dc/launch?.gx=1&.rand=6esksqr08gh0a
12/30/2009
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Concord, NH 0330 1-5087
http ://www.fws.gov/newengland
FERC No. 2631
January 21, 2010
Mr. Alfred Nash, P.E.
P.O. Box 195
Palmyra, ME 04965
Dear Mr. Nash:
This responds to your recently submitted draft 2009 Comprehensive Fish Passage Plan (2009
Plan), and the conceptual design drawing of the new intake screening, dated December 7, 2009
and December 14, 2009. The 2009 Plan is a revision of the 2008 Revised Fish Passage Plan
approved by the Federal Energy Regulatory Commission (FERC). The proposed plan includes a
description of a revised configuration of the intake screening, a new eelway for the North Dam,
and a revised schedule for passage implementation and testing. The U.S. Fish and Wildlife
Service’s (Service) New England Field Office and our fishway engineer Dick Quinn have
reviewed the plan, schedule, and design drawings and have the following comments.
Cover Letter
The cover letter transmitting the 2009 Plan provides background information and explains why
Woronoco Hydro is proposing the modifications to the fish passage plans and schedules in the
2009 Plan. While this discussion in generally accurate, there remain a few comments which need
to be addressed. First, we note that the “intake bypass System” is not clearly defined. Please
clarify whether the narrower ¼-inch trashrack overlays are proposed for installation before the
2010 spring passage season, or during the summer of 2010.
We also note that the discussion for Woronoco to seek a change in the project reservoir level is
not relevant to the current discussion on passage implementation. The concept of raising the
impoundment level was investigated by the previous project owner and was also raised in the
past by Woronoco Hydro. In both instances, the U.S. Fish and Wildlife Service and other parties
indicated concerns about the impacts of such a change on aquatic resources, and the changes
were not pursued. Due to these concerns and past history, it is uncertain whether or not
increasing the pond height with flashboards will actually be formally proposed or whether it
would be approved through FERC and state permitting. Even if this change were to proceed, it
would be a number of years before the change was implemented. In the meantime, adequate
downstream passage facilities are needed with the existing project facilities, as we have indicated
January 21, 2010
2
in numerous letters from this office and as required by the FERC’ s July 21, 2009 Order
Approving Downstream Atlantic Salmon Smolt Passage Effectiveness Report and Requiring
Further Actions Pursuant to License Article 404.
We received upstream eel passage information by e-mail on December 28, 2009. This section
briefly summarizes passage at the project but provides limited or no supporting data. We will
comment on upstream eel passage issues in a separate response to that filing.
3.0 OPERATIONS AND MAINTENANCE
3.1 Downstream Fish Passage
The September 1 to November 15 dates for fall passage operation are correct, but they pertain
only to eels and fall salmon parr movements. Adult salmon, if stocked upstream of Woronoco
prior to spawning, will not move downstream until sometime after spawning is completed: until
ice-in or in the spring. Passage for post-spawned salmon kelts would, therefore, need to be open
for all or part of those periods in addition to the identified fall operation periods.
Discussion about winter operation of the bypass gate is confusing. The fish bypass is opened for
both fish passage and habitat protection. The plan acknowledges this fact, but states that the gate
will not be open during periods in the winter “to avoid ice accumulation”. The next sentence
then states that flow through the bypass would be “annually stopped from December until “iceout” or until water temperature reaches 5-degrees Celsius.” These statements appear to be
contradictory. The bypass needs to operate to provide part of the minimum bypass flow to the
channel below the fish bypass. The operation schedule for the existing and proposed fish bypass
gates should be clarified, and an explanation of how minimum flows will be complied with
should be provided.
3.2 Intake Rack Screen
The rack spacing to be used in non-passage periods should be indicated in this section.
4.4 Downstream Kelt Passage Effectiveness Testing
While we concur that passage effectiveness relative to entrainment of post-spawned salmon kelts
is not a concern at the project at this time, the bypass will need to be open and some monitoring
may be needed to assure that post-spawned kelts use the bypass and that they can safely
negotiate the plunge pooi and continue downstream. These evaluations can be discussed and an
evaluation plan developed after salmon kelts are transferred upstream.
January 21, 2010
3
4.6 Velocity Testing
We concur with the plan to do intake rack velocity testing immediately after rack installation in
spring 2010. However, the proposal to conduct measurements at only the 3-foot and 10-foot
depths and at 4-foot intervals across the rack is insufficient. Velocity measurements need to be
taken over the complete depth range of the racks, since intake velocities will affect passage,
entrainment, and impingement on both smolt and eels,. Also, since the presence of hot spots on
the rack would be problematic and since these could be localized, more measurements need to be
taken across the rack and at various depths. We recommend that measurements be taken at
depths of 2, 5, 8, ii and 14 feet, and at intervals every 2 to 3 feet across the rack.
5.0 SCHEDULE
5.2 Intake Velocity Study
The timetable for velocity testing is generally acceptable, however particular attention to the
timing of the intake racks installation, testing and reporting, is critical to assuring good passage
in 2010. The proposed filing of a draft test report, including proposed remedial measures within
seven days of test completion, is acceptable. Since the passage season will be ongoing, the
remedial measures should be implemented as soon as agency concurrence on proposed measures
is received, rather than waiting until a final report is filed with and approved by FERC.
5.4 Effectiveness testing of Smolt Passage Systems
Woronoco Hydro should consult with this office, the Massachusetts Division of Fisheries and
Wildlife, and Trout Unlimited in developing a study plan and schedule for effectiveness testing
of the new bypass system in spring 2011. This testing will need to proceed whether or not the
upstream Indian River Project is ready for testing by April 2011.
Visual monitoring of outmigrating American eels is proposed for fall 2009 and 2010. This
approach will not be effective in discerning if eels safely pass the project, or are impinged on the
racks, or entrained. American eel are bottom oriented and move at night. Observing eel passage
and behavior at the intake rack under these conditions would yield little useful information.
A mark-recapture assessment or radio-telemetry study of outmigrating eels will be necessary to
establish effectiveness. A radio-telemetry study would gather information on where and when
eels pass, and on eel movements. This information would be more valuable than data from a
mark-recapture study and may be needed to understand the problem in addition to a mark
recapture study if eels do not effectively pass the project.
Downstream Passage Design Plan
Drawing 1 of the downstream passage system, dated December 7, 2009, depicts a plan view and
an elevation view of the new bypass opening and conveyance structure. and its integration into
the new trashrack. The drawing generally appears to represent a configuration we can endorse,
January 21, 2010
4
subject to post-construction testing. However, more complete drawings with clearer indications
of the dimensions of project features and water elevations are needed before we can provide a
complete assessment.
The bypass opening will need to be 3 feet wide and pass approximately 35 cfs, but should be
adjustable to increase bypass discharge if effectiveness testing does not demonstrate effective
passage. The bypass width is unclear from the drawings; please clarify.
We also need drawings based on real field measurements of the bypass discharge pipe outlet and
plunge pool landing area. The location and height of fall to the plunge pooi, and the plunge pooi
dimensions and depth at the location of impact should be indicated on drawings.
We appreciate this opportunity to comment. If you have any questions, please contact Mr. John
Warner of this office at 603-223-2541, extension 15.
Sincerel
•
rs,
Thomas R. Chapman
Supervisor
January 21, 2010
CC:
5
Mr. Peter B. Clark, Manager
Woronoco Hydro, LLC
P.O. Box 149
Hamilton, MA 01936
CRC Ken Sprankle
MDEP Bob Kubit
MDFW Caleb Siater
Engineering FO Dick Quinn
TU- Don Pugh
FERC-Div of Hydropower Admin and Compliance
Reading file
JWarner: 1-21-10:603-223-2541
—
—
-
—
ES:

Woronoco Hydro LLC - Low Impact Hydropower Institute

Transcription

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