`
`December 23, 2019
`
`Mr. John Spain, P.E., Regional Engineer
`Federal Energy Regulatory Commission
`Division of Dam Safety and Inspections
`New York Regional Office
`19 West 34th Street; Suite 400
`New York, NY 10001
`Via E-filing and Hardcopy
`
`CEll and Non-Internet Public Materials
`
`Emergency Action Plan Exemption Annual Review
`
`RE:
`
`
`
`Dear Mr. Spain:
`
`Chapter 6 (Emergency Action Plans) of the Commission’s “Engineering Guidelines for the
`Evaluation of Hydropower Projects” states (in section 6-2.2.7) that:
`
`“Licensees of projects exempt from filing an EAP must annually perform a field
`reconnaissance to verify if there were any changes to upstream and downstream
`conditions affecting the determination that no reasonably foreseeable project emergency
`would endanger life, health, or property (see Section 6-6.2).
`
`Licensees should also develop, maintain, post, and annually verify a contact list of people
`and organizations such as local emergency management authorities and upstream and
`downstream dam owners that will be called during flood events, if their dam is in danger of
`failing, or has failed (see Section 6-6.3).
`
`In accordance with 18 C.F.R., Part 12, Subpart C, § 12.21, by December 31 of each year,
`licensees of projects exempt from filing an EAP should send a letter to the Regional
`Engineer: (1) discussing the results of the field reconnaissance, (2) if appropriate,
`requesting a continuation of the exemption from filing an EAP, and (3) including, as a
`separate enclosure, the contact list along with a statement that the information provided
`was verified to be accurate.”
`
`On behalf of the licensees for the projects listed below, Brookfield Renewable Partners (BRP) is
`providing this letter to provide the Commission with the annual Emergency Action Plan (EAP)
`exemption review for these projects:
`
`• Bar Mills Project (FERC No. 2194), licensed to Brookfield White Pine Hydro LLC
`• Brunswick Project (FERC No. 2284), licensed to Brookfield White Pine Hydro LLC
`• Shelburne Project (FERC No. 2300), licensed to Great Lakes Hydro America, LLC
`• Lewiston Falls Project (FERC No. 2302), licensed to Brookfield White Pine Hydro LLC
`
`150 Main Street Tell: 207.755.5600
`Lewiston, ME 04240 www.brookfieldrenewable.com Fax: 207.755.5655
`
`
`

`

`
`
`• Gulf Island Project (FERC No. 2283), licensed to Brookfield White Pine Hydro LLC
`(Deer Rips and Andro 3 Developments only)
`• Gorham Project (FERC No. 2311), licensed to Great Lakes Hydro America, LLC
`• Shawmut Project (FERC No. 2322), licensed to Brookfield White Pine Hydro LLC
`• Williams Project (FERC No. 2335), licensed to Brookfield White Pine Hydro LLC
`• Sawmill Project (FERC No. 2422), licensed to Great Lakes Hydro America, LLC
`• Riverside Project (FERC No. 2423), licensed to Great Lakes Hydro America, LLC
`• Cataract Project (FERC No. 2528), licensed to Brookfield White Pine Hydro LLC
`• Bonny Eagle Project (FERC No. 2529), licensed to Brookfield White Pine Hydro LLC
`• Hiram Project (FERC No. 2530), licensed to Brookfield White Pine Hydro LLC
`• Milford Project (FERC No. 2534), licensed to Black Bear Hydro Partners, LLC,
`including the Milford Dam and Gilman Falls Dam
`• GLHA Storage Projects (FERC No. 2634), licensed to Great Lakes Hydro America LLC
`(Caucogomoc Development, Dole Pond Development, Harrington Lake Development,
`Long Pond Development, Loon Lake Development, Penobscot Lake Development,
`Ragged Lake Development, only, an EAP is in place for the Project’s Canada Falls and
`Seboomook Developments)
`• Penobscot Mills Project (FERC No. 2458), licensed to Great Lakes Hydro America
`LLC (East Millinocket Development only, an EAP is in place for the Project’s North Twin,
`Stone Dam, Dolby and Millinocket Lake Developments)
`• Lockwood Project (FERC No. 2574), licensed to Merimil Limited Partnership
`• West Enfield Project (FERC No. 2600), licensed to Bangor Pacific Hydro Associates,
`including the West Enfield Dam and Run Around Dam
`• Hydro Kennebec Project (FERC No. 2611), licensed to Hydro Kennebec LLC (dam
`and powerhouse only; an EAP is in place for the Project’s canal headgate structure)
`• Medway Project (FERC No. 2666), licensed to Black Bear Hydro Partners, LLC
`• Moosehead Project (FERC No. 2671), licensed to Kennebec Water Power Co,
`including the East and West Outlet developments
`• Orono Project (FERC No. 2710), licensed to Black Bear Hydro Partners, LLC; Black
`Bear SO, LLC; and Black Bear Development Holdings, LLC
`• Stillwater Project (FERC No. 2712), licensed to Black Bear Hydro Partners, LLC; Black
`Bear SO, LLC; and Black Bear Development Holdings, LLC
`• Pontook Project (FERC No. 2861), licensed to Pontook Operating Limited Partnership
`• Errol Project (FERC No. 3133), licensed to Brookfield White Pine Hydro LLC; and Errol
`Hydroelectric Co., LLC
`
`
`
`Project Exemption Reviews
`
`BRP personnel routinely evaluate the conditions upstream and downstream of the projects listed
`above, which are exempt from filing an EAP. As a result of these field reconnaissance
`evaluations during 2019, no changes were identified upstream or downstream of these facilities
`that would reasonably be expected to adversely affect public health, safety or property in the
`event of a dam failure emergency at these projects. Therefore, BRP is not aware of any changes
`that would affect the hazard potential classification of any of these structures, and BRP thus
`requests a continuation of the exemptions from filing EAPs for the subject projects.
`
`150 Main Street Tell: 207.755.5600
`Lewiston, ME 04240 www.brookfieldrenewable.com Fax: 207.755.5655
`
`
`

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`Contact List Verification
`
`
`
`EAPs flowcharts were developed for all low and significant hazard projects as part of the BRP’s
`efforts for continual improvement in the area of public safety. Contact lists to be used in the
`event of a dam failure emergency have been established for each of the subject projects.
`Updated notification flowcharts for all Projects were submitted under separate cover on
`December 23, 2018 and were verified to be accurate.
`
`If you have any questions regarding our EAP program, please contact Ernie Deluca at (207)
`755-5619 or ernest.deluca@brookfieldrenewable.com.
`
`Sincerely,
`
`
`
`Kelly Maloney
`
`Licensing and Compliance Manager
`
`Attachments
`
`Cc: S. Michaud, N. Stevens, K. Murphy, J. Seyfried, P. McDonough, M. Swett, J. Cole, J. Rancourt,
`E. Thone, S. Gregg, B. Brochu, M. Craig, J. Auser, J. Clere, M. Pelletier; C. Karam, S. Hofacker,
`BREG
`
` BREG File: 0000 FERC General
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`
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`
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`150 Main Street Tell: 207.755.5600
`Lewiston, ME 04240 www.brookfieldrenewable.com Fax: 207.755.5655
`
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`