Docket #P-2197-054
Applicant: Alcoa Power Generating Inc.
FERC Project Name: Yadkin
August 23, 2002

The State of South Carolina is submitting this Comment to the Federal Energy Regulatory Commission (FERC) pursuant to its "Notice of Temporary Variance and Soliciting Comments, Motions to Intervene, and Protests" dated August 1, 2002. South Carolina is in agreement with the negotiated daily average minimum stream flow of 900 cubic feet per second (cfs) during Alcoa's recreation period. The purpose of this Comment is to inform FERC of South Carolina's concerns regarding minimum stream flow releases into the Great Pee Dee River from the Yadkin Project and the Tillery and Blewett Project operations after September 15, 2002. 


To date, there has been extraordinary cooperation between representatives from North Carolina (N.C. Department of Environment and Natural Resources (NCDENR), Alcoa, and CP&L) and South Carolina (S.C. Department of Natural Resources (SCDNR) and S.C. Department of Health and Environmental Control (SCDHEC)) in negotiations on the minimum flow in the Yadkin/Pee Dee River. Several facts mandated these negotiations take place. First, there is a finite volume of water stored in the North Carolina reservoirs, and currently inflow into the North Carolina reservoirs is only about 300 cfs. Therefore, when the storage in the North Carolina reservoirs is depleted, the flow in the Pee Dee River in South Carolina will be reduced to approximately 400-500 cfs. This flow is insufficient to provide adequate water for South Carolina water suppliers and industries on the Pee Dee. The goal of these negotiations has been how to reduce, and by what amount, flow in the Yadkin/Pee Dee River to save as much water as possible for all users (see letters written by SCDHEC to FERC on July 31, 2002, and SCDNR to FERC on July 30, 2002). 

SCDHEC, SCDNR, and the USGS studied the river to determine the lowest flow required to support all users of the river, including industries and water suppliers. It was determined that a daily average flow at the NC/SC border of 900 cfs is required to maintain the salt front at a sufficient distance from all but one of the water supply intakes near the coast (Georgetown County Water &Sewer Authority intake is already affected). In addition, SCDHEC consulted with all users of the river to ensure that 900 cfs would be an adequate flow. Our industries have made extensive and expensive modifications to their operations to accommodate the lower flow. SCDNR fish and wildlife staff agree that a daily average of 900 cfs would be an acceptable flow. The South Carolina Drought Committee, which represents all users, was informed of the proposed 900 cfs flow and given adequate time and opportunity to respond to the plan. The Committee agreed to the reduction in flow. 

This reduction in flow was agreed to by all parties in both states as necessary to protect human health and safety in South Carolina and as beneficial for users in North Carolina (see letters to FERC written by SCDNR on July 30, 2002 and SCDHEC on July 31, 2002.) Reducing the flow to 900 cfs will extend by forty days the time until the storage in the North Carolina reservoirs is depleted. Alcoa and CP&L have made modifications in the operation of their reservoirs to provide a daily average release of 900 cfs from Blewett Falls into South Carolina. As is apparent, all parties have been cooperative and willing to make adjustments for the mutual benefit of the residents of both States.


Current Status of Drought
The State has experienced drought conditions since June 1998, the longest drought since hydrologic records have been kept. The rainfall deficit across the State since June 1998 ranges from 20 to 70 inches. On August 20th, the South Carolina Drought Response Committee declared all 46 counties "extreme," the most dire drought category. 

Forty to sixty percent of the state's monitored streams are reporting record low flows for this time of year. Many streams have reached all-time record lows surpassing the previous record from the 1950s, including 65% of unregulated sites with more than 30 years of record. Groundwater levels are declining at an accelerated rate. As of August 19th, of the largest 350 water systems in the state, 29 water systems are enacting mandatory restrictions, with most of these systems reporting an 11-20 percent water-use reduction. Of the water systems surveyed, 104 are asking for voluntary reductions in water use, with most of these seeing less than a ten percent reduction in use. 

Industries are spending hundreds of thousands to millions of dollars on measures to deal with the drought, such as installation of water-saving devices, drilling new wells, and building retention ponds and cooling towers. Agriculture is in a critical situation because of the continuing drought, the worst in many years. According to the South Carolina Forestry Commission, the drought is significantly contributing to the southern pine beetle epidemic. Trees weakened by drought are more susceptible to the tree-killing beetles. Timber losses due to beetles will easily exceed $200 million, which are almost double the previous 1995 record losses of $107 million.

The five-year drought has had a major economic impact on the state, with significant effects on tourism, forestry, and agriculture. Losses continue to accumulate, but are difficult to quantify because of the indirect impact it has on so many sectors.

Effect on Water Supply
The entire northern coast of South Carolina from Little River, near the State line, to the City of Georgetown depends on the Pee Dee for their water supply. Included are the Cities of Myrtle Beach, North Myrtle Beach, Conway, Loris, Surfside Beach, and Georgetown, the towns and communities of Little River, Socastee, Aynor, Wampee, Garden City, Murrells Inlet, Litchfield Beach, Pawleys Island and Debidue Beach and unincorporated areas of Horry and Georgetown Counties. These areas are served by four water treatment plants: Myrtle Beach, Grand Strand Water and Sewer, City of Georgetown, and Georgetown County - Waccamaw Neck. Inland from the coast, the City of Cheraw draws its water from the Pee Dee River. Together these serve a year-round population of 275,000. With the Grand Strand area being a major tourist destination, the summer population easily exceeds half a million people. In addition, the City of Florence is completing construction on a new water plant that will add 60,000 new users.

The Georgetown County plant has already experienced numerous occasions since last October when the saltwater intrusion elevated chloride levels beyond the EPA secondary standard of 250 mg/l, and they had to cease operations. The daily average 900 cfs in the Pee Dee River is not sufficient to prevent the long term shutdown of this intake. Georgetown County has been relying on wells that are high in fluoride and sodium and is purchasing some treated water from the Grand Strand Water Plant in order to maintain its system during the shutdowns.

Using the best computer model and information available, hydrology modeling shows that at 900 cfs at the South Carolina/North Carolina border, the saltwater front should be maintained at a close but safe distance from the Grand Strand Water Plant's intake on Bull Creek, a water course connecting the Pee Dee River with the Waccamaw River. Since the Grand Strand Plant serves as the backup for both the Georgetown County and the Myrtle Beach Plants, shutting this intake down would place hundreds of thousands of people out of water. It is imperative that this flow in the Pee Dee River be maintained.

Effect on Industry
Low flows in the Pee Dee River have already resulted in significant costs to industrial users of the river. Industries are incurring approximately $136,000 per month in additional costs for such things as rental of auxiliary pumps and additional treatment due to low flows. Approximately $370,000 has already been spent on in-house conservation measures, engineering studies and planning on how to address drought related problems at various plants. One industry is spending $3 million to expand wastewater holding capabilities to decrease discharges during critical low flow periods. Another is spending $900,000 for cooling towers to decrease dependency on and withdrawals from the river. One industry is spending between $500,000 and $1 million on a system of wells to decrease surface water use by up to 50%. Another, while already spending $8,000 more per month for increased process water treatment, is anticipating spending an additional $280,000 to reduce chloride levels, just at they did last fall during extremely low flow periods. Yet another is studying the feasibility of spending $250,000 to divert effluent from a nearby publicly owned waste treatment facility for use as process water thereby decreasing withdrawal from the river by up to 7.5 mgd. It is anticipated that if flows decrease, additional costs will be incurred.

Effect on Fish and Wildlife
The extremely low water level in the Pee Dee River has resulted in more fish crowding and more competition for space, food and spawning areas. Additionally, fish are denied the normally excellent woody debris habitat along shorelines. "Drop-in" food sources are greatly reduced. Traditional spawning sites must be abandoned for alternate sites of lesser quality. Water quality, particularly dissolved oxygen, is commonly low in the summer in coastal plain streams. Reduced stream flows cause increased heat budgets and lowers dissolved oxygen levels even further. Municipal and industrial effluents are diluted much less as they enter streams, lengthening dissolved oxygen recovery zones. Thus, water scarcity stresses fish in the Pee Dee River, threatening their ability to maintain population levels. Fish can be stranded in rapidly shrinking pools. Normally, fish move downstream to avoid the effects of droughts, but in this case, they are likely to be met by a wall of salt water. Anadromous species depend on flowing water for upstream access (over shoal areas) as well as for spawning and egg development. Although most anadromous activity is finished for now, upstream migrations will begin again as early as October or November.

The low water levels South Carolina is now experiencing are likely to cause significant damage to invertebrate populations important to fish forage. Although invertebrates usually recover rapidly, their recovery may not be soon enough to save a year-class of fishes. Reduced water volume favors large predatory fish like flathead catfish. Already a problem, the flatheads do not need further assistance in restructuring native fish populations. In short, the present low water levels are causing a number of problems, some of which the State can readily observe, and others that will only show up in time. If flow levels are reduced still further, fish populations will be more subject to catastrophic occurrences, such as dissolved oxygen depletions, chemical spills, or worse. Coastal plain fishes are hardy and adaptable,but their limits of endurance may soon be reached.

Effect on Navigable Waters
Navigation has for all practical purposes ceased to exist in a portion of the river that even before the construction of the reservoirs supported barge and commercial steam traffic from Georgetown to Cheraw. Evidence of that is currently visible from the remains of riverboats and gunboats sunk in the river and previously covered by water. Although there is currently no commercial traffic of that magnitude, navigation is still important to commercial and recreational users.


South Carolina recognizes that North Carolina has and will continue to suffer hardships brought about by this severe drought. Consequently, South Carolina has made accommodations in stream flow during the recreation period to ease the drought's effects on pool levels of Alcoa's reservoirs. Indeed, South Carolina has agreed to a minimum downstream flow of 900 cfs on a daily average, the extreme outer limits of what South Carolina water suppliers and industries can withstand, in order to preserve water in North Carolina.  After September 15th, the various legal instruments governing Alcoa's operations leave unclear what its discharge amount will be and under what conditions. South Carolina believes the operative instrument to be the 1968 FERC Order amending Alcoa's license. However, under the persistent drought conditions affecting both States, South Carolina will continue to accept an average daily flow of only 900 cfs after September 15th, until inflows increase and lake levels improve. At that time, there should be an incremental increase in downstream minimum releases. It is in both States' best interest that the Alcoa reservoirs are replenished so that constant downstream flow over the course of the upcoming year is likely. 


South Carolina expects all parties to fully cooperate in reaching a fair and equitable stream flow applicable after September 15th. However, if all parties cannot expeditiously settle on a stream flow amount during Alcoa's non-recreational period, South Carolina respectfully asks FERC to exercise its authority under Article 13 of Alcoa's license to establish a stream flow in the interest of public health and welfare. 

Respectfully submitted,

Dated: August 23, 2002 STATE OF SOUTH CAROLINA

s/Stephen P. Bates
Chief Legal Counsel
Office of the Governor 
Post Office Box 11829
Columbia, South Carolina 29211
Telephone: (803) 734-6313