delauro ferc response 4.19.11

8/7/2019 DeLauro FERC Response 4.19.11

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FEDERAL ENERGY REGULATORY COMMISSIONWASHINGTON. DC 20426

OFFICE OF THE CHAIRMAN Apri119,2011The Honorable Rosa L. DeLauroU.S. House of Representatives59 Elm Street, Second FloorNew Haven, CT 06510Dear Congresswoman DeLauro:

Thank you for your March 15, 2011 letter regarding FirstLight Hydro Generating Co.' s(FirstLight) Housatonic River Hydroelectric Project (Federal Energy Regulatory CommissionProject No. 2576). In your letter, you request an investigation on behalf of your constituentsfrom the Town of Derby about the lack of additional warnings following the initial warning fromFirstLight during high flows from Stevenson Dam on March 12,2011. You also formallyinvited a representative of the Commission to meet with city officials to further discuss thisissue. In a follow-up telephone conversation, your office clarified that you also would likeinformation on the actions taken by FirstLight in response to rising water levels at the same damearlier that week due to a flooding event on March 6-7, 2011.

The Commission's review of the recent flooding of the Housatonic River began onMarch 9, 2011 when the Commission's staff requested that FirstLight submit a summary of theMarch 6-7, 2011 flooding incident. FirstLight submitted responses on March 17, 2011 andMarch 23,2011. In addition, on March 30, 2011, FirstLight submitted documentation oftelephone notifications it made between March 7 and March 15, 2011 to the communitiesdownstream of Stevenson Dam. Commission staf f has reviewed all of the information that FirstLight submitted regarding the Lower Housatonic Flood Plan and FirstLight's notificationprocedures. On March 31, 2011, the Commission's staff sent a letter to FirstLight (copyenclosed) that contained its conclusions.

The Housatonic River Hydroelectric Project includes five developments. The fivedevelopments do not provide flood control capability for the downstream communities;nonetheless, FirstLight is required to alert downstream communities of potential flood levels.Commission staffdetermined that the company notified the downstream authorities inaccordance with the procedures set for the "Lower Housatonic Flood Plan (Stevenson Dam)."This included notifications to the downstream towns when the flow levels in the river reached7,000, 10,000, 14,000, and 20,000 cubic feet per second (cfs) during the March 6-7 flooding.In addition, FirstLight made notification calls to the downstream communities every two hoursfrom March 7 through March 14,2011.

In your letter, you asked for recommendations to change the flood plan to ensure that inthe future all appropriate steps will be taken by the operator to minimize the impact of floodingin the surrounding areas. The Commission's staffhas notified FirstLight that it should improveits flood plan coordination with the emergency management agencies (EMAs) and that it take


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specific steps to meet these objectives. Specifically, FirstLight should add additionalnotifications to downstream response agencies when flows rise above 20,000 cfs and confirmthat all parties understand their roles and responsibilities during floods. Furthermore, we requirethat FirstLight meet individually with the downstream EMAs to determine the lessons learnedand hear their thoughts on changing the flood plan. Afterwards, FirstLight must meet with alllocal EMAs to come to a consensus on any changes to the emergency action plan and flood plan.After the plans are updated, FirstLight will schedule a tabletop exercise so that all parties will bepart of a walk through and become familiar with how notifications and warnings would occurduring future dam-related emergencies and floods.

I appreciate your invitation to further discuss these issues with city officials.Commission staff is currently working with the EMAs and FirstLight on updating its flood planand will attend the tabletop exercise. Mr. Richard Laudenat at FirstLight should be able toprovide your staff with more information on the dates and times of the future meetings. On April15,2011, Mr. Laudenat sent the Commission a letter outlining a general schedule for futuremeetings (copy enclosed). In the meantime, we would be happy to discuss any remaining issueswith Derby officials. If I can be of further assistance in this or any other Commission matter,please let me know.

s ~ e r e l ~ Y ..\ rJ '. .\ iJon We . off

ChairmanEnclosure


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5027 FERC PDF (Unof f ic ia l ) 4/15/2011 8:05:29 AM

Richard T. Laudenat, P.E.Plant Manager143 West Street Ext Suite EFfrstLight New Milford. CT 06776T (860) 354-3617F (860) 350-3987C ([email protected]

April 15, 2011FERC0051hMr. Gerald T. CrossFERC New York Regional OfficeOffice of Energy ProjectsDivision of Dam Safety & Inspections19 West 34th Street, Suite 400New York, NY 10001

March 6. 7 2011 Flood Event And EAP Actions for the Lower Housatonic River FERC No. 2576 - CT, Housatonic River Project

Dear Mr. Cross:FirstLight Power Resources Services, LLC (FLPR), acting as agent for FirstLight HydroGenerating Company, herein submits this response to your letter dated March 31,2011 on thesafety-related incident for flooding along the Lower Housatonic River.Initial meetings with officials from the two towns that experienced the most flooding during theevent have been held. The first meeting with the town of Derby was held on March 31, 2011.The second meeting with both the towns of Derby and Shelton was held on April 13, 2011. Inthat meeting. Mr. Eugene Gall of the FERC staff was in attendance.Both meetings confirmed that opportunities exist to utilize new technologies to improvecommunications around future flooding events with the assistance of the State of ConnecticutDepartment of Emergency Management and Homeland Security (CT-DEMHS).FLPR has made initial contact with the CT-DEMHS to schedule a meeting within the nextseveral weeks to discuss options for improved communications. Several meetings will takeplace to finalize a plan and draft revised Emergency Action Plans (EAPs) accordingly.When draft EAPs are ready, a combined validation meeting/final review meeting with the townsof Oxford. Seymour, Derby and Shelton will be held prior to implementation. Representativesfrom the Derby Dam, Connecticut OEM Region 2, the Connecticut DEP and the NationalWeather Service will also be invited.Subsequent to the final review meeting a table top exercise will be held to confirm the revisedEAPs achieve the intended objective.
mailto:[email protected]:[email protected]


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FERC PDF (Unof f ic ia l ) 4/15/2011 8:05:29 AM

The time frame for this process is not fully defined yet due to the large number of stakeholdersinvolved along with an extensive revision to complex EAPs. As more definitive plans aredeveloped we will provide additional communications ..Sincerely,

Richard T. Laudenat, P. E. FirstUght Power Resources Services, LLC


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5027 FERC PDF (Unoff ic ia l ) 4/15/2011 8:05:29 AMContent (s)

Response to FERC 03.31.11.PDF ............................... 1-2


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FEDERAL ENERGY REGULATORY COMMISSION OFFICE OF ENERGY PROJECTS

DIVISION OF DAM SAFETY AND INSPECTIONS NEW YORK REGIONAL OFFICE 19 West 34th Street - Suite 400 New York, New York 10001

Office No. (212) 273-5900 FAX No. (212) 631-8124In Reply Refer to: P-2S76-CT, Housatonic River Project March 6-7, 2011 Flood Event and EAP Actions for the Lower Housatonic River

March 31,2011Mr. Richard T. Laudenat, P.E.Station Manager - CT HydroFirstLight Power Resources143 West Street Ext. - Suite ENew Mllford, CT 06776Dear Mr. Laudenat:

This letter responds to your 12.10 report on a safety-related incident for floodingalong the Lower Housatonic River submitted by letter dated March 17, 20 II. The reportincludes a summary of the March 6-7,2011 flood and the actions FirstLight took to notifythe local Emergency Management Agencies (EMA) downstream ofStevenson dam. Byletter dated March 23, 2011 you also provided a supplemental response regarding operationof the Shepaug dam during this event.

You indicate FirstLight reacted to the flood in accordance with your "LowerHousatonic Flood Plan (Stevenson Dam)" (LHFP). The plan is designed to provide earlywarning of the potential for high water for the people downstream of the dam by havingFirstLight notifyEMAs in four steps related to increasing river flows. The plan calls for thenotificationofdownstream towns and emergency response agencies as flows are predicted toexceed 7,000, 10,000, 14,000, and 20,000 cfs. The notification forms indicate calls weremade to FirstLight personnel; local EMAs including police departments and officials fromthe towns of Oxford, Seymour, Derby and Shelton; Derby dam; the State Warning Point;Connecticut OEM Region 2; Connecticut DEP; and the National Weather Service.


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P-2576-CT 2

Your actions show that you notified the authorities downstream of the dam inaccordance with your "Lower Housatonic Flood Plan (Stevenson Dam)." However, we areaware ofa number of local news reports that (I) downstream residents complained about alack of infonnation during flood; and (2) EMAs had some uncertainty on the requiredresponse to your alerts. Based on these reports, it appears that more coordination with theEMAs is required and enhancements are required to your LHFP. We request you take thefollowing actions:

I. Add additional notifications to downstream response agencies, especiallyfor flows above 20,000 cfs to the LHFP.2. Meet with the local EMAs to review and discuss the details of theEmergency Action Plan (EAP) and the LHFP, draw attention to anychanges or updates, and ensure that both you and the local EMAsthoroughly understand their responsibilities, responses and roles inachieving an effective EAP and LHFP.

Your plan to meet with the local EMAs and conduct "lessons learned" sessions isessential for ensuring adequate procedures are in place to notify local EMAs and ensureresidents are warned and able to evacuate before being impacted from high water levels fromfloods and dam related emergencies. You propose to hold these meetings in the near futureand develop potential improvements to the notification procedures.You should first meet individually with the downstream EMAs to determine thelessons learned and their thoughts on potential changes to the flood plan. Once thisinformation is gathered, and you develop the required changes and updates to the EAP andLHFP, you should hold a meeting with all local EMAs to come to a consensus on anychanges to the EAP and LHFP. After the flood plan is revised, you should schedule atabletop exercise so all parties can walk through how notifications and warnings would occurduring future dam related emergencies and floods.We will attend the initial meetings with the local EMAs, the combined meeting ofall

ofthe EMAs, and the tabletop exercise. Please call us when you know the schedule for theinitial meetings with downstream municipalities. By April 15, 2011, provide a plan andschedule of the initial meetings, the combined meeting and the table top exercise.


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P-2576-CT J

Your cooperation is appreciated. Ifyou have any questions, please contactMr. EugeneGall, Chief, Dam Safety Branch 3, at (212) 273-5935.

y ~ v . f t . -Gerald L. Cross, P.E. Regional Engineer

delauro ferc response 4.19.11

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