NC0024406_Entrainment Characterization Study_20160525

Sir DUKE Environmental Services
ENERGY, Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address:
Mail Code EC13K/P.O.Box 1006
Charlotte, NC 28201-1006
May 13, 2016
Mr. Tom Belnick, Supervisor
NPDES Complex Permitting
NC DEQ/DWR/WQ Permitting Section
1617 Mail Service Center RECEIVED/NCDEQ/p
Raleigh, NC 27699-1617 WR
MAY 2 5 2D 15
VVater Quality
Perrnitting Section
Subject: Belews Creek Steam Station
National Pollutant Discharge Elimination System - Permit No. NC0024406
316(b) Entrainment Characterization Study Plan (ECSP)
Dear Mr. Belnick:
Please find enclosed the final Entrainment Characterization Study Plan (ECSP) for Belews Creek
Steam Station. The plan incorporates comments from the fisheries biologists peer reviewers, as
well as comments from the North Carolina Department of Environmental Quality (NCDEQ)
received on March 3, 2016. Responses to comments from NCDEQ are also enclosed.
If you have any questions or comments, please contact Nathan Craig at Nathan.Craig@duke-
energy.com / 704-382-9622 or Keeley McCormick at [e-mail] /
336-580-4521.
Sincerely, /
0111111,04 1.11.•.1
iv
Reginald D. Anderson
General Manager III, Regulated Stations
Belews Creek Steam Station
Power Generating Carolinas East

RECEIVED/NCDEQ/DWR
MAY 252016
Water Quality
Permitting Section
Response to NCDEQ
Comments:
Entrainment Characterization Study
Plan — Belews Creek Steam Station
Prepared for:
V' EUKE
NERGY
Prepared by:
HDR Engineering, Inc.
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Entrainment Characterization Study Plan
Response to NCDEQ Comments—Belews Creek Steam Station
1 Introduction
The U.S. Environmental Protection Agency's (EPA) rule implementing §316(b) of the Clean
Water Act(the rule)was published on August 15, 2014 in the Federal Register. The rule applies
to existing facilities with design intake flows (DIF) of more than 2 million gallons per day (MGD)
that withdraw from Waters of the United States, use at least 25 percent of that water exclusively
for cooling purposes, and have or require an NPDES permit. Existing facilities with an actual
intake flow a 125 MGD are required to provide an entrainment characterization study (at 40
CFR 122.21(rX9)) as part of its permit renewal application materials. Duke Energy facilities in
the Carolinas that meet the 125 MGD flow threshold are proposing a two-year entrainment
sampling program to gather the information necessary to fulfill the entrainment characterization
requirements. The goal of the proposed program is to estimate the seasonal and annual total
abundance of fish eggs and larvae that are drawn into the cooling water systems. Entrainment
sampling at each facility is proposed from March through October of 2016 and 2017.
2 Development of Entrainment Characterization
Study Plans
An Entrainment Characterization Study Plan (ECSP) was developed for Belews Creek Steam
Station (BCSS). The ECSP describes the sampling design and site-specific approach being
used at BCSS to sample for entrainment; the rationale for the selection of gear type, sampling
location, and other components of the sampling design; and a discussion on how the study
fulfills the requirements of the rule. While not required to undergo a peer-review, a draft of the
ECSP was sent to a subject matter expert in fisheries biology for an independent review. After
addressing comments and incorporating relevant changes, the final ECSP was sent to the
Director for comment. Comments were received from Bryn H. Tracy (Senior Environmental
Specialist, North Carolina Department of Environmental Quality[NCDEQ]) by email on March 3,
2016.We thank Mr. Tracy for his comments and have provided responses in Table 2-1.
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Entrainment Characterization Study Plan
Response to NCDEQ Comments—Belews Creek Steam Station
Table 2-1. Responses to Bryn H. Tracy (Sr. Environmental Specialist, North Carolina Department of Environmental Quality)
Comments on the Entrainment Characterization Study Plan for Belews Creek Steam Station
Facility Comment Response and Resolution
Page 8,Section 2.2.1:I might have missed this somewhere,but what are the
Belews current approach velocities at each of the plants where a§316(b) Approach velocity at the five fossil facilities that are sampling for entrainment is greater
Creek demonstration is required? Are they all>0.5 ft/sec,<0.5 ft/sec.or a than 0.5 fps when all pumps are operating at design flows.
combination of these?
Multiple causes could have contributed to low entrainment densities in the 1970s(e.g.,
nutrient levels)but temperature was not specifically implicated.
Janz et al.(2010)points out that aquatic organisms,and in particular oviparous(egg
laying)vertebrates(including fish),are the most sensitive to selenium toxicity.Sulfur-
Page 12,Section 3,second paragraph: I find it hard to believe that the containing proteins in vitterogenin(an important precursor of egg yolk proteins)can
extremely low(or non-existent)entrainment values observed in 1976 and 1977 contain selenium.At sufficiently high levels,selenium exposure results in embryo
Belews attributed to selenium toxicity given the fact that the two units had been teratogenesis(formation of congenital malformations)and reduced survival of larval fish.
Creekon line for only 2 or 3 years.Could the elevated water temperatures have also Similar fish kill events and reproductive failure have been observed in other waterbodies
been a factor? (e.g.,Martin Lake,TX and Kesterson Reservoir.CA)(Hamilton 2004).
Fish populations in Belews Lake have rebounded since the power plant stopped
discharging water with selenium,while thermal loading remains unchanged.For this
reason,we think selenium toxicity was the likely source of low larval fish densities in the
1976-77 study. Ultimately.Duke Energy will not be relying on data from the 1970s
entrainment study to support the analyses required by the final rule.
Belews Page 17,first paragraph:Replace"Roxboro"with"Belews". This will be corrected.
Creek
Pages 17 and 18(same as Allen Steam Station comments:a)Please provide
Belews reason(s)as to why you decided on bi-weekly sampling(or is it just twice a
Creek month?)vs.weekly sampling.I attended an NC AFS workshop in 2005 lead by Please see Section 3—Twice per Month Sampling for Estimating Entrainment.
Dr.Doug Dixon(EPRI)and I have in my notes that bi-weekly sampling is more
biased than more frequent sampling.
b)One sample collected every six hours--please provide reason(s)why there
Belews is no replication within a six hour period.I read your response in Appendix B
Creek (and I wondered about this issue even before I got to Appendix B),but wonder Please see Section 3—Twice per Month Sampling for Estimating Entrainment.
why you chose not to replicate.even before any samples are collected? Is this
common practice not to replicate? Has this been done at other projects?
Belews Page 19,Section 6.2,first paragraph,last sentence:Please provide citation(s) Please see Section 3—Twice per Month Sampling for Estimating Entrainment.
Creek justifying as to why twice per month sampling is sufficient.
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Entrainment Characterization Study Plan
Response to NCDEQ Comments—Belews Creek Steam Station
3 Twice per Month Sampling for Estimating
Entrainment
Sampling interval — or the time between sampling events — is typically assigned to a regular
schedule(e.g., one month,two weeks, one week, etc.). In some cases, the interval may change
on a seasonal basis (EPRI 2014). In the rule and its preamble, EPA provides no guidance on
the sampling interval associated with entrainment characterization studies required under
§122.21(rX9). The ECSPs reviewed by NCDEQ are based on twice per month 24-hour
sampling events where each sampling event contains four samples collected throughout the 24-
hour period, resulting in eight depth integrated entrainment samples per month. This sampling
frequency was selected based on careful consideration of study objectives, gear selection, and
historical 316(b) studies. This section provides additional clarification on sample frequency
selection based on NCDEQ comments.
The Electric Power Research Institute (EPRI), in its 2014 entrainment abundance monitoring
support document, took advantage of a large dataset from an intensive entrainment monitoring
program undertaken at the Indian Point Generation Station on the Hudson River, NY. These
data were collected over 5 years (1983-1987) continuously or near-continuously (24-hours per
day, 7-days per week). Using these data, different sampling frequency and intensity scenarios,
including monthly, twice per month, and weekly sampling frequency, were modeled for their
effect on entrainment abundance estimates.
A sampling frequency of one day in a twice per month interval produced a coefficient of variation
(CV—the ratio of the standard deviation to the mean) of annual entrainment estimates ranging
from 750 percent for taxa entrained at very low densities (0.001 per 100 m3) to roughly 50
percent at the highest densities (100 per 100 m3). The CV declined as the frequency of
sampling increased (Table 3-1). At densities between 0.1 and 1.0 per 100 m3 and greater, the
CV stabilized between 25-50 percent for weekly sampling and 50-75 percent for twice per
month sampling.
The Hudson River estuary is a dynamic and variable environment that is affected daily by tides,
salinity and temperature gradients, and freshwater and nutrient inputs. At locations such as this,
species compositions and their relative abundance can fluctuate rapidly. In addition, the
spawning season is more spread out than in freshwater (i.e., spawning can take place in any
month of the year). Comparatively, a southeastern Piedmont reservoir represents a more stable
ambient sourcewater system and the spawning season is discrete within the year. Based on
these factors, it is assumed that comparable levels of precision can be achieved with less
frequent sampling in southeastern Piedmont reservoirs than would be needed on the Hudson
River. Even Brunswick Steam Electric Plant(BSEP), which withdraws from an estuary, exhibits
similar estimates in entrainment based on monthly and twice per month sampling as described
below.
Organisms collected at very low densities will generally not contribute substantially to the
economic benefits valuation and as a result selection of fish protection technologies will not
Duke Energy 13

Entrainment Characterization Study Plan L �
Response to NCDEQ Comments—Belews Creek Steam Station 1
typically be driven by species rarely entrained'. Therefore, greater variability (CV) in estimates
for these rarely collected species should be acceptable for the Entrainment Characterization
Study and the analyses these data support. In addition, as shown in Table 3-1, there is
relatively little difference in the CV between the weekly and twice per month sampling
frequencies for the more abundant species which have a greater affect on the valuation of
economic benefits and the selection of fish protection technologies.
Table 3-1. Estimated Mean Coefficient of Variation of Annual Entrainment Estimates
Based on 100 Iterations of Different Sampling Scenarios (100 m3 per Sample) Applied to
Indian Point Entrainment Data from 1983-1987 (Modified from EPRI 2014)
Approximate Coefficient of
Sample Mean Variation (°/a)
Density Weekly Twice per Month
(No./100 m3) Sampling Sampling
0.001 `''"""2T3'— 425-750 ;'l'
0.01 125-50 350-150
0.1 50-75 50-150
1 25-50 50-75
10 25-50 50-75
100 25-50 50-75
We note EPRI (2014) did not provide entrainment estimates associated with the sample
frequencies modeled. Our assumption is the total estimated entrainment generally remains
consistent regardless of the frequency of sampling, but the CV around the estimate decreases
with increased sampling. This is consistent with observations at BSEP. Data from yearly
sampling at BSEP from 1979 to 2004 were used to demonstrate that estimates of entrainment
based on weekly sampling were similar to those based on a monthly sampling frequency (see
green and blue lines in Figure 3-12). Based on this data, and consultation with NCDEQ, Duke
Energy decreased the sampling frequency at BSEP from weekly to monthly.
A potential exception to this rule is when Federally-listed species may be involved in entrainment,
however, no Federally listed species are associated with potential for entrainment at these Duke Energy
facilities.
2 Baseline and Post-baseline refer to prior to and after the installation of entrainment reduction technology
and operation measures (fine-mesh panels and seasonal flow reduction) at BSEP, respectively. The
post-baseline data includes all sampling frequencies(i.e., weekly and monthly combined).
Duke Energy 14

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Entrainment Characterization Study Plan � �
Response to NCDEQ Comments—Belews Creek Steam Station
100
a 80
a
a 60
et
40
m 50th Percentile 80th Percentile
E Nu. % Nu. %
m 20 Baseline 9.45 18.46
G Weekly 1.44 84.7 4.13 77.6
Monthly 2.38 74.9 5.06 72.6
Post-baseline 1.79 81.1 4.79 74.0
ID r
0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150
Number entrained (millions)
BasNin• IN•ekly Monthly -Post-baseline]
Figure 3-1 Cumulative Distribution of Total Entrainment at Brunswick Steam Electric
Plant under Varying Sampling Frequency
3.1 Conclusion
In determining sampling frequency, twice per month sampling was selected to balance the level
of uncertainty and costs with rule requirements and considerations of how these data would be
used in the later §122.21(r) reports. Changing the sample frequency from twice per month to
weekly would double or more3 the program costs yet not materially improve the quality of the
larger technology evaluations required under the rule. For these reasons, the twice per month
sample frequency was proposed in the study plans and remains the recommendation after both
peer review and NCDEQ comments have been received.
3 Increasing sample frequency from twice per month to weekly will at least double the cost of the
entrainment characterization program. Given the scale of Duke Energy's fleet-wide entrainment
characterization effort, such an effort may require hiring of additional contractors and field/laboratory
staff raising the potential for even further cost escalation.
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Entrainment StudyPlan
Response to NCDEQ Comments—
Belews Creek Steam Station
References
Donner, M.T. and R. Eckmann. 2011. Diel vertical migration of larval and early juvenile burbot
optimises survival and growth in a deep, pm-alpine lake. Freshwater Biology 56: 916-925.
Electric Power Research Institute (EPRI). 2014. Entrainment Abundance Monitoring Technical
Support Document: Updated for the New Clean Water Act §316(b) Rule. 3002001425.
EPRI, Palo Alto,CA. 156 pp.
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I Entrainment Characterization
I Study Plan
IPrepared for:
"� DUKE
ENERGY
Prepared by:
IHDR Engineering, Inc.
I April 15, 2016
Belews Creek Steam
Station
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IEntrainment Characterization Study Plan ��
Belews Creek Stamm Station
IContents
1 Introduction 1
I1.1 Regulatory Background 1
1.2 Study Plan Objectives and Document Organization 3
I 2 Generating Station Description 3
2.1 Source Waterbody 4
I
2.1.1
2.1.2 Belews Lake 4
Dan River 4
2.2 Station and Cooling Water Intake Description 7
2.2.1 Belews Lake Cooling Water Intake Structure 7
2.2.2 Dan River Make-up Pumping Station 10
I 3 Historical Studies 12
4 Threatened and Endangered Species 13
I 5 Basis for Sampling Design 14
6 Entrainment Characterization Study Plan 19
6.1 Introduction 19
I6.2 Sample Collection 19
6.2.1 Location 20
I 6.3 Sample Sorting and Processing 25
6.4 Data Management 26
6.5 Data Analysis 28
'
6.6 Field and Laboratory Audits 27
6.7 Laboratory Quality Control 28
' 6.8 Reporting 28
6.9 Safety Policy 28
' 7 References 29
APPENDIX A—Select Species Spawning and Early Life History Data 31
ILife History References 33
APPENDIX B—Response to Informal Review Comments 34
IAPPENDIX C-Comparison of Pumps and Nets for Sampling lchthyoplankton 40
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Entrainment Characterization Study Plan
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Tables
Table 1-1. §316(b)Rule for Existing Facilities Submittal Requirements Summary 2
Table.2-1. Belews Creek Steam Station Design Intake Flow Rate by Unit and Daily Average Water
Withdrawal from Belews Lake, 2011-2014 7
Table 2-2. Belews Creek Steam Station Design Intake Flow Rate for the make-up intake and Daily
Average Water Withdrawal from the Dan River, 2011-2014 7
Table 3-1. Entrainment Sampled by Flow (m3) at Belews Creek Steam Station, March 1976 through
August 1977 13
' Table 5-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for Estimating
Ichthyoplankton Density in Cooling Water Intake Structures (some information adapted from EPRI 2014)
16
' Table 5-2. Potential Disadvantages of Pumped Ichthyoplankton Sampling at Belews Creek Steam Station
17
Table 5-3. Summary of Approach for Development of §122.21(r)(9) Required Entrainment
Characterizations 18
' Table 6-1. Entrainment Sampling Details 20
Table B-1. Directed Charge Questions 34
Table B-2. Peer Reviewer Responses to Directed Charge Questions 36
Table C-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for Estimating
' Ichthyoplankton Density in Cooling Water Intake Structures (some information adapted from EPRI 2014)
42
' Table C-2. Total Number (N) and Mean Densities (MD) (mean number of shad/ 1,000 m3) of All Shad
Collected with Comparison Gear and Shad <28 mm Total Length Collected with a Tucker Trawl on Lake
Norman, North Carolina, 6-10 June 1982, with Average Volume of Water Filtered per Sample (m3)
' (Leonard and Vaughn 1985) 51
Table C-3. Summary of Major Studies Designed to Comparatively Evaluate the Sampling Efficiency of
Various Large-Volume Pumps and Tow Nets (Taggart and Leggett 1984). 53
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Belews Creek Steam Station
Figures
Figure 2-1.Aerial View of Belews Lake(Image Modified from: Google Earth) 5
Figure 2-2. Belews Creek Steam Station Vicinity Map(Source:Alden 2004) 6
' Figure 2-3. Aerial View of the Make-up Water Intake on the Dan River and Belews Creek in Rockingham
County, North Carolina(Image Modified from: Google Earth) 8
' Figure 2-4. Site Configuration of Belews Creek Steam Station (Image Modified from: Duke Energy 2011)9
Figure 2-5. Plan and Section View of the Make-up Water Intake (Modified from: Belews Creek Steam
Station Belews Lake Pumping Station-Velocity Cap Engineering Drawing, BC-1394-00.39) 11
' Figure 4-1. Geographical Boundary of the IPAC Search 14
Figure 6-1. Section View of the Belews Creek Steam Station's Cooling Water Intake Structure with
Approximate Location of Sample Inlets at Three Depths — Sampler pipe (in red) not Shown to Scale
(Image Modified from:Alden 2004) 21
Figure 6-2. Aerial View Showing Approximate Locations of Sampling Gear(Image Modified from: Google
Earth) 22
Figure 6-3. Example Entrainment Pump Sampling System Configuration 24
Figure 6-4. 7.5-Horsepower Electric Pump Used for Entrainment Sampling 24
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Entrainment Characterization Study Plan EN
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Acronyms and Abbreviations
F degrees Fahrenheit
AlAIactual intake flow
AOQL Average Outgoing Quality Limit
I BCSS Belews Creek Steam Station
BTA Best Technology Available
CCW condenser cooling water
' cfs cubic feet per second
CSP continuous sampling plan
CWIS cooling water intake structure
IDIF design intake flow
Director National Pollutant Discharge Elimination System Director
I Duke Energy Duke Energy Carolinas, LLC
El. elevation
ECSP Entrainment Characterization Study Plan
I EPRI Electric Power Research Institute
FGD flue gas desulfurization
gpm gallons per minute
I
HDR HDR Engineering, Inc.
IPAC Information for Planning and Conservation (website)
m3 cubic meter
IMW megawatt
pm micrometer or micron
I
mm millimeter
MGD million gallons per day
MIL-STD military-standard
I NCDENR North Carolina Department of Environment and Natural Resources
NPDES National Pollutant Discharge Elimination System
Normandeau Normandeau Associates, Inc.
I
PVC Polyvinyl chloride
QA Quality Assurance
QC Quality Control
IRTE rare, threatened, or endangered
SOP Standard Operating Procedures
USFWS U.S. Fish and Wildlife Service
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Entrainment Characterization Study Plan
Belews Creek Steam Station
1 Introduction
1 .1 Regulatory Background
The Clean Water Act was enacted in 1972 and introduced the National Pollutant Discharge
Elimination System (NPDES) permit program. Facilities with NPDES permits are subject to
§316(b) of the Act, which requires that the location, design, construction and capacity of cooling
water intake structures (CWIS) reflect best technology available (BTA) for minimizing adverse
environmental impacts. Cooling water intakes can cause adverse environmental impacts by
drawing early life-stage fish and shellfish into and through cooling water systems (entrainment)
or trapping juvenile or adult fish against the screens at the opening of an intake structure
(impingement).
On August 15, 2014, the final §316(b) rule for existing facilities was published in the Federal
Register. The rule applies to existing facilities with design intake flows (DIF) of more than 2
million gallons per day (MGD) that withdraw from Waters of the United States, use at least 25
percent of that water exclusively for cooling purposes, and have or require an NPDES permit.
The rule supersedes the Phase II rule, which regulated large electrical generating facilities until
it was remanded in 2007, and the remanded existing-facility portion of the previously
promulgated Phase Ill rule. The final rule became effective on October 14, 2014.
Facilities subject to the new rule are required to develop and submit technical material, identified
at §122.21(r)(2)-(14), that will be used by the NPDES Director (Director) to make a BTA
determination for the facility (Table 1-1). The specific information required to be submitted and
' compliance schedule are dependent on actual intake flow rates (AIF) at the facility and the
NPDES permit renewal date. Existing facilities with an AIF a 125 MGD are required to address
both impingement and entrainment and provide explicit entrainment studies which may involve
' extensive field and economic studies (§122.21(r)(9)-(13)). Existing facilities with AIF < 125 MGD
have fewer application submittals. For such facilities, the Director must still determine BTA for
entrainment on a site-specific basis and the applicant may supply information relevant to the
Director's decision. Facilities are to submit §316(b) application material to their Director along
with their next permit renewal, unless that permit renewal takes place prior to July 14, 2018, in
which case an alternate schedule may be negotiated.
' Duke Energy Carolinas, LLC's (Duke Energy) Belews Creek Steam Station (BCSS) is subject to
the existing facility rule and, based on its current configuration and operation, must develop and
submit each of the §122.21(r)(2)-(13) submittal requirements with its next permit renewal in
accordance with the rule's technical and schedule requirements. Within the §122.21(r)(2)-(13)
requirements, (r)(4), (7), (9), (10) and (11) have specific requirements related to entrainment
evaluations (refer to Table 1-1 for additional detail). This document provides an Entrainment
Characterization Study Plan (ECSP) to support §316(b) compliance at the facility with
' consideration of these specific requirements. As a part of development of this Study Plan, Duke
Energy submitted an earlier draft of this document to review by a subject matter expert in the
field of fisheries (see Appendix B) and identified to the State as a peer reviewer.
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IEntrainment Characterization Study Plan
Belews Creek Steam Station Im)
IWhile the equipment and methods contained in this Study Plan were developed with the intent
to be implemented as written, changes to the Study Plan may be required based on facility
Irequirements and/or situations encountered during execution.
ITable 1-1. §316(b) Rule for Existing Facilities Submittal Requirements Summary
Submittal Requirements Submittal Descriptions
Iat§122.21(r)
(2) Source Water Characterization of the source water body including intake area of influence
Physical Data
(3} Cooling Water Intake Characterization of cooling water system;includes drawings and narrative;description of operation;
IStructure Data water balance
Source Water Characterization of biological community in the vicinity of the intake:life history summaries;
(4) Baseline Biological susceptibility to impingement and entrainment;must include existing data;identification of missing
Characterization data data;threatened and endangered species and designated critical habitat summary for action area;
identifies fragile fish and shellfish species list(<30 percent impingement survival)
i Narrative description of cooling water system and intake structure;proportion of design flow used
Cooling water Water reuse summaproportionbody (monthly),
of source water withdrawn month) seasonal op
operation
System Da CC summary.
.summary;existing Impingement mortality and entrainment reduction measures;flow/MW efficiency
Chosen Method of Compliance with Provides facility's proposed approach to meet the impingement mortality requirement(chosen from
(6) Impingement Mortality seven available options);provides detailed study plan for monitoring compliance.if required by
Standard selected compliance option;addresses entrapment where required
.itii
1 , Entrainment Provides summary of relevant entrainment studies(latent mortality,technology efficacy);can be
Performance studies from the facility or elsewhere with justification;studies should not be more than 10 years old without
justification;new studies are not required
Provides operational status for each unit;age and capacity utilizations for the past five years:
'
(8) Operational Status upgrades within last 15 years;uprates and Nuclear Regulatory Commission relicensing status for
nuclear facilities;decommissioning and replacement plans:current and future operation as it relates
to actual and design intake flow
I 'Requires at least two years of data to sufficiently characterize annual,seasonal,and diel variations
in entrainment,including variations related to climate,weather,spawning,feeding,and water
Column migration:facilities may use historical data that are representative of current operation of the
Entrainme _facility and conditions at the site with documentation regarding the continued relevance of the data
II
Characteri i,to document total entrainment and entrainment mortality:includes identifications to the lowest taxon
Study j
yo ss. data must be representative of each intake;must document how the location of the intake
in the water body and water column are accounted for;must document intake flows associated with
,the data collection;documentation In the study must include the method in which latent mortality
would be identified(including QAQC);sampling and data must be appropriate for a quantitative
survey
Comprehensive
(10) Technical Feasibility Provides an evaluation of technical feasibility and incremental costs of entrainment technologies:
&Cost Evaluation Net Present Value of facility compliance costs and social costs to be provided; requires peer review
I Study
,Provides a discussion of monetized and non-monetized water quality benefits of candidate
;entrainment technologies from(r)(10)using data in(rX9);benefits to be quantified physical or
Benefits Valuation , `biological units and monetized using appropriate economic valuation methods:includes changes in
(11) Study ;fish stock and harvest levels and description of monetization;must evaluate thermal discharges,
•facility capacity,operations,and reliability;discussion of previous mitigation efforts and affects;
rbenefits to environment and community;social benefits analysis based on principle of willingness-to-
- pay;requires peer review
111 Non-Water Quality Provides a discussion of non-water quality factors(air emissions and their health and environmental
12 Environmental and impacts,energypenalty,thermal discharge,noise,safety,grid reliability,consumptive water use,
( � Other Impacts P 9 P
Assessment etc.)attributable to the entrainment technologies;requires peer review
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Entrainment Characterization Study Plan
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Submittal Requirements
at§122.21(r) Submittal Descriptions
Documentation of external peer review,by qualified experts,of submittals(r)(10),(11),and(12
(13) Peer Review Peer Reviews must be approved by the NPDES Director and present their credentials.The
applicant must explain why it disregarded any significant peer reviewer recommendations.
(14) New Units Identify the chosen compliance method for the new unit 41111
1 .2 Study Plan Objectives and Document Organization
to su ort BCSS's 316 b compliance
The ECSP provided in this report was developedpp § ( ) p
through development of a site-specific ECSP with the following primary objectives in mind:
1. Collect data to support development of §122.21(r)(9)which requires at least two years of
entrainment studies be conducted at the facility;
1 2. Collect data to support development of §122.21(r)(7) which allows for summaries of
relevant technology efficacy studies conducted at the facility; and
1 3. Collect data to support Duke Energy's objective of having data sufficient to evaluate
biological efficacy of potential alternative intake technologies that may require site
' specific evaluations and support social cost-benefit analyses as a part of the
§122.21(r)(10)-(12) compliance evaluations.
While not a primary objective, the entrainment data gathered will help support development of
§122,21(r)(4) which requires a listing of species and life stages most susceptible to entrainment
at the facility.
To meet these objectives, this document provides summaries of the station's configuration and
operation (Section 2), historical biological sampling efforts conducted at the facility that are
relevant to cooling water intake evaluations (Section 3), a summary of Threatened and
Endangered Species identified near the facility (Section 4), a sampling program design based
on this information (Section 5), recommended study methods including gear type, schedule,
frequency, and quality control procedures (Section 6), references cited (Section 7), life history
information on species likely to be entrained that supports reducing the sampling period from
12-months per year to 8-months per year (Appendix A), documentation of the subject matter
' expert review of an earlier draft of this study plan (Appendix B), and a white paper on the use of
pumped samplers in entrainment monitoring (Appendix C).
' 2 Generating Station Description
This section presents background information on the source waterbodies (Belews Lake and the
Dan River) from which BOSS withdraws cooling water and the design and operation of the
CWIS.
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Entrainment Characterization Study Plan
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2.1 Source Waterbody
1 2.1.1 Belews Lake
Belews Lake was created in 1973 by the formation of a rolled earth fill dam with a concrete
' spillway across Belews Creek. Belews Lake has a surface area of 3,863 acres and a shoreline
of approximately 88 miles. The lake was created to provide cooling water for BCSS which is one
' of the largest coal-fired generating stations on the Duke Energy system.
Belews Lake is comprised of three distinct regions: (1) West Belews Creek arm; (2) Belews
Creek arm; and (3) main body of the lake (termed downlake region) (Figure 2-1). The upper
portion of the West Belews Creek arm of the lake receives heated effluent from BCSS's once-
through condenser cooling water (CCW). The West Belews Creek arm is physically separated
from the remainder of Belews Lake, except for a 0.93-mile long man-made canal which
facilitates the return of heated CCW effluent to the Belews Creek arm. Moving southward from
the downlake region into the Belews Creek arm, beginning approximately 0.6 miles from
BCSS's CCW discharge canal, is the narrow portion of the reservoir historically termed the
"midlake" region. This region represents a transitional area, situated between the lake's
headwaters and the downlake region. In this portion of the lake, the upper part of the water
' column typically has downlake water quality as influenced by the edge of BCSS's thermal
plume. However, the deeper portion of the midlake water column typically has water quality
more like that observed in the headwater portion of the reservoir (i.e. cooler water, with greater
concentrations of nutrients and suspended solids)(Duke Energy 2011).
Belews Lake is characterized as a southeastem Piedmont reservoir which receives heated
' discharges from a steam-electric power plant and exhibits strong summer stratification and
complete winter mixing. The BCSS heated discharge influences the heat content in Belews
Lake and longitudinal mixing in the downlake region via continued recirculation between Belews
' CCW discharge canal and the CCW intake. Belews Lake lies in the Roanoke River basin. The
lake has a retention time of approximately 1,236 days and a usable storage capacity of 181,664
acre-feet.
2.1.2 Dan River
The Dan River near BCSS is located within Stokes and Rockingham counties, North Carolina. A
make-up water pumping station located on the Dan River near BCSS (Figure 2-2) is used to
maintain the storage capacity and water surface elevation at Belews Lake during extreme
drought periods (see Section 2.2.2 for more detail).
Electrofishing samples during February 2009 demonstrated a diverse fish community at
locations upstream of, downstream of, and near the make-up water intakes. This Dan River fish
community was composed of 24 fish species that included seven cyprinids, six catostomids, six
' percids, three centrarchids, and two ictalurids. The fish community was dominated by species
with an intermediate pollution tolerance rating and species known to feed on insects (Duke
Energy 2009a).
Duke Energy 14

II
Entrainment Characterization Study Plan rL)
Belews Creek Steam Station
1
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I
Duke Energy 15

r — O r M — am no woe r I N — all M M M M M
Entrainment Characterization Study Plan ImiN
Belews Creek Steam Station
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Duke Energy I 6

I Entrainment Characterization Study Plan
Belews Creek Steam Station ���
2.2 Station and CoolingWater Intake Description
P
I BCSS has two coal-fired units with an electric generating output of 2,220-megawatts (MW).
Units 1 and 2 are rated at 1,110 MW each and began commercial operation in August 1974 and
December 1975, respectively. The design pumping capacity for the Belews Lake CWIS is 1,514
IMGD (757 MGD/unit; Table 2-1). The Dan River make-up CWIS has a design pumping capacity
of 26 MGD (Tables 2-2).
Il
Table.2-1. Belews Creek Steam Station Design Intake Flow Rate by Unit and Daily
Average Water Withdrawal from Belews Lake, 2011-2014
I
Design Flow Rate
(MGD) Average daily water withdrawal (MGD)from Belews Lake
Unit
2011 2012 2013 2014
1 757
2 757 1,259.1 1,265.4 1,185.0 1,220.9
Facility 1,514
I
Table 2-2. Belews Creek Steam Station Design Intake Flow Rate for the make-up intake
Iand Daily Average Water Withdrawal from the Dan River, 2011-2014
Design Flow Average Daily water withdrawal from the Dan River
Rate(MGD) 2011 2012 2013 2014
Dan River
make-up 26 0.0 13.9 0.03 0.0
Iwater intakes
1 2.2.1 Belews Lake Cooling Water Intake Structure
BCSS withdraws circulating water through a single CWIS located in the west arm of Belews
I Lake (Figures 2-3 and 2-4). BCSS's CWIS is 158 feet long and is divided into eight, 18.5 feet-
wide intake bays. A trash rack spans the upstream face of each intake bay. The trash racks are
23 feet tall and are made of 2-inch by 0.5-inch steel bars spaced every 3 inches on-center.
I Behind each trash rack is a 23 foot tall vertical fixed screen comprised of coarse mesh panels
with 3/8-inch mesh spacing. Each of the fixed-panel screens is equipped with a differential
pressure alarm that sounds if the differential pressure across the screen reaches 10 inches,
I signifying fouling and a need for screen cleaning. Eight circulating water pumps (one in each
intake bay, four pumps per unit) are located 26 feet downstream of the fixed-panel screens.
Each pump has a capacity of 131,500 gpm (189 MGD). With all eight pumps operating, the
Imaximum design flow of BCSS is 1,052,000 gpm (1,515 MGD).
1
I
IDuke Energy 17

Entrainment Characterization Study Plan
Belews Creek Steam Station
ke-up : Make-up
Water Intake Water Intake
(approxim ate (approximate
location) location)
1 a
Make-up Water Belews
Pum•in Station Creek
' Dan River
1
' Figure 2-3. Aerial View of the Make-up Water Intake on the Dan River and Belews Creek in
Rockingham County, North Carolina (Image Modified from: Google Earth)
1
I
I
Duke Energy 18

Entrainment Characterization Study Plan
Belews Creek Steam Station 01
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Energy 2011)
I
1
IDuke Energy 19

Entrainment Characterization Study Plan
Belews Creek Steam Station
1 2.2.2 Dan River Make-up Pumping Station
' In 2008, a flue gas desulfurization (FGD) system was installed at BCSS which increased the
consumptive use of Belews Lake by approximately 5.4 MGD. To meet the additional water
demand, primarily during drought conditions, Duke Energy constructed a make-up pumping
t station on the Dan River adjacent to the BOSS site (at the Dan River/Belews Creek confluence).
The make-up pumping station has two pumps rated at 9,000 GPM (13 MGD) each. The two
make-up water intakes are low profile horizontal intake structures embedded in the bottom of
the Dan River and Belews Creek, respectively and each are equipped with a velocity cap'
(Figure 2-5). Water withdrawn from the Dan River and Belews Creek flows into a pit and tunnel
system and is routed to a collection basin at an on-shore pumping station. The make-up
pumping station is equipped with Beaudrey Water Intake Protection (WIP)screens comprised of
2-millimeter fine mesh. The WIP screens were designed to have an approach velocity of less
' than 0.5 feet per second. The pumping station was designed with an integrated fish recovery
and return system. This system utilizes a fish pump to lift fish to the top of the pump station and
discharges them back into the Dan River downstream of the make-up water intakes via a
submerged fish return line (Duke Energy 2009b).
1
1
1
1
'
1 Note that these velocity cap intakes do not meet the definition of velocity cap as used by EPA in the final
Rule for impingement compliance under Compliance Alternative 4 (§125.92(v)), because they are not
located 800 ft from the shoreline
1
' Duke Energy 110

IEntrainment Characterization Study Plan FYZ
Belews Creek Steam Station
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I
Creek Steam Station Belews Lake Pumping Station-Velocity Cap Engineering Drawing,
BC-139400.39)
I
I
Duke Energy i 11

Entrainment Characterization Study Plan
Belews Creek Steam Station
3 Historical Studies
The most recent entrainment study conducted at BOSS occurred during two sampling periods in
1976 and 1977. The first study period was from March 1, 1976 to September 29, 1976 and the
second study period was from April 26, 1977 to August 31, 1977 (Alden 2004). Twenty-four hour
samples were collected three times per week from a 2-inch gate valve located upstream of the
Unit 1 main condenser water box. Sampling consisted of using a 794-micron (pm) plankton net
' placed in a 55-gallon drum. Flow rates were estimated by the time required to fill the drum.
Sample times were recorded to the nearest minute. Sample volumes were estimated based on
flow rate and time sampled. Sample volumes averaged 347 cubic meters (m3). No eggs or
' larvae were collected in 1976 and only six common carp (Cyprinus carpio) larvae were collected
in 1977 (Table 3-1).
' The low entrainment levels observed in 1976 and 1977 were likely influenced by the presence
of toxic levels of selenium (from BOSS ash basin discharge to Belews Lake) and subsequent
recruitment failure, which has been documented to have occurred in Belews Lake during the
' 1970s and 1980s (Alden 2004). Ash basin discharge water was rerouted to the Dan River in
1985 which has led to the recovery of the Belews Lake ecosystem over time. However, changes
in entrainment rates at the BCSS CMS are unknown at this time. The detailed EPA
' questionnaire submitted by Duke Energy listed bluegill (Lepomis macrochirus), black crappie
(Pomoxis nigromacutatus), threadfin shad (Dorosoma petenense), and gizzard shad (Dorosoma
' cepedianum) larvae as entrainable species and lifestages at BOSS. Because of their life history
and fecundity, threadfin and gizzard shad larvae are commonly collected in entrainment
samples at other facilities where these species occur.
1
1
' Duke Energy I 12

Entrainment Characterization Study Plan
Belews Creek Steam Station r LN
ITable 3-1. Entrainment Sampled by Flow (m3) at Belews Creek Steam Station, March 1976
through August 1977
I
March 1976 4,794 0
April 1976 4,104 0
I May 1976 3,846 0
June 1976 4,238 0
July 1976 4,614 0 iiiiirril
IAugust 1976 5,052 0.
September 1976 3,570 0 .BEM
1 April 1977 2,016 MEI
May 1977 6,166 0
I
June 1977 6,706 0MIMI
July 1977 4,945 A 0
August 1977 4,197' 0
I 4 Threatened and Endangered Species
There are no critical habitat designations within Belews Lake, nor are there expected to be any
I State or Federal rare, threatened or endangered (RTE) species within the Lake. However, the
Dan River has two aquatic RTE species (i.e., Roanoke logperch [Perciana rex] and James
spinymussel [Pleurobema collina]), neither of which is expected to be present in Belews Lake.
IThe U.S. Fish and Wildlife's map-based search tool (IPAC) was consulted to generate a
resource report and determine the potential presence of Federally-listed species within Belews
I Lake and the surrounding land (Figure 4-1; USFWS 2015). The only aquatic species identified
was the endangered James Spinymussel (Pleurobema collina). However, the James
Spinymussel lives in stream sites that vary in width from 10-75 feet and depth of 1/2 to 3 feet. It
Irequires a slow to moderate water current with clean sand and cobble bottom sediments.
(USFWS 1990). The habitat near the Belews Creek intake is not suitable to James Spinymussel
and it is not anticipated to reside anywhere near the BCSS CWIS.
I
I
I
IDuke Energy 113

I
Entrainment Characterization Study Plan L��
Belews Creek Steam Station r
1 Iii
t dl
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r Vii i .l __ �"
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Figure 4-1. Geographical Boundary of the IPAC Search
5 Basis for Sampling Design
HDR Engineering, Inc. (HDR) and Normandeau Associates, Inc. (Normandeau) participated in a
I
site visit to BOSS on May 12, 2015 to evaluate potential entrainment sampling methods and
locations that would be practicable based on best professional judgment and previous
entrainment sampling experience. During this site visit, it was determined that pumped samples
Ifrom within the CWIS would best represent entrainment rates at BCSS. Sampling at the intake
using a pumped-sampler eliminates the potential for damage to or loss of organisms that can
I occur if organisms pass through the cooling water system and are sampled at the discharge. In
addition, properly designed and operated pumped systems have shown collection efficiencies of
95 percent or greater for fish eggs and larvae with little or no organism damage (EPRI 2014).
ITwo primary methods that have been historically used to estimate ichthyoplankton entrainment
at power plant intakes are utilizing streamed/towed nets and collecting pumped samples.
I Traditional ichthyoplankton nets can be used to filter water as it enters the intake and collect
organisms. Alternatively, pumps can be used to convey water from the intake structure to a fine-
'
Duke Energy 114

Entrainment Characterization Study Plan 1
Belews Creek Steam Station "J/
' mesh net onshore. Onshore nets are suspended in a buffering tank to minimize damage and
extrusion of eggs and larvae.
' Each method has advantages and disadvantages and a comparison of the two methods are
summarized in Table 5-1. Pumped sampling was selected as the preferred sampling method for
' the BCSS. The primary advantages of utilizing pumps at this location include metering precise
sample flows, longer sample collection times, reduce the potential to miss samples due to
inclement weather or other events, and increase the ability for technicians to safely observe net
' filtering and other aspects of the data collection. Pumped samplers are among the preferred
gear types accepted by the EPA and have been used extensively to successfully monitor
entrainment at power plant intakes for decades. Their versatility includes being utilized in fresh,
' estuarine, and marine water environments. Properly designed and operated systems can be
accurate and effective. While no sampling method is perfect, we believe pumped samplers offer
the best, most cost-effective, and consistent sampling method available for BCSS.
1
1
Duke Energy I 15

■ Entrainment Characterization Study Plan
Belews Creek Steam Station
Table 5-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for Estimating lchthyoplankton Density in Cooling Water Intake Structures (some information adapted from EPRI 2014)
' Gear Type Advantages Disadvantages
Hoop Nets Deployed in the Intake Large volumes are sampled quickly(less manpower required for the same number of pumped - Can be difficult to deploy and retrieve in the confined space of intake structures—precludes the use
samples). of some net types (e.g., standard bongo, neuston nets, or Tucker trawls).
- If net frames are not used, then there is limited to no modifications to the intake required for - on deployment method, may require modifications to intake structures (e.g., frame
deployment. mounted nets in frame guides).
-No potential for mechanical damage associated with pump passage. - Less precise flow metering than pumped samplers.
' - Large volumes are sampled quickly—capturing less temporal variability as compared to pumped
samples.
- Relatively small nets needed to fit in the intake structure offer a small spatial sample. Multiple nets
can be used to increase sampled area at the cost of additional samples to be processed in the
laboratory.
-Tow speeds in the range of 1-2 meters per second (commonly used during ichthyoplankton
sampling) is above the intake velocities at the majority of intakes.
-Some active avoidance possible by larger motile life stage (e.g., late larvae and early juvenile).
Larger hoops can be used to decrease potential for avoidance, but would require a larger
deployment area, since length is proportional to opening diameter in properly sized nets2.
-Greater potential for extrusion than pumped samples (no buffering tank).
-Boat deployed nets are subject to weather delays and associated safety concerns.
Pumped Samplers in the Intake - 100 m3 samples are collected over roughly 2 hours increasing the potential to capture temporal - Some active avoidance possible by larger motile life stage(e.g., late larvae and early juvenile).
variability in ichthyoplankton densities not observed in net samples. Improperlydesi ned samplers can lead to damage to organisms duringsampling.
g P 9 9 P g.
-
Limited modifications to intake structures are required to install— usually just anchoring points for -Samples a smaller portion of the spatial variability, because pump inlets are generally smaller than
the sample pipe.
net openings.
' - In-line flow metering offers greater precision in measuring the volumes of flow sampled.
-Some potential for mechanical damage. However, correctly designed systems can offer<5%
damage or destruction of eggs and larvae.
- Fixed pipe allows precise control over water depth and orientation to intake flows.
- Less potential for extrusion than nets, because the filtering net sits in a buffering tank.
' - Lower potential for missed samples due to severe weather.
-Allows technicians to observe sample collections and minimize potential for invalid samples (e.g.,
use of 330-urn nets increases potential for net occlusion and frequent net change outs may be
required during certain times of the year).
I
I
2 A general rule of thumb,as described in EPRI 2014,states that the total effective open area of the netting(percent open area x area of netting)should be at least twice the area of the net mouth opening.Others have suggested a net length to mouth opening diameter ratio of three or more.

Entrainment Characterization Study Plan FYZ
Belews Creek Steam Station
' While all sampling techniques are biased to some degree, the design for the Belews Creek
CWIS 1 is ideal for pumped entrainment sampling. Potential disadvantages to pumped
' entrainment sampling at intake structures (compared to sampling at the discharge) have been
studied by EPRI (2014). An explanation of how these potential disadvantages are minimized at
Belews Creek is provided in Table 5-2. Despite some potential disadvantages, pumped samples
collected at the intake structure remain a better option than sampling at the discharge
because:(1) organisms will be less damaged compared to those passing through the cooling
water system to the discharge (resulting in a higher probability of taxonomic identification); (2)
' access to the intake structure is easier logistically; (3) lower velocities at the intake structure will
result in less extrusion of larvae and/or damage to nets; and (4) safety issues and inclement
' weather will not be major factors resulting in lost sampling dates.
Table 5-2. Potential Disadvantages of Pumped Ichthyoplankton Sampling at Belews
Creek Steam Station
' Potential Disadvantage Sampling at BCSS
las described in EPRI 20051
Non-random vertical distribution may Sampler at BCSS will be designed to sample near surface, mid-
require depth-stratified sampling depth, and near bottom simultaneously(see Section 6)
' Low water velocities at some CWIS `'
my increase likelihood of active gea take velocities at BCSS are greater than 1.0 fps at the point of
avoidance for more motile larval an mpling and avoidance is unlikely.
juvenile stages
Potential uncertainty as to whether No escape from entrainment is anticipated at the sampling location,
' organisms were destined to be
entrained because velocities downstream of the bar rack are greater than 1.0
fps.
The recommended approach for BCSS is to pump water from between the trash racks and the
' vertical fixed-panel screens to an entrainment sampling tank. The sampling system will utilize a
fixed pipe with three orifices that will allow simultaneous withdrawal from near surface, mid-
water, and near bottom. Two identical pipes will be installed at Units 1 & 2 to allow flexibility in
' sampling (i.e., if one unit is not in operation on any given sampling date, samples can be
collected from the other unit). These locations are near the mid-point of the CWIS resulting in
samples that are representative of all pumps in operation. Both sampling pipes will be equipped
with quick-connect couplings to allow either pipe to be sampled from a single pump. The quick-
connect couplings will also allow above deck piping to be removed between sampling events to
facilitate cleaning the fixed panel screens.
' Entrainment sampling will be collected twice per month between March 1 and October 31 in
2016 and 2017. This period corresponds to when fish eggs and larvae are likely present in
' Belews Lake based on spawning characteristics of the species with the potential to be entrained
and historic sampling described in Section 3 (see Appendix 1). To account for potential shifts in
spawning time periods, the entrainment sampling program will be modified, if necessary, in
111
Duke Energy 117

IEntrainment Characterization Study Plan 1 ��
Belews Creek Steam Station 1
Iresponse to entrainment densities. For example, if the densities of entrainable organisms
remain high during October 2016 sampling, additional sampling events will be added to the
I program in 2016 and the sampling period in 2017 will be extended accordingly. Similarly, if
densities of entrainable organisms are high in early March 2016 when the program is initiated,
the 2017 sampling plan will begin earlier (e.g., February). These adjustments, if necessary, will
I provide the greatest potential to collect representative samples throughout the entrainment
season.
I Each sampling collection event will be conducted over a 24-hour period with sample sets
collected in four, 6-hour intervals. This sampling frequency will provide fish taxa, density
distribution, and seasonal/diel variation in data collected over the two year period.
IFactors important to meeting §122.21(r)(9) requirements, along with a basis for how these
requirements will be addressed at BCSS, are summarized in Table 5-3.
I
I
Table 5-3. Summary of Approach for Development of§122.21(r)(9) Required Entrainment
Characterizations
122.21(r)(9) Requirement Basis for Meeting the Requirement
ITwo years of data and annualEntrainment samples will be collected during 2016(Year 1)and
variation 2017(Year 2)
I
Seasonal variation Entrainment samples will be collected twice per month during March
through October each year
Diel variation Each 24-hr sampling event will be split into four, 6-hr sampling
I
periods to capture diel variation
ari ton re ate a t timate and Weather information and water temperature will be collected during ':.
weather each sampling event to evaluate differences_in entrainment rates
I based on these factors
Year 1 and Year 2 data will be analyzed to determine species/life
Variation related to spawning, stage variations over time along with spawning and feeding variation;
I
feeding and water column
migrations Entrainment samples will be collected at three depths(near surface,
mid-depth, and near bottom)to account for depth variability by
species/life stage for water column migrations
I The resolution of taxonomic and life stage designations will be
Identification of lowest taxon monitored through regular evaluations of catch data with the goal of
possible reducing percent of unidentified organisms and increasing resolution
of genera and higher taxonomic designations
IData must be representative of each Sampling in Units 1 &2 are expected to be representative of the total
intake CWIS
I How the location of the intake in the Sampling of near surface, mid-depth and near bottom at downstream
water body are accounted for of the bar racks will result in t the collection of a representative
entrainment sample
I Document flow associated with the Facility will monitor and provide documentation of circulating water
data collections flows during sampling events
I
Duke Energy 118

Entrainment Characterization Study Plan
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122.21(r)(9) Requirement Basis for Meeting the Requirement
Methods in which latent mortality will Latent mortality will not be evaluated as a part of this study,
be identified therefore, methods are not provided
Data must be appropriate for a Data will be expressed as taxon and life stage specific densities
quantitative survey which can be multiplied by flow to determine entrainment rates
6 Entrainment Characterization Study Plan
6.1 Introduction
This section of the ECSP provides methods, materials, and procedures for entrainment sample
' collection and processing. A site-specific Standard Operating Procedure (SOP) will also be
developed and serve as a companion document to this ECSP. The SOP will lay out detailed
field sampling procedures, laboratory procedures, data quality assurance and quality control
' (QA/QC), and database management. This will ensure field sampling and laboratory methods
are adhered to and provide consistency with other plants in Duke Energy's fleet where
entrainment sampling is required.
1 6.2 Sample Collection
Entrainment sampling will be conducted twice per month between March 1 and October 31 in
2016 and 2017 (16 sampling events in each year). This frequency should be sufficient to
capture the annual, seasonal, and diel variability in entrainment with acceptable confidence
' levels (inferred from EPRI 2014). This period corresponds to when fish eggs and larvae are
likely present in Belews Lake based on spawning characteristics of the species with potential to
be entrained and historic sampling described in Section 3 (see Appendix A). To account for
' potential shifts in spawning time periods, the entrainment sampling program will be modified, if
necessary, in response to entrainment densities. For example, if the densities of entrainable
organisms remain high during October 2016 sampling, additional sampling events will be added
' to the program in 2016 and the sampling period in 2017 will be extended accordingly. Similarly,
if densities of entrainable organisms are high in early March 2016 when the program is initiated,
' the 2017 sampling plan will begin earlier (e.g., February). These adjustments, if necessary, will
provide the greatest potential to collect representative samples throughout the entrainment
season. Coordination with station operations will be necessary to ensure pumps are scheduled
to operate for the duration of the sampling period in order to obtain representative density
measurements. This twice per month sampling frequency should be sufficient to adequately
describe seasonal patterns in entrainment as requested in the final §316(b) rule for existing
facilities.
During each 24-hour sampling event, the Unit 1 or Unit 2 intake bay will be sampled (depending
upon which unit is in operation) within the following discrete 6-hour time intervals: 2100-0300
(night), 0300-0900 (morning), 0900-1500 (day) and 1500-2100 hours (evening). During each 24-
hour sampling event, 2-hour samples will be taken within each of the above 6-hour sampling
Duke Energy 119

Entrainment Characterization Study Plan F)�
Belews Creek Steam Station
window resulting in four samples during each sampling event. In the crepuscular periods, target
sample collection times will be 1 hour preceding and 1 hour following sunrise and sunset. A total
of 64 samples will be collected during each year over the entrainment season for a program
total of 128 for the two years of study (Table 6-1). This sampling frequency will provide fish taxa,
density distribution, and seasonal variation in data collection over the two year period.
Table 6-1. Entrainment Sampling Details
Details
Units to be Sampled Unit 1 or Unit 2
Sampling Events(Days) 32 sampling events per year; twice per month; March 1 through
IOctober 31, 2016 and March 1 through October 31, 2017
Daily Collection Schedule Samples collected within every 6 hours in a 24-hr period (4
collections/24-hr period)
' Targeted Organisms Fish eggs, larvae, and juveniles
Depths eigwr
Depth integrated sample using selective withdrawal from near
surface, mid-depth, and near bottom.
Sample Duration Approximate 100 m3 samples collected within each 6-hour sampling
interval.
Number of Samples per Sampling Four samples per event
Event(Day)
Total Number of Samples 16 sampling events/year x 4 samples/sampling event(days)x 2
1
years = 128 samples
6.2.1 Location
Entrainment samples will be collected from either the northern section of the intake bay of Unit 1
or southern end of the intake bay of Unit 2, which are immediately adjacent to one another. If
both pumps are operational on a given sampling date, the Unit 1 bay will be selected
preferentially. Samples will be collected from between the trash racks and the fixed screens
using a polyvinyl chloride (PVC) sampling pipe with three openings: near surface (-4 feet from
full pond surface elevation; - El. 7213), mid-water (mid-point between full pond surface elevation
and bottom of intake; - El. 714), and near bottom (+4 feet from bottom of intake; -- El. 707) (See
Figures 6-1 and 6-2). Sampling pipe openings will be sized to allow concurrent equal flow from
' each depth, thereby contributing to a single aggregate sample.
The electric pump and buffering tank will be located on the CWIS west of the trash rack open
1 area in front on the units, with PVC or flexhose piping running along the top of the intake
structure deck to the sampling locations between Unit 1 and Unit 2 (Figure 6-2). Changes or
variations in the sampling location over the duration of the 2-year study will require Duke Energy
' notification and approval.
3 Elevations in this document refer to Mean Sea Level
1
Duke Energy 120

MI — — r — On M MN — M In r MO N MI — In N M
Entrainment Characterization Study Plan FYR
Belews Creek Steam Station
TRASH RACK AND TRASH SCREEN GUIDES Cl CIRCULATING
WATER PUMP
__\TRASH SLUICE
\16\1 ....._a____=7,_.7. —L ?OP DECK EL 735.0'
MAX FLOOD EL. 735.0' —I—
c CIRCULATING
II
i WATER PUMP
FULL POND EL. 725.0' --Y--- 1 • DISCHARGE
MAX DRAW DOWN EL. 720.0' —i— . I Near-surface Inlet
L.W.I. EL. 715.0' —t-- • r Mid-depth Inlet
r / _ I
A
�
/�- Near-bottom Inlet
EL. 703.0' 1 _. /1/1
-.-- 43 2' — ►
0' 25' 5C '
Figure 6-1. Section View of the Belews Creek Steam Station's Cooling Water Intake Structure with Approximate Location of
Sample Inlets at Three Depths— Sampler pipe (in red) not Shown to Scale (Image Modified from: Alden 2004)
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IEntrainment Characterization Study Plan F)?
Belews Creek Steam Station
I
•
1 �; - . �
A. fz ' Sampler Pump
Piping { •• and Tank ,.
Connecting ` '}t•' • Location . ;
—. Pum • to Sampler
4'' '1
•
7 v `t, <P,. . .E1 ,� it
I .
-',.
-- �� i Wil= T 1 T
l
I . A., ,..., Sampling Location Sampling Location
I
1
Figure 6-2. Aerial View Showing Approximate Locations of Sampling Gear (Image
Modified from: Google Earth)
IThe water volume sampled will be measured using an in-line flowmeter. Depending on actual
pump flow rates (which are dependent on suction head), pumping 100 m3 of water (target
I sample volume) will require approximately 2 hours with additional time required to wash down
nets and prepare the samples for shipping. Samples will be processed discretely to investigate
diel variability in ichthyoplankton composition and abundance.
IPumped water from the sampler will be filtered through 330-pm plankton nets suspended in a
water-filled tank to reduce velocity and turbulence and prevent extrusion of larvae through the
I mesh. A larger mesh (e.g., 505-pm) may be used if net clogging precludes sampling with 330-
pm mesh. An example ichthyoplankton sampler is shown in Figure 6-3. The proposed electric
pump has been used successfully at other power plant intake structures to collect entrainment
Isamples with little or no damage to eggs and larvae (Figure 6-4). Pump specifications are
provided below:
I • Capacity: 240 gpm;
• Range: 5 gpm — 380 gpm
I • 7.5 horsepower
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I

' Entrainment Characterization Study Plan F��
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• Inlet diameter: 3 inches
• 230/460 volts
I • 18/9 amps
• 3 Phase
• Length: 36 inches
• Self Priming
• Suction Lift: approximately 25 feet
' • Impeller: Urethane coated steel
• Weight: 230 lbs.
' The net mouth will be suspended above the water line in the tank to prevent overflow and loss
of organisms in the event of tank overflow. In an effort to minimize organism damage, the net
will be washed down at least twice during each sample collection. Washdowns will be combined
in the field to provide a single concentrated 100 m3 sample. If high debris buildup leads to net
clogging then more frequent net washdowns may be required. The net and collection cup will be
carefully rinsed into sample jars with preprinted labels and preserved in a 5 to 10 percent
formalin solution containing.
Total sample volume, total sample duration, intake water temperature, dissolved oxygen, pH,
and conductivity will be recorded on field data sheets. Samples will be transported back to the
laboratory for analysis under a required chain-of-custody, provided in the SOP.
1
1
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IEntrainment Characterization Study Plan 1.01
Belews Creek Steam Station
I
I JOINT MUST SWIVEL f I
APPROX.90
(POSSIBLY MORE)
SAMPLE FLOW RATE-240 gpm
3'0 ADAPTER SOCKET
WOODEN CRADLES(Iyp.21 - , 1 [ 3-0 OVERFLOW DRAIN
r
ISTAINLESS STEEL BANDS(typ.2)—J I ' 330p ICHTHYO-NET
I INLINE / '
FLOW TOTALIZING 3"0 PVC VALVE
METER
(PVC SADDLE MOUNT) __ 3'0 PVC
c - 330p 110 gal C It F (PASSIVE DISCHARGE)
1 COD END- IN POLYETHYLENE _y
BUCKET . TANK
SAMPLER I —
-- (, __-�
FLOW iN _ �"�L
3"0 PVC NIPPLE!
i ; 3 0 PVC �:
i (DISCHARGE THROUGH NET)
3'0 RADIAL FLEX HOSE--' -3'0 QUICK-CONNECT 3"0 PVC VALVE
NOT TO SCALE
IFigure 6-3. Example Entrainment Pump Sampling System Configuration
ti
I _ _
I
pump
I ....tp
Figure 6-4. 7.5-Horsepower Electric Pump Used for Entrainment Sampling
I
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Entrainment Characterization Study Plan L��
Belews Creek Steam Station 1
1 6.3 Sample Sorting and Processing
' Upon arrival in the laboratory, all ichthyoplankton samples will be logged on an Ichthyoplankton
Sample Control Sheet/Sorting Form. Because Belews Lake is a freshwater reservoir, we do not
anticipate shellfish larvae, as defined as commercially important crustaceans or bivalves, will be
present in the samples. Therefore, procedures for identifying shellfish larvae are not presented.
Before sorting, ichthyoplankton samples will be rinsed using a U.S. Standard Sieve with a mesh
size opening of less than or equal to 330 pm to remove excess detritus and formalin. All fish
eggs and larvae retained on the sieve will be hand-sorted from the debris with the aid of an
illuminated magnifier. Samples that are estimated to contain more than 400 fish eggs and larvae
(all taxa combined) will be split with a plankton splitter and to a subsample quota of about 200
eggs and larvae combined and then analyzed. The number of eggs and larvae present in the
' sample will be recorded. If possible, long-dead and/or non-viable eggs will be identified using
appropriate and well-defined techniques identified in the SOP and categorized in the database
accordingly. For example, the SOP may require that eggs collected live be whole, show signs of
fertilization and not be covered with fungus at the time of their entrainment. Ichthyoplankton
from each sample will be placed in individually labeled vials and preserved in 5 to 10 percent
formalin prior to taxonomic analysis. Examples of organisms identified as long-dead or non-
viable will be stored in separate vials.
Fish eggs, larvae, and juveniles will be identified using a dissecting scope equipped with a
' polarizing lens. Identifications will be made to the lowest practical taxonomic level using current
references and taxonomic keys (e.g., Auer 1982, Wallus et al. 1990, Kay et al. 1994, Simon and
Wallus 2004, EPRI Larval Fish Identification Key http://www.larvalfishid.com/). Larvae and
juveniles will be categorized as follows:
• Yolk-sac larvae: Phase of development from the moment of hatching to complete
absorption of the yolk;
• Post yolk-sac larvae: Phase of development from complete absorption of yolk to
development of the full complement of adult fin rays and absorption of finfold;
• Juvenile: Complete fin ray development and finfold absorption.
Ichthyoplankton larval life stage will be identified as larvae" if they are damaged to the point
that they cannot be confidently classified as yolk-sac or post yolk-sac.
For each diel (6-hour) sample, the following morphometric data will be collected:
• Up to 10 yolk-sac, post yolk-sac and "larvae" of each fish species will be measured for
total length, greatest soft tissue body depth, and head capsule depth to the nearest 0.1
' mm. Among dorso-ventrally compressed organisms whose body or head capsule width
exceeds the body or head capsule depth, soft tissue body and head capsule width will
also be measured to the nearest 0.1 mm.
' • Up to 10 eggs of each taxon will be measured for minimum and maximum diameter to
the nearest 0.1 mm.
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Entrainment Characterization Study Plan
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Only whole organisms will be subject to morphometric evaluations. If more than 10 eggs or
larvae are present, a random subset of each species and life stage will be measured. Length
measurements will be performed with a calibrated ocular micrometer or other calibrated tool
(e.g., ImageTool" Software).
Organism identification will be cross-checked using the QC procedure described below.
6.4 Data Management
Field and laboratory data will be recorded on forms compatible for computer entry and data
processing activities will be recorded on log sheets for each batch of data. A digital image of the
datasheet will be taken in the field prior to the datasheets leaving the site. Data sheets will be
inspected for completeness prior to data entry. The data will be entered using a double data
entry software, a feature that ensures entry errors will be caught and corrected as the operators
' key the data. Using this procedure, data sets are entered twice in succession and the software
compares the first and second entries and identifies any discrepancies. Discrepancies must be
resolved before the second data entry can continue. Keyed data sets will be error checked. If
any errors are encountered, they will be corrected in the database. Once the database is
cleared of errors, the data file compared to the data sheets will be audited to ensure an Average
' Outgoing Quality Limit (AOQL) of 1 percent (a 99 percent accuracy). The data set will then be
ready for the production of summary tables, which will be proofed to confirm that the summary
program worked properly. The data editor will sign and date each proofed summary table and
include notations as to which values were verified.
6.5 Data Analysis
Data analysis will be performed using the QAQC'ed database and will include summaries of
proposed vs actual samples collected, sample volumes, entrainment densities, morphometric
' measurements, and water quality parameters. Generally, minimum, average or median, and
maximum values will be provided by sample event or month. Collection densities, expressed as
number per 100 m3, will be calculated from entrainment catch data for each taxon and life stage
by month of sampling, sample event (i.e., including all samples collected within a 24-hour
period), and by six hour diel intervals (e.g., 2100-0300 [night], 0300-0900 [morning], 0900-1500
[day] and 1500-2100 hours [evening]) across all sampling events. Average concentration of
organisms per unit volume in the hth stratum (i.e., month, sample event or six hour interval),
will be calculated as:
1
xh = — xn
' nh i=1
where:
nh =the number of samples in the hth stratum
x, is the i"'observation in the ht stratum.
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Entrainment Characterization Study Plan
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Next, these densities will used to estimate the total entrainment at cooling water intake based
on design and actual intake flows. The estimated total entrainment will be calculated in the
following manner. First, the average concentration of organisms per unit volume in the hth month
will calculated using the equation provided above. The total number entrained (E) during the
sampled months will then then calculated as:
H
E= EV,k,
where:
H = total number of months sampled
Vh = volume of water withdrawn by the station in the he' stratum.
1 6.6 Field and Laboratory Audits
Prior to the first scheduled sampling, an experienced senior staff member will accompany and
1 train field personnel, including: protocols for site access and contact with facility personnel;
safety requirements as contained in the Health and Safety Plan, implementation of the field
SOP including the operation of the pump samplers, sample collection, sample preservation,
proper datasheet documentation, chain-of-custody, and shipping. At this time, a readiness
review will be conducted to ensure that trained personnel, required equipment, and procedural
controls are in place. In addition, equipment will be tested to ensure its proper operation.
After initiation of sampling, two trained QA staff members (one each from HDR and entrainment
sampling contractor)will each conduct separate independent QA audits to ensure that the SOP
is being implemented correctly. Results of the audit will be summarized in a technical memo.
This memo will categorize deviations from the SOP into three categories: (1) those that do not
affect the quality of the data, (2) those that may affect the quality of the data, and (3)those that
affect the quality of the data. Variances from approved procedures will be documented and
corrected, either by modifying the SOP to address systematic problems or by testing and/or
retraining staff, as necessary. Any changes to the SOP will be discussed with and agreed upon
by Duke Energy representatives before being implemented in the field. Partway through the
sampling program a trained QA staff member from HDR will conduct an independent QA audit
' following the same procedures to provide on-site training, to observe sampling activities, and to
verify that the project's SOP is being followed. In addition, qualified staff will observe initial
laboratory and data management activities to verify the same.
Implementation of the laboratory SOP will be overseen by a senior laboratory manager who will
also ensure that staff technicians have been properly trained. Once during each year of
' sampling, an audit will be conducted to ensure that the SOP is followed. These audits will
include safety, sampling procedures, sample processing, and identification. Audit reports will be
prepared and any substantial shortcomings identified will be addressed prior to the next
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Entrainment Characterization Study Plan
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sampling event. Samples from the first collection event will be analyzed prior to the initiation of
the second event to ensure that organisms are being collected with limited damage to allow
' identification.
6.7 Laboratory Quality Control
' Quality control methods for split, sort and identification of ichthyoplankton will be checked using
a continuous sampling plan (CSP) to assure an AOQL of 10 percent (a90 percent accuracy).
Identification checks will be inspected using a QC procedure derived from MIL-STD (military-
standard) 1235B (single and multiple level continuous sampling procedures and tables for
inspection by attributes). Detailed methods for quality control will be provided in the SOP
' developed by the entrainment contractor. The QC checks will be recorded on appropriate
datasheets and these records will be maintained for review. Samples will be stored for a
' minimum of three years after the end of the project or longer if Duke Energy requests additional
storage time.
6.8 Reporting
During the study, monthly progress updates will outline the status of the on-going sampling and
laboratory processing. At the end of the first year of study, preliminary results of testing will be
provided to Duke Energy, which will include entrainment estimates by month and diel period
using design intake flow. At the completion of the study, a comprehensive report describing all
aspects of the study program (facility description, study design, sampling methods, data
analysis methods, and results)will be generated. The final report will include all tables, figures,
photographs and engineering drawings as necessary to fully document the evaluations
' conducted. Included will be estimates of entrainment by species, life stage, month, and diel
period under design and actual intake flows. The report will be organized with supporting
information and detail in attached appendices, as needed.
1 6.9 Safety Policy
All work performed under the direction of Duke Energy on Duke Energy properties and/or on
properties owned or operated by third parties (i.e., not owned or operated by the contractor or
Duke Energy) will be performed using safe work practices that are at least equivalent to those
required for Duke Energy personnel and of any third party owner or operator. At a minimum, all
contractors are expected to be aware of, and adhere to, Duke Energy's Corporate Safety Policy,
and other location-specific safety policies and procedures.
1
1
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' Entrainment Charaderizatlon Study Plan
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7 References
' Alden Research Laboratory, Inc. (Alden). 2004. Evaluation of the Belews Creek Steam Station
with respect to the Environmental Protection Agency's §316(b) Rule for Existing Facilities.
Prepared for Duke Power. Holden, MA.
_. 2012. Generating Station Assessment Draft 316(b) Rule Compliance Options, Belews
' Creek Steam Station. Prepared for Duke Energy and The Electric Power Research
Institute. Holden, MA.
Auer, N.A. (ed.). 1982. Identification of Larval Fishes of the Great Lakes Basin with Emphasis
on the Lake Michigan Drainage. Great Lakes Fisheries Committee Special Publication 82-3,
Ann Arbor, MI. 744 pp.
' Collier, C., F. Rhode, J. Schoolfield, and C. Stewart. 2007. Assessment of fish populations in
the lower Cape Fear River, 2002-2007. Final Report for Grant NA16F1543. North Carolina
' Division of Marine Fisheries, Morehead City.
Duke Energy. 2009a. The Fish Community in the Dan River, Rockingham and Stokes Counties,
NC, near a proposed permanent water withdrawal structure. Duke Energy. Huntersville,
NC. June 2009.
' 2009b. Pre-Construction Notification Form, Duke Energy Permanent Pump Facilities,
Belews Creek Steam Station. Duke Energy. Charlotte, NC. September 2009.
I . 2011. Assessment of balanced and indigenous populations in Belews Lake for Belews
Creek Steam Station. Duke Energy. Charlotte, NC.
EPRI (Electric Power Research Institute). 2014. Entrainment Abundance Monitoring Technical
Support Document: Updated for the New Clean Water Act §316(b) Rule. 3002001425.
EPRI, Palo Alto, CA.
Kay, L.K., R. Wallus, and B.L. Yeager. 1994. Reproductive Biology and Early Life History of
Fishes in the Ohio Drainage. Volume 2: Catostomidae. Tennessee Valley Authority,
Chattanooga, TN, USA.
North Carolina Department of Environmental and Natural Resources, Division of Water Quality.
' 2012. Issuance of NPDES Permit NC0024406, Belews Creek Steam Station. Stokes
County, NC, October 12, 2012.
Simon, T.P. and R. Wallus. 2004. Reproductive Biology and Early Life History of Fishes in the
Ohio River Drainage, Volume 3: Ictaluridae—Catfish and Madtoms. CRC Press. 204 pp.
' U.S. Fish and Wildlife Service (USFWS). 2015. Information for Planning and Conservation
(IPaC) Report for Belews Creek Steam Station (Belews Lake). Generated November 05,
' 2015.
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Entrainment Characterization Study Plan
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. 1990. James Spinymussel (Pleurobema collina) Recovery Plan. U.S. Fish and Wildlife
Service, Northeast Division, Newton Corner, MA. 38 pp.
' Wallus, R., B.L. Yeager, and T.P. Simon. 1990. Reproductive Biology of Early Life History
Fishes in the Ohio River Drainage, Volume 1: Acipenseridae through Esocidae. Tennessee
Valley Authority, Chattanooga, TN. 273 pp.
1
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tnuainmenrL.naractenzaaonatuoyTian J
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APPENDIX A — Select Species Spawning and Early Life History Data
ISampling for entrainment year-round at BCSS is expected to be a poor allocation of resources, since few if any eggs or larvae are likely to be present in Belews Lake during the winter months. Several species were
identified as likely to be present in entrainment samples and life history information for these species is summarized here and supports a sampling period of March through October. It is important to note that low densities
I of entrainable organisms at the outset and conclusion of the sampling period are unlikely to change the estimates of entrainment in any meaningful way and thus do not warrant the additional sampling costs necessary to
extend the sampling season.
I
Species Spawning Period Spawning Habitat Nest Structure Eggs Fecundity Rates NCDENR Young-of-the-
Year Cut Off Lengths Larvae
Size References
Family Centratchidae
Demersal and
adhesive
Black Crappie (Pomoxis Spring Shallow calm waters near vegetation or cover.., Depression in sand or gravels. 3,000 to 188,000 <75 mm
I
nigromaculatus)
ri...111
Average diameter:
... . ... . .,. ` 0.93 mm. _.
I
Spring and Early
Bluegill Summer Saucer-shaped depressions in sand or gravel typically .. Up to 60,000
Shallow waters with sand and gravels. one to two feet in diameter and a few inches dee Adhesive eggs <50 mm
(Lepomis macrochirus) _ p. gg
Water Temperatures
170 75°F 1110111111M 11111111111111111 .
. .. . Spring and Early II _ Demersal and _ .
IIISummer adhesive
Green Sunfish (Lepomi 9 Saucer-shaped depressions in sand or gravel typical) up to 50,000 <50 m 1, 2,4, 5, 3
t bellow waters with sand and ravels: one to two feet in diameter and a few inches dee eggs
cyanellus) Water Temperatures p' Average diameter: .-` 99
6080 °F 1.0 to 1.4 mm•
II
I
Largemouth Bass
Early Spring 1
Shallow water on bottoms composed of sand,, Circular area 2 to 3 feet in diameter with clean sand or 5,000 to 43,000 , • <100 mm 11111.11P liiiiiii
6-6.5 mm 1, 2, 4, 3
60-75 °F
(Micropterus salmoides) Water Temperatures gravelor pebbles near cover. fine gravel clear of organic debris and silt. Adhesive eggs
: M
I
Spring and Early ll Demersal and
Summer adhesive . u to 14,000 • lIIII:i
RedbreastSunfish (Lepomis , aucer-s aped depressions in grr silt. p1, 6, 2 4,8
Aveer:
Water Temperatures 9
I
65-75°F 1.0 to 1.5 mm
Demersal and NOW
Spring adhesive
Redear Sunfish (Lepomis Shallow water on firm substrates often in Depressions in sand to soft mud constructed in areas 2,000 to 10,000 I <50 mm N/A 1, 7, 2, 3
I microlophus) Water Temperatures locations exposed to the sun. containing aquatic plants. Average diameter eggs ;
68-70 °F
1.0 to 1.5 mm
IFamily Clupeidae
Gizzard Shad (Dorosoma Spring and Early Shallow water Open water Demersal and Up to 50,000
<100mm N/A 1, 2
cepedianum) Summer adhesive eggs viii:
I Spring and Earlyiii411
EflshadDorojI
Summer Demersal and 2,000 to 24,000 4.9-5.5
Eggs scattered over plants or loose sediments. Open water adhesive eggs 111Li<100mm 1, 2, 4, 3
petenense) Water Temperatures
60-80 °F
all
Family Cyprinidae
I

cnuainmen[L.narac►enzaaonaruayrnan
Belews Creek Steam Station TJqC
t
Species Spawning Period Spawning Habitat Nest Structure Eggs Fecundity Rates NCDENR Young-of-the- Larvae References
Year Cut Off Lengths Size
IISpring and Early Demersal a
Summer adhesive
Carp (Cyprinus Eggs scattered in shallow waters with aquatic 36,000 to •.0 5.5'
Common
Carpio) vegetation, mud bottoms,and over debri Open water 2,000,000 egg ' <150 mm mm • 1, 2, 5, 3
I
`Water Temperatures FArnj
60-80 °F 1.5-2.1 m - -
May to mid-August
4 " � . I
' Satinfin Shiner(Cyprinella Shallow waters with typically with filamentous Demersal and 380 to 3,600
analostana) Water Temperatures algae or root aquatic plants. Eggs are deposited in crevices and bottom substrates adhesive ' eggs <40 mm NIA 1, 6
65-85 °F
I :. Family Moronidae
Adhesive •
White Perch Late Spring and Early Shallow water Eggs are deposited over sands and gravelIII 20,000 to ... 1, 5, 3
(Morone americana) Summer Average diameter: 150,000 eggs
Ili 0.75 mm
III
I
I
I
I
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' Entrainment Characterization Study Plan
Belews Creek Steam Station
Life History References
1) Rohde, F.C., R.G. Amdt, D.L. Lindquist, and J.F. Pamell. 1994. Freshwater fishes of the
Carolinas, Virginia, Maryland, & Delaware. The University of North Carolina Press.
' Chapel Hill, NC
2) Hendrickson, Dean A., and Adam E. Cohen. 2015. "Fishes of Texas Project Database
' (Version 2.0)" doi:10.17603/C3WC70. Accessed (insert date).
3) Auer, N.A. 1982. Identification of larval fishes of the Great Lakes Basin with emphasis on
the Lake Michigan drainage. Great Lakes Fishery Commission, Ann Arbor, MI 48105.
Special Pub. 82-3 744 pp.
4) Ross, S. T. 2001. The Inland Fishes of Mississippi. University Press of Mississippi,
Jackson.
' 5) Animal Diversity Web. http://animaldiversity.org/
6) Helfrich, L., Newcomb, T., Hallerman, E., and Stein, K. 2005. The Virtual Aquarium.
' Virginia Tech University, The Department of Fisheries and Wildlife Sciences.
7) Adams, J.C., and R.V. Kilambi. 1979. Maturation and fecundity of redear sunfish.
' Arkansas Acad. Scie. Proc. 33:13-16.
8) Wang, J.C.S and R.J. Kernehan. 1979. Fishes of the Delaware Estuaries. A guide to the
early life histories, Towson, MD. pp. 410. ISSN 0-931842-02-6.
1
1
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I APPENDIX B - Response to Informal Review
I Comments
While not required to be peer reviewed under the Rule, Duke Energy engaged subject matter
I experts to informally review this Entrainment Characterization Study Plan. The purpose of the
informal review was to afford the Biology Peer Reviewer the opportunity to evaluate the
entrainment study objectives and methodology, and to comment if the proposed methods do not
I meet industry standards. Duke Energy's intent was to ensure that if data were collected as
detailed in the ECSP that the data would be sufficient for the intended use in the Best
Technology Available (BTA) determination process required in §122.21(r)(10)-(12), and would
I
not be questioned at a later time.
In order to help focus the review, charge questions were developed (Table B-1). The primary
I goal was to develop a study that meets the objectives of the Rule-required Entrainment
Characterization Study.
ITable B-1. Directed Charge Questions
Question Entrainment Characterization Study Response Comments (if any)
Number Plan
IWill the proposed sampling depth(s) Yes/No
1) and location provide for a
representative sample of the water
I column? ,
Considering fish and shellfish known or Yes/N'
expected to be in the source waterbody,
I 2) will the proposed sampling period
(months) provide the ability to
understand seasonal variations in
entrainment? ..
I Is the sampling equipment proposed Yes/No
3) appropriate to collect entrainable
organisms at this type of intake
I structure?
Does the plan lay out QA/QC Yes/No
4) requirements clearly? Are these
I requirements adequate? 411
Identifying eggs and larvae to species is Yes/No
often difficult and sometime impossible.
Does the sampling plan provide
5) sufficient measures to preserve
organism integrity and support
identification to the lowest taxon
practicable?
s_
Does the study design meet the Yes/No
6) requirements of the Rule at 40 CFR
122.21(r)(9)?I
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Duke Energy 134

' Entrainment Characterization Study Plan ���
Belews Creek Steam Station
Question Entrainment Characterization Study Response Comments(if any)
Number Plan
Will the study design provide sufficient Yes/No
data to support a benefits analysis of
�) entrainment reducing technologies
required to be evaluated by the Rule
' including biological performance as
required in 40 CFR 122.21(r)(11)?
Are there any deficiencies in the study Yes/No
'
8) plan that might prevent you or others
(e.g., Regulators) from understanding
what is being proposed for sampling? If
so,what needs to be added or clarified?
After receipt of the peer reviewer's comments, the following responses were developed and the
' ECSPs were updated to reflect those changes. Comments were divided into four categories as
follows:
• Category 1: Comments that are clearly applicable (i.e., relevant under the charge and
improve the quality of the work product). These comments were incorporated into the
ECSP.
' • Category 2: Comments that represent a misunderstanding by Informal Reviewers. These
comments were not incorporated into the ECSP.
' • Category 3: Comments that are minor and do not materially change or lend additional
value to the ECSP (e.g., comments that were meant as "FYI", or meant as preferential
suggestions, or are beyond the scope of the charge). These comments may or may not
' have been incorporated into the ECSP at the discretion of the Report Originator.
• Category 4: Major Peer Reviewer comments that the Report Originators do not agree
with and choose not to incorporate into the ECSP.
' Below are the site-specific responses to comments received on the Belews Creek ECSP.
' Duke Energy 135

EntrainmentCharacterizationStudyFlan
Belews Creek Steam Station
ITable B-2. Peer Reviewer Responses to Directed Charge Questions
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� fCategory Charge No. Comment Response and Resolution
The depth distribution of the three openings on the in-water sampler is appropriate to adequately integrate any
•
1 vertical variation in distribution of eggs or larvae(but see comments regarding potential effects of orifice size on No response required
I sampling efficiency in response to question 3).
T 1 I agree that the proposed locations in the intake bays for Units 1 and 2 should be representative for CWIS. No response required
The description of the sampler pipe routing would be easier to follow if the structures mentioned(e.g., intake bay
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wall, fixed screen channel)were labeled onFigure 2 in the ECSED. It is unclear to me from the information provided
where exactly the sampling pipe orifices will be situated in relation to the walls or other physical structure of the To the extent possible the entrainment sampling pipe will be placed in an area of the intake that is well
bays. Just as water velocity in a stream can vary in different places in response to physical structures, and is always mixed and typical of hydraulic conditions within the intake.That is, away from structures that could be
1 1 slower near the bottom and sides than in the middle of the stream and water column, so it seems possible that flow causing vortices(highly turbulent areas)or in eddies or other areas of stalled flows.At some facilities
may be lower in localized areas near the sides of the intake or around any structures(e.g.,the wall or structure on we may be limited by where we can access the intake(e.g., a facility with an existing access grate on
which the sampling pipe is mounted)due to eddies,turbulence or other hydrodynamic processes. It will be important the deck would be used preferentially to cuffing through the concrete decking). In many cases, best
to ensure that the intake flow immediately adjacent to each orifice opening is representative of flow across the mouth professional judgment can be used. If velocity measurements are warranted they will be undertaken.
I of the intake in general. If this cannot be determined with confidence from first principles or historical data, a few
strategically located measurements with a current meter may suffice. AIL
The proposed sampling period and frequency are appropriate to encompass the periods when fish eggs and larvae
3 2 are likely to be present, and to provide information on seasonal patterns of entrainment(but see concerns regarding No response required
I the need for sample replication in response to question 3).
It isn't clear why life history information is provided for some species and not others. Detailed life history information 111111111.111111111r if 11111MW-
of the type provided is reasonable for the primary entrainment candidates, but at least limited, key information ought
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2 to be provided on the other species present in the reservoir. Consider providing a complete species list in table form
that gives the spawning period for each species, the kind of eggs and larvae they have(e.g., adhesive eggs, pelagic This is an excellent idea and was added to this and other ECSPs
larvae)and other key relevant information, along with the source reference(s),to provide some evidence that the
sampling period is sufficient for all of them.That would be more valuable than extensive narratives on each species
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that include information that isn't particularly relevant. Mill
I noted that life history information is provided for grass carp;are fertile grass carp present in Belews Lake(only Agreed. Information on Grass t
sterile triploid grass carp can be stocked legally in NC). If not,this information is unnecessary. .
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Pump sampling has been used in a variety of settings to sample zooplankton and fish early life history stages.
However, sampling efficiency of pump sampling is likely to be different(likely lower)than traditional net sampling
approaches.Traditional net deployment and retrieval methods may not be feasible in the intake bays, but if a
3
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judicious number of samples could be collected with another method, at a time when densities are relatively high), See Pumped Sampler White Paper(Appendix C)
that would go a long way toward addressing any concerns about if,or how much, this method underestimates actual
entrainment. If such comparisons are already available from other studies, so much the better; note them.Another
approach that might allow a useful comparison would be to collect samples using a Schindler-Patalas trap. However,
' this gear samples a very small volume of water, so even at peak densities it may not be feasible.
Orifices were sized to achieve equivalent flow rates through each port while minimizing friction losses
to reduce the amount of suction lift required. Calculations were performed for each facility to account
Orifices will vary in size to allow equal flow from each depth. It is important that flow(and therefore contribution to for differing standpipe and piping dimensions; as well as reservoir, intake deck, and inlet port
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the total sample volume)be equal through all three openings, but orifice size and flow velocity at the orifice opening elevations. Calculations were based on friction losses(converging flow, piping material and length,
3 are both likely to affect sampling efficiency. If each orifice samples the same amount of water, but samples orifice size)and elevations to determine total head and pump flow. Details will be provided in the final
organisms with different efficiencies,then the combined sample of entrained organisms will not reflect equal report.
I contributions from all three depths.
Volumes sampled and orifice intake velocities are both important considerations and will factor into the
design of the sampling pipe.
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Entrainment Characterization Study Plan
Belews Creek Steam Station
I
Category Charge No. Comment Response and Resolution
I
Sizing of the sampling pipe orifices will be described in greater detail in the final reports.
It would be difficult to simulate the flow field conditions from a power plant in a laboratory setting.
Presumably one would want to test at the approach velocities similar to levels in the field.This would
I
What sizes will the orifices be, and what will the flow velocity be at the opening? Both could affect capture require a test flume with flow control to achieve the desired test velocities. Since one would be
efficiency, given escape behaviors and rheotaxis exhibited by larval fish. If the differences are fairly small it may not removing organisms and water while sampling,one would have to develop a method to replace the
4 3 matter. But some assurance is needed that the setup will sample the organisms equally, not just the water. If removed organisms and water. If you use a recirculating flume, so only the volume of water removed
necessary, test runs could be done in the lab, sampling larvae of a known density out of a tank. would need to be replaced,then that replacement water would have to seeded with organisms of a
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known number.The test pump would be removing 240 gallons per minute,so your total capacity in
your flume would likely need to be at least 5x this volume, if not much higher(otherwise the pump
sampler would be inducing flows not the circulating pump on the flume). If you want to test different
species, life stages and/or organism sizes,then several tests would be required.What at first glace
Iappears to be a simple test, is actually quite complicated.
If a 330-pm mesh net works without clogging,that would be ideal; but if problems occur then use of a—500 pm mesh
3 3 net would be acceptable for egg and larval fish collections.That mesh size is often used in larval fish collections,and No response required
I
the prior study at Hyco in 1979-80 used 571 pm mesh net(note that replicate samples were collected in that project).
The proposal notes that"properly designed and operated pumped-systems have shown collection efficiencies of 95 Systems using trash pumps with recessed impellers routinely collect greater than 95 percent of fish
percent orgreater for fish eggs and larvae with little or no organism damageEPRI 2005)." However,, it wasn't clear eggs and larvae. Unfortunately neither EPRI 2005 or EPRI 2014 can provide much greater detail. Both
3 gg ( state, "Studies of properly designed and operated pumped systems have revealed little damage or
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how this was measured and if it directly applies to this situation(I believe Dr. Coutant also indicated that an updated destruction of entrained organisms with collection of greater than 95 percent of fish eggs and larvae
version of this EPRI document is available). It would be helpful if you could elaborate a bit. being routinely achieved."
I Emil
3 I agree that collection at the intake structure is preferable to sampling organisms after passage through the cooling.ti„�osponse required
system ,
3 I don't think it's a problem if low intake velocities(for the CWIS)allow some animals to escape due to avoidance_AIL Agreed.
behavior, as that would happen anyway.
IThe lab and field SOP and audit plans are generally sound. However, an Average Outgoing Quality Limit(AOQL)of
4
1%(?99%accuracy)strikes me as rather liberal for data entry. It seems to me that an error rate of one error per Typically the average outgoing quality(AOQ)is better than the AOQL. Both this and the AOQL for
100 entries is too high. How does it compare to the observed error rate on similar work(I expect actual accuracy is larval identification are industry standard for entrainment sampling.
I typically better than that)? If it is feasible to commit to a lower error rate that would be preferred.
The sampling plans implemented under our proposed QC procedures have a specified average
Likewise, an AOQL of 10 percent for organism identification seems pretty high to me(I expect the error rate will be outgoing quality limit(AOQL)of 10 percent,which represents the maximum fraction of all items(e.g.,
lower than that for experienced personnel). I recognize that identifying fish eggs and larvae is tricky, so I fully expect measurements, taxonomic identifications or counts)that could be defective as a worst case.A
3 4 some individuals to end up in broader categories(e.g., unidentified shad or unidentified larvae)—I don't consider defective item could be a measurement or count that falls outside of a specified tolerance limit(e.g.,
that an identification error. But I would expect organisms identifiable to a given taxonomic level to be correctly plus or minus 1 to 10 percent).Typically the average outgoing quality(AOQ)is better than the AOQL.
classified more than 90%of the time.Again,what is the observed error rate on similar analyses? Maybe my Items are inspected using a QC procedure derived from MIL-STD (military-standard) 12358(single and
' it expectations are too high. multiple level continuous sampling procedures and tables for inspection by attributes)to the 10 percent
AOQL. Both this and the AOQL for data entry are industry standard for entrainment sampling.
. The111E
The data security and chain-of-custody plan is good, but one can never be too careful. Data remain vulnerable to
I
loss during the period when they exist only on one hardcopy datasheet, particularly while still in the field. You might, This is a good idea.We added words that a digital image of the datasheet will be taken in the field prior
consider taking a picture of each datasheet when completed,to have an electronic backup until the datasheet can to the datasheets leaving the site.
be scanned or entered into a computer. "
1 4 Given that regulatory compliance is sometimes the subject of litigation, I think that retaining samples for only three ECSP revised to indicate samples will be held until Duke Energy authorizes their disposal.
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years is not sufficient. My sense is that something on the order of seven years would be a better safeguard.
Adequate information is provided to document that the specific pump(s)to be used are of the type that will not cause
3 5 No response required.
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organism damage as noted in EPRI (2005).
3 5 Proposed preservation methods will fix organisms in a manner that will maintain their morphological integrity for No response required.
identification purposes.

entrainmentunaractenzation tuayrian
Belews Creek Steam Station
Category Charge No. Comment Response and Resolution
' The proposal indicates that"To the extent practicable, long-dead, moribund,and/or non-viable eggs will be identified
using appropriate and well-defined techniques developed in the SOP and categorized in the database accordingly. 11111111.0.111111111.1111111, MOW
iill
When estimates of entrainment are generated, moribund, dead,and non-viable individuals will not be included." The t
Agreed.We will want to look at the data inclusive and exclusive of our two categories and both will be
discrimination of dead, moribund or non-viable eggs from live eggs is a critical step because it directly affects
' entrainment estimates. Differences between live and dead individuals are often fairly obvious in fresh samples, but preserved for future inspection.At present there are few reliable methods that are not time
can be markedly reduced after preservation. Because any error in this process will bias entrainment estimates consumptive or expensive to implement. Here we are thinking of excluding only the most obvious
downward I expect this step would receive heightened scrutiny. Therefore the methodology should be fully categories of organism. For example,we might require eggs be whole, show signs of fertilization, and
explained, and be pretty Even if it is, I certainlyrecommend retainingboth groups of eggs in separate vials, not be covered with fungus. s
P iron-clad. 9 P 99 P
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111 . and be prepared to provide entrainment estimates based on both groups combined as a conservative measure of
entrainment if necessary. r
The final Rule does not require replication nor is there an obligation to provide confidence intervals or
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bounds around the entrainment estimates generated.The study must be sufficient to show diel,
monthly,and annual variation,which this study plan addresses.
The Rule requires"sufficient data to characterize annual, seasonal,and diel variations in entrainment, including but We interpret the Rule as requiring sufficient sampling to collect data over the range of conditions that
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not limited to variations related to climate and weather differences, spawning,feeding,and water column migration." are likely to occur and to prevent bias through selective sampling. For example,you could not propose
The ro osed sam lin Ian calls for collectin a sin le, lar a sam le in each sam lin eriod. I believe that this to sample only during the day, because you would miss any density differences due to diel variability.
P P P 9 P 9 9 9 P P 9 P You could not propose to sample only on sunny days, because you would miss any density differences
collection plan will provide data representative of the entrainment at the intakes, but determining if apparent patterns due to weather.You could not propose to sample only from near the bottom of the intake, because you
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4 6
or differences are real(as the requirements seem to call for)requires some measure of variability in the estimates. would miss any density differences due to vertical stratification in the water column.
That requires replicates.The number of samples collected over the course of the project will be sufficient to detect
annual variation between the two years, but seasonal, diel and weather effects would be confounded with each We believe that the way in which these data will be used do not justify extensive replication.
other.Additional replication is necessary in order to determine if any of these factors affect entrainment. For Relationships between weather, climate, spawning,and feeding(as a few examples)and entrainment
example, one could not separate weather effects from temporal differences in this sampling design. If it is necessary rates are not going to change the determination of best technology available for entrainment reduction
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to be able toe. show whether r not there are effects of weather,enough samples will be needed to use weather rora the outcome of any social cost/social benefit calculations. In addition, the study plan includes some
variables(e.g.,water temperature, cloud cover)as covariates to test for effects. replication. Each sampling event is divided into four independent samples based on time of collection.
In addition sampling events occur twice in each month. If necessary, confidence intervals can be
generated based on these 8 samples within a month. Determination of whether confidence intervals
are beneficial can be made at the end of the program.
That said, I think this issue could be addressed with a modicum of additional effort.The simplest approach would be We disagree that splitting each 2-hour sample into smaller sub samples requires only a small
I isms
to divide each 2-hour sample into at least three, preferably four, samples collected immediately one after the other. additional effort.While it is true that the extra effort in the field would be minimal(extra net wash-
The collection cup(or entire net)could be swapped out after a sample and processed while the next sample is being downs, extra datasheets to fill out), the effort(and associated labor costs)in the laboratory would
collected.This replication would allow straightforward statistical analysis to determine if these factors(or their increase proportionally. So splitting the 2-hour samples into four sub samples will quadruple the lab
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interaction)affects entrainment.The individual samples could still be combined into one composite sample if . �..... .
warranted, but the inverse isn't true. costs
Replication is important for density estimates, but it would not be necessary to have morphometric measurements on MOW lir illir 111111, •
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6 a full compliment of individuals from each replicate;one pooled sample for each six-hour period would suffice.A total Morphological measurements will be collected from up to 10 eggs and larvae per species and life stage
of up to 10 individuals of each taxon could be drawn at random from all the individuals collected in all replicates from each 6-hour diel sample.
Ear
combined within one six-hour sampling period.
Any vertical migration should be adequately integrated by the multi-depth sampling scheme, and the temporal We agree. Our interpretation of EPA's request is that sampling encompasses the range of conditions
pattern of sampling should detect the seasonality of spawning. It is unclear to me what"feeding variation" refers to or and fish behaviors likely to occur in a typical entrainment season.That is, if feeding behavior impacts
how sampling will assess it, but it is also unclear to me how that is relevant for this assessment. If this refers to vertical migrations in the water column,then you would need to sample during periods that include
changes in feeding behavior over the diel period or seasonally that would increase or decrease vulnerability to those in which larvae are feeding.
Ientrainment, then I believe such effects would be adequately captured by the proposed sampling scheme.
3 With minor modifications as noted in responses to other questions,this study design should provide a sound basis to •
No response required.
support the required benefits analysis.
8 In general the proposal is clearly written and understandable,with only minor exceptions. Some points to be added No response required. 4
or elaborated upon,or deficiencies in the design, have been noted above. - . ..:o
The Dan River Make-up Pumping Station is described in the proposal, but why it is included is unclear.This pumping
' station meets the criterion in§316(b)Rule for existing facilities of 2 MGD in its design flow rate and in its actual The information on the pumping station was included for completeness such that the reader would
3 8 average daily water withdrawals in some years, but it is well short of the 125 MGD threshold requiring an have a fuller understanding of how this facility operates and its connection to the watershed.
entrainment characterization study and no entrainment study is described for it.Thus, its inclusion is rather
confusing and would benefit from clarification.
1

EntrainmentUriaractenzatlonJuicyrian
Belews Creek Steam Station
1
Category Charge No. Comment Response and Resolution
8 There are some errant,potentially confusing labels for Sutton[This was identified at Sutton in a Belews Crept We have tried to improve the figure,but we are unsure if theewer intended this comment to apply
1 Comment Received from the Informal Reviewer]facilities on page 6,just before figure 2.1. to Belews Creek or whether it is a hold over from Sutton.
1 8 A table number isn't complete on p. 18, line 24 of the Belews Creek ECSP document(Table 6.2 I think). This was corrected.
1 1 8 In Table 6.2,second row,either indicate 64 sampling events,or 32 sample events per year. This was corrected.
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1 BelewSteam
s Creek Station Entrainment Characterization
Study Plan
APPENDIX C - Comparison of Pumps and Nets for
' Sampling Ichthyoplankton
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Duke Energy 140

Entrainment
tion
1 Belews Creek Steam Station Study Plan
1 Comparison of Pumps and Nets for Sampling Ichthyoplankton
1 Prepared by:
440 S. Church Street, Suite 900
1 Charlotte, NC 28202-2075
February 19, 2016
1 Introduction
As a part of Duke Energy compliance projects associated with the 2014 Clean Water Act
§316(b) rule for existing facilities (Final Rule), the company submitted draft Entrainment
1 Characterization Study Plans (ECSPs) to informal review by subject matter experts. In the
comments received on the draft ECSPs and during discussions at a peer review kick off
meeting°, there was a concern among the biological reviewers that the proposed pumped
1 ichthyoplankton sampling method could impart a systematic bias compared to nets for
estimating power plant entrainment. In particular, there was a concern that pumped samples
could underestimate entrainment and that additional gear efficiency testing could potentially be
1 undertaken periodically throughout the entrainment sampling period to determine if a bias exists
and quantify the magnitude of difference if it exists. As a preliminary step, HDR conducted a
literature review. The sections that follow provide background, the methods and results for the
literature review, and conclusions.
Background
Two primary methods have been historically used to estimate ichthyoplankton entrainment at
power plant intakes: streamed/towed nets and pumped samplers. Traditional ichthyoplankton
1 nets can be used to filter water as it enters the intake or exits the discharge and collect
organisms. Alternatively, pumps can be used to convey water to a fine-mesh net onshore.
Onshore nets are typically suspended in a buffering tank to minimize damage and extrusion of
1 eggs and larvae.
Each method has advantages and disadvantages and a comparison of the two methods are
1 summarized in Table C-1. The primary advantages of utilizing pumps include ability to meter
precise sample volumes, longer sample collection times, reduction in the potential to miss
samples due to inclement weather or other events, and increased ability for technicians to safely
1 observe net filtering and other aspects of the data collection. Their versatility includes being
utilized in fresh, estuarine, and marine water environments. Properly designed and operated
systems can be accurate and effective. While no sampling method is perfect, pumped samplers
Held at HDR offices in Charlotte,NC,January 28-29,2016.
1
1 Duke Energy 141

' Entrainment Characterization Study Plan
Belews Creek Steam Station
were determined to offer the best, most cost-effective, and consistent sampling method for Duke
Energy and therefore were included in the draft ECSPs.
1 Pumped samplers have been used in sampling plankton as far back as 1887 (Gibbons and
Fraser 1937; Aron 1958; both as cited in Taggart and Leggett 1984) and have a long history of
successful application for collecting ichthyoplankton samples at power plants (Bowles and
Merriner 1978; as cited in EPRI 2014). Pumped samplers are among the preferred gear types
accepted by EPA and have been used extensively to successfully monitor entrainment at power
plant intakes for decades.
At present, HDR is aware of on-going or state approved plans for pumped entrainment sampling
' at power plants to support the Final Rule in at least seven states: Florida, Wisconsin, New
Yorks, Pennsylvania, New Hampshire6, Massachusetts, and Virginia. If this list of states is
expanded to include sampling under the remanded Phase II Rule, then the list of states would
be expanded to include Connecticut, Louisiana, Texas, Ohio, Michigan, New Jersey, and
Maryland. In addition, there may be other states that HDR is unaware of, that have also
approved this approach. Still other States could be added to the list as more power generating
companies begin entrainment studies over the next few years under the Final §316(b) Rule.
Table C-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for
Estimating Ichthyoplankton Density in Cooling Water Intake Structures (some
I information adapted from EPRI 2014)
Gear Type Advantages Disadvantages
Hoop Nets - Large volumes are sampled quickly(less - Can be difficult to deploy and retrieve in the
Deployed in the manpower required for the same number of confined space of intake structures—
Intake pumped samples). precludes the use of some net types(e.g.,
- If net frames are not used,then there is standard bongo, neuston nets, or Tucker
trawls).
limited to no modifications to the intake
required for deployment. -Depending on deployment method, may
No potential for mechanical damage require modifications to intake structures
- (e.g.,frame mounted nets in frame guides).
associated with pump passage.
- Less precise flow metering than pumped
samplers.
-Large volumes are sampled quickly-
I capturing less temporal variability in a single
sample as compared to pumped samples.
- Relatively small nets needed to fit in the
' intake structure offer a small spatial sample.
Multiple nets can be used to increase
sampled area at the cost of additional
samples to be processed in the laboratory.
I
5 New York State applies a more stringent standard than the Final Rule under the New York State Department of Environmental
Conservation Policy CP-52 for Best Technology Available(BTA)for Cooling Water Intake Structures.
6 The states of New Hampshire and Massachusetts do not have delegated authority to issue NPDES permits and are administered
by EPA Region 1.
111
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I Entrainment Characterization Study Plan ���
Belews Creek Steam Station
IGear Type Advantages Disadvantages
- Tow speeds in the range of 1-2 meters per
I second(commonly used during
ichthyoplankton sampling)is above the
intake velocities at the majority of intakes.
- Some active avoidance possible by larger
I motile life stage(e.g., late larvae and early
juvenile). Larger hoops can be used to
decrease potential for avoidance, but would
require a larger deployment area, since
I length is proportional to opening diameter in
properly sized nets'.
- Greater potential for extrusion than pumped
samples(no buffering tank).
Boat deployed nets are subject to weather
delays and associated safety concerns.
I - May be restricted to relatively deep areas that
are free of floating debris,submerged
snags, and other obstructions
I Pumped
Samplers in the -Sample durations are typically longer Some active avoidance possible by larger
increasing the potential to capture temporal motile life stages(e.g., late larvae and early
Intake variability in ichthyoplankton densities not juvenile).
observed in net samples.
I - Improperly designed samplers can lead to
Limited modifications to intake or discharge damage to organisms during sampling.
structures are required to install—usually
just anchoring points for the sample pipe. -
Samples a smaller portion of the spatial
variability, because pump inlets are
I - In-line flow metering offers greater precision generally smaller than net openings.
in measuring the volumes of flow sampled.
-Some potential for mechanical damage.
I However, correctly designed systems can
offer<5%damage or destruction of eggs
and larvae.
I - Fixed pipe allows precise control over water
depth and orientation to intake flows.
-Less potential for extrusion than nets,
because the filtering net sits in a buffering
I tank.
- Lower potential for missed samples due to
severe weather.
l -Allows technicians to observe sample
collections and minimize potential for invalid
samples(e.g., use of 330-urn nets
I increases potential for net occlusion and
frequent net change outs may be required
during certain times of the year).
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'A general rule of thumb, as described in EPRI 2014, states that the total effective open area of the netting(percent open area x
area of netting)should be at least twice the area of the net mouth opening. Others have suggested a net length to mouth opening
diameter ratio of three or more.
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iDuke Energy 143

Entrainment Characterization
Belews Creek Steam Station Sludy Plan -)/
Literature Review
Methods
HDR conducted a literature review to assemble and assess the available data on the
' comparative effectiveness of pumped entrainment samplers and nets to estimate power plant
entrainment. Available data were identified via online electronic searches for published articles
and government and industry reports. The electronic literature search used Google, Google
Scholar, and the ProQuest Aquatic Science Collection database accessed through the
University of Massachusetts, Amherst. In addition, we consulted the EPRI technical support
document on entrainment abundance monitoring (EPRI 2014)to identify relevant literature. The
' literature search revealed a short list of relevant citations and abstracts. Several of these were
available in HDR's corporate library and some were obtained from the publishers. For some of
the industry gray literature and less common symposium papers, we relied on abstracts or
1 summaries presented in other documents (primarily EPRI 2014).
Below is an annotated bibliography of several of the key references that were reviewed. To the
' extent practical, these studies were critiqued and the results and findings put in the context of
the goals of entrainment monitoring at the Duke Energy facilities.
' Annotated Bibliography
Cada, G.F. and J.M. Loar. 1982. Relative Effectiveness of Two Ichthyoplankton Sampling
' Techniques. Canadian Journal of Fisheries and Aquatic Sciences 39(6): 811-814.
Cada and Loar (1992) collected triplicate pump and towed-net samples during both day and
' night near the water's surface to detect differences in the effectiveness of a pumped sampler
and towed nets for collecting ichthyoplankton. The effectiveness of 1.1 m3/min (290 gallons per
minute [gpm]) pumps was compared to a 2 m long (6.6 feet), 0.5-m (1.6-feet) diameter, 243-pm
' mesh conical plankton net in the headwaters of Watts Bar Reservoir in eastern Tennessee. The
net was towed for 5 minutes at velocities between 120 and 189 cm/s (4 to 6 feet per second),
which resulted in sample volumes of 85 to 100 m3. The pump system used a 7.6-cm (3-inch)
diameter intake hose that had a cylindrical trash screen with 6.4-cm2 (1-inch) openings. This
hose inlet was placed 0.25 m (10 inches) below the surface and slowly moved through the
water.
Both gear collected clupeid larvae (Threadfin Shad and Gizzard Shad) between 4 and 17 mm
(0.16 to 0.67 inches) although larvae greater than 10 mm (0.4 inches) long were collected in
' relatively low numbers. Clupeid larvae 4-10 mm (0.16 to 0.4 inches) long were collected in
sufficient numbers to make meaningful statistical comparisons based on date, station, diel
I period (day vs. night), and fish length. Due to the difficulty in differentiating small Dorosoma spp.
both species were combined for the analysis. The differences in the mean densities of most
length groups between nighttime pump and tow samples were not statistically significant.
°By comparison,the pumps proposed for use for entrainment sampling at Duke Energy facilities have a target capacity of 240 gpm
with a range from 5 to 380 gpm depending upon head.
1
Duke Energy I 44

Entrainment Characterization Study Plan ��J
Belews Creek Steam Station
However, the pump collected significantly more 4-mm larvae and the towed net collected more
5- to 10-mm larvae during the day. Cada and Loar (1992) concluded that based on sampler
intake velocities and the potential for avoidance, it would generally be expected that pumps are
more effective than fixed nets, that towed nets are more effective than low volume pumps, and
that high volume pumps are equally or more effective than towed nets in collecting
ichthyoplankton. The lack of differences between densities of ichthyoplankton at night suggests
that gear avoidance is associated with a visual escape response and not a tactile response to
changes in hydraulic conditions. The authors caution that any gear comparisons should account
for sizes of sampled organisms and how that could impact performance and that care should be
used when using pumped samplers, because pumps may not adequately sample all entrainable
organisms.
These results should be used with caution and may not be representative of what would be
observed with a fixed entrainment sampler at a cooling water intake. First, Cada and Loar
(1992) moved the pump inlet though the water which could alter the flow fields relative to what
would be observed around a static system. Second, the distance from the boat that these two
systems were deployed is unknown. Theoretically, boat-induced hydraulics, noise, and/or
shadow could have induced differential behavioral responses between the two gear types if
deployment distances were different. Third, the inlet to the pump had a trash screen with 1-inch
openings. The authors did not describe the size of the trash screen. This screen and its wake
could have acted as visual avoidance stimuli.
Elder, J.A., J.W. Icanberry, D.J. Smith, D.G. Henriet, and C.E. Steitz. 1979. Assessment of
a Large Capacity Fish Pump for Sampling Ichthyoplankton for Power-plant Entrainment
Studies. California Cooperative Oceanic Fisheries Investigation 20: 143-145
A centrifugal, single-port bucket-style pump that delivered 3.0 m3/min (793 gpm) at a 3-m (10-
feet) head and in excess of 4.3 m3/min (1,136 gpm) at lower heads was evaluated for sampling
entrainment. These pumps were originally designed for hatchery and aquaculture use and were
reported by the manufacturer to lift 30-cm (12-inch) trout 3 m (10 feet) above water surface with
99.5 percent survival. The pump discharged into a 505-pm mesh net with a cod-end bucket
suspended in a 2 m3 (528 gallon) box. The inlet to the pump was a 15.2-cm (6-inch) diameter
pipe. The exit pipe was larger (25.4-cm [10-inch] diameter) to reduce velocity entering the net.
' This pump sampler was compared to the sampling efficiency of a 1.0-m [3.3-feet] 505-pm nylon
mesh net towed across the mouth of the intakes near where the pump was operating. During 20
paired samples, there were no statistical differences in larval fish densities captured by the net
' and the pump. There were statistically higher densities of opossum shrimp (Neomysis spp.)
collected by the pump than by the nets. Damage to pumped specimens was limited. Specimens
collected by pump remained highly identifiable and were in the same physical condition as net-
captured specimens. Given that the pumps evaluated by Elder et al. (1979) had a much higher
capacity than those proposed for use at the Duke Energy facilities, it is difficult to make a direct
comparison, but the results indicate that a pumped sampler could be as efficient as nets for
sampling entrainment.
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Gale, W. R, and H.W. Mohr, Jr. 1978. Larval Fish Drift in a Large River with a Comparison
of Sampling Methods. Transactions of the American Fisheries Society 107:46-55.
While this study was primarily designed to test the drift of larvae in the Susquehanna River
(1974-1975), use of a pumped sampler and nets simultaneously allows for a comparison of the
two gear types. Samples were collected from April 10 to October 10, 1974 with boat mounted
nets. The nets were made of nylon and had 0.4 x 0.8-mm mesh and 24 x 54-cm (9.4 x 21.3-
inch) rectangular mouths. Simultaneous samples were collected at near each shore and the
main channel (about 80 m [262 feet] from the west shore) at set intervals (0800-1000 h and
2300-0100 h). Five-minute fixed net samples were collected from a stationary boat and push-net
samples were collected propelling the boat slowly downstream for abut 300 m (984 feet). From
March through August 1974 a high capacity trash pump, raised and lowered by a hand winch,
was used to collect samples. Replicate pump samples were collected about 50 cm from the
surface and 10-20 cm (4-8 inches)from the bottom at 3-hour intervals for a 24-hour period near
the middle of the river. Flow rate was about 2,500 liters per minute (660 gpm). Based on surface
samples only,9 the pumped and fixed net samples collected about the same number of larvae
per 10 m3 and no statistical differences were detected.
Harris, R.P. L. Fortier, and R.K. Young. 1986. A Large-Volume Pump System for Studies
of the Vertical Distribution of Fish Larvae Under Open Sea Conditions. Journal of the
1 Marine Biological Association of the United Kingdom 66(4): 845-854.
' Harris et al. (1986) evaluated a pumped sampler for application in an open ocean setting. The
pump was 2.8 m3/min (740 gpm) submersible, centrifugal pump designed for pumping waste
water. Comparative efficiency trials by day and night showed that the pump was generally as
efficient, or in some cases more efficient, in capturing larvae than towed 200-pm WP2 nets10,
although there was some evidence of visual avoidance by particular larval size classes during
daylight. The authors indicated that fine-scale temporal and spatial resolution is necessary to
study the distribution of larval fish and that large-volume pumps, sampling at rates in excess of
1 m3/min (264 gpm) can be used as an alternative to conventional nets. The design and
application of the pump sampler used by Harris et al. (1986) is substantially different (e.g., 15-
cm [6-inch] intake line; boat-mounted and sampled while in motion; and marine open-water
ecosystem) than what is being proposed for use at the Duke Energy facilities. For this reason,
the results have limited direct applicability to the Duke Energy fleet.
1
°Sampler efficiency was only presented for surface sampler in Gale and Mohr 1978.
10 The WP2 Net is a vertical plankton net with messenger operated dosing mechanism based on the design of the UNESCO
Working Party 2.
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King, L. R., B. A. Smith, R. L. Kellogg and E. S. Perry. 1981. Comparison of
Ichthyoplankton Collected with a Pump and Stationary Plankton Nets in a Power Plant
Discharge Canal. Fifth National Workshop on Entrainment and Impingement. San
Francisco, CA, May 1980. Loren D. Jensen, Ed.
King et al. (1981) compared the performance of pumped samples and nets in the discharge
canal at Indian Point Generating Station on the Hudson River. Simultaneous ichthyoplankton
sampling was completed using a 15-cm (6-inch) pump/larval table system and stationary 0.5-m
(1.6-feet) diameter conical plankton nets. A total of 79 paired samples were collected on 6 days
in June and July 1978. The average density of total ichthyoplankton collected was 3.0/m3 for
pump samples and 3.3/m3 for net samples. No significant differences (P > 0.05) were detected
between density estimates for total ichthyoplankton determined from pump and net samples for
eggs, yolk-sac larvae, post yolk-sac larvae, and juveniles. Thirteen out of 14 taxa compared
showed no significant difference between pump and net collections. The pump and net
collection systems were equally effective for estimating densities of most ichthyoplankton.
Petering, R W; Van Den Avyle, MJ. 1988. Relative Efficiency of a Pump for Sampling
Larval Gizzard and Threadfin Shad. Transactions of the American Fisheries Society 117:
78-83.
Efficiency of a pump sampler and a plankton net were compared based on monthly nighttime
collections on Lake Oconee, Georgia" from April through August 1982. The two samplers were
used on the same night or on two consecutive nights. The gasoline-powered pump had a 1.18
m3/sec (312 gpm) capacity. Pumped samples were discharged into a 297-pm mesh net
suspend over the side of a boat. A cylindrical metal sieve with 8 mm (5/16 inch) holes was
attached to the inlet of the pump to exclude large debris. Three, 10-minute samples were
collected by slowly raising and lowering the intake hose in the upper 2-m (6.6 feet) of the water
column. Sample volumes were assumed to be 11.8 m3 (3,117 gpm) based on manufacturer's
pumping specifications. Triplicate samples (75 m3) were collected with a towed net that was
0.25-m2 (2.7 feet2) with 0.5-m (5.4 foot) square opening that was towed at 1.0 m/s (3.3 feet per
second) for 5 minutes. Net samples contained seven fish taxa whereas only two were collected
' by pumps; however, Gizzard Shad and Threadfin Shad accounted for more than 97 percent of
the specimens caught in both samplers. The authors conclude that the pumped sampler
collected fewer taxa and that the estimates of shad density were lower and less precise than net
samples.
There are serious concerns with this study design that call into question the authors' findings.
First, when calculating organism density, the authors used pump flow rates as defined by the
manufacturer's specifications rather than metering the flow. The authors evaluated the pump in
the laboratory and determined that the intake rates were typically within 10 percent of advertised
values, but no methods or results for the laboratory evaluation are provided to allow a critique.
This lack of metering casts doubt on the accuracy of the entrainment estimates. Second, similar
"A 7,709-hectare pumped storage reservoir in central Georgia.Not to be confused with Duke Energys Oconee Nuclear Station on
Lake Keowee in South Carolina.
1
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Entrainment Characterization
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to Cada and Loar(1982), the inlet to the pumped sampler was screened and moved through the
water. The screening could alter the localized hydraulics (e.g., increase in velocity entering the
screening), which may be perceived and avoided by later larvae and early juveniles with
sufficient swimming capacity. Moving the inlet through the water could also induce hydraulic
changes perceptible to fish. It is also unknown if, or to what extent, entrainment rates with the
pumped sampler could have been affected by its proximity to a moving boat. Finally, samples
were not necessarily collected on the same night with both gear types. Daily variability in
ichthyoplankton density was likely an unaccounted for confounding factor.
Leithiser, R.M., K.F. Ehrlich, and A.B. Thum. 1979. Comparison of a High Volume Pump
and Conventional Plankton Nets for Collecting Fish Larvae Entrained in Power Plant
1 Cooling Systems. Journal of the Fisheries Research Board of Canada, 1979, 36(1): 81-84
Leithiser et at (1979) compared a high volume pump to conventional ichthyoplankton nets for
entrainment monitoring. The pumping system had a capacity of about 2.5 m3/sec (660 gpm). No
information was given about the size of the piping on the suction end of the pump. The nets
used by Leithiser et al. (1979)were 0.5-m (363-pm) and 1.0-m (335-pm mesh) conical plankton
nets.
The average density of large larvae (> 5 mm Total Length [TL])was significantly greater with the
pumped sampler than what was observed with the 1-m plankton nets. Compared to the pump,
both sizes of plankton nets (0.5 and 1.0 m diameter) in each test greatly under sampled larvae
' over 5.0 mm TL. The data suggest that the pump and plankton nets sampled the small larvae
equally well, but that the larger larvae were better able to avoid the plankton net than the pump
inlet. Leithiser et al. (1979) collected samples in the power plant intake canal at different
I approach velocities. While it was expected that larval avoidance would decrease with increasing
channel velocity, this was not observed with either the pumped or net samples, but the number
of channel velocities tested were limited.
The authors concluded that the high volume pump was a more effective larval fish sampler than
the conventional plankton nets. It is important to note that on the California coast where these
studies were undertaken, there are greater densities of small larvae (< 5 mm TL)than would be
expected in southeastern Piedmont reservoirs, which would make the differences between
these two gear types more dramatic at the Duke Energy facilities. It is unclear how these results
can be transferred directly to what is being proposed at the Duke Energy facilities because of
the higher flow rate used in this study(660 gpm vs. 240 gpm).
Duke Energy I 48

1 BSteam
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Leonard, T.J. and G.E. Vaughn. 1985. A Comparison of Four Gear Types to Measure
Entrainment of Larval Fish. Proceedings of the Annual Conference of the Southeast
Association of Fish and Wildlife Agencies 39: 288-297.
A study was undertaken at the McGuire Nuclear Station (MNS) on Lake Norman, North
Carolina. The purpose of this program was to determine the relative efficiency, reliability, and
cost of four different systems for measuring larval fish entrainment into the cooling water
system: 1) a tap valve in the condenser, 2) a pump-net system, 3) a fine-mesh screen; and 4) a
stationary net. Night samples were collected on five consecutive nights 6-10 June 1982, which
was anticipated to coincide with the peak abundance of Threadfin Shad and Gizzard Shad.
The stationary net was a single 0.5-m conical net (2.5-m [8-feet] long, 800-pm mesh) was
suspended from a barge located 7 m [23 feet] upstream of the intake. A flow meter was placed
in the mouth of the net to monitor the volume of water sampled. The net was fished by quickly
lowering the net to the bottom of the intake structure and raising it in 1-m intervals over the 9.5-
m high effective opening to the intake. Rapidly lowering and raising of the net caused the net to
I collapse, preventing the flow meter from recording flow during the decent and retrieval. On the
first night the net was raised at 1-m (3-feet) increments at 2-minute intervals, but this resulted in
less than desirable volumes sampled and on subsequent nights the net was raised at 1-m (3-
feet) increments at 3-minute intervals for the remainder of the study, resulting in an average
sampling duration of 27 minutes.
' The fine-mesh screen was a 9-cm (3.5-inch) deep rectangular wooden frame that had a 50.8 x
57.5-cm (20 x 22.6-inch) mouth opening covered on one side with 800-pm mesh. This panel
was attached to a traveling screen in the intake bay being sampled. The traveling screen was
rotated manually to position the fine-mesh panel into the flow. The screen was rotated so that
the fine-mesh panel was raised in approximate 1-m (3-feet) increments at 4 minute intervals,
resulting in an average duration of 38 minutes. Once at the water surface, the screen was
rotated without stopping to retrieve the sample.
The pumped sample was collected using a 10.1-cm (4-inch) diameter centrifugal pump
' (2,270 Umin [600 gpm] pumping capacity at 0.6 m head). Water was withdrawn through a 10.1-
cm (4-inch) diameter flex hose and discharged via a 10.1-cm (4-inch) PVC pipe into a plankton
net. An ultrasonic flow meter was used to measure flow through the discharge pipe. The hose
was lowered as close to the bar racks as possible and raised at 1-m (3-feet) increments at 3-
minute intervals starting at just above the bottom of the intake opening. Water from the pump
was discharged just below the water surface into a 2.4-m (8-feet) long, 794-pm mesh
suspended from the side of the barge.
Water was sampled through a 7.6-cm (3-inch) gate valve on the condenser and discharged into
an 800-pm mesh plankton net suspended in a 208-L (55-gallon) drum. Two consecutive
samples averaging 192 minutes each were collected on each night. Though longer duration
than the other sampling techniques, the volumes of water sampled were similar.
All four gear types were compared to Tucker trawls taken from the intake embayment and used
to estimate density and length frequency distributions of larvae potentially susceptible to
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entrainment. The Tucker trawl had 710-pm mesh with a 1 m2 (10.8 feet2) effective opening.
Samples were collected perpendicular to the intake (starting as near as possible to the intake).
1 Samples were collected at two depths —surface to the top of the intake structure opening (about
4.6 m [15 feet]) and from the intake opening to the bottom of the intake structure (4.6 m [15 feet]
to 14 m [50 feet]). Each stratum was towed obliquely. Trawl durations were 2 to 5.5 minutes and
collected every two hours starting at about 30 minutes after sunset and extending until sampling
with all the other gear types was completed. Two or three sets of tows were made on each
night.
' Results were variable by gear type (Table C-2). Few shad were collected by pumped sampler
on 6 and 7 June due to a ripped seam in the net. Trawl samples from the upper stratum were
I greater in number than the lower stratum. While not identified by the authors, it should be noted
that it is difficult to measure the flow sampled with the fine-mesh screen approach. Differential
open area between the fine-mesh overlay and the surrounding coarse-mesh panels would likely
have resulted in flow diverting to the coarse-mesh panels or gaps between panels, side seals,
and the screen boot preventing accurate measurement of volumes sampled. In most cases, the
samples collected at the condenser tap were higher than what was observed in the lower trawls.
There were no significant differences in ichthyoplankton density by date (P = 0.83), but there
were differences by gear type. Mean densities of the pumped samples were not significantly
different from the tap samples (P= 0.60). Stationary nets and fine-mesh screen collections were
significantly different from one another and from the pumped and tap collected samples (P <
0.05). Length frequencies between the pump and tap samples were not significantly different
from one another. Mechanical damage from collection was minimal for all four techniques with
the highest observed damage associated with pump passage (3 percent unidentifiable). Tap
sampling was considered for use at McGuire for the 2016 entrainment program, but was
eliminated because of concerns with access to secure locations within the power plant. This
study indicates that the selected method for entrainment monitoring (pumped sampling) is
statistically no different than measuring ichthyoplankton density at the condenser tap and better
than a streamed net.
I
I
I
I
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I Entrainment Characterization Study Plan F��
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ITable C-2. Total Number (N) and Mean Densities (MD) (mean number of shad/ 1,000 m3) of
All Shad Collected with Comparison Gear and Shad <28 mm Total Length Collected with
a Tucker Trawl on Lake Norman, North Carolina, 6-10 June 1982, with Average Volume of
IWater Filtered per Sample (m3) (Leonard and Vaughn 1985)
Net Screen Pump -= Upper Trawl Lower Trawl
I
Date © MD N MD N MD © MD N MD N MD
Jun 6 0 0.0 2 a 1° ` 5 56.4 164 195.3 27 27.9
I Jun 7 0 0.0 8 34.0 6b --C 12 182.0 590 410.5 190 70.7
Jun 8 1 4.7 15 53.0 38 91.1 10 103.0 659 536.4 75 43.1
Jun 9 1 7.0 11 43.0 80 196.9 25 346.1 511 666.1 86 76.4
I
Jun 10 0 5.0 10 32.1 36 82.4 4 82.0 279 406.5 134 85.7
Total 2 0.0 46 161 56 2,203 512
1
Ave. 29 92 65 38 206 317
Sample
I Volume
(m3)
Ia-Unable to calculate volume
b-Number not considered valid due to malfunctioning equipment
°-Density not calculated on invalid data
I Taggart, C.T. and W.C. Leggett. 1984. Efficiency of Large-Volume Plankton Pumps, and
Evaluation of a Design Suitable for Deployment from Small Boats. Canadian Journal of
Fisheries and Aquatic Sciences 41(10) 1428-1435.
ITaggart and Leggett (1984) identified and evaluated five major studies that compared the
efficiency of large-volume pumps (defined as withdrawing > 0.5 m3/min [132 gpm]) and nets
I (Table C-3). In addition the authors evaluated a boat mounted large-volume pumping system.
Taggart and Leggett (1984) found, in general, that among the reviewed studies, densities of
I organisms sampled with the pumps was equal to or greater than the densities in the towed net
samples, but there were differences based on length classes and time of day. The authors
pointed out that the gear configurations relative to towed net diameters, pump intake diameter,
I the presence of intake screens, intake velocities and mesh sizes were highly variable between
the studies, which made it difficult to compare. The authors were particularly critical of the lack
of accurate flow measurement used in many of these studies. Despite these challenges, no
Isystematic biases were detected.
In addition to the literature review, Taggart and Leggett (1984) tested a large-volume pump
Isystem with standard plankton nets. The boat mounted system used a 22.2-cm (8.7-inch)
impeller that could pump up to 1.7 m3/min (450 gpm) depending upon head. Divers confirmed
1 the inlet was oriented into the direction of travel. Simultaneously to pump sampling, a 0.5-m
IDuke Energy 151

1 oankttiStudy Plan
Blsteam saon
(1.6-feet) diameter 2-m (6.6 feet) long 80- and 153-pm mesh standard plankton nets were also
fished. Three sets of comparisons were made. In 1981 an 80-pm net was towed immediately
below the surface 2 m (6.6 feet) behind the pump intake. In 1982 and 1983 a 153-pm net was
towed immediately below the surface 13-15 m (43-50 feet) astern of the pump sampler. The
pump intake was maintained at a depth of 0.25 m (0.8 feet)for all comparisons.
' The authors concluded that the nets and pumped sampler were equally effective in capturing
capelin (Ma!lotus villosus) larvae (5-mm length), herring (Clupea harengus) larvae (9-mm
length), large copepods (>750 pm), small jellyfish, and hyperiid amphipods, despite only
sampling 8 percent of the water volume sampled by the nets. In addition, the pump was more
efficient at collecting crab zoea and megalops larvae and efficiency of collecting euphausiids
and chaetognaths increased as their natural densities increased. Nets were superior in the
capture of fish eggs (primarily cunner, Tautogolabrus adspersus), possibly due to the vertical
' distribution of eggs in the water column. The average length of capelin larvae captured by
pumping was consistently 0.2 mm longer than that of larvae taken in nets, but the length—
frequency distribution of larvae sampled was similar to that of larvae entering the pelagic
environment.
The very fine meshes and small organism sizes likely contributed to the high collection
efficiency of the pumped sampler used by Taggart and Leggett(1984)as other studies reviewed
here indicate it is the larger more motile life stages that tend to be collected more efficiently by
nets than by pumped samplers. Like other studies that have towed the pumped sampler inlet
through the water, it is unclear whether these results are directly applicable to the application
being implemented by Duke Energy. Despite these uncertainties, this study seems to support
use of pumped samples for estimating ichthyoplankton and zooplankton densities.
1
1
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Table C-3. Summary of Major Studies Designed to Comparatively Evaluate the Sampling Efficiency of Various Large-Volume
Pumps and Tow Nets (Taggart and Leggett 1984).
PwnP Tow or current
Suction speed Volume sampled
Type and Tow net and (mis) (m3)
mesh size Row Diameter Velocity mesh size
Reference (pm) (ms/min) (m) (mis) (pm) Pump Net Pump Net Gear comparison protocol
Arm 1958 Centrifugal, 1.514 0.076 5.55 0.5-m dia.std., 1.7' 1.7' 15 200 50 paired hauls"near
544 silk 476 nitex surface"(marine)
Partner and Rohde Tandem propeller, 8.6 0.20 4.60 0.5-mdie.std., Local current 86' 44' 11 I paired stationary
1977 5(X)nitex 500 nitex 0.4 samples at 4.5,8,and
9 m(riverine)
Gale and Mohr Open impeller 2.5 0.10 5.30 0.24 x 0.54-m-rect., Local current 7 stationary sets of 4 pump
1978 centrifugal, 400 x 800 miter "moderate-strong" - - and 8 net replicates
400 X 800 niter (0.24)° (0.92)6 at surface sad bottom
(riverine)
Leirhiser et al. Fish transfer, 2.1 0.15 1.92 (a)I-mdia.cy cera, Local current (a)62 121 (a)10 stationary pairs at
1979 335 miter 335 nitex (a)0.26 0.5-1.5 m depth
(riverine)
(b)as in(a)and (b)0.30 (b)64 414 (b)as in(a)above
0.5-m dia.std., 64 105
363 Mex
Cada and Lou Open impeller 1.10 0.076 4.04 0.5-m-dia. "Slowly" 1.2-1.9 17 85-1111 3 sets of 3 replicates mnt
1982 243 minx (0.021)6 (1.1)° Hensen net, paired in time at
243 nitex 0-0.S m depth(riverine)
'Estimated from data provided in paper referenced.
°Measured at intake,which differs in size from suction hose.
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' Results
' The literature review, as described in detail above, indicates that there have been several
studies that have compared the effectiveness of pumps and net sampling. In general, the results
have been equivocal with no clear pattern of one gear type out performing the other. The most
extensive power plant entrainment gear comparison studies were undertaken at the Indian Point
Generating Station on the Hudson River (EA 1978; 1979; 1981; King et al. 1981; NAI 1982;
1987 —as cited in EPRI 2014)12. The results of these studies indicated no consistent differences
in estimated densities between the two gear types (EPRI 2014). There is some indication that at
relative low velocities, high-volume pumped samples collect higher densities of ichthyoplankton
than nets (Leithiser et al. 1979). In a southeastern reservoir(Tennessee), Cada and Loar(1982)
' found that for most length classes there were no significant differences in density between
pump and net samples. The data suggest that avoidance is more common during daylight hours
' in clear water when organisms can observe and avoid the gear. At night and/or in turbid water
avoidance is minimized (Cada and Loar 1982; Harris et al. 1986). Petering and Van Den Avyle
(1988) collected significantly lower densities of fish larvae in a Georgia reservoir using a
' pumped sampler as compared to nets, but there are concerns with the methods and gear, as
described in detail above, that could account for some of these differences. Leonard and
Vaughn (1985) sampled Threadfin Shad (Dorosoma petenense) and Gizzard Shad (Dorosoma
' cepedianum) using pumps, a streamed net, a fine-mesh panel on a traveling screen, and a tap
at the condenser at the McGuire Nuclear Station and reported the highest density at the
condenser tap where the water was well mixed. Leonard and Vaughn (1985) reported the
highest rate of damaged larvae from the pumped samples, but damage was s 3 percent. Gear
avoidance occurs with both pumps and nets and increases with increasing fish length, which is
' likely a result of increased swimming ability, maturing fish sensory systems, and avoidance
behavior.
Caution should be used when applying the results of specific previous gear efficiency studies to
the Duke Energy entrainment program because of the variability in gear types and sampling
techniques used in these studies (e.g., net type and shape; mesh sizes and material; methods
of gear deployment; deployment location; flow metering; inlet orifice size, shape, and
orientation; inlet velocity; impeller size, shape and material; mechanism for suction [vacuum,
diaphragm, centrifugal]; and pumping capacity). Instead, the weight-of-evidence across
' scientifically sound studies should be used which supports pumped samples as being generally
equal in terms of collection efficiency to towed and streamed nets.
Conclusions
Nets and pumps are the two primary methods by which ichthyoplankton densities are estimated
at power plant intakes. Pumped samplers have been used successfully in a wide variety of
11 During the peer review kick off meeting, a biological peer reviewer mentioned an Indian Point Generating study evaluating the
effectiveness of fine-mesh wedgewire screens to reduce entrainment.As part of that study,samples we collected by nets and
' pumps. That study was not reviewed here for several reasons: a)the study was not designed to compare gear types; b)the
sampler used for pump sampling at Indian Point was a unique design that is dissimilar from what is being proposed at the Duke
Energy fadlities;and c)Indian Point is part of on-going 316(b)-related litigation and those study reports are not readily available to
the public.
' Duke Energy 154

Entrainment
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Belews Creek Steam Station Study Plan -)1
' deployment conditions at power plants in the U.S. routinely since the 1970s. This method has
been well vetted by regulatory agencies including in the northeastern U.S., which along with
California, has historically applied the most stringent 316(b) requirements in the nation. In
addition, pumped samplers continue to be accepted for 316(b) monitoring as evidenced by the
list of states where these samplers are deployed or approved to be deployed to support 316(b)
evaluations under the final Rule. Importantly, the final Rule became effective October 14, 2014
and many facilities have not yet chosen the method by which they intend to sample entrainment
and the list of states approving pumped samplers is likely to increase.
Studies that have evaluated nets and pumps have shown no clear pattern of one technology
outperforming the other. The results from published and unpublished industry studies are
' equivocal with some examples suggesting that pumped samples outperform netted samples
and vise-versa.
Perhaps the greatest impediment to determining the collection efficiency of gear from existing
data is the lack of standardized techniques for netting (e.g., net type, net shape, mesh sizes,
' mesh materials, methods of deployment, deployment location, and flow metering) or pumped
samples (e.g., orifice size, orifice orientation, inlet velocity, impeller size, impeller shape,
impeller material, mechanism for suction [vacuum, diaphragm, centrifugal], deployment location,
' and pumping capacity). These factors, along with site-specific hydraulics and life history
characteristics of the early life stages of fish sampled, are likely to impact the performance of
both collection systems. Further, short of a duplicative sampling with both sampling systems in
' tandem, it is unlikely that a study program could be developed that would provide the necessary
data to develop a universal correction factor that could be used to quantitative adjust
entrainment estimates.
' We acknowledge that no system for sampling ichthyoplankton densities is perfect given the
patchy temporal and spatial distribution of fish eggs and larvae and inherent biases of all gear
types. That said, the available data indicate that pumped samplers can be as efficient as nets.
Because entrainment monitoring by pumped sampling is commonly used, widely accepted, and
has practical advantages over using nets at the Duke Energy facilities, our recommendation is
1 that no gear efficiency testing is necessary or warranted.
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' Entrainment Characterization Study Plan
Belews Creek Steam Station
' References
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Plankton Patchiness. Journal of Marine Research 16: 158-173.
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Cada, G.F. and J.M. Loar. 1982. Relative Effectiveness of Two lchthyoplankton Sampling
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' Duke Energy 158

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tion
Belews Creek Steam Station Study Plan EN
Leonard, T.J. and G.E. Vaughn. 1985. A Comparison of Four Gear Types to Measure
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