NC0003425_Characterization_20160601

DUKE Duke Energy Progress, LLC.
ENERGY Roxbom Steam Electric Plans
® (700 Dunnaway Road
PROGRESS Senora NC 27343
May 26, 2016
Mr. Tom Belnick, Supervisor
NPDES Complex Permitting RECEIVEDINCDEQiDWR
NC DEQ/DWR/WQ Permitting Section ,JUN 0 1 2016
1617 Mail Service Center
Raleigh, NC 27699-1617 Water Duality
Permitting Section
Subject: Roxboro Steam Electric Plant
National Pollutant Discharge Elimination System-Permit No. NC00003425
316(b)Entrainment Characterization Study Plan (ECSP)
Dear Mr. Belnick:
Please find enclosed the final Entrainment Characterization Study Plan(ECSP) for Roxboro Steam
Electric Plant. 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 7, 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 Robert Howard at [e-mail]/ 336- 598-
4077.
Sincerely,
2� (J /
William J. Thacl—cer
Roxboro Station Manager
Attachments:

FN
RECEIVEDINCDEWWR
JUN 01 2016
Water Quality
Permitting Section
Response to NCDEQ
Comments:
Entrainment Characterization Study
Plan — Roxboro Steam Station
Prepared for:
(ft. DUKE
!'' ENERGY
Prepared by:
HDR Engineering, Inc.

Entrainment Characterization Study Plan
Response to NCDEQ Comments—Roxboro Steam Station
Contents
1 Introduction....................................................................................................................................1
2 Development of Entrainment Characterization Study Plans............................................................1
3 Twice per Month Sampling for Estimating Entrainment...................................................................3
3.1 Conclusion ...........................................................................................................................5
4 Clarifications on"Variability"and a Method for Estimating 95 Percent Confidence Intervals............6
4.1 Data Analysis and Confidence Intervals................................................................................8
4.2 Conclusion...........................................................................................................................8
References..............................................................................................................................................9
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Entrainment Characterization Study Plan 1
Response to NCDEQ Comments—Roxboro Steam Station 1
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 >_ 125 MGD are required to provide an entrainment characterization study (at 40
CFR 122.21(r)(9)) 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 Roxboro Steam Station
(RSS). The ECSP describes the sampling design and site-specific approach being used at RSS
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 7, 2016. We thank
Mr. Tracy for his comments and have provided responses in Table 2-1.
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Entrainment Characterization Study Plan FN -
Response to NCDEQ Comments—Roxboro 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 Roxboro Steam Station
Ii� Response and Resolution
Pages 13,Section 5(same as Allen,Belews, Marshall,and Roxboro plants),
second and third paragraphs:a)Please provide reason(s)as to why you
Roxboro decided on bi-weekly sampling(or is it just twice a month?)vs.weekly Please see Section 3—Twice per Month Sampling for Estimating Entrainment.
sampling.I attended an NC AFS workshop in 2005 lead by Dr.Doug Dixon
(EPRI)and I have in my notes that bi-weekly sampling is more biased than
more frequent sampling.
Roxboro b)Please provide cr ation(s)justifying as to why twice per month sampling is Please see Section 3—Twice per Month Sampling for Estimating Entrainment.
sufficient.
Replication in entrainment abundance sampling is rare,except when paired Bongo nets
are used.Generally,sampling of a large volume of water(e.g., 100 m')for each sample
is understood to integrate temporal variation in entrainment densities. Neither the EPRI
(2014)entrainment abundance guidance document nor the Final 316(b)rule or
ample collected every six hours--please provide reason(s)why there preamble considers the need to collect duplicate or replicate samples.This suggests
c)One swithin a six hour period.I read your response in Appendix B that neither EPA nor EPRI believes it to be a critical issue for entrainment sampling.
is no replication
Roxboro and I wondered about this issue even before of to Appendix B),but wonder Because entrainment varies temporally and spatially,true replication would require
( g pp simultaneous sampling with a second set of gear,which would roughly double the
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? equipment costs.The increased effort in the field during sampling would be marginal,
but the laboratory processing effort(and associated costs)would also double.Samples
are collected during four periods at each bimonthly sampling event for eight samples in
each month.Confidence intervals can be generated utilizing data from these eight
samples as one way to better understand variability without increasing sampling(See
Section 4).
Page 15,Section 6.2,last sentence:a)A citations)is necessary that would
Roxboro substantiate the statement that twice per month sampling is adequate(Same Please see Section 3—Twice per Month Sampling for Estimating Entrainment.
as 1 b above)
b)Please keep in mind that the reservoir's productivity may have changed
during the past 35 years(since the last entrainment studies were completed in
Roxboro the early 1980s)and that the fish community has since changed following the No response necessary.
selenium toxicity problems that were encountered during the 1970s, 1980s,
and early 1990s.
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Entrainment Characterization Study Plan ��J
Response to NCDEQ Comments—Roxboro 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(r)(9). 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 rl. The CV declined as the frequency of
sampling increased (Table 3-1). At densities between 0.1 and 1.0 per 100 m' 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 ��
Response to NCDED Comments—Roxboro Steam Station r
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 m; per Sample) Applied to
Indian Point Entrainment Data from 1983-1987 (Modified from EPRI 2014)
I F Approximate Coefficient of
Sample Mean Variation I%)
D- . •
rr
"lip RvalB WMR!"N"'mr, " 425-750
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 3-1z). 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.
s 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).
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Entrainment Characterization Study Plan FN
to NCDEQ Comments–Roxboro Steam Station
100
CIO 80
u
a�
Q- 60
a
40
7FBaseline
50th Percentile 80th Percentile
ENu. % Nu.
20 9.45 18.46
(� 1.44 84.7 4.13 77.6
2.38 74.9 5.06 72.6
line 1.79 81.1 4.79 74.0
0
0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150
Number entrained (millions)
�BasNlno �Waakly —Monthly �Port-basNine
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 more' 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.
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 Characterization Study Plan 1
Response to NCDED Comments—Roxboro Steam Station 1
4 Clarifications on "Variability" and a Method for
Estimating 95 Percent Confidence Intervals
The rule requires "sufficient data to characterize annual, seasonal, and diel variations in
entrainment, including but not limited to variations related to climate and weather differences,
spawning, feeding, and water column migration." Through this language, the rule is requiring
sufficient sampling to collect data over the range of conditions at the intake and to prevent bias
through selective sampling. For example, samples should be collected during the day and night
to capture the variation in entrainment associated with diel periods. Many marine and freshwater
fish species exhibit diel vertical migrations (Helfman 1993; Cech et al., 2005, Mehner et al.
2007, Adams et al., 2009). The typical pattern is for organisms to ascend in the water column in
the evening and return to deeper water during the day — although some species have the
reverse pattern (Lampert 1989). In addition to species and life stage, other factors such as light,
temperature, turbidity, and presence of predator and prey species, can influence vertical
migration. Because vertical migration is common, samples should be collected from throughout
the water column during day and night to capture this variation.
The rule requires that the entrainment data capture variations in entrainment rates from biotic
and abiotic factors, but EPA did not intend for facilities to tease apart the causal relationships
between these factors and entrainment. First, covariance of several factors identified by EPA
would make it difficult, if not impossible, to design a study to separate their effects on
entrainment. Using the example from above, separating differences in entrainment associated
with "water column migration" from those due to "diel variation" would not be possible for many
species, because vertical migration behavior is triggered by time of day (i.e., diel period).
Second, for some of the factors identified by EPA, understanding their relationship to
entrainment has no practical application toward determining Best Technology Available. For
example, entrainment rates may change with weather, but use of weather as a decision-making
tool for electrical generation and as a method for compliance with 316(b) is unreasonable.
4.1 Data Analysis and Confidence Intervals
The proposed Entrainment Characterization Study has sufficient "replication" to allow the
development of a 95 percent confidence intervals (95% CI) around the annual estimated
entrainment. Samples are collected during two 24-hour sampling events in each month. With
four samples collected during each sampling event, a total of eight samples are collected each
month at each facility. These individual samples can be used as replicates within each month to
estimate a month specific variance and a 95% Cl around the annual entrainment estimate. It is
important to note that this 95% Cl would be conservative, i.e., it would err on the side of over
estimating the upper and lower bounds on the 95% Cl, because it would include variance due to
assignable causes (e.g., diel variation). Nonetheless, it may be useful in the context of 316(b)as
it provides and upper and lower bound on the estimated annual entrainment. The following
provides one potential method for developing 95% Cl based the sampling design contained in
the ECSPs.
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Entrainment Characterization Study Plan
Response to NCDEQ Comments—Roxboro Steam Station 1
Organism densities, expressed as number per 100 m3, would be calculated from entrainment
data for each species and life stage. Calculation of sample event densities provides seasonal
abundance trends while diel densities provide abundance trends throughout a day based on all
samples combined. Densities would be calculated as the sum of the total collected divided by
the total sample volume in m3, for the relevant interval, times 100. These densities can then be
used to calculate the total number of early life stage fish entrained during March through
October and the associated 95% Cl can be calculated. First, the average Concentration of
organisms per unit volume in the h`h stratum (i.e., month sampled), Xh , would be calculated as:
1_
xh = —1Xhf
nh ;=1
where:
nh= the number of samples in the h"stratum
xh;is the f"observation in the hr"stratum.
The total number entrained (E) is then,
H
E=ZYh Xh
h=1
where:
H=total number of months sampled
Vh =volume of water withdrawn by the station in the h" stratum.
The variance of the estimated total entrained is:
Yar�E�=IYhz(1_ `h)Sh
h=1 nh
where:
S„ = variance of the hth stratum
1z
Z(Xhl—'Xh/
nh —1
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Entrainment Characterization Study Plan FN
to NCDED Comments—Roxboro Steam Station
and fh = finite population correction for the h`h stratum. The finite population correction would be
computed as the volume of facility flow sampled in the month (i.e., h'h stratum) divided by the
total plant flow during the month. This factor becomes important when a substantial percentage
(>10 percent) of the total flow is sampled.
The 95 percent Cl can then be computed as:
Ez,PPe, =E+t.of Yar E
EgWe =E—t.cr V Yar E
where:
a = specified probability of Type I error, in this case 0.05
of= degrees of freedom, n-1
4.2 Conclusion
The final rule does not require replication nor is there an obligation to generate confidence
intervals or bounds around the individual entrainment estimates for a given sampling episode or
stratum (month or year). The use of the term "variation" in §122.21(r)(9) is not synonymous with
"replication", rather, variation refers to the natural temporal and spatial changes in organism
densities. The Entrainment Characterization Study must be sufficient to characterize diel,
monthly, and annual variation, which our proposed studies address. While not required by the
rule, the proposed Entrainment Characterization Studies generate data sufficient to develop
reasonable estimates of entrainment and 95 percent Cl to estimate variability, if needed.
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Entrainment Characterization Study Plan ��
Response to NCDEO Comments—Roxboro Steam Station r
References
Adams, C.F., R. J. Foy, J. J. Kelley, and K. O. Coyle. 2009. Seasonal changes in the diel
migration of walleye Pollock (Theragra chalcogramma) in the northern Gulf of Alaska.
Environmental Biology of Fishes 86: 297-305 (as cited in Donner and Eckmann 2011).
Cech, M., M. Kratochvil, V. Drastik, and J. Matena. 2005. Diel migrations of bathypelagic perch
fry. Journal of Fish Biology 66: 685-702 (as cited in Donner and Eckmann 2011).
Donner, M.T. and R. Eckmann. 2011. Diel vertical migration of larval and early-juvenile burbot
optimises survival and growth in a deep, pre-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.
Helfman, G.S. 1993. Fish behavior by day, night, and twilight, In: Behavior of Teleost Fish (T.J.
Pitcher, Ed.) pp. 366-387. The Johns Hopkins University Press, Baltimore. (as cited in
Donner and Eckmann 2011).
Lampert, W. 1989. The adaptive significance of diel vertical migration of zooplankton. Functional
Ecology 3: 21-27.
Mehner, T., P. Kasprzak, F. Holker. 2007. Exploring the ultimate hypothesis to predict diel
vertical migrations in coregonid fish. Canadian Journal of Fisheries and Aquatic Sciences
64: 874-886. (as cited in Donner and Eckmann 2011).
Duke Energy 19

1 FN
RECEIVEDINCDEWWR
JUN 01 2016
Water Quality
Permitting Section
Entrainment Characterization
' Study Plan
' Prepared for:
� DUKE
- ENERGY
' Prepared by:
HDR Engineering, Inc.
' April 15, 2016

1 FN
1
1 Entrainment Characterization
1 Study Plan
1 Prepared for:
ENERGY
1
Prepared by:
1 HDR Engineering, Inc.
1 April 15, 2016
1

' Entrainment Characterization Study Plan ��
Roxboro Steam Station �"'
' Contents
1 Introduction..........................................................................................................................................1
' 1.1 Regulatory Background.............................................................................................................1
1.2 Study Plan Objectives and Document Organization..................................................................3
' 2 Generating Station Description............................................................................................................3
2.1 Source Waterbody.....................................................................................................................3
' 2.2 Station and Cooling Water Intake Description...........................................................................5
2.2.1 Intake Structure.............................................................................................................5
3 Historical Studies.................................................................................................................................7
' 4 Threatened and Endangered Species.................................................................................................9
5 Basis for Sampling Design.................................................................................................................10
' 6 Entrainment Characterization Study Plan..........................................................................................15
6.1 Introduction..............................................................................................................................15
6.2 Sample Collection....................................................................................................................15
' 6.2.1 Location ......................................................................................................................16
6.3 Sample Sorting and Processing..............................................................................................21
' 6.4 Data Management...................................................................................................................22
6.5 Data Analysis...........................................................................................................................22
6.6 Field and Laboratory Audits.....................................................................................................23
6.7 Laboratory Quality Control.......................................................................................................24
6.8 Reporting .................................................................................................................................24
' 6.9 Safety Policy............................................................................................................................24
7 References.........................................................................................................................................25
' APPENDIX A—Select Species Spawning and Early Life History Data......................................................26
' Life History References.........................................................................................................................31
APPENDIX B—Response to Informal Review Comments.........................................................................32
APPENDIX C—Comparison of Pumps and Nets for Sampling Ichthyoplankton........................................40
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Entrainment Characterization Study Plan ��
Roxboro Steam Station r
' Tables
Table 1-1. §316(b) Rule for Existing Facilities Submittal Requirements Summary ..................................... 2
' Table 2-1. Roxboro Steam Station Design Intake Flow Rate by Unit and Daily Average Water Withdrawal
fromHyco Reservoir, 2011-2014.................................................................................................................. 5
' Table 3-1. Ichthyoplankton (No./1,000 m) Collected from Roxboro Steam Station Unit 3 Intake Water,
1979-1980.....................................................................................................................................................8
' Table 3-2. Months that Larval Fish were Collected from Hyco Reservoir(1979-1980) (Modified from CP&L
1981)................. ........................................................................................................................................... 9
t 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)
.................................................................................................................................................................... 12
Table 5-2. Potential Disadvantages of Pumped Ichthyoplankton Sampling at Roxboro Steam Station... 13
Table 5-3. Summary of Approach for Development of §122.21(r)(9) Required Entrainment
' Characterizations........................................................................................................................................ 14
Table 6-1. Entrainment Sampling Details................................................................................................... 16
' Table A-1. Life Histories of Selected Species Near Roxboro Steam Station.............................................27
Table B-1, Directed Charge Questions-...... ..
. ............................................................................................ 32
Table B-2. Peer Reviewer Responses to Directed Charge Questions.......................................................34
' 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 m) 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 (m)
(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
t
Duke Energy I ii
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' Entrainment Characterization Study Plan L�`
Roxboro Steam Station r
' Figures
Figure 2-1. Roxboro Steam Station Vicinity Map(Source: Duke Energy 2013)...........................................4
' Figure 2-2. Site Configuration of Roxboro Steam Station (Source: Progress Energy 2005).......................6
' Figure 4-1. Geographical Boundary of the IPAC Search ........................................................................... 10
Figure 6-1. Section View of the Roxboro Steam Station's Cooling Water Intake Structure with
Approximate Location of Sample Inlets at Three Depths (Image Modified from: Carolina Power and Light
' Company Engineering Drawing, G-174662) .............................................................................................. 17
Figure 6-2. Aerial View Showing Approximate Locations of Sampling Gear (Image Modified from: Google
' Earth).......................................................................................................................................................... 18
Figure 6-3. Example Entrainment Pump Sampling System Configuration.................................................20
' Figure 6-4. 7.5-Horsepower Electric Pump Used for Entrainment Sampling............................................. 20
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' Entrainment characterization Study Plan
Roxboro Steam Station r��
' Acronyms and Abbreviations
'
OF.................................................................................................................. degrees Fahrenheit
AIF ....................................................................................................................actual intake flow
AOQL .........................................................................................Average Outgoing Quality Limit
t BTA ...................................................................................................Best Technology Available
CSP .................................................................................................... continuous sampling plan
MIS .............................................................................................cooling water intake structure
' MIS 1 ............................................................................Units 1-3 cooling water intake structure
CWIS 4.................................................................................Unit 4 cooling water intake structure
DIF........................................................ ...........................................................design intake flow
' Director................................................National Pollutant Discharge Elimination System Director
Duke Energy........................................ .......................................... Duke Energy Carolinas, LLC
' El....................................................................................................................................elevation
ECSP ...........................................................................Entrainment Characterization Study Plan
EPRI ........................................................................................Electric Power Research Institute
gpm ................................................................................................................gallons per minute
HDR ..........................................................................................................HDR Engineering, Inc.
IPAC........................................................... Information for Planning and Conservation (website)
' m3.............................................................................................................................. cubic meter
MW............................................................................................................................... megawatt
Jim ............................................................................................................. micrometer or micron
mm ...............................................................................................................................millimeter
MGD......................................................................................................... million gallons per day
' MIL-STD........................................................... .................................................military-standard
NPDES ............................................................ National Pollutant Discharge Elimination System
NCDENR-DWQ..... North Carolina Department of Environment and Natural Resources, Division of Water Quality
Nonnandeau ..................................................................................Normandeau Associates, Inc.
Progress Energy.........................................................................Progress Energy Carolinas, Inc.
PVC.................................................................................................................. Polyvinyl chloride
' QA ..................................................................................................................Quality Assurance
QC........................................................................................................................ Quality Control
Roxboro................................................................................................... Roxboro Steam Station
' SOP ...........................................................................................Standard Operating Procedures
USFWS .........................................................................................U.S. Fish and Wildlife Service
1
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' Entrainment characterization Study Plan 1 ��
Roxboro Steam Station r
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 withdraws 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 III 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 >_ 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) Roxboro Steam Station (Roxboro) 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.
' Duke Energy 1 1

Entrainment Characterization Study Plan FN
Steam Station
' While 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
' requirements and/or situations encountered during execution.
' Table 1-1. §316(b) Rule for Existing Facilities Submittal Requirements Summary
DescriptionsSubmittal
' (2) Source Water Physical Data Characterization of the source water body including intake area of influence
(3) Cooling Water Intake Characterization of cooling water system;includes drawings and narrative;description of operation;
' Structure 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)
Cooling Water Narrative description of cooling water system and intake structure;proportion of design flow used;
' (5) System Data water reuse summary;proportion of source water body withdrawn(monthly);seasonal operation
summary;existing impingement mortality and entrainment reduction measures;flow/MW efficiency
Chosen Method of Provides facility's proposed approach to meet the impingement mortality requirement(chosen from
' 8 Compliance with
Impingement Mortality seven available options);( ) P );provides detailed study plan for monitoring compliance,if required by
Standard selected compliance option;addresses entrapment where required
' 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
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
Entrainment facility and conditions at the site with documentation regarding the continued relevance of the data
Characterization to document total entrainment and entrainment mortality;includes identifications to the lowest taxon
' Study possible;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
' 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;
benefits to environment and community;social benefits analysis based on principle of willingness-to-
pay;requires peer review
' Non-Water Quality Provides a discussion of non-water quality factors(air emissions and their health and environmental
12 Environmental and impacts,energy penalty,thermal discharge,noise,safe
( ) Other Impacts P gyp ty 9 safety,grid reliability,consumptive water use,
Assessment etc.)attributable to the entrainment technologies;requires peer review
1
' Duke Energy 1 2

' Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
1 '
Submittal Descriptions
Documentation of external peer review,by qualified experts,of submittals(r)(10),(11),and(12).
' eer Review Peer Reviews must be approved by the NPDES Director and present their credenfials.The
applicant must explain why it disregarded any significant peer reviewer recommendations.
' M!New Units Identify the chosen compliance method for the new unit
1 .2 Study Plan Objectives and Document Organization
' The ECSP provided in this report was developed to support Roxboro's §316(b) compliance
' 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;
' 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
' 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
1 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 waterbody (Hyco Reservoir) from
' which Roxboro withdraws cooling water and the design and operation of the CWIS.
2.1 Source Waterbody
' Roxboro is located on Hyco Reservoir, which was created in 1963-1964 by damming the upper
reaches of the Hyco River, a tributary of the Dan River (Figure 2-1). Hyco Reservoir is located
' approximately 4 miles south of the North CarolinaNirginia border in Person and Caswell
Duke Energy 1 3

' Entrainment Characterization Study Plan
Roxboro Steam Station r L��
Counties in the northern Piedmont of North Carolina. Currently, Hyco Reservoir has a balanced,
self-sustaining aquatic community which is comprised of species typically present in
southeastern Piedmont impoundments.
Hyco Reservoir lies within the Roanoke River Basin. Hyco Reservoir has a surface area of
' 4,349 acres, its mean depth is 20 feet, and the reservoir drains an area of 293 square miles.
Hyco Reservoir has a retention time of approximately six months (= 180 days) with a usable
storage capacity of 77,990 acre-feet at normal water elevation of 410.5 ft-msl'. The reservoir
' has an average inflow of 130 MGD. The land use along the 159-mile long shoreline is primarily
residential, forested, and agricultural lands.
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Figure 2-1. Roxboro Steam Station Vicinity Map (Source: Duke Energy 2013)
1
All elevations in this report are relative to mean sea level (msl).
' Duke Energy 1 4

' Entrainment Characterization Study Plan
Roxboro Steam Station r LN
' 2.2 Station and Cooling Water Intake Description
Roxboro has four coal-fired units with a combined electric generating output of 2,558 megawatts
(MW). Unit 1 is rated at 411 MW and began operation in 1966. Unit 2 is rated at 657 MW and
began operation in 1968. Units 3 and 4, rated at 745 MW each began operation in 1973 and
1980, respectively. Units 1 and 2 operate in a once-through cooling mode. Unit 3 operates in a
' once-through cooling mode part of the year (October 15`h — April 30`h) and during summer
months (May 1" — October 14th) condenser cooling water is routed to once-though mechanical
draft cooling towers. Unit 4 is equipped with closed-cycle evaporative cooling towers that
operate year-round. Make-up water for the Unit 4 cooling towers is withdrawn from the Units 1-3
cooling water discharge canal (Figure 2.2). As a result, there is no net increase in cooling water
withdrawal for the Unit 4 cooling tower make-up water. The design pumping capacity for the
station is 1,130 MGD (Unit 1 = 249 MGD, Unit 2 = 342 MGD, Unit 3 = 505 MGD, Unit 4 = 35
MGD) (Table 2-1).
' Table 2-1. Roxboro Steam Station Design Intake Flow Rate by Unit and Daily Average
Water Withdrawal from Hyco Reservoir, 2011-2014
Designr Average daily water withdrawal(MGD)from Hyco
249 -r
2 342
3 505 870.6
4 34
Facility 1,130 - -
2.2.1 Intake Structure
' Roxboro uses two CWIS. The CWIS for Units 1-3 (CWIS 1) is located at the small pond (intake
forebay) immediately east of the Unit 1 turbine-generator (Figure 2-2). The CWIS for Unit 4
(CWIS 4) is located on the north bank of the discharge canal, adjacent to the eastern-most Unit
' 4 closed-cycle cooling tower.
Roxboro withdraws cooling water through eight bays in CWIS 1 via a 1.7-mile intake canal
' located east north-east of the plant. The intake canal directs water to an intake pond which is
connected to the CWIS 1 intake forebay area via a submerged culvert. Unit 1 consists of two
' intake bays equipped with one circulating water pump per bay. Units 2 and 3 each consist of
three intake bays equipped with one circulating water pump per bay. Each of the eight intake
bays for CWIS 1 is equipped with trash racks and coarse-mesh (3/8-inch mesh size) vertical
' traveling screens. The traveling screens are equipped with a debris spray wash system and
debris collection trough. Debris and organisms washed from the traveling screens are routed via
a debris trough to the Units 1-3 discharge canal.
1
Duke Energy 1 5

' Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station F-
1
' CWIS 4 withdraws cooling water from the discharge canal through one intake bay equipped with
two small cooling tower make-up pumps. Make-up cooling water for CWIS 4 passes through
fixed, fine-mesh screens'.
In the event surface water temperatures in Hyco Reservoir exceed 90 degrees Fahrenheit
gates located on along a dike immediately north of the intake pond are opened to route cooler
' water from the bottom of Hyco Reservoir into the intake pond. The cooler water is withdrawn
under a skimmer wall that extends to a depth of 23 feet below normal reservoir elevation (Figure
2.2). This arm of the reservoir served as the plant's intake canal until 1973, when the 1.7-mile
intake canal was completed.
4 �
y/
1 mnn
4
1 6 1
.nfl Gc'Wiy I''
J ,
1 �
Figure 2-2. Site Configuration of Roxboro Steam Station (Source: Progress Energy 2005)
1
' Fine mesh is Type 304 stainless steel wire mesh (#2 Mesh with 16 gauge wire).
' Duke Energy 1 6

Entrainment Charactenzation Study Plan
Roxboro Steam Station r L��
3 Historical Studies
' Historically, Duke Energy sampled entrainment at Roxboro Unit 3 biweekly beginning March
1979 and continuing through December 1980 (CP&L 1981). Ichthyoplankton nets (0.5-meter
' diameter, 571-micron [Nm] mesh) were lowered into the water on a frame placing them in the
path of water drawn into Unit 3 for a known period of time (from 1 —4 hours). Replicate samples
were collected during daylight and after dark. The organisms were removed from the net and
preserved in buffered formalin for later identification, enumeration, and measurement in the
laboratory.
t Entrainment catches adjusted to a standard volume (1,000 cubic meters [m3] of water
withdrawn) were low (Table 3-1). The highest entrainment rate recorded was 57 Gizzard Shad
(Dorosoma cepedianum) larvae per 1,000 m3 during the night of May 7, 1980. The next highest
' entrainment rate was 36 fish per 1,000 m3 on the night of May 22, 1979. Entrained organisms
consisted of Gizzard Shad, Golden Shiner (Notemigonus crysoleucas), unidentified shiners,
Lepomis spp. (sunfish), unidentified fish larvae, and unidentified fish eggs. Ichthyoplankton was
found in only 12 of the 77 (16 percent) samples collected. The mean entrainment rates for 1979
and 1980 were 1.8 and 1.7 fishes per 1,000 m3, respectively.
1 Larval fish sampling in Hyco Reservoir was also conducted in 1979-1980 (CP&L 1981).
Samples were collected day and night at 10 stations along five transects using push nets. At
each station, 6-minute horizontal samples were collected using 0.5-meter conical nets with 560-
pm mesh. Samples were collected weekly April-August, bi-weekly March and September, and
once-per-month in January, February, October, November, and December.
' In the two years combined, larval fish first appeared in samples collected in March and were last
collected in October, indicating an 8-month spawning season. This time period corresponds to
the proposed entrainment sampling window proposed in this study plan (Table 3-2). The
greatest abundance of organisms occurred April through June each year. Gizzard Shad was the
most abundant species collected, followed by sunfishes (Lepomis spp.) and Yellow Perch
' (Perca flavescens).
1
1
1
1
' Duke Energy 1 7

Entrainment Characterization Study Plan
Roxboro Steam Station r
Table 3-1. Ichthyoplankton (No./1,000 m) Collected from Roxboro Steam Station Unit 3 Intake Water, 1979-1980
®®®®®®®®®®®®®®®®
Gizzard Shad — — 1 2 1 5 — 1 _ 6 MEW
—
Golden Shiner — — — — — — — — _ — ■■■ 1
unidentified shiner — — 5 — 2 — ■■■
Lepomis sp. -- — 1 — — 26 2 — 2
r
unidentified larvae -- 1 12
_
unidentified fish -- — _ _
— 1 —
eggs xz
TOTAL 0 1 2 2 2 36 2 3 2 0 0 6 1 57 0 13
Note: Sampling was conducted biweekly from March 1979 through December 1980, data presentation limited to April through June due to low and
zero catches outside of this period.
Duke Energy 1 8

' Entrainment Characterization Study Plan FN
Steam Station
' Table 3-2. Months that Larval Fish were Collected from Hyco Reservoir (1979-1980)
(Modified from CP&L 1981)
Gizzard Shad Apr-Jul Mar-Jul
' Minnow Family Apr-Aug Apr-Jul
Carp — Apr-Jul; Sep
' Golden Shiner Apr-Jun Apr-Jun
' Shiner Apr-May;Aug-Sep Apr-Jun
Satinfin Shiner May-Oct Apr-Oct
' White Catfish Jun —
Channel Catfish Jun-Jul MayJun
' Sucker — Apr-May
Sunfish family May Jun
' Sunfish Apr-Sep May-Aug
Bluegill Jul —
' Crappie Apr-Jun Jun
' Black Crappie Apr-May —
Yellow Perch Mar-May Apr
4 Threatened and Endangered Species
' The 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 Hyco
Reservoir and the surrounding land (Figure 4-1; USFWS 2015). The only aquatic species
identified was the endangered Dwarf Wedge Mussel (Alasmidona heterodon). However, the
Dwarf Wedge Mussel lives on muddy sand and gravel bottoms in creeks and rivers of various
sizes. It requires areas of slow to moderate current, good water quality, and little silt deposition.
' (USFWS 1993). The habitat near Roxboro's intake is not suitable to Dwarf Wedge Mussel and it
is not anticipated to reside anywhere near the Roxboro CW IS.
tDuke Energy 1 9

' Entrainment Characterization Study Plan
Roxboro Steam Station r
coon _ -
[ n
VIRGINIA
3- - - -- - a _ _ _ .. --
1-rao vr1R
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' Figure 4-1. Geographical Boundary of the ]PAC Search
5 Basis for Sampling Design
' HDR Engineering, Inc. (HDR) and Normandeau Associates, Inc. (Normandeau) participated in a
site visit to Roxboro on May 13, 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
entrainment samples from within the CWIS 1 would best represent entrainment rates at
' Roxboro. Note that since CWIS 4 only services the close-cycle Unit 4 and withdraws from the
Unit 1-3 thermal discharge, no entrainment sampling is proposed for this unit. Sampling at the
' intake with a pumped sampler minimizes damage to or loss of organisms that can occur if
samples are collected at the discharge side of the condenser cooling water system. In addition,
properly designed and operated pumped systems have shown collection efficiency of 95
percent or greater for fish eggs and larvae with little or no organism damage (EPRI 2014).
Two primary methods that have been historically used to estimate ichthyoplankton entrainment
' at power plant intakes are utilizing streamed/towed nets and collecting pumped samples.
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 1 10

iEntrainment Charactenzation Study Plan 1 ��
Roxboro Steam Station r
tmesh 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 . Pumped sampling was selected as the preferred sampling method for the
' Roxboro. 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 Roxboro.
1
1
' Duke Energy 1 11

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' Entrainment Characterization Study Plan
Roxboro Steam Station r L��
' While all sampling techniques are biased to some degree, the design for the Roxboro 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 Roxboro is
provided in Table . 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
Roxboro Steam Station
1Potential Disadvantage
Roxboro
(as described in EPRI 2014)
' Non-random vertical distribution may Sampler at Roxboro 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 CW IS
my increase likelihood of active gear Intakeveloci es at &boro are less than 1.0 feet per second(fps)at
' avoidance for ffwMIAggWojgggdApIL.AMMLBgigLgLsampling and some avoidance may occur.
juvenile stag
' Potential uncertainty as to whether Only the late larvae and early juvenile fish might escape entrainment
organisms were destined to be from downstream of the bar racks where velocities are greater than
entrained 0.5 fps.
' The recommended approach for Roxboro (described in greater detail in Section 6), is to pump
water from immediately behind the Units 2 or Unit 3 trash racks to an entrainment sampler
located in a concrete pit adjacent to the intake structure. The sampling system will utilize a rigid
pipe with three orifices that will allow simultaneous withdrawal from near surface (— EI. 410),
mid-water (— EI. 404) and near bottom (— EI. 398). Two identical pipes will be installed at Units 2
' and 3 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
CWIS 1 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 allow access to the intake deck.
Entrainment sampling will be conducted 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 Hyco
' Reservoir based on spawning characteristics of the species most likely to be entrained (see
Appendix A). To account for potential shifts in spawning time periods, the sampling program will
' be run adaptively in response to entrainment densities. For example, if the densities of
' Duke Energy 1 13

' Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
' 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 be extended to begin earlier (e.g.,
February). As a result, the adaptive management plan will provide the greatest potential to
' collect representative samples throughout the entrainment season.
Each sample collection event will be conducted over a 24-hour period with sample sets
t 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.
' Factors important to meeting §122.21(r)(9) requirements, along with a basis for how these
requirements will be addressed at Roxboro, are summarized in Table .
' Table 5-3. Summary of Approach for Development of§122.21(r)(9) Required Entrainment
Characterizations
Basis for Meeting the Requirement
' Two years of data and annual Entrainment samples will be collected during 2016(Year 1)and
variation 2017 (Year 2)
Seasonal variation Entrainment samples will be collected twice per month during March
through October each year
Diel variation Each 24-hour sampling event will be split into four 6-hour sampling
' periods to capture diel variation
Variation related to climate and Weather information and water temperature will be collected during
each sampling event to evaluate differences in entrainment rates
weather
' 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;
' feeding and water column Entrainment samples will be collected at three depths(near surface,
migrations mid-depth, and near bottom)to account for depth variability by
species/ life stage for water column migrations
' 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
Data must be representative of each Sampling in Units 2 and 3 are expected to be representative of
intake CWIS 1
' How the location of the intake in the Sampling of near surface, mid-depth and near bottom behind the bar
water body are accounted for racks will result in the collection of a representative entrainment
sample
' Document flow associated with the Facility will monitor and provide documentation of circulating water
data collections flows during sampling event
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
1
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Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
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.
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 Hyco Reservoir 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 event in order to obtain representative density
measurements. The 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 2 or Unit 3 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, collections will be taken within each of the above 6-hour sampling window
resulting in four samples during each sampling event. In the crepuscular periods, target sample
collection times will be one hour preceding and one 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 61). This sampling frequency will provide fish taxa,
density distribution, and seasonal/diel variation in data collected over the two year period.
1
' Duke Energy 1 15

' Entrainment Characterization Study Plan
Roxboro Steam Station r LN
' Table 6-1. Entrainment Sampling Details
Units to be Sampled Unit 2 or Unit 3
Thirty-two(32)sampling events total (16 sampling events per year);
' Sampling Events(Days) twice per month for two years; March 1 through October 31, 2016
and March 1 through October 31, 2017
Daily Collection Schedule Samples collected within every six hours in a 24-hour period (4
' collections/24-hr period)
Targeted Organisms Fish eggs, larvae, and juveniles
t Depths Depth integrated sample using selective withdrawal from near
surface, mid-depth, and near bottom.
Approximate 100 m'samples collected within each 6-hour sampling
Sample Duration
' interval.
Number of Samples per Sampling
Event(Day) Four samples per event
' Total Number of Samples Sixteen(16)sampling events/year x 4 samples/sampling event
(days)x 2 years= 128 samples
' 6.2.1 Location
Entrainment samples will be collected from either the eastern-most pump bay of Unit 2 or
' western-most pump bay of Unit 3, which are immediately adjacent to one another. If both pumps
are operational on a given sampling date, the Unit 2 bay will be selected preferentially, because
it is more centrally located within the CWIS. Samples will be collected immediately behind the
trash racks using a polyvinyl chloride (PVC) sampling pipe with three openings: near surface (-3
feet from normal water level; -- EI. 410°), mid-water (mid-point between normal water level and
bottom of intake; — El. 404), and near bottom El. 398) (See Figures 6-1). 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 in the concrete pit west of Unit 1 with PVC
or flexhose piping running along the top of the intake structure deck to the sampling locations at
Unit 2 and Unit 3 (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.
1
1
4 All elevations in this document refer to Mean Sea Level.
1
' Duke Energy 1 16

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Entrainment Characterization Study Plan
Roxboro Steam Station F L��
Electric Pump
' and Tank
Location
Flex-hose or Piping "W ,• 1/9 •Kf �
Connecting Pump to
' In-water Sampler
t t
' Sampling Location Sampling Location
' N
1
Figure 6-2. Aerial View Showing Approximate Locations of Sampling Gear (Image
Modified from: Google Earth)
t During each six-hour sampling window, one sample, aggregated by depth, with a target volume
of 100 m3 will be collected such that on each sampling day, four discrete 6-hour samples will be
collected at Roxboro. The 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 sample volume) will require approximately two 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.
Pumped 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
mesh. A larger mesh (e.g., 505-Nm) 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
samples with little or no damage to eggs and larvae (Figure 6-4). Pump specifications are
provided below:
• Capacity: 240 gpm;
1
' Duke Energy 1 18

1 Entrainment Characterization Study Plan 1
Roxboro Steam Station r
1 • Range: 5 gpm — 380 gpm
• 7.5 horsepower
1 Inlet diameter: 3 inches
• 230/460 volts
• 18/9 amps
1 3 Phase
• Length: 36 inches
1 Self Priming
• Suction Lift: approximately 25 feet
• Impeller: Urethane coated steel
1 Weight: 230 lbs.
The net mouth will be suspended above the water line in the tank to prevent overflow and loss
1 of organisms in the event of tank overflow. In an effort to minimize organism damage, the net
will be washed down 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.
iTotal sample volume, duration, intake water temperature, dissolved oxygen, pH, and
conductivity will be recorded on field data sheets. Samples will be transported back to the
1 laboratory for analysis under a required chain-of-custody provided in the SOP.
1
i
1
i
1
i
i
i
Duke Energy 1 19

' Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
' JOINT MUST SWIVEL
APPROX.90'
(POSSIBLY MORE)
SAMPLE FLOW RATE-240 9PM
' - -. - 3"0 ADAPTER SOCKET
WOODEN CRADLES(typ.2) j _ 3-0 OVERFLOW DRAIN
' STAINLESS STEEL BANDS(typ.2) 330p ICHTHVO-NET
INLINE
ROW TOTALIZING 3"0 PVC VALVE
METER
(PVC SADDLE MOUNT) WO PVC
' 330p t_ 710gal (PASSIVE DISCHARGE)
COD END POLYETHYLENE
SAMPLER BUCKET . TANK 7
FLOW IN i�J-
'3'0 PVC NAME
ITHROUGH NET)
3"0 RADLLL RIX HOSE 3"0 QUICK-CONNECT 3'0 PVC VALVE _
NOT TO SCALE
Figure 6-3. Example Entrainment Pump Sampling System Configuration
' Figure 6-4. 7.5-Horsepower Electric Pump Used for Entrainment Sampling
tDuke Energy 1 20

' Entrainment Characterization Study Plan ��
Roxboro Steam Station r
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 Hyco Reservoir 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
1 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.
Duke Energy 1 21

' Entrainment Characterization Study Plan
Roxboro Steam Station r L��
• Up to 10 eggs of each taxon will be measured for minimum and maximum diameter to
the nearest 0.1 mm.
' 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., ImageToolTA° 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 (>_ 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 Inth stratum (i.e., month, sample event or six hour interval),Xh ,
will be calculated as:
1 �n
X = — EXhi
where:
1
Duke Energy 1 22

Entrainment Characterization Study Plan
Roxboro Steam Station r L��
' nh = the number of samples In the hth stratum
' xh, is the i1h observation in the hth stratum.
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 h 1 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,, x,,
' n=1
where:
iH = total number of months sampled
' Vh = volume of water withdrawn by the station in the hth stratum.
' 6.6 Field and Laboratory Audits
Prior to the first scheduled sampling, an experienced senior staff member will accompany and
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
Normandeau) 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
1 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
' Duke Energy 1 23

' Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
' 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
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 (>_90 percent accuracy).
' Identification checks will be inspected using a QC procedure derived from MIL-STD (military-
standard) 12356 (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 and actual 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.
' 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.
' Duke Energy 1 24

' Entrainment Characterization Study Plan
Roxboro Steam Station F L��
7 References
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, Michigan. 744 pp.
Carolina Power and Light (CP&L). 1981. Hyco Reservoir Environmental Report 1979-1980:
Volume III — Biological and Chemical Studies.
' Duke Energy. 2013. Roxboro Steam Electric Plant, 2012 Environmental Monitoring Report.
Duke Energy Progress. Raleigh, North Carolina
' EPRI (Electric Power Research Institute). 2014. Entrainment Abundance Monitoring Technical
Support Document. 1011280. 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,
1 Chattanooga, TN, USA.
Progress Energy Carolinas, Inc. (Progress Energy). 2005. Roxboro Steam Electric Plant
' Proposal for Information Collection, NPDES Permit No. NC0003425.
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 Roxboro (Hyco Reservoir). Generated November 05, 2015.
. 1993. Dwarf Wedge Mussel (Alasmidonta heterodon) Recovery Plan. U.S. Fish and
Wildlife Service, Northeast Region, Hadley, MA. 52 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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' Entrainment Characterization Study Plan FNRoxboro Steam Station
APPENDIX A - Select Species Spawning and Early
Life History Data
Sampling for entrainment year-round at Roxboro is expected to be a poor allocation of
' resources, since few if any eggs or larvae are likely to be present in Hyco Reservoir 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 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.
1
1
Duke Energy 1 26

M M i 1=1 IM
Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
Table A-1. Life Histories of Selected Species Near Roxboro Steam Station
NCDENR
Young-of-
Spawn
Period I Spawning Rates Cut-off
Lengths
ML
emersal F
and olk-sac
Spring adhesive (YS)2-
Shallow cal
Black Crappie � 4 mm
(Pomoxis Water waters nea Depression in sand
nigromaculatus) Temperatures vegetation gravels. Post 1, 6
64.4-68°F cover Average olk-sac
diameter: PYS)3-
66 1
0.93 mm 18 mm
Spring and 4P' Adhesive
Early Summer Saucer-shaped YS 4-6
Shallow waters depressions in sand or mm
Blmacr (Lepomis with sand and gravel typically one to Average <50 mm 1, 4
macrochirus) Water diameter:
gravels. two feet in diameter and PYS 7 14
Temperatures 1.2 to 1.4
70-75°F a few inches deep. mm mm
emersal
FTemperatures
Saucer-shaped and YS 3-6 adhesiveGreen SunfiShallow wat depressions in sandmm(Lepomiswith sand an gravel typically one to 1,4,5,7Avera eCyanellus) gravels. n two feet in diameter and g YS 7-11 diameter:a few inches deep. mnl t 1.0 to 1.4
mm
Adhesive
Early Spring Shallow water on Circular area 2 to 3 feet YS 3-8
Largemouth Bass bottoms composed in diameter with clean 5,000 to mm
(Micropterus Water of sand,gravel,or sand or fine gravel clear Average 43,000 <100 mm 1, 4,5
salmoides Temperatures diameter:
p pebbles near of organic silt.
sand 1.49 to 1.67 eggs PYS 6-16
60-75°F cover. silt. mm mm
Duke Energy 1 27

Entrainment Characterization Study Plan L�']
Roxboro Steam StationSpawning Fecundity r `
NCDENIR
. .
.- - Spawning Habitat -
Lengths
� emersal� .
and
Spring Shallow water on Depressions in sand to adhesive [YSIPM
Redear Sunfi 2,000 m
firm substrates soft mud constructed in
(Lepomis Water often in locations areas containing Average 10,0 1,4, 7,
microlophus) Temperatures exposed to the sun. aquatic plants. diameter: eggs YS 5-15
68-70°F 1.0 to 1.5 mm
mm
L'�.A
^.Demersa �,.
and
Gizzard Shad adhesive
(DorosomaSAverage
cepedianum) iameter:
75 to 1.1
mm
Spring and '.r : YS 3 7
---
Early Summer
Threadfin Shad Eggs scattered Demersal 000 mm
(Dorosoma Water over plants or loose Open we and 24,000E <100 mm 1,4, 5
petenense) Temperatures sediments. adhesive eggs PYS 6-20
60-80°F mm
Family Cyprinidae
Spring and Demersal
Early Summer Eggs scattered in and YS 3-8
Common Carp shallow waters with adhesive 36,000 to mm
(Cyprinus carpio) Water aquatic vegetation, Open wat 2,000,000 <150 mm 1,4,7
Temperatures mud bottoms, and Average eggs PYS 8-21
60-80 .F over debris. diameter: mm
5-2.1 mm ..r..
Duke Energy 1 28

Entrainment Characterization Study Plan
Roxboro Steam Station
SpawningNCDENIR
Fecundity
Period Spawning Habitat Nest Structure Rates the-Year
Lengths
Spring through
Late Summer . dhesive ,
E s are scattered g
Golden Shin 99 Open water, sometim $ YS 3-6 mm
over filamentous
(Notemigon Water algae or rooted over nest of Average <75 mm pYS 5-11 1, 3,4
crysoleucas Temperatures largemouth bass.
P aquatic plants. diameter: S
>70 *6°F 1.0 mm t
>70 °F
May to mid-
August Shallow waters
Satinfin Shiner with typically with Eggs are deposited in DemersaI r
(Cyprine/la filamentous algae crevices and bottom and to <40 mm
analostana) Water or root aquatic substrates adhesive 3,60000 eggs
Temperatures plants.
65-85°F
Family ktaluridas
Late Spring and Eggs are deposited in Adhesive
Early Summer crevices with hollow
Channel Catfish Streams or Up to
Ictalurus woody debris and YS 6
( Water reservoirs bottoms undercut banks. Nest Average 21,000
Nest
punctatus) Temperatures with cover. can be made directly diameter: eggs .
2.4-3.0 mm
70-85(°F). mud bottoms atm
Early Summer Eggs are deposited
crevices of hollow
White Catfish Stream or reservoir woody debris andF
Up to 4,000
(Ameiurus catus) Water bottoms undercut banks. N eggs <75 mrrt,
Temperatures can be made direc
65-75(°F) in mud bottoms.
v.
Duke Energy 1 29

Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
NCDENR
Spawning i Fecundity . .
.. Nest Structure the-YearRates Cut-off
Lengths
Late Winter or dhesive
Early Spring and S 8-20
Yellow Perch Shallow wate Eggs are deposited demersal ? mm
with modera over submerged
lams, logs, ravel Average 1, 7
(Perca flavescens) Water vegetation p 9 g
and rocks. diameter: ; YS 8-21
Temperatures 1.9 to 2.8 s;
44.6-51.8'F mmmm
Duke Energy 130

iEntrainment Characterization Study Plan
Roxboro Steam Station r FN
iLife History References
i1) Rohde, F.C., R.G. Arndt, D.L. Lindquist, and J.F. Parnell. 1994. Freshwater fishes of the
Carolinas, Virginia, Maryland, & Delaware. The University of North Carolina Press.
1 Chapel Hill, NC.
2) Adams, J.C., and R.V. Kilambi. 1979. Maturation and fecundity of redear sunfish.
i Arkansas Acad. Scie. Proc. 33:13-16.
3) Lazur A.M. and F.A. Chapman. 1996. Golden shiner Culture: A reference profile.
1 Department of Fisheries and Aquatic Sciences, Florida Cooperative Extension Service,
Institute of Food and Agricultural Sciences. University of Florida.
1 4) Hendrickson, Dean A., and Adam E. Cohen. 2015. "Fishes of Texas Project Database
(Version 2.0)" doi:10.17603/C3WC70.
5) Ross, S. T. 2001. The Inland Fishes of Mississippi. University Press of Mississippi,
1 Jackson.
6) //www.flmnh.ufl.edu/fish/gallery/Descript/BlackCrappie/BlackCrappie.htmI
i7) Myers, P., R. Espinosa, C. S. Parr, T. Jones, G. S. Hammond, and T. A. Dewey. 2016.
The Animal Diversity Web (online).
1 8) Helfrich, L., Newcomb, T., Hallerman, E., and Stein, K. 2005. The Virtual Aquarium.
Virginia Tech University, The Department of Fisheries and Wildlife Sciences.
i
1
1
i
1
1
1
1
1 Duke Energy 1 31

Entrainment Characterization Study Plan
Roxboro Steam Station FN
APPENDIX B - Response to Informal Review
' Comments
While not required to be peer reviewed under the Rule, Duke Energy engaged subject matter
' 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
' 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
' not be questioned at a later time.
In order to help focus the review, charge questions were developed (Table ). The primary goal
was to develop a study that meets the objectives of the Rule-required Entrainment
Characterization Study.
' Table B-1. Directed Charge Questions
® Entrainment Characterization Study .. Comments(if any)
Plan
Will the proposed sampling depth(s)
�) and location provide for a Yes/No
representative sample of the water
' column?
Considering fish and shellfish known or
expected to be in the source waterbody,
' 2) will the proposed sampling period Yes/No
(months)provide the ability to
understand seasonal variations in
entrainment?
' Is the sampling equipment proposed
3) appropriate to collect entrainable MI
/No
at this type of intake
' structure? L
Does the plan lay out QA/QC
4) requirements clearly?Are thew-
mag
' requirements adequate?
Identifying eggs and larvae to species is
often difficult and sometime impossible.
' Does the sampling plan provide
5) sufficient measures to preserve Yes/No
organism integrity and support
identification to the lowest taxon
' practicable?
Does the study design meet the
6) requirements of the Rule at 40 CFR -
122.21(r)(9)?
' Duke Energy 1 32

Entrainment Characterization Study Plan
Roxboro Steam Station 0♦J
Entrainment Characterization Study Commerts (if any)
Plan
' Will the study design provide sufficient
data to support a benefits analysis of
?) entrainment reducing technologies Yes/No
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
' plan that might prevent you or others
8) (e.g., Regulators)from understanding Yes/No
what is being proposed
so,what needs to be ad
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.
t • 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 Roxboro ECSP.
1
' Duke Energy 1 33

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Entrainment Characterization Study Plan L�'1
Roxboro Steam Station r `
Response and Resolution
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
judicious number of samples could be collected with another method,at
..3 a time when densities are relatively high),that would go a long way See Pumped Sampler White Paper(Appendix C)
toward addressing any concerns about if,or how much,this method
irunderestimates 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
L
ill vary in size to allow equal Flow from each depth.It is while minimizing friction losses to reduce the amount of suction lift
that flow(and therefore contributlon to the total sample required.Calculations were performed for each facility to account for
e equal through all three openings,but orifice size and flowdiffering standpipe aM piping dimensions;as well as reservoir,intake
the orifice opening are both likely to affect sampling deck,and inlet port elevations.Calculations were based on friction
It each orifice samples the same amount of water,butlosses(converging Flow,piping material and length,orifice size)and
rganisms with different efficiencies,then the combined elevations to determine total head and pump flow.Details will be
entrained organisms will not reflect equal contributions from Provided in the final report.
MOM
Volumes sampled and orifice intake velocities are both important
7 considerations and will factor into the design of the sampling pipe.
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 require a
What sizes will the orifices be,and what will the flow velocity be at the test flume with flow control to achieve the desired test velocities.Since
opening? Both could affect capture efficiency,given escape behaviors one would be removing organisms and water while sampling,one
'VON rheotaxis exhibited by larval fish.If the differences are fairly small it would have to develop a method to replace the removed organisms
may not matter.But some assurance is needed that the setup will and water.If you use a recirculating flume,so only the volume of water
sample the organisms equally,not just the water. If necessary,test runs removed would need to be replaced,then that replacement water
could be done in the lab,sampling larvae of a known density out of a would have to seeded with organisms of a known number.The test
tank. 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 appears to be a simple test,is actually quite
complicated.
Duke Energy 35

r r r r �■ �r r� �■r r ■� r r r r r r r . r
Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
Response and Resolution
If a 330-pm mesh net works without dogging,that would be Ideal;but I
problems occur then use of a—500 pm mesh net would be acceptable
" 3 for egg and larval fish collections.That mesh size Is often used in larval No response required
fish collections,and the prior study at Hyco in 1979.80 used 571 pm
Wesh net(note that replicate samples were collected in that project).
T Systems using trash pumps with recessed impellers routinely collect
The proposal notes that"property designed and operated pumped- greater than 95 percent of fish eggs and larvae.Unfortunately neither
systems have shown collection efficiencies of 95 percent or greater for EPRI 2005 or EPRI 2014 can provide much greater detail.Both state,
3� 3 fish eggs and larvae with little or no organism damage(EPRI 2005)." "Studies of properly designed and operated pumped systems have
However,it wasn't clear how this was measured and if it directly applies revealed little damage or destruction of entrained organisms with
to this situation.It would be helpful if you could elaborate a bit. collection of greater than 95 percent of fish eggs and larvae being
routinely achieved."
s. agree that collection at the intake structure Is preferable to sampling No response required.`
organisms atter passage through the cooling system.
I don't think it's a problem if low intake velocities for the CW )allow
� _
' 3 some animals to escape due to avoidance behavior,
w
or,as that would Agreed.
happen anyway.
3 4 The lab and field SOP and audit plans are generally sound, No response needed.
However,an Average Outgoing Quality Limit(AOQL)of 1%(a 99%
accuracy)strikes me as rather liberal for data entry.It seems to me that Typically the average outgoing quality(AOQ)is better than the AOQL.
an error rate of one error per 100 entries is too high.How does it
3 4 compare to the observed error rate on similar work(I expect actual Both this and the AOQL for larval identification are industry standard for
accuracy is typically better than that)? If it is feasible to commit to a entrainment sampling.
lower error rate that would be preferred.
The sampling plans implemented under our proposed QC procedures
Ikewise,an AOQL of 10 percent for organism identification seems have a specified average outgoing quality limit(AOQL)of 10 percent,
pretty high to me(I expect the error rate will be lower than that for which represents the maximum fraction of all items(e.g.,
experienced personnel).I recognize that identifying fish eggs and larvae measurements,taxonomic identifications or counts)that could be
is tricky,so I fully expect some individuals to end up in broader defective as a worst case.A defective item could be a measurement or
to,
categories(e.g.,unidentified shiners or unidentified larvae)—1 don't count that falls outside of a specified tolerance limit(e.g.,plus or minus
consider that an identification error.But I would expect organisms 1 to 10 percent).Typically the average outgoing quality(AOQ)is better
identifiable to a given taxonomic level to be correctly classified more than the AOQL.Items are inspected using a QC procedure derived
than 90%of the time.Again,what is the observed error rate on similar from MIL-STD(military-standard)1235B(single and multiple level
analyses? Maybe my expectations are too high. 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.
Duke Energy 36

r� r r r r w r r w r r w r r r w r ■� ■�
Entrainment Characterization Study Plan 1
Roxboro Steam Station J��`
®� Response and Resolution
The data security and chain-of-custody plan is good,but one can never
be too careful.Data remain vulnerable to loss during the period when
4 they exist only on one hardcopy datasheet,particularly while still in the This is a good idea.We added text that a digital image of the datasheet
field.You might consider taking a picture of each datasheet when will be taken in the field prior to the datasheets leaving the site.
completed,to have an electronic backup until the datasheet can be
scanned or entered into a computer.
■ Given that regulatory compliance isometimes the subject litigation, I
think that retaining samples for only three years is not sufficient.
nt My Revised to indicate samples will be held until Duke Energy aufhoriz
il
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) . response
,on ,uired... -
5 to be used are of the type that will not cause organism damage as No response required..
noted in EPRI(2005).
5 Proposed preservation methods will fix organisms in a manner that will No response req
jnaintain their morphological integrity for identification purposes.
Pfhe 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.When estimates of entrainment are
generated,moribund,dead,and non-viable individuals will not be
included." The discrimination of dead,moribund or non-viable eggs Agreed.We vri11 want to look at the data inclusive and exclusive of our
from live eggs is a critical step because it directly affects entrainment two categories.At present there are few reliable methods that are not
5 estimates.Differences between live and dead individuals are often fairly time consumptive or expensive to implement. Here we are thinking of
_ obvious in fresh samples,but can be markedly reduced after excluding only the most obvious categories of organism. For example,
preservation.Because any error in this process will bias entrainment we might require eggs be whole,show signs of fertilization,and not be
estimates downward I expect this step would receive heightened covered with fungus.
scrutiny.Therefore the methodology should be fully explained,and be
pretty iron-clad.Even if it is,I certainly recommend retaining both
_ groups of eggs in separate vials,and be prepared to provide
iientramment estimates based on both groups combined as a
16servative measure of entrainment if necessary.
Duke Energy 37

Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
®M Response and Resolution
The final Rule does not require replication nor Is there an obligation to
provide confidence intervals or bounds around the entrainment
estimates generated.The study must be sufficient to stow diel,
monthly,and annual variation,which this study plan addresses.
e Rule requires"sufficient data to characterize annual,seasonal,and We interpret the Rule as requiring sufficient sampling to collect data
I variations in entrainment,including but not limited to variations over the range of conditions that are likely to occur and to prevent bias
ted to climate and weather differences,spawning,feeding,and through selective sampling.For example,you could not propose to
ler column migration." The proposed sampling plan calls for sample only during the day,because you would miss any density
lacting a single,large sample in each sampling period.I believe that differences due to diel variability.You could not propose to sample only
s collection plan will provide data representative of the entrainment at on sunny days,because you would miss any density differences due to
intakes,but determining if apparent patterns or differences are real weather.You could not propose to sample only from near the bottom of
the requirements seem to call for)requires some measure of the intake,because you would miss any density differences due to
'ability in the estimates.That requires replicates.The number of vertical stratification in the water column.
pies collected over the course of the project will be sufficient to
act
annual variation between the two years,but seasonal,diel and We believe that the way in which these data will be used do not justify
ther effects would be confounded with each other.Additional extensive replication.Relationships between weather,climate,
lication is necessary in order to determine if any of these factors spawning,and feeding(as a few examples)and entrainment rates are
ecl entrainment.For example,one could not separate weather effects not going to change the determination of best technology available for
temporal differences in this sampling design.If it is necessary to be entrainment reduction or the outcome of any social cost/social benefit
e to show whether or not there are effects of weather,enough calculations.In addition,the study plan includes some replication.Each
pies will be needed to use weather variables(e.g.,water sampling event is divided into four independent samples based on time
perature,cloud cover)as covariates to test for effects. 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 to divide each 2-hour We disagree that splitting each 2-hour sample into smaller sub-samples
sample into at least three,preferably four,samples collected requires only a small additional effort.While it is true that the extra
"8 immediately one after the other.The collection cup(or entire net)could effort in the field would be minimal(extra net wash-clowns,extra
be swapped out after a sample and processed while the next sample is datasheets to fill out),the effort(and associated labor costs)in the
being collected.This replication would allow straightforward statistical laboratory would increase proportionally.So splitting the 2-hour
ibgnalysis to determine if these factors(or their interaction)affects samples into four sub-samples will quadruple the lab costs.
Flintrainment.
�...,.....__W Replication is important for density estimates,but it would not be
necessary to have morphometric measurements on a full compliment of
indviduals from each replicate;one pooled sample for each six-hour
pe would suffice.A total of up di 10 individuals of each taxon could Agreed.
at random from all the individuals collected in all replicates
Mkowithin one six-hour sampling period.
Duke Energy 38

Entrainment Characterization Study Plan FN
Roxboro Steam Station
®� Response and Resolution
. Any vertical migration should be adequately integrated by the multi-
' pth sampling scheme,and the temporal pattern of sampling should We agree.Our interpretation of EPA's request is that sampling
tect the seasonality of spawning. It is unclear to me what"feeding encompasses the range of conditions and fish behaviors likely to occur
nation"refers to or how sampling will assess it,but itis also unclear to in a typical entrainment season.That is,if feeding behavior impacts
a how that is relevant for this assessment.If this refers to changes in vertical migrations in the water column,then you would need to sample.,
ing behavior over the diel period or seasonally that would increase during periods that include those in which larvae are feeding.
decrease vulnerability to entrainment,then I believe such effects
Ertl'
uld be adequately captured by the proposed sampling scheme.
minor modifications as rested in responses to other questions,this
y design should provide a sound basis to support Me required No response required.
benefits analysis.
The proposal is dearly written and understandable.Points to be added
8..... . or elaborated upon,or deficiencies in the design,have been noted No response required.
above.
Duke EnwW 30

' Entrainment Characterization Study Plan
Roxboro Steam Station r L��
APPENDIX C - Comparison of Pumps and Nets for
Sampling Ichthyoplankton
Duke Energy 40

' Entrainment Characterization Study Plan 1
Roxboro Steam Station r
' Comparison of Pumps and Nets for Sampling Ichthyoplankton
' Prepared by:
440 S. Church Street, Suite 900
' Charlotte, NC 28202-2075
February 19, 2016
' 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
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
meetings, there was a concern among the biological reviewers that the proposed pumped
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
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
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
eggs and larvae.
Each method has advantages and disadvantages and a comparison of the two methods are
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
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
s Held at HDR offices in Charlotte,NC,January 28-29,2016.
Duke Energy 1 41

Entrainment Characterization Study Plan
Roxboro Steam Station 1 L
1
' were determined to offer the best, most cost-effective, and consistent sampling method for Duke
Energy and therefore were included in the draft ECSPs.
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
York', Pennsylvania, New Hampshire', 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
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
associated with pump passage. (e.g.,frame-mounted nets in frame guides).
- Less precise flow metering than pumped
samplers.
-Large volumes are sampled quickly—
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.
e 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.
The states of New Hampshire and Massachusetts do not have delegated authority to issue NPDES permits and are administered
by EPA Region 1.
Duke Energy 1 42

' Entrainment Characterization Study Plan 1
Roxboro Steam Station r
1Gear Type Advantages Disadvantages
- 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 nets8.
- Greater potential for extrusion than pumped
samples(no buffering tank).
- Boat deployed nets are subject to weather
delays and associated safety concerns.
- May be restricted to relatively deep areas that
are free of floating debris,submerged
snags,and other obstructions
Pumped -Sample durations are typically longer - Some active avoidance possible by larger
Samplers in the 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. - Improperly designed samplers can lead to
i - 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
- In-line flow metering offers greater precision generally smaller than net openings.
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-um nets
increases potential for net occlusion and
frequent net change outs may be required
during certain times of the year).
1
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.
Duke Energy 1 43

Entrainment Charactenzation Study Plan 1 ��
Roxboro Steam Station r
' 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
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]) pump' was compared to a 2 m long (6.6 feet), 0.5-m (1.6-feet) diameter, 243-Nm
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
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.
Duke Energy 1 44

' Entrainment Characterization Study Plan 1 ��
Roxboro Steam Station r
' 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-Nm 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-Nm 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.
' Duke Energy 1 45

' Entrainment Characterization Study Plan
Roxboro Steam Station r L��
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,10 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
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-Nm WP2 nets",
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.
' 10 Sampler efficiency was only presented for surface sampler in Gale and Mohr 1978.
" The WP2 Net is a vertical plankton net with messenger operated closing mechanism based on the design of the UNESCO
Working Party 2.
' Duke Energy 1 46

' Entrainment Characterization Study Plan
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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.O/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 and M.J. Van Den Avyle. 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, Georgia12 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
M'/sec (312 gpm) capacity. Pumped samples were discharged into a 297-Nm 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 m) were collected with a towed net that was
0.25-m2 (2.7 feet) 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 Energy's Oconee Nuclear Station on
Lake Kecwee in South Carolina.
1
' Duke Energy 1 47

' Entrainment Characterization Study Plan L��
Roxboro Steam Station r
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
Cooling Systems. Journal of the Fisheries Research Board of Canada, 1979, 36(1): 81-84
Leithiser et al. (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-Nm) and 1.0-m (335-Nm 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
' 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).
1
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' Entrainment Characterization Study Plan L��
Roxboro Steam Station (�
' 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-um 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
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-Nm 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-Um 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.
1 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
' Duke Energy 1 49

' Entrainment Characterization Study Plan FN
Steam Station
' entrainment. The Tucker trawl had 710-Nm mesh with a 1 m2 (10.8 feetz) effective opening.
Samples were collected perpendicular to the intake (starting as near as possible to the intake).
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
' 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.
1
Duke Energy 1 50

' Entrainment Characterization Study Plan FN
Steam Station
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 (m) (Leonard and Vaughn 1985)
��JMn��
®' ©®' ©®' © 5®' ©6.4 164 1®' ©95.3 27 2®'
' 7.9
Jun 7 0 0.0 8 34.0 60 -0 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
' 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
Ave. 29 92 65 38 206 317
Sample
Volume
(m)
' a-Unable to calculate volume
-Number not considered valid due to malfunctioning equipment
' `-Density not calculated on invalid data
' 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.
Taggart 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
(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
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,
' 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
systematic biases were detected.
In addition to the literature review, Taggart and Leggett (1984) tested a large-volume pump
' system 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
' the inlet was oriented into the direction of travel. Simultaneously to pump sampling, a 0.5-m
Duke Energy 1 51

' Entrainment Characterization Study Plan
Roxboro Steam Station r LN
(1.6-feet) diameter 2-m (6.6 feet) long 80- and 153-Nm mesh standard plankton nets were also
fished. Three sets of comparisons were made. In 1981 an 80-Nm net was towed immediately
' below the surface 2 m (6.6 feet) behind the pump intake. In 1982 and 1983 a 153-Nm 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 (Mallotus villosus) larvae (5-mm length), herring (Clupea harengus) larvae (9-mm
' length), large copepods (>750 Nm), 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
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' Duke Energy 1 52

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' Entrainment Characterization Study Plan
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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)13. 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 <_ 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
13 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 were 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 facilities;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 1 54

Entrainment characterization Study Plan
Roxboro Steam Station r L��
' 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
that no gear efficiency testing is necessary or warranted.
' Duke Energy 1 55

Entrainment Charactenzation Study Plan 1 ��
Roxboro Steam Station r
References
' Aron, W. 1958. The Use of Large Capacity Portable Pump for Plankton Sampling, with Notes on
Plankton Patchiness. Journal of Marine Research 16: 158-173.
Bowles, R.R. and J.V. Merriner. 1978. Evaluation of ichthyoplankton sampling gear used in
power plant entrainment studies. In L. Jensen (ed.). Fifth National Workshop on
Entrainment and Impingement. pp. 149-158.
' 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.
' Ecological Analysts, Inc. (EA). 1978. Indian Point Generating Station Entrainment Survival and
Related Studies 1977 Annual Report. Consolidated Edison Company of New York, Inc.
' EA. 1981. Indian Point Generating Station Entrainment and Near Field River Studies: 1979
Annual Report. Consolidated Edison Company of New York, Inc.; Power Authority of the
' State of New York.
Elder, J.A., J.W. Icanberry, D.J. Smith, D.G. Henriet, and C.E. Steitz. 1979. Assessment of a
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