The next generation of large-volume neutrino telescopes will include low-energy subarrays which will be able to measure neutrinos with energies of a few GeV. In this energy range the primary signal below the horizon is neutrinos created by cosmic ray interactions in the atmosphere. The measured event rate will depend on the neutrino mass hierarchy, allowing determination of this quantity to a significance level of about 3.5 sigma within a 5-year period, mostly limited by systematic uncertainties. We present here the impact of the uncertainties on the atmospheric neutrino flux normalization on the determination of the neutrino mass hierarchy. We suggest constraining the systematic uncertainties by including the downgoing neutrino sample, whi...