FEDERAL ENERGY REGULATORY COMMISSION Project No. 405 ...

20100204-3055 FERC PDF (Unofficial) 02/04/2010 

OFFICE OF ENERGY PROJECTS 

Ms. Colleen Hicks 

Exelon Power 

300 Exelon Way 

Kennett Square, PA 19348 

FEDERAL ENERGY REGULATORY COMMISSION 

WASHINGTON, D.C. 20426 

February 4, 2010 

Project No. 405-087- Maryland/Pennsylvania 

Conowingo Hydroelectric Project 

Exelon Generation Company, LLC 

Reference: Study Plan Determination for the Conowingo Hydroelectric Project 

Dear Ms. Hicks: 

Pursuant to 18 CFR § 5.13(c) of the Commission regulations, this letter contains 

my study plan determination for Exelon Generation Company, LLC’s (Exelon) 

Conowingo Hydroelectric Project. This determination is based on staff’s review of the 

revised study plan, comments on the proposed and revised study plans, and the verbal 

record, including comments made at the study plan meetings. 

Some study issues have been resolved. The bases for my findings on the issues 

still in dispute are discussed in Appendix A. A list of the approved studies is attached as 

Appendix B. 

Background 

On August 24, 2009, Exelon filed a proposed study plan that included studies on 

water quality (study 3.1), upstream and downstream fish passage for anadromous fish and 

American eel (studies 3.2 through 3.9), Maryland darter (study 3.10), hydrology of the 

lower Susquehanna River (study 3.11), reservoir water levels (study 3.12), tributary 

access in Conowingo Pond (study 3.13), debris management (study 3.14), sediment 

introduction and transport (study 3.15), instream flow and aquatic habitat (study 3.16), 

aquatic vegetation (study 3.17), aquatic communities and freshwater mussels (studies 

3.18 and 3.19, respectively), salinity and salt wedge encroachment (study 3.20), 

migratory fish reproduction (study 3.21), shortnose and Atlantic sturgeon (study 3.22), 

habitat areas for bald eagles (study 3.23), zebra mussels (study 3.24), creel surveys and


Project No. 405-087 2 

recreation needs (studies 3.25 and 3.26, respectively), shoreline management (study 

3.27), and cultural resources (study 3.28). On September 22 and 23, 2009, Exelon held 

study plan meetings to discuss the proposed study plan. 

Following the conclusion of the study plan meetings, Exelon filed a revised study 

plan on December 22, 2009. In addition to the studies listed above and in order to 

address comments received during the study plan meetings, the revised study plan 

contains four additional studies that address the potential effects of the project on 

downstream flooding (study 3.29); osprey and black crowned night heron nesting (studies 

3.30 and 3.31, respectively); and a re-evaluation of the closing of the project catwalk to 

recreational fishing (study 3.32). Comments on the revised study plan were filed by the 

U.S. Department of the Interior (Interior), Maryland Department of Natural Resources 

(Maryland DNR), the Pennsylvania Fish & Boat Commission (Fish & Boat 

Commission), the Susquehanna River Basin Commission (SRBC), and the Nature 

Conservancy on January 20, 2010; the Pennsylvania Department of Environmental 

Protection (Pennsylvania DEP) on January 21, 2010; and the U.S. Department of 

Commerce (Commerce) on January 26, 2010. 1 Staff also considered comments on the 

proposed study plan filed by the Pennsylvania Game Commission on November 23, 

2009. Although the Pennsylvania Game Commission commented on the proposed study 

plan, it did not comment on the revised study plan. 

Study Plan Determination 

The applicant’s revised study plan filed on December 22, 2009, is approved, with 

the following modifications: 

Seasonal and Diurnal Water Quality in Conowingo Pond and below Conowingo Dam 

(Study 3.1) 

In order to better evaluate the impact of the project on water quality in the 

Conowingo Pond and in the Susquehanna River below Conowingo dam, the revised 

study plan must include: 

Reporting river flow data for both the Conowingo and Marietta U.S. 

Geological Survey (USGS) stream gauges when water quality is sampled. 

1 On October 1, 2009, a number of resource agencies requested that the deadline 

for stakeholders to file comments on the revised study plan be extended from 

January 6, 2010, until January 20, 2010. By letter issued October 19, 2009, the 

Commission granted the extension of time request and published a revised process plan 

and schedule, which is included here as Appendix C.



Sampling of three transects below Conowingo dam (across Station 643, across 

the area known as “Lee’s Ferry” and across the area known as “The Pool”) 

using the same methodology proposed for upstream transects. 

Designation of a mid-point station for each water quality transect as the deeper 

of two stations closest to the mid point of the river. 

Hourly collection of water quality in the discharge boils from July 1, 2010, to 

August 31, 2010, over the course of two consecutive days according to the 

following schedule regardless of stratification in the Conowingo Pond, river 

flow, or water temperature: 

Friday/Saturday 7/2 & 7/3; 7/16 & 7/17; 7/30 & 7/31; 8/13 & 

8/14;8/27 & 8/28 

Sunday/Monday 7/4 & 7/5; 8/1 & 8/2; 8/15 & 8/16; 

Wednesday/Thursday 7/14 & 7/15; 8/25 & 8/26 

Sampling the discharge boils from all operating turbines for dissolved oxygen 

and water temperature regardless of turbine type. 

Downstream Fish Passage Effectiveness Study (Study 3.2) 

I am not requiring the on-site turbine mortality testing component of the study 

because sufficient information is available in existing literature to assess this issue. 

Biological and Engineering Studies of American Eel at the Conowingo Project (Study 

3.3) 

In order to evaluate potential protection, mitigation, or enhancement measures at 

the project, the study plan must include all areas of the dam and spillway, including the 

far eastern portion. The study report must include a literature-based identification and 

evaluation of all known American eel avoidance or exclusion techniques at hydropower 

projects. 

American Shad Passage Study (Study 3.4) 

I am not requiring the American shad study because the information is either 

redundant with other studies or would not inform a decision on fish passage at the 

project. 

Upstream Fish Passage Effectiveness Study (Study 3.5) 

In order to help inform an evaluation of potential protection, mitigation, or 

enhancement measures, the study plan must: consider both operational and structural 

factors that may affect successful or timely passage; not use recreational anglers to



collect test fish; track radio-tagged fish from mid-April until August 1; conduct weekly 

tracking covering the entire area from the mouth of the river upstream to Holtwood dam; 

change the study location designation “10” to “11”; add two additional remote 

monitoring stations (below the spillway and between the tailrace and Port Deposit); 

assess the influence of all independent variables on radio-tagged fish movement and 

behavior; determine the location of all tagged fish before, during, and after changes to 

project operations; and plot the hourly locations of stranded fish on plan view maps. The 

study plan must also clarify that additional fieldwork may be required in 2011 if the 

Commission determines that testing certain agency-recommended project manipulations 

is necessary. 

Conowingo East Fish Lift Attraction Flows (Study 3.6) 

In order to inform an evaluation of potential protection, mitigation, or 

enhancement measures, the study plan must be clarified to indicate that the results of the 

upstream fish passage effectiveness study (study 3.5), as well as all historical data from 

2000 to the present that are available and relevant, will be reviewed and discussed in the 

study report. The analysis in the report must also include an evaluation of the following 

parameters: turbine on/off times; duration of turbine operation; river flow; spill data; 

water temperature; attraction flow velocities; and hourly passage of American shad and 

gizzard shad. Finally, the study plan must clarify that additional field study may be 

required in 2011 if the Commission determines that testing certain agency-recommended 

changes in project operation or structures is necessary. 

Downstream Flow Ramping and Fish Stranding Study (Study 3.8) 

The study plan must be clarified to indicate that surveys of stranded fish will occur 

as soon as possible after the cessation of peaking generation, that the number and general 

condition of any stranded fish will be recorded, and that photographic documentation of 

stranded fish will accompany the proposed GIS mapping of stranding locations. This 

information will be useful in interpreting the results of the proposed instream flow habitat 

assessment (3.16) as well as evaluating any proposed, recommended, or required 

operational changes. 

Hydrologic Study of the Lower Susquehanna River (Study 3.11) 

In order to assess the degree to which each hydroelectric facility in the lower 

Susquehanna River contributes to sub-daily fluctuations of river flow, potential 

operational alternatives will be evaluated to assess potential benefits to downstream 

environmental resources. Potential operational alternatives that must be assessed include: 

(1) existing conditions; (2) run-of-river operation; (3) introduction of ramping rates; 

(4) restrictions on peaking operations during time periods with critical life history stages 

for migratory fish; and (5) changes in minimum flows.



Water Level Management (Littoral Zone and Water Level Fluctuation) (Study 3.12) 

In order to comply with accepted scientific methodology, the study plan must be 

clarified to indicate that an aquatic ecologist must be present during all habitat mapping. 

Sediment Introduction and Transport (Sediment and Nutrient Loading) (Study 3.15) 

Exelon’s revised study plan includes projections of sediment accumulation and 

options to manage, mitigate, and remove accumulated sediment. However, it did not 

address benchmarks (triggers) for potential impacts and actions. Given the temporal 

variability of when the reservoir will reach its sediment storage capacity, the study report 

should include a sediment management plan that includes projections of sediment 

accumulation; benchmarks for potential impacts and actions; and options to manage, 

mitigate, and remove accumulated sediment. If, at the completion of the Sediment 

Introduction and Transport (Sediment and Nutrient Loading) Study, the results of the 

study do not adequately characterize the geographic and temporal cumulative effects, 

Exelon may be required to conduct a sediment transport modeling study during the 

second field season (2011). 

Freshwater Mussel Characterization Study below Conowingo Dam (Study 3.19) 

In order to comply with accepted scientific methodology, the study plan must be 

revised to expand the literature and specimen search to: include museum holdings not 

necessarily near the project site; specify that river flow will be recorded during all mussel 

surveys; and specify that voucher specimens collected will be deposited into the 

collections of a state or regional natural history museum. 

Salinity and Salt Wedge Encroachment (Study 3.20) 

Because the goal of the study is to evaluate the impact of project operation on 

salinity encroachment in the drinking water intakes for the City of Havre de Grace, 

Maryland, the critical salinity threshold of 0.3 parts per thousand (ppt) in Task 1 of the 

revised study plan must be revised to the current Environmental Protection Agency 

standard for drinking water of 0.25 ppt. 

Impact of Plant Operations on Migratory Fish Reproduction (Study 3.21) 

In order to characterize the current levels of migratory fish reproduction which are 

not likely to be reflected by historical data, the study plan must be revised to include onsite 

ichthyoplankton sampling during 2011 at locations indicated by the radio-telemetry 

data collected in study 3.5 during 2010.



Shortnose and Atlantic Sturgeon Life History Studies (Study 3.22) 

In order to inform an evaluation of potential protection, mitigation, or 

enhancement measures, the study plan must be revised to indicate that the study report 

will include a comparison between the Conowingo fish lift and any East Coast passage 

facilities where successful shortnose or Atlantic sturgeon upstream passage has been 

documented. Also, Exelon must consult with Commerce on the deployment of a second 

array of receivers near the mouth of the Susquehanna River to monitor the lower river for 

sturgeon tagged with acoustic transmitters, in addition to the array proposed by Exelon 

near the project dam. 

Dreissenid Mussel Monitoring Study (Study 3.24) 

The study plan must be revised to clarify in section 3.24.2 that zebra mussel 

veligers (larvae) were documented during 2009 at the Peach Bottom Atomic Power 

Station intake canal. 

Creel Survey of Conowingo Pond and the Susquehanna River below Conowingo Dam 

(Study 3.25) 

In order to obtain an accurate representation of angler use at the project, the study 

plan must be revised to include an aerial count schedule which includes counts conducted 

during peak fishing times, both in the morning and evening, in addition to mid-day. The 

schedule must also consist of either randomized sampling between weekdays and 

weekends, or a near-equivalent sampling of each period. 

Recreational Inventory and Needs Assessment (Study 3.26) 

The plan proposes a literature review to identify recreational organizations that 

would be utilized as data sources as well as surveyed via phone. To ensure that sufficient 

input from the angling community is solicited, the list of entities included in the literature 

review phone surveys must include fishing organizations within the project because of 

the apparent popularity of angling. Also, in order to accurately evaluate whether existing 

recreation facilities and access to the Susquehanna River in the investigation area are 

meeting current user needs, Task 1 of section 3.26.7 (methodology) must be expanded to 

include on-site surveys conducted at Fisherman’s Park and downstream fishing sites 

within the project boundary. 

To ensure recreational safety is adequately assessed in terms of current project 

operation, the study plan must be revised to indicate that the location of the line 

designated to restrict boaters from accessing the tailrace will specifically be re-evaluated 

as part of the study.



Finally, the plan should be modified to indicate that the study report will include 

an updated list of all project recreational sites, facilities, and opportunities to clarify 

which sites will be evaluated within the needs assessment beyond what is provided in 

table 2.8-1 (Recreational Project Facilities Required, Contemplated, & Currently 

Existing). 

Shoreline Management (Study 3.27) 

In order to assess whether protection measures should be included in the shoreline 

management plan, Tasks 1 and 2 of section 3.27.7 (methodology) must be expanded to 

identify unique, sensitive, and/or critical fish and wildlife habitat on the project shoreline. 

If you have any questions, please contact John Smith at (202) 502-8972. 

Sincerely, 

Jeff C. Wright 

Director 

Office of Energy Projects 

Enclosures: Appendix A, Study Request Issues 

Appendix B, Approved Studies 

Appendix C, Revised Process Plan and Schedule 

cc: Mailing List 

Public File


Project No. 405-087 

APPENDIX A – STUDY REQUEST ISSUES 

Staff’s Findings/Response to Comments on the Study Plan 

Below staff discuss comments and recommendations on the revised study plan 

filed by the U.S. Department of the Interior (Interior), Maryland Department of Natural 

Resources (Maryland DNR), the Pennsylvania Fish & Boat Commission (Fish & Boat 

Commission), the Susquehanna River Basin Commission (SRBC), and the Nature 

Conservancy on January 20, 2010; the Pennsylvania Department of Environmental 

Protection (Pennsylvania DEP) on January 21, 2010; and the U.S. Department of 

Commerce (Commerce) on January 26, 2010. Staff also considered comments on the 

proposed study plan filed by the Pennsylvania Game Commission on November 23, 

2009. Although the Pennsylvania Game Commission commented on the proposed study 

plan it did not comment on the revised study plan. To the extent that the revised study 

plan was not responsive to issues raised by the Pennsylvania Game Commission, staff 

have attempted to address those issues under the appropriate subheading below. 

3.1 Seasonal and Diurnal Water Quality in Conowingo Pond and below Conowingo 

Dam 

In Task I of the revised study plan, Exelon proposes to conduct weekly water 

quality monitoring at five historically established transects in Conowingo Pond from 

April through October 2010. At each transect, Exelon would collect dissolved oxygen 

(DO) and water temperature profiles from the surface to the bottom at 5-foot intervals. In 

addition, surface pH, turbidity and fecal coliform samples would be collected at the midpoint 

station of each water quality transect and weather conditions, river flow as 

measured at the United States Geological Survey (USGS) gauge at Marietta, 

Conowingo’s generation status, and approximate wind speed during each sampling event 

would be recorded. No water quality monitoring is proposed downstream of the project 

in the riverine section. 

The Maryland DNR, Pennsylvania DEP, Fish & Boat Commission, Interior, 

SRBC, and Pennsylvania DEP (agencies) request that Task 1 of the water quality study 

be revised to include sampling at three transects downstream of the Conowingo dam 

using the same methodology as proposed for the upstream transects because downstream 

monitoring was not included in the study plan. The three transects are described as 

follows: 

1) Station 643 – Extending from station 643 across the river to the east shore, to 

the backwater labeled P7 (as shown in figure 4.4.6-1 of the preapplication 

document (PAD));



2) Lee’s Ferry – Extending the entire width of the river in the area known as 

‘Lee’s Ferry” and being generally perpendicular to the banks of the river in this 

area; and 

3) The Pool – Extending the entire width of the river in the area known as “The 

Pool” and being generally perpendicular to the banks of the river in this area. 

In addition, the agencies comment that in cases where there is an even number of 

points on a given transect upstream, the mid-point station could not be readily identified 

and suggest a method for identifying the mid-point station by depth measurement. For 

each transect, the mid-point station would be designated by measuring depth at the two 

transect points closest to the mid-point of the Conowingo Pond. The deeper of the two 

transect points would be designated as the mid-point station for that water quality 

transect. 

The agencies also comment that river flow data from the USGS gauge at 

Conowingo would provide additional useful data for the water quality study and 

recommend that river flow at the Conowingo USGS gauge be recorded for each water 

quality sampling event in addition to river flow at the Marietta USGS gauge. 

In water quality investigations performed at other hydropower facilities, studies 

that include water quality monitoring in the impoundment (upstream) typically include a 

downstream water quality monitoring component to evaluate the effects of the project on 

water quality. The additional water quality transects proposed by the agencies would 

provide useful information on impacts of the project downstream in the Lower 

Susquehanna River and the proposed methodology is consistent with generally accepted 

practice in the scientific community. Measuring water quality across a transect at station 

643 also would inform a decision about how representative station 643 is as a compliance 

point for water quality downstream of the project. With additional downstream water 

quality transects, recording river flow data downstream of the project at the Conowingo 

USGS gauge during each water quality sampling event would provide beneficial 

information to correlate water quality with river flow. In addition, the proposed 

designation of the mid-point station by depth measurement would ensure that the vertical 

profile water quality data captures a depth profile over each water quality transect. 

Therefore, staff believe it is reasonable to include the three water quality transects below 

the dam, recording river flow data for the Conowingo and Marietta USGS gauges 

whenever water quality is sampled, and a designation of the mid-point station to Task 1 

of the Water Quality Study. As such, Task 1 of the water quality study should be revised 

to include these modifications. 

Task 2 – Discharge boil water quality sampling



For Task 2, Exelon proposes to sample the discharge boils of the operating 

turbines when Conowingo Pond is stratified primarily from July to August 2010. The 

goal of this task is to determine if the compliance monitoring point (station 643) is 

representative of actual DO levels that the project discharges during all modes of 

operation during a historic period of higher temperature and low DO. This period 

historically corresponds to flow less than 10,000 cubic feet per second (cfs) and water 

temperatures greater than 75 degrees Fahrenheit ( o F). Discharge boils would be sampled 

for temperature and DO over the course of two consecutive days from 6:00 a.m. to 6:00 

p.m. The agencies have requested sampling the discharge boils from operating turbines 

during the entire period of historic low flow and higher temperatures (July 2 through 

August 30, 2010) from 6:00 a.m. to 6:00 p.m. for two consecutive days on Friday and 

Saturday of the first week and Sunday and Monday of the second week regardless of 

stratification in Conowingo Pond, river flow or water temperature according to the 

following schedule in order to better understand the impact of a variety of project 

operation modes on DO. 

Friday/Saturday 7/2 & 7/3; 7/16 & 7/17; 7/30 & 7/31;8/13 & 8/14;8/27 & 8/28 

Sunday/Monday 7/4 & 7/5; 7/18 & 7/19; 8/1 & 8/2; 8/15 & 8/16; 8/29 & 8/30 

While we agree with the agencies sampling approach, modifying the study to 

sample mid week on a few occasions over the course of the study would better represent 

variations in project operation since periods of higher electricity demand occur during 

mid week rather than on weekends. Therefore, we recommend modifying the agencies’ 

recommended sampling schedule to include monitoring for two consecutive days mid 

week (Wednesday and Thursday) once each month during July and August according to 

the following schedule to better capture variations in project operation. 

Friday/Saturday 7/2 & 7/3; 7/16 & 7/17; 7/30 & 7/31; 8/13 & 8/14;8/27 & 

8/28 

Sunday/Monday 7/4 & 7/5; 8/1 & 8/2; 8/15 & 8/16; 

Wednesday/Thursday 7/14 & 7/15; 8/25 & 8/26 

Comments from Maryland DNR, SRBC, the Fish & Boat Commission, and 

Pennsylvania DEP also state that Exelon’s proposed sampling schedule for the discharge 

boils has the potential to exclude manual DO sampling of the discharge boils. Based on 

historic river flow and water quality data, it is unlikely that river conditions during the 

July through August sampling period would not be suitable for sampling the discharge 

boils. However, we believe that Exelon has placed too many conditions that must be met 

before initiating the discharge boil sampling program which could limit the amount of 

data collected for this portion of the study. A reduced data set has the potential to limit 

the statistical evaluation of whether station 643 is a representative compliance point. 

Therefore, in order to provide sufficient data for the Task 3 statistical analysis, the study



plan should be modified to sample discharge boils according to the schedule listed above 

regardless of thermal or DO stratification in the Conowingo Pond or river flow. 

The agencies also request that the word ‘Francis” be removed from the description 

of “operating turbines” in Task 2 as this also could significantly limit the amount of data 

collected from the discharge boils. Limiting the monitoring of the discharge boils only to 

operating Francis turbines would reduce available data for analysis and would not capture 

the range of project operations. Therefore, Task 2 should be modified to collect DO and 

water temperature data from the discharge boils of all operating turbines regardless of 

type. 

Interior recommends that DO be measured “in the turbine boils at all minimum 

flow generation” including flows greater than 10,000 cfs because flow releases greater 

than 10,000 cfs could still be withdrawn from oxygen deficient levels in the 

impoundment thus impacting water quality in the tailrace. Staff are unclear what is 

meant by “minimum flow generation.” We interpret this recommendation as a request to 

sample all discharge boils during historic periods of higher temperature and lower DO to 

include minimum flows above and below 10,000 cfs. Staff’s recommended modification 

above to Task 2 should capture all minimum flows when the level of DO is low in the 

impoundment. However, staff do not recommend that Task 2 be modified to measure 

water quality at the discharge boils when flow exceeds 10,000 cfs beyond the revised 

July-August sampling period because monitoring outside this period would not likely 

capture periods of low DO in the impoundment. 

Continuous temperature monitoring 

Interior states that project operations could create temperature zones that act as a 

barrier to fish movement or migration and recommends the addition of continuous water 

temperature monitoring at various locations in Conowingo Pond, the tailrace, and 

downstream of the project in the Susquehanna River to the upper Chesapeake Bay. 

Under Task 1, the proposed water quality study will monitor temperature during 

the spring anadromous fish migration season and the historic period of low flow and high 

temperature upstream and downstream of the project. Exelon will also report generating 

status for the project (number of turbines operating, flow etc), which will capture 

information on how project operation is impacting water quality. Staff believe that the 

water quality study with the included modifications will provide sufficient information to 

evaluate the effects of the project on water temperature. If the data supplied in the water 

quality study report are insufficient to evaluate project impacts on temperature, additional 

monitoring could be required during the second study season (2011). 

Water Quality Modeling



Interior, The Nature Conservancy and SRBC all request modeling to assess the 

impacts of the project on water quality (including salinity) in the Susquehanna River and 

upper Chesapeake Bay. Interior also recommends collection of water quality data from 

the National Oceanic and Atmospheric Administration, Chesapeake Bay Interpretive 

Buoy System for the Susquehanna buoy at the mouth of the river for inclusion in the 

water quality model. Exelon is not proposing any changes in operation and the proposed 

water quality study with staff’s recommended modifications in conjunction with the other 

studies should be sufficient for an understanding of the effects of the project on water 

quality. If the data supplied in the water quality study report after the first year of study 

is insufficient to evaluate project impacts on water quality, modeling could be required 

for the second study season. 

3.2 Downstream Fish Passage Effectiveness Study 

Exelon proposes to estimate entrainment, impingement, and related mortality of 

both resident and migratory fish at the project based on a literature review, on-site turbine 

mortality testing using balloon tagging methods, and project-specific physical 

characteristics such as hydraulic head and turbine specifications. 

Maryland DNR, SRBC, Fish & Boat Commission, and Pennsylvania DEP request 

several modifications to the turbine mortality part of Exelon’s proposed study as follows: 

1) study of all five specific turbine models at the project not just the two general types 

(Kaplan and Francis) proposed by Exelon; 2) turbine testing during July and August to 

better simulate natural conditions during the most stressful downstream passage period; 

3) testing during various operational scenarios, such as “aeration on” versus “aeration 

off,” over a range of wicket gate settings, etc.; 4) a better explanation of the statistical 

analyses to be used to determine turbine test sample size calculations; 5) mandatory 

American eel testing regardless of their seasonal availability; and 6) an increase in the 

sample sizes of fish and number of species to be tested. In addition to items (2) and (3) 

from the list above, Interior also recommends that Exelon be required to conduct turbine 

mortality tests on river herring. 

Given the amount of available literature on turbine mortality rates for rivers with 

similar species assemblages and dams of similar design to Conowingo, staff do not 

believe that on-site turbine mortality testing is necessary to make reasonable estimates of 

turbine mortality at the project. While Exelon is certainly free to conduct such studies, 

staff believe that a literature review, combined with a review of the compiled studies of 

migratory fish already conducted at the project during the current license term, will be 

adequate to evaluate proposed, recommended, or required measures. 

3.3 Biological and Engineering Studies of American Eel at the Conowingo Project



Exelon proposes both a literature review, as well as certain on-site field surveys to 

evaluate the biological and engineering feasibility aspects of American eel passage at the 

project. 

Maryland DNR, SRBC, Fish & Boat Commission, Pennsylvania DEP, and Interior 

request that Exelon be required to survey and sample the entire spillway, including the 

east shore area, as possible locations for an upstream eel fishway at the dam. Maryland 

DNR, SRBC, Fish & Boat Commission, and Pennsylvania DEP also recommend that 

Exelon conduct a literature review to identify and evaluate all known avoidance and 

exclusion techniques for American eel at hydropower plants. 

Staff agree that the entire spillway, including the far eastern end, should be studied 

because eels are known to congregate and attempt passage wherever a spillway surface is 

wetted and a suitable attraction flow is present. If reasonable safety precautions are 

taken, all areas of the dam could be safely studied. Staff also agree that the a review and 

evaluation of known avoidance and exclusion techniques should be included in the study 

report to assist in evaluating any proposed, recommended, or required measures. 

3.4 American Shad Passage Study 

In order to summarize existing information on shad restoration progress and 

population trends, Exelon proposes to conduct a literature review and prepare a summary 

report of all fish passage studies and data available at the Conowingo Project. Exelon 

also proposes to develop a shad population model for the Susquehanna River. 

Maryland DNR, SRBC, Pennsylvania DEP, Fish & Boat Commission, and Interior 

question the necessity of this study and note that they did not request such a study, do not 

think it is necessary, and do not think it is a good use of the estimated $110,000 cost. 

The literature review and a summarization component of the study was 

specifically requested by Commission staff because staff believed it would be useful to 

have a single document on the extensive fish passage and behavior research that has 

occurred over the years in pursuit of agency migratory fish restoration goals. However, 

given that many of the other fish passage, fish protection, and fish behavior studies 

proposed in the revised study plan will include reports that contain summaries of existing 

literature, staff agree this study is no longer necessary. Staff also do not believe that the 

proposed shad population model is likely to contribute much to the analysis of potential 

restoration measures in any environmental document prepared by Commission staff. It 

appears that the reason for the rise and fall of the numbers of shad returning to 

Conowingo dam is not well understood at this time and it is unclear how a model could



be successfully used to predict future run numbers when at least some of the basic 

assumptions of the model would be scientifically unverifiable. 

3.5 Upstream Fish Passage Effectiveness Study 

Exelon proposes to evaluate the effectiveness of the existing Conowingo East fish 

lift by tracking radio-tagged adult shad released into the river below the dam. 

Maryland DNR, SRBC, Pennsylvania DEP, and the Fish & Boat Commission 

recommend several modifications to the revised study plan as follows: 1) consider both 

operational as well as structural factors that may be affecting successful and/or timely 

passage; 2) not allow recreational anglers to participate in the collection of test fish 

because differences in fish handling procedures could introduce bias into the study; 3) 

monitor all radio-tagged fish until August 1 to better understand their ultimate fate; 4) 

consider the results of this study’s applicability to study 3.6 Conowingo East Fish Lift 

Attraction Flows and discuss this study in the report generated for study 3.6; 5) change 

the study location designation “10” to “11” to prevent it from being confused with the 

location near Port Deposit; 6) conduct a second season of tracking radio-tagged fish after 

the results of the first season have been provided to the agencies, thus allowing the 

agencies to suggest structural or operational manipulations that they believe should be 

tested. 

In addition to modification (3) from the list above, Interior also recommends that 

Exelon assess the influence of all independent variables on radio-tagged fish movement 

and behavior, determine the location of all tagged fish before, during, and after changes 

to project operation and plot the hourly locations on plan view maps, add additional 

monitoring stations between stations 1 and 8 as well as an additional station along the 

spillway immediately downstream of the dam, and require mobile tracking on a weekly 

basis from the mouth of the Susquehanna River up to Holtwood dam in order to locate 

“lost fish.” 

Staff believe that modification (1) is necessary and would be helpful in evaluating 

the range of potential measures which may be proposed, recommended, or required. 

Modification (2) makes sense because without this clarification, data may be 

biased and misinterpreted due to differences in fish handling practices. 

Modification (3) as well as Interior’s recommendation to track fish weekly from 

the mouth of the river up to Holtwood dam, are both necessary to determine the ultimate 

fate of radio tagged fish. Without these study criteria, conclusions about the 

effectiveness of the upstream fish passage facilities may be unclear.



Modification (4) would coordinate the results of this study with those from study 

3.6. Because studies 3.5 and 3.6 both address the effectiveness of upstream passage at 

the Conowingo dam, the findings of each study may be useful in the interpretation and 

conclusions drawn in the other. Therefore, the study reports from each of these two 

studies (3.5 and 3.6) should discuss the relevant findings from both studies, to the extent 

they are useful in interpreting the data and making recommendations for improving the 

effectiveness of upstream passage at the east fish lift. 

Staff recommends incorporation of modification (5) in order to avoid confusion in 

the study results. 

Modification (6) addresses the possible need for additional field study in 2011 

based on the results of 2010 studies. Staff do not consider it appropriate at this time to 

assume that additional study will be necessary. However, Exelon should clarify that 

additional tests of agency-recommended project manipulations may be required in 2011 

if the Commission determines that the information would be needed to evaluate any 

proposed, recommended, or required measures. 

Interior’s recommendations to assess the influence of all independent variables on 

radio-tagged fish movement and behavior, determine the location of all tagged fish 

before, during, and after changes to project operations, and plot the hourly locations on 

plan view maps would all add to the value of the study for evaluating the need for any 

additional 2011 field work and, ultimately, evaluating any proposed, recommended, or 

required measures. 

Interior’s recommendation to add additional remote monitoring stations to detect 

radio-tagged fish has merit because Interior’s recommended new locations would 

otherwise be unsampled under Exelon’s proposed study design. Placing a station directly 

below the spillway would help identify if fish get lost and/or stranded in this area. By 

placing a station somewhere between the tailrace and Port Deposit (the site of station 8), 

additional information about shad behavior may be learned, especially as it relates to 

passage delays which could be affecting upstream passage effectiveness. 

3.6 Conowingo East Fish Lift Attraction Flows 

In this study, Exelon plans to study the relationship between shad passage and 

attraction flow velocities during the 2010 shad passage season (and possibly 2011). 

Exelon also plans to review 2008 and 2009 “historical data” from the East fish lift and 

produce a report discussing the historical and current data along with data gathered 

during study 3.5 Upstream Fish Passage Effectiveness Study.



Maryland DNR, SRBC, and Pennsylvania DEP recommend several modifications 

to the revised study plan as follows: 1) coordinate this study with study 3.5; 2) review all 

applicable data from 2000 to 2009 under the designation of “historical data;” 3) analyze 

and report turbine on/off times, duration of turbine operation, river flow at the 

Conowingo gage, spill data, and water temperature; 4) conduct a second year of study in 

2011 to evaluate project manipulations recommended for testing by the agencies after 

they have the chance to review the first season’s data; 5) make the measurement of 

attraction flow velocities mandatory, unless there are demonstrated safety considerations; 

and 6) add hourly passage of American shad and gizzard shad correlated to all units to the 

listed correlation matrices. The Fish & Boat Commission recommends modification (1) 

from the list above. Interior recommends modification (2) from the list above as well as 

requiring Exelon to include a “fine-scale, near-field flow modeling analysis (2-D or 3- 

D)” of the tailrace and the spillway from the dam to the upstream end of Rowland Island. 

Modifications (1) and (2) require the inclusion of all relevant data from other 

ongoing studies and historical information to the interpretation of data from this study. It 

makes sense to review all historical data as far back as 2000, or earlier, to the extent it is 

available and relevant. Similarly, since studies 3.5 and 3.6 both address the effectiveness 

of upstream passage at the Conowingo dam, the findings of each study may be useful in 

the interpretation and conclusions drawn in the other. Therefore, staff recommend that 

Exelon clarify that the study reports from each of these two studies (3.5 and 3.6) will 

discuss the relevant findings from both studies, to the extent they are useful in 

interpreting the data and making recommendations for improving the effectiveness of 

upstream passage at the east fish lift. 

Modifications (3), (5), and (6) address data collection methods and parameters that 

could be useful in the interpretation of the study results and possibly inform a decision 

about any necessary 2011 field work. By analyzing data on turbine on/off times, duration 

of turbine operation, river flow, spill data, water temperature, attraction flow velocities, 

and hourly passage of American shad and gizzard shad, many of the hypotheses 

regarding how to enhance the effectiveness of attraction flows and upstream passage at 

the east fish lift could be tested. Therefore, we recommend including these 

modifications. 

Modification (4) addresses the possible need for a second field season in 2011, 

after the agencies have had a chance to review and consider the results of study 3.5 and 

3.6 for 2010. Staff do not consider it appropriate at this time to assume that additional 

study will be necessary. However, Exelon should clarify that additional tests of agencyrecommended 

project manipulations may be required in 2011 if the Commission 

determines that the information would be needed to evaluate any proposed, 

recommended, or required measures.



Interior’s recommendation for additional flow field modeling is not supported by 

an explanation of why such modeling is necessary or how Exelon’s methods are not 

considered scientifically acceptable as required under section 5.9(b)(6). Therefore, staff 

have no basis for recommending this modification of the study plan. 

3.8 Downstream Flow Ramping and Fish Stranding Study 

Exelon proposes to review existing habitat assessment data below Conowingo dam 

to assess when and where stranding is a problem and then conduct field surveys to 

determine the extent of fish stranding. 

Maryland DNR, SRBC, Pennsylvania DEP, and Fish & Boat Commission stress 

that the surveys must be conducted at “first light” before stranded fish may be eaten by 

predatory birds. Maryland DNR also recommends that Exelon be required to collect and 

report the general condition of fish observed in the field surveys. Interior recommends 

that Exelon be required to delineate in a GIS format, with photo documentation in the 

final report, any isolated pools and remnant flow channels that form in the spillway reach 

during all minimum flow conditions. 

Staff agree that in order to accurately characterize the extent of fish stranding 

impacts below the Conowingo dam, surveys should be conducted as soon as possible 

after peaking generation has ceased. Therefore, specifying the exact time of day (e.g., 

“first light”) would seem to be unnecessary and potentially confusing since peaking does 

not always occur at the same time. Staff also agree that any stranded fish should be 

enumerated, identified by species, and their general condition should be noted. Exelon 

already proposes to identify fish species and produce maps of stranding locations in a 

GIS format, although the revised study plan does not mention photo documentation as 

Interior recommends and Exelon does not state whether fish will be counted or if their 

condition will be noted. Therefore, staff recommends these modifications and 

clarifications. This information would be useful in quantifying any stranding effects and 

evaluating any proposed, recommended, or required operational changes. 

3.11 Hydrologic study of the Lower Susquehanna River 

In its revised study plan Exelon proposed a hydrologic study to identify a potential 

comprehensive flow management regime for the lower Susquehanna River that could 

minimize environmental impacts, while maintaining the viability of energy generation 

and water supply uses. This study would be accomplished by developing a timeline of 

flow management in the lower Susquehanna River through a literature review, by 

hydrologic analysis of historical data collected at two USGS gauging stations, and by 

evaluating various alternative operating scenarios with Exelon’s operations model.



Pennsylvania DEP, the Fish & Boat Commission, and SRBC (agencies) request 

that Exelon demonstrate, by way of social and economic values, that operating as a 

peaking facility convincingly outweighs the benefits of a return to natural flows. 

The revised study plan includes the development of an operations model to 

simulate the movement of water through hydropower projects including Safe Harbor, 

Holtwood, Muddy Run and Conowingo. The operations model would be calibrated to 

existing conditions, also referred to as “baseline” conditions. The operations model 

would then be used to simulate the effects of alternative flow management scenarios 

(e.g., minimum flow and water level restrictions, run-of-river operation). The results of 

the alternative flow management scenarios would then be compared to the baseline 

condition to determine the relative impacts to reservoir water levels, streamflow, and 

energy generation. In the revised study plan, Exelon is proposing to compare peaking 

operations (baseline conditions) to natural flow operation (run-of-river operation). Staff 

understand that Exelon will develop an economic value for each scenario using base load 

and peaking rates. Therefore, it is our opinion that the revised study plan addresses the 

agencies’ request. 

Indicators of hydrologic alteration analysis 

Exelon proposes in its revised study plan in section 3.11.7, Task 2, to develop a 

hydrologic analysis of historical data collected at two USGS gauging stations to confirm 

the accuracy of the data and to calculate hydrologic statistics. The calculation of several 

of the hydrologic statistics will be achieved through the completion of an Indicators of 

Hydrologic Alteration (IHA) analysis. In the revised study plan, Exelon states that they 

will use the software package IHA Version 7. Exelon goes on to state that they will 

develop a frequency distribution of hourly or 15-minute flow levels. 

Maryland DNR, Pennsylvania DEP, Fish & Boat Commission, and SRBC 

recommend that Exelon use the most recent version of the IHA software at the time of 

study. Maryland DNR, the Nature Conservancy, Pennsylvania DEP, the Fish & Boat 

Commission, SRBC, and Interior recommend that Exelon use 15-minute data when 

available. 

IHA Version 7.1 is the current version of the software. Staff agree that the newest 

and most advanced version of this software program should be used for analysis. 

Software is revised to address bugs and add capability, which would benefit this study. 

Therefore, staff recommend that Exelon use the latest version of the IHA software 

available at the commencement of the hydrologic study. 

It is staff’s opinion that the revised study plan implies that a frequency distribution 

will be developed using 15-minute flow data, if available. If 15-minute data are not



available at the two USGS gauging stations, then hourly data will be used. Staff agree 

with this approach. However, the entire historical record must consist of uniform time 

steps. Therefore, if a portion of the historical data is available in 15-minute increments 

and another is only available as hourly data, then it would be appropriate to use hourly 

data to develop the frequency distribution. 

Model time-step increment 

Exelon is proposing in section 3.11.7, Task 3, to conduct model production runs to 

evaluate various alternative operating scenarios to determine the resulting impacts that 

changes in operation of the hydropower projects may have on other water uses (e.g., 

minimum flow and water level restrictions, run-of-river operation) at the Conowingo 

Project and the upstream hydropower projects, as well as at public water withdrawal and 

discharge points. The model production runs will be conducted using the Exelon model 

that is based on the SRBC model. However, the Exelon model also includes the lower 

Susquehanna River hydropower projects, namely Safe Harbor, Holtwood, Muddy Run 

and Conowingo, and operates on an hourly time step to better simulate hydropower 

generation. 

The Nature Conservancy and SRBC recommend that the hydrologic modeling be 

conducted on a sub-daily time step to capture flow variations that drive hydrologic, water 

quality related, and aquatic habitat conditions downstream of the dam. 

Staff understand that Exelon has developed and will use an operations model to 

investigate flow management alternatives using an hourly time step. Therefore, it is our 

opinion that the revised study plan addresses this request. 

Assessment of sub-daily flow fluctuations 

The Nature Conservancy, SRBC, and Interior recommend an assessment of the 

degree to which each hydroelectric facility in the lower Susquehanna River contributes to 

sub-daily fluctuations of river flow, and an assessment of varied dam operations to 

discern potential benefits to downstream reaches of operations. The identified operation 

alternative include: (1) existing, (2) run-of-river, (3) introduction of ramping rates, (4) 

restrictions on peaking operations during time periods with critical life history stages for 

migratory fish and (5) changes in minimum flows. 

Because the revised study plan did not provide a comprehensive list of operations 

to be modeled, the study plan should be revised to include operation alternatives so that 

potential benefits to downstream reaches of operations may be evaluated. 

3.12 Water Level Management (Littoral Zone and Water Level Fluctuation)



Exelon proposes to survey and map littoral zone habitat in the impoundment at 1foot 

contours so an assessment can be made of habitat affected by impoundment 

fluctuations. 

Maryland DNR, SRBC, Pennsylvania DEP, Fish & Boat Commission, and Interior 

recommend that an aquatic ecologist be present on board during all habitat surveys. 

In Task 2 of this study plan, Exelon states that if practical an aquatic ecologist will 

be on board during the bathymetric surveys. Staff interpret this statement to mean that, if 

practical, the bathymetry data collected in Task 1will occur simultaneously with the 

littoral zone habitat mapping data in Task 2 in order to reduce study cost and level of 

effort. Staff recommend that Exelon clarify that all habitat surveys should be conducted 

or accompanied by an aquatic ecologist, regardless of whether the bathymetry and habitat 

mapping tasks occur simultaneously. This is consistent with accepted methodology in 

order to ensure that aquatic habitats are accurately and consistently described during the 

surveys. 

3.15 Sediment Introduction and Transport (Sediment and Nutrient Loading) 

Exelon is proposing in section 3.15.1 of the revised study plan, to draw on existing 

information and ongoing regulatory initiatives that address sediment issues in the lower 

Susquehanna River and the Chesapeake Bay to prepare a cumulative impacts assessment 

of sediment issues in the lower Susquehanna River (including an analysis of the current 

and future, adverse and positive, impacts of the project). 

Maryland DNR and SRBC request that Exelon perform a literature review of 

nutrient and sediment loadings into the Chesapeake Bay and then develop a cumulative 

impact analysis rather than to conduct a literature-based analysis of the existing 

cumulative impacts of nutrient and sediment loadings into the Chesapeake Bay. 

Staff understand the confusion from the language presented in the revised study 

plan. It is our understanding that Exelon would conduct a literature review of nutrient 

and sediment loadings into the Chesapeake Bay to develop a cumulative impact analysis 

rather than conducting a literature review of the existing cumulative impacts. Therefore, 

it is staff’s opinion that the revised study plan addresses Maryland DNR’s and SRBC’s 

request. 

Best management practices (BMPs) 

Exelon is proposing in section 3.15.8, Task 4, to review and summarize 

watershed-based management efforts and documented successes in load reductions to



Conowingo reservoir. Best management practices (BMPs) that could be employed by 

Exelon to manage sediment / nutrient contributions from project lands will be examined. 

Maryland DNR and SRBC request Exelon develop BMPs rather than discuss 

BMPs. 

Staff understand that Exelon will review existing types of BMPs. From these 

BMPs that are reviewed, Exelon would identify those BMPs that could be successfully 

used to manage, mitigate and remove sediment related to the project. Therefore, it is our 

opinion that the revised study plan addresses Maryland DNR’s and SRBC’s request. 

Sediment management 

In their comments on the revised study plan, Maryland DNR and SRBC request 

that Exelon develop a sediment management plan that includes projections of sediment 

accumulation; benchmarks for potential impacts and actions; and options to manage, 

mitigate and remove accumulated sediment. Commission staff provided a similar 

comment on Exelon’s proposed study plan. Staff understand that the revised study plan 

includes projections of sediment accumulation and options to manage, mitigate and 

remove accumulated sediment. However, there is no discussion of benchmarks (triggers) 

for potential impacts and actions. In Appendix G of the revised study plan, Exelon states 

that the USGS predicts that the 30 million tons of sediment needed to bring the reservoir 

to steady-state (sediment storage capacity) is 15 to 20 years (2023 to 2028), extending 

into the new license period. USGS computes that a reduction of sediment yield rates of 

20 percent will extend this 5 to 10 years. Reductions in sediment trap efficiency would 

also extend this temporal prediction. Given the temporal variability of when the reservoir 

will reach its sediment storage capacity, the study report should include triggers for 

potential impacts and actions. 

PM&E measures 

Maryland DNR and SRBC request that the Commission require Exelon to develop 

options to manage, mitigate and remove accumulated sediments to ensure that a detailed 

sediment management plan is developed prior to issuance of the new license. The 

Sediment Introduction and Transport (Sediment and Nutrient Loading) Study Plan was 

developed, in part, to obtain information necessary to develop a sediment management 

plan. Using the results obtained from relevant studies, Exelon will prepare a preliminary 

license proposal (PLP) to include protection, mitigation, and enhancement (PM&E) 

measures with respect to each resource affected by the project proposal. Therefore, it is 

our opinion that the revised study plan addresses this request. 

Potential in-reservoir options



Maryland DNR and SRBC request Exelon perform the following studies to 

develop pros and cons of potential in-reservoir management options: 1) investigate 

adverse impacts of increased sediment loads on downstream natural resources; 2) identify 

localized impacts associated with downstream sediment starvation and alternations of 

sediment characteristics; 3) determine the potential for increased DO impacts from 

sediment accumulation in the impoundment (Conowingo Pond); and 4) determine 

impacts associated with increased downstream sediment transport, assuming the 

impoundment reaches capacity. It is staff’s opinion that the studies included in the 

revised study plan address this request. 

Sediment dynamics model 

Maryland DNR, The Nature Conservancy, SRBC, and Interior request that Exelon 

develop a sediment dynamics model to forecast the effects of: alternative project 

operations (e.g., ramping of flow changes, alternative minimum flows) on sediment 

deposition in the impoundment and river reach downstream of the dam; releases of 

sediment from sediment banks in the impoundment; and scour of sediment from the river 

reach downstream of the dam. Exelon states that the goals and objectives of the 

requestors are addressed by studies already proposed. These proposed studies include: 

Sediment Transport (Sediment and Nutrient Loading – Study 3.15); Water Level 

Management (Littoral Zone and Water Level Fluctuation – Study 3.12); Downstream 

EAV / SAV Study (Water Level Vegetative Cover Study – Study 3.17). Exelon states 

that these studies, integrated with the findings of other hydraulics-based and fisheriesbased 

studies, in combination with new field data collection and analysis with existing 

models, will provide the information necessary to address the requestor's concerns. 

In Appendix H of the revised study plan, Exelon includes a Synopsis of Sediment 

Transport Studies Completed on the lower Susquehanna River. The synopsis states that 

on October 29, 2009, the U.S. Army Corps of Engineers (Corps) convened a sediment 

task force meeting to discuss sediment build-up behind the lower Susquehanna River 

dams. The Corps’ study will address sediment issues in the lower Susquehanna River 

and upper Chesapeake Bay. The Corps’ study would also investigate the potential 

impacts to the Chesapeake Bay of Conowingo reservoir reaching a steady-state condition. 

Sediment transport modeling will be used to advance the understanding of sediment yield 

to the lower Susquehanna River, including Conowingo reservoir; sedimentation within 

Conowingo reservoir; and Conowingo dam’s effect on the Chesapeake Bay. No 

timeframe was provided for this study but the results could be used as an existing 

information source if the results become available prior to development of the PLP. 

Exelon proposes the Sediment Introduction and Transport (Sediment and Nutrient 

Loading) Study to describe the effects of the project on resources based on the new



license term (30 to 50 years) and highlight the effect on the cumulatively affected 

resources. The study report should include a sediment management plan that includes 

projections of sediment accumulation; benchmarks for potential impacts and actions; and 

options to manage, mitigate, and remove accumulated sediment. If, at the completion of 

the Sediment Introduction and Transport (Sediment and Nutrient Loading) Study, the 

results of the study do not adequately characterize the geographic and temporal 

cumulative effects, Exelon may be required to conduct a sediment transport modeling 

study during the second field season (2011). 

3.16 Instream Flow Habitat Assessment below Conowingo Dam 

Exelon proposes to evaluate instream habitat below Conowingo dam over a range 

of flows using a combination of literature review, field surveys of bathymetric and 

hydraulic data, and hydraulic habitat modeling. 

SRBC and The Nature Conservancy recommend that Exelon be required to 

develop site-specific habitat suitability curves for the species being evaluated and to 

incorporate ecological dynamics into the model. Interior recommends that if Exelon 

cannot verify that literature-based habitat suitability curves are representative of 

conditions below Conowingo dam, then Exelon should be required to develop sitespecific 

curves. 

Staff agree that one of the requirements of a successful and meaningful instream 

flow habitat assessment is the use of appropriate habitat suitability curves for the species 

and life stages of interest. However, it is premature to require Exelon to develop sitespecific 

suitability curves prior to conducting a literature review. It is accepted practice 

to initially search for appropriate curves that have already been developed and then 

consult with stakeholders about the findings of the search and the necessity of sitespecific 

curves. This is the procedure Exelon proposes in Task 1 of this study plan. 

Therefore, staff do not recommend modification of the revised study plan. 

SRBC and The Nature Conservancy did not elaborate on what they mean by 

requiring ecological dynamics to be incorporated in the model. Therefore, staff do not 

recommend a modification to the study. Exelon’s methodology is consistent with 

accepted methodology for instream flow habitat assessments and will be adequate to 

evaluate possible operational changes that may be proposed, recommended, or required. 

3.18 Characterization of Downstream Aquatic Communities 

Exelon proposes to conduct a literature review and produce a report summarizing 

and characterizing the fish and macroinvertebrate communities below Conowingo dam.



Maryland DNR, SRBC, Pennsylvania DEP, Fish & Boat Commission, and The 

Nature Conservancy recommend the following modifications to the revised study plan: 

1) study the fish and aquatic community at a reference site and compare it to the project 

site below Conowingo dam if the agencies determine an ecologically and physically 

similar site has been identified; and 2) collect current aquatic community information via 

field surveys because the studies that Exelon cites for the literature review rely too 

heavily on fish lift data or data collected prior to the implementation of the current 

minimum flow regime. In addition to the above listed modifications, Interior also 

recommends that Exelon specifically collect current data on reproductive success, age, 

sex, and condition factors of fish, as well as standardized catch-per-unit-effort. 

Regarding the agencies’ request to compare the study area with existing or historic 

data from a reference site, while possible in some circumstances, staff are not convinced 

a suitable reference location can be located. Also, it is not clear how any differences 

between the Conowingo site data and the hypothetical reference site data would be 

analyzed to discern between potential project effects on the aquatic community and 

effects caused by other variables, such as water quality parameters, depth and substrate, 

proximity to head of tide, fishing pressure and regulations, and stream order and general 

size (mean flow), to name a few. There may be numerous other variables that could 

affect aquatic communities. Therefore, staff do not recommend the reference site 

modification to the study plan. 

Collecting current aquatic community data may be necessary if the literature-based 

summary report does not give an accurate and reasonably complete characterization of 

the current aquatic community below Conowingo dam. Staff agree that Exelon should 

ensure that all studies be included, not just data from the fish lift collections, which do 

not include size, age, condition factor, or catch per unit of effort. Staff do not 

recommend a modification to the revised study plan at this time, but may recommend onsite 

field work in 2011 if the final literature-based study report does not provide enough 

information on the aquatic community to evaluate proposed, recommended, or required 

operational changes to the project. 

3.19 Freshwater Mussel Characterization Study below Conowingo Dam 

Exelon proposes to characterize the freshwater mussel community below 

Conowingo dam using a combination of a literature search, semi-quantitative field 

surveys, a quantitative survey of areas where mussels are found, measurement of habitat 

parameters where quantitative surveys are conducted, and reporting of data which will 

include GIS-based maps. 

Maryland DNR recommends the following modifications to the revised study 

plan: 1) review and compare the Conowingo Project study data to existing or historic



data from a reference location; 2) expand the literature search to other institutions with 

large mussel holdings regardless of distance from the project area; 3) conduct the semiquantitative 

survey over the entire survey area regardless of substrate; 4) avoid visual 

survey methods without the use of view buckets, snorkel masks, or SCUBA; 5) during 

the quantitative sampling, surface mussels should first be removed and placed in a mesh 

bag and then subsurface mussels should be excavated and placed in the same or a 

separate mesh bag; 6) use a systematic sampling design with multiple random starts 

instead of a simple random sampling design; 7) perform quantitative sampling of all 

significant concentrations found in the study area; 8) report river flow at the time of each 

mussel survey; and 9) retain a representative sample of all non-state or federally listed 

species and deposit them at a state or regional natural history museum. SRBC 

recommends modifications (1), (7), (8), and (9) from the list above. Pennsylvania DEP 

and Fish & Boat Commission recommend modifications (7), (8), and (9) from the list 

above. Interior recommends modifications (1) and (9) from the list above. The Nature 

Conservancy recommends modification (1) from the list above. 

Regarding the agencies’ request to compare the study area with existing or historic 

data from a reference site, while possible in some circumstances, staff are not convinced 

a suitable reference location can be located. Also, it is not clear how any differences 

between the Conowingo site data and the hypothetical reference site data would be 

analyzed to discern between potential project effects on the aquatic community and 

effects caused by other variables, such as water quality parameters, depth and substrate, 

proximity to head of tide, fishing pressure and regulations, and stream order and general 

size (mean flow), to name a few. There may be numerous other variables that could 

affect mussel communities. Therefore, staff do not recommend the reference site 

modification to the study plan. 

Modification (2) makes sense because it would not greatly expand the level of 

effort or cost to Exelon, but may result in more complete information about the mussel 

community in the area. 

Modifications (3), (4), (5), and (6) address various aspects of the sampling design 

and field survey methods. No explanation or citations are provided to indicate how these 

modifications would be more scientifically accepted that those that Exelon is proposing, 

and Exelon’s proposed sampling design and field methods appear to be consistent with 

those used during several other relicensing studies. Therefore, staff are not 

recommending these modifications. 

Modification (7) would require quantitative sampling methods to be used in all 

locations where “significant concentrations” of mussels are found. Exelon plans to 

survey the entire 4.5-mile stretch using timed semi-quantitative methods, such as 

snorkeling, viewing buckets, or SCUBA. Exelon states that “up to 3” concentrations of



mussels are expected which would be quantitatively surveyed using quadrats, surface 

collection, and excavation of sub-surface mussels. It is not clear whether Exelon would 

consider employing quantitative survey methods on more than 3 concentrations, if they 

were discovered, or if Exelon is limiting their potential level of effort by suggesting that 3 

areas is the maximum at which they will use the quantitative methods. In any case, the 

objectives of the study are to characterize the mussel community and determine if project 

operations affect the community. Even if there is a maximum of 3 locations where 

quantitative survey methods are employed, this should not reduce the value of the study 

for achieving the stated goals. Therefore, staff do not recommend this modification. 

Modification (8) appears to require only a minor clarification. Exelon states that 

the semi-quantitative methods will be conducted at minimum flow conditions and under 

Task 4 Exelon states that river flow will be recorded during each of the quantitative 

surveys. Even though Exelon seems to have already proposed recording river flow 

during each mussel search, staff suggest that this clarification be included in the study 

plan. 

Modification (9) would require Exelon to deposit the voucher specimens collected 

into a state or regional natural history museum. This modification is consistent with 

accepted scientific procedures as well as requirements for mussel surveys conducted at 

other Commission relicensing proceedings and therefore staff recommend this 

modification. 

3.20 Salinity and Salt Wedge Encroachment 

In their comments on the revised study plan, the Maryland DNR, Fish & Boat 

Commission, and the SRBC request a revision to Task 1 of the study plan to require 

collection of additional 15-minute salinity data in 2010 to augment the post 2007 data, if 

needed. Because the data supplied for this analysis are provided from external sources, 

all available data should be used in the frequency and duration analysis. If subsequent 

statistical analyses of the available data set show that the data set is too small, additional 

data collection could be required in a second season of studies (2011). 

Salinity threshold 

In Task 1 of the study plan, Exelon proposes to use a critical salinity threshold of 

0.3 parts per thousand (ppt) in the frequency and duration analysis for the salinity data. 

In their comments on the revised study plan, Maryland DNR, Fish & Boat Commission, 

and the SRBC request that Task 1 of the study plan be modified to use the current 

Environmental Protection Agency (EPA) standard for drinking water of 0.25 ppt for a 

critical salinity threshold. A goal of the study is to evaluate the project’s operational 

effect on salinity levels at freshwater intakes at the City of Havre de Grace, Maryland.



Staff recommend that the study plan be modified to include the 0.25 ppt threshold for 

salinity to evaluate the impact of project operation on salinity exceedances at drinking 

water intakes downstream of the project. 

Alternative operating scenarios 

Maryland DNR, Fish & Boat Commission, SRBC, and the Nature Conservancy 

recommend an additional task to assess whether potential alternative project operational 

scenarios could mitigate or eliminate exceedances of salinity thresholds. Because the 

recommended task is an evaluation of a potential PM&E measure, Exelon should 

evaluate PM&E measures following completion of studies and the evaluation in its PLP. 

As such, staff are not recommending that Exelon add this additional task. 

Analysis of salinity data 

The Fish & Boat Commission states that a 15-miunte time step interval should be 

used in the statistical analysis of the data in Task 2 instead of the 1-hour interval 

proposed by Exelon. It is unclear how the analysis of 15-minute time-step data is 

consistent with generally accepted practice in the scientific community. As such, staff do 

not recommend this modification to the study. 

Effects of project operation on salinity 

Interior states that Exelon should study the effects of project operation on salinity 

at additional downstream sites of interest including sites in the upper Chesapeake Bay. 

The study plan as proposed should address the effects of project operation on 

salinity. If the data supplied in the study report after the first year of study is insufficient 

to assess project impacts on salinity downstream of the project, additional study could be 

required during the second study season (2011). 

3.21 Impact of Plant Operations on Migratory Fish Reproduction 

Exelon proposes to conduct a literature review and prepare a report that 

summarizes and characterizes the suitability of the project’s reservoir and the river below 

the dam for migratory fish spawning. 

Maryland DNR recommends that Exelon use the results of the 2010 American 

shad radio telemetry study to identify potential spawning locations which could then be 

sampled for ichthyoplankton in 2011. SRBC, Pennsylvania DEP, Fish & Boat 

Commission, and Interior also recommend on-site ichthyoplankton studies. Collectively,



all the entities that commented on this study agree that the existing ichthyoplankton data 

from the early 1980s are not indicative of current conditions. 

Since the early 1980s, when the most recent ichthyoplankton sampling was 

conducted, significant changes have occurred as a result of increased minimum flows, 

more effective upstream fish passage, and the resultant increase in the numbers of shad 

and river herring returning to the Susquehanna River. Staff agree that the historical 

icthyoplankton data are not likely to be representative of current conditions and staff 

recommend that ichthyoplankton sampling be conducted as part of this study. Maryland 

DNR’s suggestion about how to locate ichthyoplankton sampling sites seems reasonable. 

Therefore, staff recommend that Exelon conduct ichthyoplankton sampling in 2011 after 

the radio-telemetry data collected in study 3.5 has been reviewed. 

3.22 Shortnose and Atlantic Sturgeon Life History Studies 

Exelon proposes to evaluate the possible effects of continued operation of the 

project on shortnose and Atlantic sturgeon using a combination of literature review, 

analysis of habitat below the dam (study 3.16), documentation of any sturgeon stranding 

(study 3.8), and deployment of an array of receivers to monitor the river immediately 

below the dam for sturgeon tagged with acoustic transmitters. Exelon also proposes to 

conduct informal Endangered Species Act consultation with Commerce after the 2010 

study has been completed to determine what, if any, additional studies may be required in 

2011. 

Commerce recommends that the revised study plan be modified to require Exelon 

to consult with Commerce on the deployment of a second array of receivers near the 

mouth of the river, in addition to the array that Exelon proposes near the dam. SRBC, 

Interior, and Fish & Boat Commission state that Exelon should include in the literature 

review a comparison of Conowingo’s fish passage facilities with other East Coast 

passage facilities where sturgeon have successfully passed. Interior also recommends 

that the study area of study 3.16 for sturgeon extend from the dam downstream to at least 

the mouth of the Susquehanna River and that 2-D modeling be extended to cover this 

area. 

The second array of receivers recommended by Commerce is warranted because 

of the federally listed status of the shortnose sturgeon and the possibility that project 

operation may affect sturgeon or sturgeon habitat near the mouth of the river. Therefore, 

staff recommend incorporation of this modification. 

Staff agree that Exelon’s final report for this study should include a section which 

compares the Conowingo Project’s fish lift with facilities that have been known to 

successfully pass either shortnose or Atlantic sturgeon on the East Coast. This



information would be useful for evaluating the need for and feasibility of modifications 

to the Conowingo fish passage facilities. 

Staff believe the proposed 3.16 study area (4.5-mile stretch downstream from the 

dam) is adequate to characterize potential sturgeon spawning habitat suitability for the 

reach most affected by project operations. If data collected in 2010 indicate that 

additional habitat surveys are needed (along with the additional 2-D modeling 

incorporating the survey data), then that work could be conducted in 2011. However, we 

note that because the depth and wetted width of the river between the proposed 

downstream boundary of the study area and the mouth of the river becomes increasingly 

dominated by tidal influence, rather than project outflow, it is not clear at this time that 

the same 2-D modeling would be appropriate. Therefore, staff do not recommend 

extending the study area beyond the 4.5-mile reach proposed by Exelon or conducting 2- 

D modeling at this time. 

3.23 Study to Identify Habitat Use Areas for Bald Eagle 

Interior requests that the Transmission Line Avian Interaction Study proposed for 

the Muddy Run Project be included in the Conowingo Project study plan. This study was 

included in the Muddy Run study plan because the transmission lines associated with 

Muddy Run are primary transmission lines, thus within the project boundary. The 

transmission lines present at the Conowingo Project are not primary transmission lines 

and are, therefore, not project features. The Commission’s jurisdiction is limited to 

primary transmission lines, that is the primary line or lines transmitting power from the 

project to the point of junction with the distribution system or with the interconnected 

primary transmission system (FPA section 3(11)). The project does not have any primary 

transmission lines and the Commission has no authority to require any modifications to 

the lines to reduce or mitigate any potential adverse effect to avian species (i.e., bald 

eagle). Moreover, the transmission and distribution lines would continue to transmit and 

distribute power regardless of whether the Conowingo Project exists or would continue to 

operate under a new license; therefore, they are independent of the Commission’s action. 

Thus, staff do not recommend this study for the Conowingo Project. 

3.24 Dreissenid Mussel Monitoring Study 

Exelon proposes to monitor for zebra mussel and quagga mussel veligers (larvae) 

twice monthly and increase the frequency and intensity of sampling if these species are 

detected. 

Maryland DNR, SRBC, and Pennsylvania DEP request that the sentence in section 

3.24.2 beginning with “zebra mussel veligers were” be replaced with “zebra mussel



veligers were documented during 2009 in the intake canal at Peach Bottom Atomic 

Power Station (PBAPS).” 

Staff concur with this wording change because it is more descriptive than what the 

revised study plan states. 

3.25 Creel Survey of Conowingo Pond and the Susquehanna River below Conowingo 

Dam 

Section 3.25.7 (methodology) of the revised study plan proposes a potential 

schedule which limits aerial surveys to occur mid-day. Maryland DNR expresses 

concern that “mid-day” counts are not sufficient to properly assess angler use. It 

recommends that counts be conducted during peak fishing times, both in the morning and 

evening. Maryland DNR also recommends that all aerial surveys between weekdays and 

weekends be randomized since there are likely to be significant differences between those 

times. Staff agree that limiting aerial counts to only occur mid-day would be insufficient 

in obtaining an accurate representation of angler use at the project. Staff recommend 

the aerial count schedule to include counts conducted during concentrated fishing 

periods, both in the morning and evening, in addition to mid-day. Staff also agree that 

results from aerial surveys conducted on weekdays could be considerably different than 

those conducted on weekends. Therefore, the study should be modified to have either a 

near-equivalent sampling of each, or implement randomized sampling. 

Reporting format 

Interior recommends that the study plan utilize a reporting format similar to 

Normandeau (2004). While staff do not object to employing this format, it is unclear 

why the proposed format is not sufficient, so staff have no basis for recommending the 

requested change. 

Photo documentation 

Interior also requests that the study include photo documentation of access sites 

and boat launches. While staff find this to be a reasonable request, photographic 

documentation of each recreational feature is already included within Task 3 of 3.26.7 

(methodology) of the proposed Recreational Inventory & Needs Assessment study. 

Angling access sites and boat launches should be included in the list of the photographed 

recreational features. Therefore, staff find one set of documentation to be sufficient for 

both studies. 

3.26 Recreational Inventory and Needs Assessment



The Fish & Boat Commission, Interior, Maryland DNR, and SRBC state that 

Exelon did not address several of the resource agencies’ specific requests, including an 

evaluation of the effects at high and low water levels on the current access at Fishing 

Creek and an assessment of the feasibility of refurbishing Shure’s Landing. The agencies 

request the inclusion of these portions within the study. Section 3.26.4 (purpose) states 

the goals of the study are to characterize existing recreational uses at or in the vicinity of 

the Conowingo Project, to evaluate the adequacy of existing project recreation facilities, 

and to assess the need for providing additional recreational access at the project. 

Exelonproposes to address several objectives related to recreational resources in the 

study. One of these objectives is to determine the cost associated with rehabilitation and 

development of the evaluated facilities, which should be inclusive of Shure’s Landing. 

Further, recreational access with respect to fluctuating water levels is another listed 

objective within this proposed study and will also be specifically evaluated within the 

Tributary Access Study. Fishing Creek is listed (table 3.13-1) as one of the shoreline 

tributaries to be evaluated within the study. Therefore, staff believe these specific 

requests have been adequately addressed. 

Tailrace access 

The Maryland DNR recommends that the applicant be required to re-evaluate the 

location of the line designated to keep boaters from accessing the tailrace. Staff find this 

to be a reasonable request and recommends the study plan be modified to clarify that this 

issue will be specifically addressed in assessing public access, safety, and recreation with 

respect to blocked and impeded access and fluctuating water levels, as listed within the 

study plan’s objectives found in section 3.26.1. 

Literature review/outreach 

Task 1 of section 3.26.7 (methodology) proposes to conduct a literature review 

and outreach. The applicant intends to conduct an internet literature review to identify 

readily known and identified recreational organizations. These organizations will be 

utilized as data sources as well as surveyed via phone. The list of entities included in the 

literature review phone surveys should specifically include fishing organizations within 

the project area and the immediate vicinity because of the apparent popularity of angling. 

Also, in order to accurately evaluate whether the existing recreation facilities and access 

to the Susquehanna River in the investigation area are adequately meeting current user 

needs, this section should be expanded to include on-site surveys conducted at 

Fisherman’s Park and downstream fishing sites within the project boundary. 

Table 2.8-1 presents a list of the recreational project facilities required, 

contemplated, and currently existing. However, the revised study plan does not provide a 

list of sites and facilities which will be evaluated within the needs assessment portion.



Staff recommends that this list be provided after the recreation field inventory of access 

and use (Task 3) has been conducted and updated. 

3.27 Shoreline Management 

Interior recommends that unique, sensitive, and/or critical fish and wildlife habitat 

be identified in order to permit the creation and evaluation of a shoreline management 

plan that protects such habitats. Figure 4.8.3-1 of the PAD describes sensitive resources 

associated with the project. As stated in section 2.8 of the revised study plan, additional 

data on these resources will be collected and refined in developing the proposed 

Shoreline Management Plan (SMP) for the Muddy Run Project. However, it is not 

specified that this will be done for the SMP for the Conowingo Project. The study plan 

states that sensitive resources occupy approximately 883 acres (36 percent) of project 

lands. In order to determine whether applicable protection measures are necessary to be 

included in the plan, staff recommend modifying the study to identify any unique, 

sensitive, and/or critical fish and wildlife habitat within the project boundary.



APPENDIX B 

APPROVED STUDIES 

No. Study Name 

3.1 Seasonal and Diurnal Water Quality in Conowingo Pond and below Conowingo 

Dam (as modified) 

3.2 Downstream Fish Passage Effectiveness Study (as modified) 

3.3 Biological and Engineering Studies of American Eel at the Conowingo Project 

(as modified) 

3.5 Upstream Fish Passage Effectiveness Study (as modified) 

3.6 Conowingo East Fish Lift Attraction Flows (as modified) 

3.7 Fish Passage Impediments Study below Conowingo Dam 

3.8 Downstream Flow Ramping and Fish Stranding Study (as modified) 

3.9 Biological and Engineering Studies of the East and West Fish Lifts 

3.10 Maryland Darter Surveys 

3.11 Hydrologic Study of the Lower Susquehanna River (as modified) 

3.12 Water Level Management (Littoral Zone and Water Level Fluctuation) (as 

modified) 

3.13 Study to Assess Tributary Access in Conowingo Pond 

3.14 Debris Management Study 

3.15 Sediment Introduction and Transport (Sediment and Nutrient Loading) (as 

modified) 

3.16 Instream Flow Habitat Assessment below Conowingo Dam 

3.17 Downstream EAV/SAV Study (Water Level Vegetative Cover Study) 

3.18 Characterization of Downstream Aquatic Communities 

3.19 Freshwater Mussel Characterization Study below Conowingo Dam (as modified) 

3.20 Salinity and Salt Wedge Encroachment (as modified) 

3.21 Impact of Plant Operations on Migratory Fish Reproduction (as modified) 

3.22 Shortnose and Atlantic Sturgeon Life History Studies (as modified) 

3.23 Study to Identify Habitat Use Areas for Bald Eagle 

3.24 Dreissenid Mussel Monitoring Study (as modified) 

3.25 Creel Survey of Conowingo Pond and the Susquehanna River below Conowingo 

Dam (as modified) 

3.26 Recreational Inventory and Needs Assessment (as modified) 

3.27 Shoreline Management (as modified) 

3.28 Archaeological and Historic Cultural Resource Review and Assessment 

3.29 Effect of Project Operations on Downstream Flooding 

3.30 Osprey Nesting Survey 

3.31 Black-crowned Night Heron Nesting Survey 

3.32 Re-evaluate the Closing of the Catwalk to Recreational Fishing



APPENDIX C 

REVISED PROCESS PLAN AND SCHEDULE (revised dates in bold) 

Responsible 

Party 

Pre-Filing Milestone Date 1 FERC 

Regulation 

Exelon Issue Public Notice for NOI/PAD 3/12/09 5.3(d)(2) 

Exelon File NOI/PAD with FERC 3/12/09 5.5, 5.6 

FERC Tribal Meetings 4/11/09 5.7 

FERC 

FERC 

All 

stakeholders 

Issue Notice of Commencement of 

Proceeding; Issue Scoping Document 

Conowingo Project Site Visit and 

Scoping Meetings 

PAD/Scoping Document Comments 

and Study Requests Due 

5/11/09 5.8 

6/11/09 & 

6/12/09 

5.8(b)(viii) 

7/10/09 5.9 

FERC Issue Revised Scoping Document 8/24/09 5.1 

Exelon File Proposed Study Plan 8/24/09 5.11(a) 

All 

stakeholders 

Proposed Study Plan Meeting 9/23/09 5.11(e) 

All 

stakeholders 

Proposed Study Plan Comments Due 11/22/09 5.12 

Exelon File Revised Study Plan 12/22/09 5.13(a) 

All 

stakeholders 

Revised Study Plan Comments Due 1/20/10 5.13(b) 

FERC Director's Study Plan Determination 2/4/10 5.13(c) 

Appropriate 

stakeholders 

Any Study Disputes Due 2 

2/24/10 5.14(a) 

Dispute panel Dispute Resolution Panel Convenes 3/16/10 5.14(d) 

Exelon 

Applicant Comments on Study 

Disputes Due 

3/21/10 5.14(i) 

Dispute panel Third Dispute Panel Member Selected 3/31/10 

March/April 

5.14(d)(3) 

Dispute panel 

Dispute Resolution Panel Technical 

Conference 

2010 [prior to 

engaging in 

deliberative 

meetings] 

5.14(j) 

Dispute panel Dispute Resolution Panel Findings 4/15/10 5.14(k)



Responsible 

Party 

FERC 

Issued 

2 

Pre-Filing Milestone Date 1 FERC 

Regulation 

Director's Study Dispute 

Determination 

5/5/10 5.14(l) 

Exelon First Study Season 2010 5.15(a) 

Exelon Initial Study Report 1/21/11 5.15(c)(1) 

All 

stakeholders 

Initial Study Report Meeting 2/5/11 5.15(c)(2) 

Exelon Initial Study Report Meeting Summary 2/20/11 5.15(c)(3) 

All 

stakeholders 

All 

stakeholders 

FERC 

Any Disputes/Requests to Amend 

Study Plan Due 

Responses to Disputes/Amendment 

Requests Due 

Director's Determination on 

Disputes/Amendments 

3/22/11 5.15(c)(4) 

4/21/11 5.15(c)(5) 

5/21/11 5.15(c)(6) 

Exelon Second Study Season 2011 5.15(a) 

Exelon Updated Study Report due 1/21/12 3 

5.15(f) 

All 

stakeholders 

Updated Study Report Meeting 2/5/12 5.15(f) 

Exelon 

Updated Study Report Meeting 

Summary 

2/20/12 5.15(f) 

All 

stakeholders 

Any Disputes/Requests to Amend 

Study Plan Due 

3/21/12 5.15(f) 

All 

stakeholders 

Responses to Disputes/Amendment 

Requests Due 

4/20/12 5.15(f) 

FERC 

Director's Determination on 

Disputes/Amendments 

5/20/12 5.15(f) 

Exelon File Preliminary Licensing Proposal 4/3/12 5.16(a) 

All 

stakeholders 

Preliminary Licensing Proposal 

Comments Due 

7/2/12 5.16(e) 

Exelon File Final License Application 8/31/12 5.17 

1 

If the due date falls on a weekend or holiday, the due date is the following business day. 

2 

Shaded milestones are unnecessary if there are no study disputes. 

3 

Exelon indicates in the PADs that its intent is to file its updated study report on November 1, 2011, and 

its preliminary licensing proposal as early as December 1, 2011. Exelon’s schedule assumes that a full 

year is not needed for the second study season.


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P-405-087Letter5.DOC..................................................1-35

FEDERAL ENERGY REGULATORY COMMISSION Project No. 405 ...

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