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Home My WebLink AboutSUS10041TK 1425 .S8 S9 no. 10041 SUS 10041 (also part 2 of SUS 347) Comments on Draft Exhibit E of Susitna Hydroelectric Project License Application. Letter to Eric Yould from Richard A. Neve, January 21, 1983. • To Eric Yould, Executive Director, Alaska Power Authority • From Richard A. Neve, Commissioner, Alaska Dept. of Environmental Conservation • 4 p. This document is one of four agency memorandums addressed sent in January 1983 to Eric Yould. These memorandums are assigned individual SUS numbers 10040, 10041, 10042, and 10043. These memorandums appear also in a collected document: Agency Comments on Draft Exhibit E of Susitna Hydroelectric Project License Application : Comments by NMFS, DEC, DNR, USFWS. -- SUS 347. These submitted comments are in reference to: Susitna Hydroelectric Project FERC License Application. Exhibit E / prepared by Acres. Draft. -- APA Document nos. 157-161. (This explanatory sheet is supplied by Alaska Resources Library and Information Services. Titles of memorandums are supplied from Susitna Aquatic Impact Assessment Project Bibliography with corrections made by the cataloger.) The Alas ka De partme nt o f Env iron mental Conservation is pleased t o respond to the Alaska Powe r Au tho ri ty 's req uest for c om ments o n the Susi tna Hydroelectric Pr o ject,Federal Energ y Re gul atory Licens e Ap plication,Exhib it E. These co mments are organ ized into seven pr imary categories and are presented below. 4J't .::;1111:1:1 SECO ND FL OOR ANCHORAGE.A LASKA 9 9501tsar;2 14 ·2533 P.O .BOX 615 K ODIA K.ALASKA '90"486-3350 eo.BOx 1201 SOLDOTNA ,A LASKA 99669 (90I )2 62 ·521 0 P.O.BO X 1709 VALDEZ.A L A SKA 99686 19011 83 5-4698 P.O.BO X 1{l1j4 WASIL LA .ALASKA 99681 (3Dl)316-5038 61LL SHEFFIELD,GOVERNOR o o o o i /0 I SOUT HCENTRAL REGIONAL OFFICE ! Jan uary 21, 1983 Dea r Mr.You ld: Hr .Er i c Yould Ex ec uti ve Di re c to r Alask a Powe r Au th ority 33 4 West 5t h Avenue Anc horage,Alas ka 99501 I;.....'-:-.::;-,~:-:=.';:::i ~..::r n .-.,rr::\1'"1 :7 t: -','."1 1 '1 '\\\..':.•,\."I l"'~,i l :!':J I ,d I ;;1 \"\I .'II ,. ,~I .''-I'....\I ,~•\"• r-__\;:,_,t I i ~I I J t I 1,~I .L .,_\'.'I r,"",,'':,'I-.-_.~___.'-:-.~~....-_:.1 t ........ DEPT.OF E1\"VIH01\"JIENT,\I.(;ONSEHV,\.TION II II II "II II II A. Water Qual ity II II II II l ~ II If ", ff rl- LH 1.The discuss ion on wat er quality impacts is well done for both the Wa ta na and Devil Canyon da ms .The major impact to water quality is f rom a chang e in the downstream water temperat ure that will occur with the pro ject operation.The Re s ervoir Temperature Hodel (DVRESM)i s designed to predi ct reservoir ou tflow temperatures to an accuracy of ±2°C.Thatis a range of var i at ion of 4°C. A difference of 4 °C in predicted outfl 0",temperatures could have a significant effect on the actual versus the predi cted impact on downstream fisheries .This model i ng effort shoul d be deve! oped to predi ct reservoi r operati ng parameters when us ing a given downstream i mpact,essent ially work1ng the model backwards.Accurate est imet es of the pred1 cted downstream river temperatures are an essential co mponent of the impact assessment process. 2. The sheer magn1t ude of the construction proje:t will crea te a high potential for soil erosion that may affect wate r qual 1ty.The Exhibit E needs t o be more speci fi c on how these problems will be mit 1gated • r~et h o dolog i e s ne ed to be de scr ibed i n detai 1 for construct ion of t he road , dam and townsites , a nd o ther pro ject entities. B.Hazardous Substances A very large amoun t of hazardous s ubstances will be transpo rted to,and ut i l t zed a t,the project site.D1 scharges of hazardous sub stan ces coul d con ta minat e l and as well as surface and ground water.Further i mpacts c ould occ ur to human we lfare,f ish,and wild life. The Exh ibit E docu ment does not addres s the major possible sources of f uel spills,but rather the minor ones (lea ky hydraulic lines and water p umps). A ve ry deta iled oil sp ill contingency plan needs to be developed t hat will have s everal major objectives and be written to account for a major (i.e., tank truck roll-over),as we ll as a minor spill event. Mr.Eric Yould January 21.1983 Page 2 The plan should be responsive to project needs and yet be simple enough to be functional.Major objectives of the plan are discussed in detail below: 1.To develop a training program that will stress spill prevention.This program needs to cover spill response under a 11 project condi t ions and set up several response scenarios. 2.To develop the response capability to adequately handle the worst case spill expected.This response capability should be developed for the Watana and Devil Canyon camps and the rail head stagi ng area.This would mean staging spill cleanup equipment at all sites.All hazard- ous substances that will be used on site need to be consi dered (so 1- vents.chemical additives.etc.). 3.To develop an immediate response team for each work shift.consisting of personnel dedicated to spill containment and cleanup,should a discharge incident occur.This response team would have a designated leader who would direct the team. A complete training program in spill response for this team would be essential. 4.To contain a small s ect ton on the project area environment.This would include a map of major drainage areas,fish habitat and seasonal descriptions,and wildlife habitat and seasonal descriptions.The environmental section is very important in prioritizing spill response actions (i.e.,most sensitive areas first),and for developing an ap- preciation for the impact a spill can have. C.Wastewater Treatment The type of wastewater treatment plant to be used at each camp site has to be described in greater detail to more adequately evaluate its effective- ness.The di scharge from the Watana treatment facility may not met.~fecal coliform standards because of inadequate dilution.The discharge zone should be well defined for both facil ities.The Watana and Devil Canyon camp wastewater treatment plants are to be functioning and approved before each camp is in operation. D.Concrete Batching Plant Potential impacts that may occur from the concrete production process are not descri bed in enough deta il •The di scharge from thi s proces s will a1so have,in addition to pH changes,problems with siltation,turbidity and possibly toxic additives used in the curing process.Siltation from concrete can form a mat over substrate gravels.This could suffocate emerging sa1mon fry or other i ndigenous organi sms that requi re subs trate habitat.Discharges that may have toxic concrete additives as a component may kill aquat ic organi sms.The batchi ng process may a1so have ai rborne particulate problems.Specific control measures need to be described in detail for each type of problem that may be encountered. Mr .Er ic Yould January 21, 1983 Page 3 E. Access Corridors The access route (Plan 17) was det~rm i n ed ,during the access route selec- tion process,to have greater pote ntial for major envi ronmental i mpacts than the oth er route options.The major impacts of conce rn were: 1.The Denali Highway to Watana Dam site portion passes through habitat that has historically been used by portions of the Nelchina caribou herd. 2.Many nat ive grayling strea ms can potentially be affected during the construct i on of the Dena 1 i Hi ghway to Wat ana Dam site access sect ion. 3.Access al ong the so uth s ide of the Susitna River from the Wat ana to Dev il Canyon Da m s ites passes th rough the Stephan Lake r egion.Th i s r e ~i on is i mportant habitat for moos e,wi nter ing car-t bou ,mi grat i ng wa te rfowl ,an d fur beare rs. 4.Wet lands habitat is crossed southwest of Devil Canyon. Because of the greater potential for major impacts associated with the Plan 17 access option ,more attention should be given to defining the methods that will be implemented to mitigate the :e impacts.For example : 1.How wi 11 the access route be designed to mini mize disruption to the car ibou ~erd? 2.What t echnique will be im plement ed to prevent impacts to nat ive grayl ing streams fro m road construction? 3.How will i mpact s to the Step han Lake reg ion be reduced? 4.How wi 11 project and post-project access be controlled to prevent seconda ry impacts related to access? F.Fi shery Impact Assessment The fi eld data base is incomplete for an accurate prediction of the i mpact the Susitna Hydroelec.tric Project will have on fishery resources.A good set of data has been collected for only two years.Fishery population and related wate r quality data can have inherent f l uctuat tons from year to yea r,Long t erm,1arge-sca 1e programs need to be implemented in order to ma ke a r easonably accurate population estimate.Very specif ic detailed s t udies des igned to correlate physical and chemical aspects of the aquatic h3bitat t o population flu ctuations need to be part of the long term pro gram. Th is progr am should be cont inued t hrough project construction. Mr.Eric Yould January 21,1983 Page 4 If impacts cannot be accurately predicted,a worst case (100~1055)estimate of the fishery population should be assumed and the implications this impact would have to the aquatic community and related resource use need to be discussed.By assuming a worst case estimate,a type of mit igat ion program can then be developed where compensation to the fishery p?pulation can occur tL result in an acceptable 1055. A long term post-project aquatic monitoring program should be developed as an integral part of the project.Funds should be allocated in advance to insure the continued existance of this program.The monitoring program is essent ia 1 to determi ne the effect iveness of mi t i gat ion measures that are implemented. G.Interagency Review Board It is strongly recommended that a formal interagency review board be estab- Ii shed to work wi th the Alaska POVier Authority in the development of the Susitna Hydroelectric Project.This board will identify and comment on soci oeconomic and envi ronmenta 1 issues and regulatory requi rements.It is suggested that the Formal Oesig~ation of the Susitna TeChnical Advisory Committee (see attached memo to you dated November 17,1982) be i~plemented to accomodate this recommendation. Once project construction begins,a similar interagency board should be established to monitor the socioeconomic and environmental impacts and regulatory compliance.This board would make recommendations to the Alaska Power Authority to correct associated problems as necessary. The Alaska Department of Environmental Conservation appreciates this oppor- tunity to comment on the Susitna Hydroelectric Project,Federal Energy Regula- tory License Application,l xhibit E and hopes that these comments will be useful to you.If you have any questions,or if we can be of further assistance,do not hesitate to contact Bob Martin or Steve Zrake in Anchorage. Si ncere ly, ~~ Richard A.Nev~ Commissioner Attachment cc:Bob Martin,ADEC,Anchorage Steve Zrake,ADEC,Anchorage Su-Hydro Steering Co~nittee