The First Stage Consultation Package (FSCP) contains a work plan that describes SCE’s proposed water quality study program. In general, the work plan proposes to conduct water quality studies in two steps. The first step will involve collecting all currently available information and data concerning surface water quality within the Project area. The second step will involve collecting new data to supplement the existing data as necessary to assure agency acceptance. The existing data will then be combined with the newly collected data to characterize water quality in the Kern River and to determine whether operation of the Borel project adversely affects water quality. The work plan also proposes to develop information about hazardous materials storage.

Several agencies and parties commented on SCE’s proposed water quality work plan. In general, the study requests involve four major topics, as follows:

1. Conducting a water quality sampling program in the Kern River;
2. Identifying and quantifying sources of non-point source pollution;
3. Describing current management practices and results of water quality monitoring for algicide treatment of the Borel canal; and
4. Conducting water quality surveys of Lake Isabella, including temperature and dissolved oxygen profiles.

The following paragraphs describe SCE’s approach to the first two study requests, and how the information will be used in the Exhibit E. SCE will develop information regarding algicide treatments of the Borel Canal as a separate submittal. The Lake Isabella surveys were addressed in an earlier plan, which was circulated for review and comment in January 2001 and is currently being revised. Additional sampling to evaluate the effect on water quality of reactivating the old diversion intake during low water conditions will be included in the revised study plan.

Several parties asked SCE to conduct a water quality sampling program. The most extensive requests came from the Sequoia National Forest (SQF), the State Water Resources Control Board (SWRCB) and from Ron Hyatt, owner of Sierra Sailing. For the most part, the SQF’s request is consistent with the work plan proposed in the FSCP and studies conducted on similar relicensing projects. The SWRCB’s request expands the number of sampling stations and sampling dates, but otherwise is generally consistent with the FSCP work plan. SCE proposes to conduct a water quality sampling program that provides the information requested by the SQF and the SWRCB, and meets the specific FERC requirements outlined in CFR 18.

Ron Hyatt recommends collecting a number of samples in the Borel Canal. However, because this study is designed to determine the potential effects of the Borel Project on the Kern River, not on the Canal, SCE does not propose to collect samples in the Borel Canal. SCE will continue to collect samples in the Borel Canal in connection with monitoring for the ongoing algicide treatment program, as described in SCE’s 1987 NPDES permit application to the State Water Resources Control Board. A detailed description of SCE’s algicide treatemnt program and monitoring results will be provided as an appendix of the Exhibit E.

Ron Hyatt and the SQF recommend sampling in Lake Isabella to evaluate the effect of diverting water at the old intake when the water level is very low. SCE’s water quality study plan includes one station in Lake Isabella to characterize the water released from the reservoir to the river (see below), but additional sampling would be required to evaluate the effect of reactivating the old intake. Normally, the Borel Project diverts water at the Auxiliary Dam and therefore does not affect reservoir water quality. During very low water years, however, water cannot be diverted at the dam and SCE may divert water at the old intake. Water diverted at this intake, which is upstream of the reservoir, bypasses the reservoir, potentially affecting reservoir water quality. As currently planned, SCE would conduct limnological sampling in Lake Isabella once just prior to reactivating the old intake (probably early August), once during summer after reactivating the intake (probably September), and once during winter while continuing to divert at the intake (probably November or December). A detailed description of SCE’s limnological sampling program will be presented in the draft limnology study plan that is currently being prepared for distribution and review.

In addition to the sampling to evaluate effects of reactivating the old diversion, SCE will determine water temperature, dissolved oxygen, pH and conductivity profiles in Lake Isabella once a month during May through September to evaluate the extent that potential stratification of the lake affects downstream water temperatures and other parameters. A revised description of the profiles sampling program will be included in the draft limnology study plan.

SCE will address the questions outlined in the FERC guidelines and the SQF’s, the SWRCB’s and Ron Hyatt’s study requests in two steps. The first step will involve collecting all currently available information and data concerning surface water quality within the Project area. The second step will involve collecting new data to supplement the existing data as necessary to assure agency acceptance. If the water quality study reveals problems, then SCE will develop a supplemental study plan that addresses that particular problem, provided it appears to be related to operation of the Borel Project. The sampling schedule and constituents that will be analyzed as part if the current study are further discussed later in this plan.

Existing data will be collected and reviewed. Existing sources of data include: the U.S. Environmental Protection Agency (EPA) STORET system, the USGS WATSTORE and NAWDEX databases, the Regional Water Quality Control Board – Tulare Lake Region, the Department of Water Resources, the U.S. Forest Service, Sequoia National Forest, and the Kern County Water Agency. If found to be useful, the data will be tabulated and evaluated to determine whether it adequately characterizes the Project area waters. The existing data will be used to determine the potential effects of Project operation on water quality and to address the topics outlined in the FERC guidelines and regulations.

Sampling stations have been established at the seven locations identified below. The locations of sampling sites may be modified based on discussions with the resource agencies and on the results of the existing data evaluation.

• Station 1: In Lake Isabella, near the main dam – this sample will allow us to characterize the water stored in Lake Isabella;

• Station 2: In the Kern River, just below the Main Dam – this sample will allow us to determine the quality of the water as it enters the diverted reach of the Kern River;

• Station 3: In the Kern River, immediately below the Main Dam Campground – this sample will allow us to determine potential effects of seasonal recreation activities occurring at the upper end of the Borel reach on water quality of the Kern River;

• Station 4: In the Kern River, immediately upstream of Bodfish/Havilah exit ramp – this sample will provide data from the mid-point of the diverted reach, upstream of the influence of most spring-fed tributaries in this reach;

• Station 5: In the Kern River, about 500 feet upstream of the Borel Powerhouse – this sample will allow us to determine if water quality is degraded within the diverted reach;

• Station 6: In the Borel Powerhouse tailrace – this sample will allow us to determine the quality of water entering the Kern River from the Borel Canal and Powerhouse.

• Station 7: In the Kern River, immediately downstream of Sandy Flat Campground – this will provide data on the condition of water quality as flow passes beyond project-related facilities.

SCE expects to collect samples once monthly from May 1 through September 30, 2001 (for all parameters except bacteria, which will require a more intensive sampling regime). It is expected that this sampling schedule will take into account a broad range of hydrologic and temperature conditions. Samples collected during September represent relatively high temperature conditions. Because of high biological and recreational activity during summer in Lake Isabella and the watershed, biological oxygen demand and fecal coliform bacteria should be at their maximum levels during September. We would be most likely to identify specific problem locations at this time of year. Conversely, samples collected during May would represent water quality conditions at lower temperatures and lower recreational activities. We believe that samples collected during the 2001 field season, supplemented by existing data, would adequately represent the range of water quality conditions for FERC relicensing and resource agency review. However, should data indicate a need for additional sampling, SCE will, following consultation with resource agencies, conduct a second field season to provide data on different water-year types or other information needed by agencies.

The water quality field investigation will involve a combination of in situ measurements and the collection of samples for a suite of laboratory analyses. The in situ measurements will be carried out using portable instruments following EPA methods, and will include the parameters listed in the following table.

Meteorological conditions will be noted at each sampling location and meteorological data will be obtained on a daily basis from a weather station at the Kern 1 Powerhouse, about 17 miles form the Project area. All measurement equipment will be calibrated prior to use each day of the sampling program. The calibration will be checked at the completion of each day. The water measurements and calibration information will be documented in a waterproof field logbook.

Immediately after the field measurements are recorded, the chemist will collect a subsurface sample with a clean water sampler. One replicate sample will be collected during each sampling round. This quality control (QC) sample will be used to estimate the precision of the sampling and analytical methods. The samples will be decanted into appropriate containers, placed on ice, and transported to a certified laboratory for analyses. Appropriate chain of custody protocols will be followed. Analytical samples will be collected at all sites once monthly beginning in May and continuing through September. In addition to the monthly sampling, total and fecal coliform samples at Stations 1, 2, 3 and 6 will be sampled four times within the 30 day period which includes the first week of September, to provide a total of five samples within 30 days, as required by the Basin Plan.

It is important to note two points about the table below. First, the table includes a relatively extensive list of analytes. The list was developed to include the analytes identified in the FERC’s guidelines and in the Regional Water Quality Control Board’s Water Quality Control Plan (Basin Plan). The list of analytes may be modified based on discussions with the resource agencies and on the results of our existing data search. Second, a number of the parameters in the table indicate that analyses will be undertaken for both total and dissolved samples. These pertain to those analytes that may be concentrated in the suspended sediments rather than dissolved in the water. The differences in analyte concentrations between total and dissolved samples will provide the information necessary to determine the effect of suspended sediments on water quality.

Chloride 325.1 Colorimetric

Fluoride 340.7 Colorimetric

Sulfate 375.2 Colorimetric

Phosphate 365.1 Colorimetric

Nitrate 353.2 Colorimetric

Ammonia 350.1 Colorimetric

Nitrite 353.2 Colorimetric

Sodium 273.1 Flame Atomic Absorption (AA)

Copper** 200.7 ICP

Lead** 239.2 Graphite furnace AA

Iron 200.7 ICP

Manganese 200.7 ICP

Zinc** 200.7 ICP

Mercury** EPA 1631 2 parts per trillion

Total Molybdenum 200.7 ICP

Hardness 130.2 Titrimetric

Arsenic** 206.3 Gaseous Hydride AA

Total Dissolved Solids 160.2 Gravimetric

Total Suspended Solids 160.1 Gravimetric

Chlorophyll a 1002G* Spectrophotometric or Fluorometric

Total & Fecal Coliform + 908 Multiple Tube Fermentation

BOD 405.1 5 day

Oil and Grease ++ 1.0 mg/L detection limit

Turbidity 180.1 Nephelometric

Upon completion of the analyses, the results will be summarized in a table with the location of the sampling stations, the sampling dates, and an informational column for detection limits of the analytical methods used. These results will be presented in the Exhibit E report, along with an explanation of the sampling, testing, and analytical procedures used.

The approach of the impact assessment will be to compare existing instream conditions to objective standards. Specifically, the results will be compared to the EPA Water Quality Criteria for both aquatic and human health, and to Maximum Contaminant Level Criteria (drinking water standard). The results will also be compared to the goals and objectives of the comprehensive Basin Plan. A discussion of data comparison to these standards and conclusions drawn by SCE will be contained in the Exhibit E report. Based on the evaluation of the results of this survey and results of the California Stream Bioassessment survey of macroinvertebrates conducted during February of this year, it should be possible to identify ongoing impacts to water quality that may be related either directly or indirectly to the operation of the Borel Project.

The literature and records search and the water quality study will provide documentation regarding the quality of the water within the Project reach and whether project operations might contribute to water quality degradation in the Kern River, or otherwise if the Project has no effect on water quality. In the event that the Project is determined to significantly affect water quality, SCE will prepare mitigation recommendations that consider: 1) the degree to which Project operation may be a contributing factor; 2) other potentially contributing factors, such as agency management policies, recreational uses, and County land use policies; and 3) the effects of recommended mitigation upon other resources, such as fishery resources, wildlife, recreation, and land management.

The Report on Water Use and Quality will include a section that provides information on hazardous materials. The discussion will include a summary of the type and quantity of materials that may be stored at facilities associated with the Borel Project. A Hazardous Materials Spill Contingency Plan will also be included as an appendix of the Exhibit E.

The SQF requested that SCE conduct a Non-point source (NPS) pollution study. According to the SQF, this study should be used to identify sources of pollution connected to the Borel Project, particularly sedimentation, and develop methods to reduce sediment inputs. Per the SQF request, the study will include four components, as described in the following.

The Exhibit E will include a description of SCE’s current erosion and sediment management practices and will identify any potential sites that may contribute sediment or other NPS pollution to the Kern River. The SQF notes that a number of Watershed Improvement Need (WIN) sites are known to exist in the watershed project analysis area. Some sites are directly related to the Borel hydroelectric facilities and include, among other areas, access roads and power line right-of-ways (ROWs). Other WIN sites in the watershed analysis area are not connected or associated with the hydroelectric facilities. All known WIN sites will be identified and documented. The SQF standard WIN inventory methodology will be used. The inventory will identify locations of WIN sites, the problem type, a site description, the disturbance source, site condition, beneficial uses affected, and proposed treatment.

This component of the study will involve estimating the amount of sediment introduced to the Kern River from the Borel project facilities. Sediment of concern is typically generated in areas where sediment has been disturbed, such as the canal ROW, penstocks, power line ROWs, access roads and trails.

The SQF methodology will be used to quantify sedimentation by equating it to the sedimentation that occurs from a dirt road. The unit of measure for this methodolgy is an Equivalent Roaded Acre (ERA). An ERA is a theoretical acre of land that is completely roaded (i.e., denuded of vegetation). One ERA is roughly equal to 67,500 tons of sediment/square mile/year. Sediment effects from the project will be quantified using this methodology.

The SQF has established Best Management Practices (BMPs) for soil and water conservation in coordination with the State Water Quality Control Board and EPA. This component of the study will evaluate the effectiveness of the BMPs presently in place as part of the operation of the hydroelectric facility. In addition, the study will identify additional BMPs needed to implement to protect and maintain water quality.

The study will use the methodology outlined in "Investigating Water Quality In the Pacific Southwest Region: Best Management Practices Evaluation Program" (USDA Forest Service 1992) to evaluate BMPs presently in place. Recommendations of additional BMPs to implement as part of the proposed project will follow the methodology explained in "Forest Service Handbook (FSH), R-5 Supp. 1, Chapter 10: Water Quality Management for National Forest System Lands in California – Best Management Practices" (USDA Forest Service, 1990).

This analysis will identify measures to correct erosion and other sources of chronic sedimentation and reduce sediment contribution should it be identified as a problem. The focus of NPS reduction will occur on Borel project sites and will consider allocation tradeoffs where treatments would not meet sediment NPS reduction objectives or treatments would not be cost-effective.

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