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f =~ NORMANDEAU City of Nashua

FAAS ASSOCIATES June baee3

ENVIRONMENTAL CONSULTANTS

Study: Instream Habitat and Bypass Flow Assessment
Requestor: NHFGD, NHDES
Requestor Goal & Objectives:
e Determine flow needed to protect aquatic life in the bypassed reach by observation and, if necessary,

by collection of cross sectional data at various transects in the bypassed reach and to determine if the
bypass flows meet NH dissolved oxygen criteria.
e Provide flow regime in bypassed reach that meets the life history requirements of resident fish and

wildlife.
¢ Minimize current and potential negative project operation effects on water quality and aquatic
habitat.
Suggested Approach:

e Implement a Demonstration Flow Assessment (DFA)
o Identify DFA team
o Identify target fish species, lifestages, and habitat suitability criteria (HSC)
© Identify range of bypassed reach assessment flows (~5 flows to help define the flow:habitat
trends}
o Conduct DFA

= Classify mesohabitat types within bypassed reach.

= Place a limited number of transects within bypassed reach to characterize the full
range of habitat availability in bypassed reach.

= Collect representative depth, mean column velocity, substrate and cover at each
transect.

"The product of mesohabitat type HSC for each species/lifestage and proportional
availabity of habitat within the bypassed reach will be compared to calculated
suitability values for all selected DFA flows to determine a meso-scale flow:habitat
relationship.

= The depth, velocity, substrate and/or cover profiles will be compared to the HSC to
determine the total length of each transect that qualifies as “suitable” for each species
and life-stage.

Schedule and Estimated Cost: We suggest identification of target species and bypassed flows are conducted
in consultation with the resource agencies following their review of the PSP and issuance of the RSP.
Consensus on these items should be reached prior to any field sampling which we propose to occur during the
2020 field season (May-October). The estimated cost for the effort as described here is $35,647.00.

Study: Rare, Endangered and Threatened Mussel Survey
Requestor: NHFGD
Requestor Goal & Objectives:
e Survey the Project boundary area to determine the species composition, distribution, and abundance

of freshwater mussels, including the State listed Brook Floater.

f= NORMANDEAU City of Nashua

ARS ASSOCIATES June 18, 2019

ENVIRONMENTAL CONSULTANTS Page 4

e Evaluate potential effects of project operation (including routine maintenance activities) on freshwater
mussels residing in project waters.

Suggested Approach:
e Prepare survey protocol in consultation with resource agencies.
e Conduct a qualitative survey throughout project area to determine the presence, distribution,
demographics, and habitat of freshwater mussel species in the project section of the Nashua River
with emphasis on State listed or species of concern.

Schedule and Estimated Cost: Consensus on an appropriate freshwater mussel survey protocol should be
reached prior to any field sampling. Assuming agreement on a qualitative survey methodology we propose
this project occur during a low water period during the 2020 field season (July-September). The estimated cost
for the effort as described here is $27,108.75. Note that diving may be required to evaluate habitats in areas
deeper than 4 feet and are not included in this cost.

Study: Water Quality Study

Requestor: NHDES
Requestor Goal & Objectives:
e Determine the effects of operation of the Mine Falls Project on water quality in the Nashua River and

other potentially affected water bodies to compare to NH surface water standards

Suggested Approach:
e Following the NHDES sampling guidance, develop and submit to NHDES a Sampling and Analysis Plan

(SAP) for approval prior to sampling.

e Sampling locations to include; Nashua River upstream of Project, Project impoundment, Project
bypassed reach, Nashua River downstream of confluence of tailrace and bypassed reach, Mill Pond,
Nashua Canal downstream of Mill Pond, unnamed tributary connecting Mill Pond to Nashua River
downstream of dam.

e Follow NHDES criteria for hydropower projects sampling of dissolved oxygen, temperature, pH,
nutrients, chlorophyll a and clarity for compliance with state standards.

e Target low flow, high temperature period for a 5-week period for continuous monitoring of dissolved
oxygen and temperature.

Schedule and Estimated Cost: NHDES must approve an SAP for the Mine Falls Project prior to any sampling.
We suggest that this plan be prepared by Normandeau and submitted to NHDES in advance of the 2020 field
season. Per the NHDES sampling guidelines field measurements should occur during a low flow, high
temperature period {i.e., July-August, 2020). The station should be in a period of normal operations for that
monitoring (i.e., units online and generating if conditions are appropriate). The estimated cost for the effort as
described here is $35,271.40.

Study: Telemetry Study of Upstream and Downstream Migrating Shad and Herring
Requestor: NHFGD
Requestor Goal & Objectives:
e Assess project operation effects on timing, orientation, routes and migration rates of shad and river

herring.

os NORMANDEAU City of Nashua
ARS ASSOCIATES June 18, 2019

ENVIRONMENTAL CONSULTANTS

Page 5

Assess nearfield attraction to and entrance efficiency of fish lift.

Collect lift efficiency data to include rates of approach to fishway entrances, entry into the fishway,
and passage under varied operational! conditions.

Determine proportion of post-spawned adult downstream migration route selection, passage
efficiency, and delay associated with the power canal under various operating conditions.

Compare rates and measures of delay and movement among project areas and routes utilized.

Agency Recommended Approach:

Two year evaluation using minimum of 100 adult American shad and 100 adult river herring tagged
with radio-transmitters and PIT tags
Release locations upstream and downstream of Mine Falls Project

Suggested Approach:

Push back on including adult shad in this study until a time when they are volitionally reaching the
Project.
Propose a single year of study to evaluate — include language in the PSP that a second year of study
would only be considered if targeted sample sizes could not be obtained or river conditions lie far
outside of seasonal flow range.
Approach 1 - Full Study:
o Tag 100 radio/PIT adult herring and 100 PIT only adult herring at Jackson’ to evaluate
upstream fishway at Mine Falls
Tag 100 radio adult herring from Jackson to evaluate downstream passage at Mine Falls
Assumes installation and maintenance of approximately 8 radio telemetry and 2 PIT receivers
for period May-July
Approach 2 - Reduced Study:
o Tag 75 radio/PIT adult herring and 100 PIT only adult herring at Jackson to evaluate upstream
fishway at Mine Falls
Tag 50 radio adult herring from Jackson to evaluate downstream passage at Mine Falls
Assumes installation and maintenance of approximately 8 radio telemetry and 2 PIT receivers
for period May-July
Approach 3 - Minimum Study:
Oo Tag 25 radio/PIT adult herring and 100 PIT only adult herring at Jackson to evaluate upstream
fishway at Mine Falls
o No releases of tagged herring upstream of Project to evaluate downstream passage at Mine
Falls — rely on potential radio-tagged fish released downstream to collect minimal data on
outmigration
o Assumes installation and maintenance of approximately 8 radio telemetry and 2 PIT receivers
for period May-July

* Jackson refers to the Jackson Mills Project (FERC No. 7590) which is located on the Nashua River downstream of Mine
Fails and is also owned by the City of Nashua

ff» NORMANDEAU City of Nashua
BARA ASSOCIATES june 18, 2019
ENVIRONMENTAL a eG age

ENVIRONMENTAL CONSULTANTS

Schedule and Estimated Cost: The adult herring passage evaluation should occur during the spring period
(i.e., May-July) when the Project is operating under normal conditions (i-e., no unit outages, etc.). We propose
this study be conducted during the spring of 2020. Three study approaches were described above which vary
based on the numbers of fish to be tagged and released. These three approaches vary in responsiveness to the
study objectives provided by the resource agencies. The estimated costs for each level effort as described here
is $79,056.50 (full), $64,665.00 (reduced), and $44,632.00 (minimum).

Study: Impact of Project Operations on Downstream Migration of Juvenile Alosines
Requestor: NHFGD
Requestor Goal & Objectives:
e Assess project operation effects of the Mine Falls dam on the timing, orientation, passage routes,

migration rates, and survival of juvenile alewife.

e Determine the proportion of juvenile alewife that select the turbine intakes, downstream bypass or
spill as a passage route;

e Determined if there are delays associated with downstream movement.

Agency Recommended Approach:
e Evaluate turbine passage mortality for juvenile herring using the turbines, downstream bypass and

spillway with the HI-Z balloon tag methodology.
e Evaluate downstream herring passage route selection and potential delay using radio telemetry

Suggested Approach:
e Push back on conducting a HI-Z balloon tag study. Downstream passage survival for juvenile alosines

will be considered as part of the Desktop Impingement/Entrainment Survivability Assessment.
e Approach 1 - Radio-telemetry Study:

o Will provide proportional route usage by juvenile herring at the project as well as estimates on
the duration of residence time spent above the dam prior to passage (i.e., “delay”).

© Collect an adequate number of appropriately sized juvenile herring from a location within the
Merrimack River watershed — we have assumed this can be completed in a period of four
evenings.

o Radio-tag a total of 100 juvenile herring and release upstream of Mine Falls to evaluate
downstream passage.

o Assumes installation and maintenance of approximately 7 radio telemetry receivers for period
September-November.

© Approach 2 - PIT-telemetry Study:

o Will provide an estimate of downstream bypass usage by juvenile herring at the project as well
as ability to infer proportion of fish which have entered the power canal and are entrained at
the turbines.

o Will not inform on passage outside of power canal routes (i.e., bypass or turbines) nor will it
provide any estimates on the duration of residence time spent above the dam prior to passage
(i-e., “delay”).

fs NORMANDEAU City of Nashua

BAFE ASSOCIATES Hane 18, 2019

ENVIRONMENTAL CONSULTANTS

© Collect an adequate number of appropriately sized juvenile herring from a location within the
Merrimack River watershed — we have assumed this can be completed in a period of four
evenings.

o PIT-tag a total of 200 juvenile herring and release directly into the power canal at Mine Falls to
evaluate downstream passage.

o Assumes installation and maintenance of a single PIT receiver during the period September-
November.

e Approach 3 - Defer

© Rely on results from the Desktop Impingement/Entrainment Survivability Assessment to

provide insight into the potential for poor turbine passage survival at the Project.

Schedule and Estimated Cost: The juvenile herring passage evaluation should occur during the fall period
(i.e., September-November) when the Project is operating under normal conditions (i.e., no unit outages, etc.).
We propose this study be conducted during the fall of 2020. Three study approaches were described above
which vary based on the monitoring approach utilized. These three approaches vary in responsiveness to the
study objectives provided by the resource agencies. The estimated costs for each level of effort as described
here is $64,571.50 (telemetry study as requested by NHFGD), $30,359.00 (reduced), and SO (propose to not
adopt field study approach until after review of desktop assessment).

Study: Adult Alosine Downstream Passage Assessment and Protection Evaluation
Requestor: NHFGD
Requestor Goal & Objectives:
e Assess the risk of adult herring and shad becoming injured, impinged or entrained in powerhouse
units.
e Estimate turbine survival.
e Estimate effectiveness of downstream fish passage.
e Assess risk of injury or mortality at the spillway and downstream bypass.
e Evaluate potential passage and protection measures.

Agency Recommended Approach:
e Evaluate turbine passage mortality for adult herring and shad using the turbines, downstream bypass
and spillway with the HI-Z balloon tag methodology.
e Conduct a downstream passage alternatives analysis of operational or structural modifications to
potentially minimize injuries/mortality relative to existing conditions.

Suggested Approach:
e Push back on conducting a HI-Z balloon tag study. Downstream passage survival for adult alosines will
be considered as part of the Desktop Impingement/Entrainment Survivability Assessment.
e Push back on conducting a downstream alternatives analysis pending review of proposed adult herring
telemetry study above.

Study: Three Dimensional CFD Modeling in Vicinity of Fishway Entrance
Requestor: NHFGD
Requestor Goal & Objectives:

af» NORMANDEAU City of Nashua
AFA ASSOCIATES June 18, 2019
ENVIRONMENTAL CONSULTANTS Page 8

e Determine the flow field conditions which exist in and around the fishway entrances and create a
series of color contour maps of velocity magnitude at a range of discharges for comparison with known

fish swim capabilities.

Agency Recommended Approach:
e Collect necessary data (bed topography, water velocities, water depth) under a range of discharges

and assemble a 3-D computational fluid dynamics model.

Suggested Approach:
© Push back on conducting 3D CFD modeling of the Project fisnways unless one of the proposed passage

studies indicate a lack of safe, timely and effective passage.

Study: Downstream American Eel Passage Assessment
Requestor: NHFGD
Requestor Goal & Objectives:
¢ Quantify the movement rate and relative proportion of eels passing via the various routes at the

project.
e Evaluate instantaneous and latent mortality and injury of eels passed via each potential route.

Agency Recommended Approach:
e Evaluate the timing and route of downstream passage for adult eels at Mine Falls using radio-

telemetry.
e Evaluate turbine passage mortality for adult eels using the turbines, downstream bypass and spillway
with the HI-Z balloon tag methodology.

Suggested Approach:
® Push back on conducting a HI-Z balloon tag study. Downstream passage survival for adult eels will be

considered as part of the Desktop Impingement/Entrainment Survivability Assessment.

e Push back on additional telemetry evaluation of eels at Mine Falls until results from the Alden-DOE
bypass effectiveness study results are available. It is my understanding that eels used in that
experiment will be radio-tagged and should provide some insight into egress from the power canal.

Study: Desktop Impingement/Entrainment Survivability Assessment
Requestor: City of Nashua
Requestor Goal & Objectives:
e Provide a description of physical characteristics of the Mine Falls Project (including forebay

characteristics, intake location and dimensions, approach velocities, and rack spacing).
e Analyze target species for factors that may influence vulnerability to entrainment and mortality.
e Assess the potential for impingement and entrainment for target species.
e Estimate turbine passage survival rates.
e Estimate total project survival considering all passage routes for target species at the Project.

Suggested Approach:

’—» NORMANDEAU City of Nashua
FAFE ASSOCIATES June 18, 2019

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ENVIRFONMENTAL CONSULTANTS Page 9

e The assessment of impingement, entrainment, and survival of diadromous species will be conducted
as a desktop analysis.

e The potential for impingement or entrainment will be characterized based on the relationship of site-
specific intake characteristics along with swim speed and life history characteristics of target fish
species.

e Site-specific factors likely to influence the potential for entrainment include intake location relative to
shore and littoral habitat; depth of Project intakes; degree of water level fluctuations; hydraulic
Capacity; water quality; and intake velocities.

e Entrainment survival of juvenile and adult alosines will be estimated using data from survival studies
conducted at other hydroelectric facilities with similar characteristics [e.g., (EPRI, 1997); (Winchell,
2000)], and the Franke blade strike probability equation (Franke, 1997).

e Survival of adult eels will be estimated using the multiple linear regression models (Alden, Assessment
of Fish Entrainment, Impingement, and Turbine Survival at Holyoke Nos. 1, 2, and 3, 2017).

e Total project downstream passage survival will be characterized for adult and juvenile American shad
and alewife, and adult American eels considering the turbine passage survival estimated in this study
and any available proportional route selection data collected in the studies mentioned above.

Schedule and Estimated Cost: The desktop impingement/entrainment assessment should be conducted soon
after resource agency review of the PSP and issuance of the RSP. The estimated cost for the effort as described
here is $16,184.00.

3) Study Reports and Draft Application: Each aquatic resource study eventually agreed upon by the City
and the natural resource agencies will be conducted following the methodology summarized in the
RSP. At the completion of each study, Normandeau will prepare a summary report which provides an
overview of the goals and objectives, methodology and key results for each study. These draft reports
will be distributed to the natural resource agencies for review and Normandeau will coordinate a one-
day stakeholder meeting to review each study and address agency questions. Following review and
consideration of comments received on the draft reports, Normandeau will incorporate pertinent
comments and responses and provide a finalized set of study reports.

With regards to preparation of the Draft License Application (DLA), we have assumed that the City will
take an active role in that effort as participation will help to reduce the overall cost of the relicensing
effort. In particular, the City will take the lead on preparation of Exhibits B, C, D, G and H since staff
there have access to the detailed information required in those Exhibits. We will review and advise
the City on the content of those Exhibits to ensure that they are complete and will meet FERC
requirements and expectations. As part of the DLA effort, the Normandeau team will prepare the
Initial Statement, and Exhibits A, E, and F in accordance with FERC regulations and as stipulated in
FERC’s guidance document, Managing Hydropower Project Exhibits (FERC 2014).

A preliminary schedule of the timing of proposed studies and activities associated with the Mine Falls
relicensing process is included below in Figure 1 and was established based on an assumed contract issuance

ff’ NORMANDEAU City of Nashua

FES ASSOCIATES se onee 10

ENVIRONMENTAL CONSULTANTS

date of August 1, 2019 and a set date for filing the Final License Application with FERC no later than two years
before the existing license expires (i.e., August 4, 2021).

Table 2 provides a summary of the total cost for the work scope as defined herein. Where multiple cost
options have been prepared for a particular field study, a line for each study option has been included in the
summary table. The tasks presented in Table 2 represent our best total cost estimate following consideration
of the existing resource agency study requests. If the scope or suite of resource studies is modified during the
course of study plan development then additional sampling not considered here will be billed on a time and
materials basis following the rates presented below in Tables 3 (Normandeau) and 4 (H.L. Turner).

It is assumed that reasonable terms and conditions can be agreed upon. For ease in expediting the award, we
have attached our standard terms and conditions for your consideration.

If you have any questions or would like to discuss the content of this letter proposal, please do not hesitate to
call Drew Trested directly at (603) 973-3179 or via an email dtrested@normandeau.com.

Sincerely,

3. .
pf Sree,

fan i
Drew Trested Richard Simmons
Fisheries Biologist Vice President

Normandeau Associates, Inc. Normandeau Associates, Inc.

gf» NORMANDEAU
BRA ASSOCIATES

Table 2. Estimated process cost by task for the Mine Falls relicensing.

Task

Estimated
Hours

Estimated Cost

Proposed and Revised Study Plan

1. Kickoff Meeting 32 | §$ 4,776.00
2. Develop Preliminary Study Plan 170 | $ 26,006.00
3. Preliminary Study Plan Meeting 32 | $ 4,776.00
4. Prepare Revised Study Plan 12 | $ 1,894.00
Implementation of Study Plan’
1. Instream Habitat 308 | $ 35,647.00
2. RTE Mussel Survey 200 | $ 27,108.75
3. Water Quality Study 234] $ 35,271.40
4, Telemetry Study Upstream/Downstream
Migrating Shad and Herring
Full Study 330 | $ 79,056.50
Reduced Study 314] $ 64,665.00
Minimum Study 282 | $ 44,632.00
5. Juvenile Alosine Telemetry
Radio Telemetry Study 414 | $ 64,571.50
PIT Tag Study 316 | $ 30,359.00
Defer 0| $ -
6. Desktop Entrainment Assessment 168 | $ 16,184.00
Draft Application
1. Prepare DLA * 242 | $ 55,118.00
2. Process Management 70 | $ 10,820.00
* Price includes Subcontractor costs
Total Estimated Cost
Minimum | $ 262,233.15
Maximum | $ 361,229.15

City of Nashua
June 18, 2019
Page 11

’™» NORMANDEAU City of Nashua
BAARF ASSOCIATES June 18, 2019
Se age

ENVIRONMENTAL CONSULTANTS

Table 3. 2019-2021 Normandeau rate table for the City of Nashua Mine Falls Relicensing.

LABOR CATEGORY HOURLY RATE
Senior Associate Il 326.00
Senior Associate | 214.00
Senior Principal Scientist 173.00
Principal Scientist 143.00
Senior Scientist 112.00
Scientist IV 87.00
Scientist II] 73.00
Scientist Il 59.00
Scientist | 48.00
Scientist Aide 36.00
Technology Specialist 143.00
GIS Specialist 102.00
Data Specialist 92.00
Senior Technician II 145.00
Senior Technician 107.00
Technician V 94.00
Technician IV 82.00
Technician III 64.00
Technician Il 51.00
Technician | 38.00
Administrative V 92.00
Administrative IV 80.00
Administrative Ill 66.00
Administrative II 56.00