NC0007064_Response to Comments_20161012

BSEP 16-0090
Enclosure
.:,
OCT 12 2016
Water Quality
Permitting Section
Brunswick Steam Electric Plant
Response to Comments

RECEIV EDI NCDEQ1 D'iVP
OCT 12 2016
Water Quality
Permitting Sect9on
Respons'e to NCDEQ
w
Entrain'rnent
a 3ti� s i ��, P
t�: cl:
DUKE
ENERGY
September 1,- 2016
AT
F

Entrainment Characterization Study Plan
Response to NCDEQ Comments — Brunswick Steam Electric Plant
Contents
Introduction..............................................................................................
Development of Entrainment Characterization Study Plans ...................................................
M
Duke Energy 1 1

Entrainment Characterization Study Plan
Response to NCDEQ Comments — Brunswick Steam Electric Plant
1 Introduction
M
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 a National Pollutant Discharge Elimination System
(NPDES) permit. Existing facilities with an actual intake flow >_ 125 MGD are required to provide
an entrainment characterization study (40 CFR 122.21(r)(9)) as part of their permit renewal
application. Duke Energy has proposed using entrainment data collected as part of the
Brunswick Steam Electric Plant's (BSEP's) NPDES monitoring requirements, supplemented
with the monthly collection of eggs during 2016 and 2017, to prepare the entrainment
characterization study for BSEP. The goal of the entrainment characterization study is to
estimate the seasonal and annual abundance of fish eggs and larvae that are drawn into the
cooling water systems.
2 Development of Entrainment Characterization
Study Plans
An Entrainment Characterization Study Plan (ECSP) was developed for BSEP. The ECSP
describes the sampling design and site-specific approach for entrainment sampling; the
rationale for the selection of gear type, sampling location, and other components of the
sampling design; and a discussion regarding 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 review. Comments
were received from Bryn H. Tracy (Senior Environmental Specialist, North Carolina Department
of Environmental Quality [NCDEQ]) by email on July 27, 2016 and these comments, as well
responses to comments, are provided in Table 2-1.
Duke Energy 11

Entrainment Characterization Study Plan
Response to NCDEQ Comments — Brunswick Steam Electric Plant
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 Brunswick Steam Electric Plant
Brunswick Page 44, Category,1, Charge 3, Response and
Resolution,, 3rd ,Paragraph = goes'the lack„of so,ciaf';;,-'
"benefit (commercial 'and/or recreational) for,
anchovies, gobies, and silversides outweigh their
ecological. importance as part of the forage base and
r thus,justify„ not providing them with some sort of, .tee
protection? Is this in the 316(6) final rule? Can you,
provide a scientific citation for reaching this
conclusion?
Brunswick I have rfo other comments on this Entrainment
Characterization Study Plan.
Forage fish have ecological benefit and play a” critical role in functional food webs. The
traditional approach for, estimating;the,ualue.of,forage'fish'is to determine,„their biomass
aril convert"that estimate'to fish with commerciahor recreational value'"(e.g., bass). Since
these models have trophic transfer efficiency built in (that is, 1 Ib. of forage fish equals <1 I
Ib. of bass), they necessarily confer less value to forage fish than commercial and
recreational fish: Therefore,' from, a purely resource economics' stand poi nt,.these",fish
contr'ibute'less to the °social benefit than species that are considered, important in a
recreational and commercial sense. 9
Furthermore ,'rnesh,sizes, smaller than^505-pm.LLar�e impractical for use at Brunswick due to,
clogging°and e6'sfruction.offhe'inesli''openings` Duke Energy"will`'carry""out sensitivity
analyses when developing social benefits using high and' low entrainment rates, which will
help qualify the affect over or under estimating entrainment has on the social benefits.
No response necessary.
Crabtree, Roy E. Ph.D., Regional Administrator, National Marine Fisheries Service (2012 August 20). Re: Request to Reinitiate Section 7
Consultation for Atlantic Sturgeon at Brunswick Steam Electric Plant, Units 1 and 2 [Letter to: Mr. Jeremy J. Susco. Acting Chief, Nuclear
Regulatory Commission].
Duke Energy 1 2
w°4�a��s ,a, . ,"?; a",:
•;4i<:'aeiS µ'a Y, E1.aavP."4 •• •, • • ,1y�!wCa1<""'4",""3a;;,r.l.`:\ :
`\
44
�',
1k%�,
Brunswick Page 18 — I believe there was a recent notice in the
Brunswick is within the proposed critical habitat listing for Atlantic Sturgeon, which includes
Federal Registrar regarding designation of critical
sections of the Cape Fear River from its confluence with the Atlantic Ocean to the fall line
habitat for Atlantic Sturgeon and possibly Shortnose
(Critical Habitat for the Endangered Carolina and South Atlantic Distinct Population
Sturgeon. Looking into your crystal ball, do you
Segments of Atlantic Sturgeon).
expect critical habitat for these two species to include
.
any areas in the vicinity of the Plant?
The Nuclear Regulatory Commission (NRC) received a determination from the National
Marine Fisheries Service (NMFS) regarding the potential for activities at Brunswick to
adversely affect sturgeon: it stated that Atlantic Sturgeon are not likely to be adversely
affected by the operation of Brunswick Nuclear Planta '
Brunswick Page 44, Category,1, Charge 3, Response and
Resolution,, 3rd ,Paragraph = goes'the lack„of so,ciaf';;,-'
"benefit (commercial 'and/or recreational) for,
anchovies, gobies, and silversides outweigh their
ecological. importance as part of the forage base and
r thus,justify„ not providing them with some sort of, .tee
protection? Is this in the 316(6) final rule? Can you,
provide a scientific citation for reaching this
conclusion?
Brunswick I have rfo other comments on this Entrainment
Characterization Study Plan.
Forage fish have ecological benefit and play a” critical role in functional food webs. The
traditional approach for, estimating;the,ualue.of,forage'fish'is to determine,„their biomass
aril convert"that estimate'to fish with commerciahor recreational value'"(e.g., bass). Since
these models have trophic transfer efficiency built in (that is, 1 Ib. of forage fish equals <1 I
Ib. of bass), they necessarily confer less value to forage fish than commercial and
recreational fish: Therefore,' from, a purely resource economics' stand poi nt,.these",fish
contr'ibute'less to the °social benefit than species that are considered, important in a
recreational and commercial sense. 9
Furthermore ,'rnesh,sizes, smaller than^505-pm.LLar�e impractical for use at Brunswick due to,
clogging°and e6'sfruction.offhe'inesli''openings` Duke Energy"will`'carry""out sensitivity
analyses when developing social benefits using high and' low entrainment rates, which will
help qualify the affect over or under estimating entrainment has on the social benefits.
No response necessary.
Crabtree, Roy E. Ph.D., Regional Administrator, National Marine Fisheries Service (2012 August 20). Re: Request to Reinitiate Section 7
Consultation for Atlantic Sturgeon at Brunswick Steam Electric Plant, Units 1 and 2 [Letter to: Mr. Jeremy J. Susco. Acting Chief, Nuclear
Regulatory Commission].
Duke Energy 1 2

BSEP 16-0090
Enclosure
Brunswick Steam Electric Plant
Final Entrainment Characterization Study Plan

F)�
.Entrainment, -Characterization-
Study Plan
Prepared for:
NDUKE
ERDY
Prepared by:
HDR Engineering; Inc.
September 2; 2016

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Contents
1 Introduction..................................................................................................................
1.1 Regulatory Background......................................................................................
1.2 Study Plan Objectives and Document Organization ............................................
2 Generating Station Description.....................................................................................
2.1 Source Waterbody..............................................................................................
2.2 Station and Cooling Water Intake Description.....................................................
2.2.1 Diversion Structure.................................................................................
2.2.2 Intake Canal and Intake Structure..........................................................
2.2.3 Fish Return System................................................................................
3 Historical Studies.........................................................................................................
4 Rare, Threatened, and Endangered Species................................................................
5 Basis for Sampling Design..............................................................................
6 Entrainment Characterization Study Plan ........................................................
6.1 Introduction...........................................................................................
6.2 Sample Collection..................................................................................
6.3 Sample Sorting and Processing.............................................................
6.4 Data Management and Analysis............................................................
6.5 Laboratory Quality Control.....................................................................
6.6 Reporting..............................................................................................
7 References.....................................................................................................
APPENDIX A —Select Species Spawning and Early Life History Data ......................
APPENDIX B — Response to Informal Review Comments .........................................
FN
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Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Tables
0
Table 1-1. §316(b) Rule for Existing Facilities Submittal Requirements Summary ....................................2
Table 2-1. Brunswick Steam Electric Plant Circulating Water Pump Intake Flow by Unit and Average Daily
Water Withdrawal from the Cape Fear River, 2013-2014 (USEIA 2015) ................................................... 6
Table 3-1. Number of Larval Organisms Collected During Entrainment Sampling at the Brunswick Steam
Electric Plant, 2010-2012 (Source: Duke Energy 2014)..........................................................................13
Table 3-2. Mean Annual Percent Reduction in the Number of Representative Taxa Entrained at
Brunswick Steam Electric Plant, 1984-2012 (Source: Duke Energy 2014) ..............................................16
Table 4-1. Rare, Threatened, or Endangered Species and Potential to Occur Near Brunswick Steam
ElectricPlant.........................................................................................................................................18
Table 5-1. Summary of Approach for Development of §122.21(r)(9) Required Entrainment
Characterizations................................................................................................................................... 21
Table 6-1. Entrainment Sampling Details...............................................................................................23
Table A-1. Spawning and Early Life History of Fish Species Present at Brunswick Steam Electric Plant. 30
Table A-2. Spawning and Early Life History of Crab Species Present at Brunswick Steam Electric Plant 34
Table A-3. Spawning and Early Life History of Shrimp Species Present at Brunswick Steam Electric Plant
.............................................................................................................................................................. 36
Table B-1. Directed Charge Questions...................................................................................................40
Table B-2. Peer Reviewer Responses to Directed Charge Questions.....................................................42
Duke Energy 1 11

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Figures
FN
Figure 2-1. Brunswick Steam Electric Plant Vicinity Map (Source: Progress Energy 2011) ....................... 5
Figure 2-2. Aerial View of Brunswick Steam Electric Plant........................................................................ 7
Figure 2-3. Site Configuration of Brunswick Steam Electric Plant (Source: Duke Energy 2014) ................8
Figure 2-4. Aerial View of the Diversion Structure at Brunswick Steam Electric Plant ............................... 9
Figure 2-5. Photograph of Brunswick Steam Electric Plant's Cooling Water Intake Structure (Looking
upstream)..............................................................................................................................................10
Figure 2-6. Plan View of Fish Return System at Brunswick Steam Electric Plant....................................11
Figure 3-1. Annual Number of Total Organisms Entrained at Brunswick Steam Electric Plant and Percent
Reduction from Baseline Entrainment Estimates, 1979-2004 (Source: Duke Energy 2014) ....................15
Figure 4-1. Geographical Boundary of the IPAC Search.........................................................................17
Figure 6-1. Cumulative Distribution of Sampling Results. Note the Similarity in Entrainment Estimates
Derived from Utilizing Data Collected Weekly (Blue Line) and Data Collected Monthly (Green Line)....... 23
Figure 6-2. Aerial View of Sampling Location at Brunswick Steam Electric Plant (Image Modified from:
GoogleEarth)........................................................................................................................................25
Figure 6-3. Photograph of Entrainment Sampling of the Discharge Weir at Brunswick Steam Electric Plant
(Source: Duke Energy 2014).................................................................................................................. 25
Duke Energy I ill

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Acronyms and Abbreviations
FN
°C........................................................................................................................ degrees Celsius
OF..................................................................................................................
degrees Fahrenheit
AIF...................................................................................................................
actual intake flow
BSEP...........................................................................................
Brunswick Steam Electric Plant
BTA....................................................................................................
Best Technology Available
CCW......................................................................................................
condenser cooling water
cfs...............................................................................................................
cubic feet per second
CP&L....................................................................................
Carolina Power and Light Company
CWIS.............................................................................................cooling
water intake structure
DIF...................................................................................................................
design intake flow
Director ................................................National
Pollutant Discharge Elimination System Director
Duke Energy...................................................................................
Duke Energy Carolinas, LLC
ECSP........................................................................... Entrainment Characterization Study Plan
EDT............................................................................................................
Eastern Daylight Time
EI...................................................................................................................................
elevation
EPA..................................................................................U.S. Environmental Protection Agency
EST.......................................................................................................... Eastern Standard Time
gpm.................................................................................................................gallons per minute
HDR......................................................................................................... HDR Engineering, Inc.
IPAC........................................................... Information for Planning and Conservation (website)
ms cubic meter
..............................................................................................................................
MW............................................................................................................................... megawatt
4.im.............................................................................................................. micrometer or micron
mm............................................................................................................................... millimeter
MGD......................................................................................................... million gallons per day
msl........................................................................................................................ mean sea level
NMFS......................................................................................National Marine Fisheries Service
NCDENR ..............................North Carolina Department of Environment and Natural Resources
NPDEQ...................................................... North Carolina Department of Environmental Quality
NCWRC.............................................................. North Carolina Wildlife Resources Commission
NPDES............................................................ National Pollutant Discharge Elimination System
PEC............................................................................................Progress Energy Carolinas, Inc.
QA.................................................................................................................. Quality Assurance
QC........................................................................................................................ Quality Control
RIS.......................................................................................... Representative Important Species
RTE.........................................................................................Rare, Threatened, or Endangered
SOP...........................................................................................Standard Operating Procedures
USAEC..................................................................................... U.S. Atomic Energy Commission
USEIA..............................................................................U.S. Energy Information Administration
USFWS.......................................................................................... U.S. Fish and Wildlife Service
USNRC.............................................................................. U.S. Nuclear Regulatory Commission
Duke Energy I iv

Entrainment Characterization Study Plan ��i
Brunswick Steam Electric Plant c
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 or their eggs 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 power generating facilities with design intake flows (DIF)
that withdraw more than 2 million gallons per day (MGD) 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 final Rule supersedes the Phase II Rule, which regulated large electrical
generating facilities until it was remanded in 2007, and the remanded existing -facility aspects 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 for submittal and
the compliance schedule are dependent on actual intake flow rates (AIF) at the facility and
NPDES permit renewal date. Existing facilities with an AIF z 125 MGD are required to address
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 a BTA for
entrainment on a site-specific basis and the applicant may supply information relevant to the
Director's decision. Facilities are required to submit §316(b) application materials 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 Progress, LLC's (Duke Energy) Brunswick Steam Electric Plant (BSEP) 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
timeframe 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 part of the development of this Study Plan,
Duke Energy submitted an earlier draft of this document to a subject matter expert in the field of
Duke Energy 11

Entrainment Characterization Study Plan ���
Brunswick Steam Electric Plant
fisheries (see Appendix B) for review and identified the subject matter expert as a peer reviewer
to the State.
While the descriptions of equipment and methods included in this ECSP were intended to be
implemented as written, changes to the ECSP 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
t.
(2) Source Water
Physical Data
Characterization of the source water body including intake area of influence
rCooling Water Intake
i Characterization of cooling water system; includes drawings and narrative; description of operation;
Structure Data
li 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; existing data; identification of missing data;
Characterization data
threatened and endangered species and designated critical habitat summary for action area; fragile
fish and shellfish species list (<30 percent impingement survival)
!! Cooling Water
Describes cooling water system and intake structure; proportion of design flow used; water reuse
System'Data
summary; proportion of source water body withdrawn (monthly); seasonal operation summary; f
existing impingement mortality and entrainment reduction measures; flow/MW efficiency
Chosen Method of
Compliance with
Provides facility's proposed approach to meet the impingement mortality requirement (chosen from
(i)
Mortality
seven available options); provides detailed study plan for monitoring compliance, if required by
Standard
selected compliance option; addresses entrapment where required
______—^----.------
be
i
(7)
Entrainment
Provides summary of relevant entrainment studies (latent mortality, technology efficacy); can ,f
from the facility in question or elsewhere with justification; studies should not be more than 10 years
II
Performance studies
i 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 I
u in entrainment, including variations related to climate, weather, spawning, feeding, and water
G
column migration; facilities may use historical data that are representative of current operation of the f
facility and conditions at the site with documentation regarding the continued relevance of the data i
Entrainment
(9) 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
;i
in the water body and water column are accounted for; must document intake flows associated with
i
I the data collection; documentation in the study must include the method in which latent mortality
would be identified (including QA/QC); sampling and data must be appropriate for a quantitative E
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 i
! entrainment technologies from (r)(10) using data in (r)(9); benefits to be quantified physical or
Benefits Valuation biological units and monetized using appropriate economic valuation methods; includes changes in E
(11)'i;! fish stock and harvest levels and description of monetization; must evaluate thermal discharges,
Study facility capacity, operations, and reliability; discussion of previous mitigation efforts and effects; 4
! benefits to environment and community; social benefits analysis based on principle of willingness -to-
pay; requires peer review
Duke Energy 1 2

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant c�
- `__ =00,
Non -Water Quality Provides a discussion of non -water quality factors (air emissions and their health and environmental
12 , Environmental and impacts, energypenalty,' thermal discharge, noise, safety, ( ) p p lt y.� 9 y, grid reliability, consumptive water use,
Other Impacts .'
Assessment etc.) attributable to the entrainment technologies; requires peer review
f A,-Documentation,"ofyextemal peer review„by
Peer,R'eview vnj`
„ � Peer” Reviews must "-lie `�approved� by- the
JV applicant must" explain why:significanl;'F
=applicable: ,
alified experts,° ofsubmitfals (
?DES" Director -"and $pr'e'sent,`
reviewer, =�eco' mmefid ations
"0
reoentialsr- I ne
disregarded, 'if
s
Study Plan Objectives and Document OrganizatioZ
The ECSP is developed to support BSEP's §316(b) compliance through development of a site-
specific ECSP with the following objectives in mind:
1. Collect data to support development of §122.21(r)(9), which requires a two year
minimum Entrainment Characterization Study 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 goal of obtaining sufficient data to evaluate the
biological efficacy of potential alternative intake technologies. This may require site
specific evaluations and 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 the development
of §122.21(r)(4), which requires characterization of the biological community in the vicinity of the
CWIS and includes identification 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 relevant to
cooling water intake evaluations (Section 3), a summary of Rare, Threatened, and Endangered
(RTE) 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
for species likely to be entrained (Appendix A), and responses from informal peer reviewers to
the charge questions on the ECSP (Appendix B). The species included in Appendix A are
representative species entrained and impinged at the BSEP in 2010 through 2012.
Duke Energy 1 3

Entrainment Characterization Study Plan FN
Steam Electric Plant
s
This section presents background information on the source waterbody (Cape Fear Estuary)
from which BSEP withdraws cooling water and provides information regarding the design and
operation of the CWIS.
2.1 Source Waterbody
The BSEP is located adjacent to the Cape Fear Estuary approximately 5.7 miles upstream from
the mouth of the Cape Fear River (Figure 2-1). The BSEP is located in the eastern -most part of
the Coastal Plain Physiographic Province, near the southeastern border of North Carolina. It is
in a region of low relief, with elevations ranging from sea level to approximately 30 feet above
mean sea level. Extensive areas of fresh- and salt -water marsh and swamps exist in the region
(USAEC 1974).
The point at which water is drawn into BSEP's intake canal is located in the Cape Fear Estuary.
Estuaries are tidally influenced, partially enclosed, coastal areas where freshwater and saltwater
mix. These areas are typically protected from the full force of wind -driven ocean waves, often by
barrier islands, spits, salt marshes, or other land forms (USNRC 2006). Species found in
estuaries are specially adapted for life in this transitional area.
The region surrounding the BSEP intake canal entrance is an area that experiences a large tidal
exchange (CP&L 1985). A salinity gradient exists where runoff from the Cape Fear River mixes
with water from the Atlantic Ocean. The water near the BSEP intake is well -mixed because of
complex water circulation patterns, tidal effects, and high exchange ratios with the ocean. This
portion of the estuary is shallow and irregular in shape with many islands and channels that
enhance mixing (CP&L 1985). A dredged channel extends from the mouth of the river upstream
to the North Carolina State Ports Authority located at Wilmington, NC. Salinity is influenced
primarily by tidal conditions and the rate of freshwater inflow. Because the freshwater inflow
from the Cape Fear River and its tributaries is highly variable, salinity at the intake may range
from nearly zero to thirty-two parts per thousand (USAEC 1974).
The Cape Fear Estuary serves as a nursery area for larval and post -larval stages of fish and
shellfish. Some species such as anchovy (Anchoa spp.) are spawned in the estuary while other
species such as Atlantic Menhaden (Brevoortia tyrannus) are spawned in the ocean (PEC
2003). Salinity and temperature influence the spatial and seasonal distribution of these
estuarine species (CP&L 1985). The ebb and flow of water in the estuary also contributes to the
transport and/or retention of larvae and other organisms throughout the estuary (CP&L 1980).
Duke Energy 14

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Wiz' �.�"•:,�z�=� z,= �=F � - .. a � `, 1 Y � - ' - d
�B�Pt�srvic:kwtn � � .
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Figure 2-1. Brunswick Steam Electric Plant Vicinity Map (Source: Progress Energy 2011)
Duke Energy 1 5

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant FN
7111
T ��,'=i i ` v° r a111
The BSEP is located in Brunswick County in southeastern North Carolina, near the mouth of the
Cape Fear River. The BSEP is a two -unit thermal power plant that uses boiling water reactors
and steam -driven turbine generators with a rated output of 1,870 megawatts (MW). The plant
has been in operation since the mid 1970s. The BSEP has two nuclear generation units with a
total design intake flow for the cooling system of approximately 1,921 MGD'. The BSEP
incorporates several fish protection features at the facility including: a diversion structure,
modified Ristroph traveling screens (with fine- and coarse -mesh screens), and a fish return
system. In addition, reduced intake flow from December through March reduces the entrainment
of winter spawning fish larvae. The design intake flow rates and actual flow rates (2013 and
2014) are shown in Table 2-1. The general plant layout is shown on Figure 2-2.
Table 2-1. Brunswick Steam Electric Plant Circulating Water Pump Intake Flow by Unit
and Average Daily Water Withdrawal from the Cape Fear River, 2013-2014 (USEIA 2015)
899, 669.5 619.4
Facility' 1,798 1,253 1;304.3-,
' Total station flow (1,921 MGD) includes the cooling water flow from the two main condensers for both units (1,797 MGD) along
with service water flow (115.2 MGD) and screenwash water flow (8.4 MGD).
Duke Energy 1 6

Entrainment Characterization Study Plan MBrunswick Steam Electric Plant
Figure 2-2. Aerial View of Brunswick Steam Electric Plant
Duke Energy 1 7

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
The once -through cooling system is designed to remove waste heat from the two main
condensers when both reactors operate at full power. The cooling water system includes the
intake canal, intake structure, intake pumps, condensers, equipment cooling, and discharge
canal. At the termination of the discharge canal, the Caswell Beach pumping station moves
water through the discharge pipes offshore into the Atlantic Ocean.
The cooling water is withdrawn from the Cape Fear River Estuary by way of a 3 -mile long intake
canal. The intake canal system consists of an open cut from the ship channel through Snows
Marsh and extends through the upland area between the estuary and the plant site. In total, the
intake canal system is approximately 18,000 feet in length (Figure 2-3). The canal bottom is
generally maintained at about -18 feet msl (18 feet below mean sea level) by dredging.
Maintenance of the canal dimensions helps to reduce the approach velocity to the screens.
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uiri'Lo`orancii' ��.
G 9`�:rr;
u4ccess`road'
-" ` s Fisfiu
xi=1Sh C�tllRltflUlYte Rety n base ; .
e:. ,;'•: ' .. 'i" - 'tfIVerSI®n'
nta a canal sfriacttiref
Pl6nt,&ea
�N"
< =Intake structure
ll3SC afge,` "5 if�.yt s:a000
rneters"
�.
O'` ,tom©� 2000 30` Cape Fear River
feet��"
Figure 2-3. Site Configuration of Brunswick Steam Electric Plant (Source: Duke Energy
2014)
2.2.1 Diversion Structure
A fish diversion structure was built across the mouth of the intake canal in 1982 (Figure 2-4).
The diversion structure reduces the number of fish that enter the intake canal and, thus, the
number of fish and shellfish impinged. The diversion structure at the entrance to the cooling
Duke Energy 1 8

Entrainment Characterization Study Plan FNL
Brunswick Steam Electric Plant jN
water intake canal consists of trash racks in front of fixed 3/8 -inch slot sized screens. The trash
racks and screens are inspected daily and cleaned when necessary. During the growing
season, aquatic vegetation is removed (via mechanical rake) several times daily. The diversion
structure is maintained by the BSEP to mitigate potential impacts to sea turtles as well.
Figure 2-4. Aerial View of the Diversion Structure at Brunswick Steam Electric Plant
2.2.2 Intake Canal and Intake Structure
As described above, cooling water is drawn from the Cape Fear River by way of a 3 -mile long
intake canal. The intake canal is subject to the same tidal fluctuations as the Cape Fear
Estuary. Water movement in the intake canal is complex and current velocities vary with
circulating water pump rates, tides (i.e., daily and seasonal variation), and location in the canal
(CP&L 1980). Current velocities in the intake canal are approximately 0.6 feet per second
(CP&L 2000).
The circulating water intake structure consists of eight separate intake bays (i.e., four bays per
unit), each with a trash rack, vertical traveling screen, and vertical intake pump. Over the years
several different combinations of fine -mesh and coarse -mesh panels have been used to
balance larval fish protection and debris loading. As of 2012, there were 42 fine -mesh (1 -mm)
panels and eight coarse -mesh (9.5 -mm) panels on each traveling screen. Each unit typically
operates with three bays in service. The screens are rotated and washed continuously. Fish are
washed off the screens using a low pressure wash. Debris is then removed using a high
Duke Energy 19

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant FN
pressure wash. The fish and debris returns are combined and routed into a common fish return
flume near the end of the intake structure (Figure 2-5).
Figure 2-5. Photograph of Brunswick Steam Electric Plant's Cooling Water Intake
Structure (Looking upstream)
The fish and debris washed from the intake screens are collected and returned via a fish return
system (Figure 2-6). The screenwash water, carrying marine life and debris, flows via the fish
return system into a holding pond (also referred to as the return basin). From this return basin,
the organisms can move into the Walden Creek nursery area and then the Cape Fear River
(Figure 2-3) (Progress Energy undated). Prior to the construction of the fish return system,
CP&L transported impinged organisms to the Cape Fear Estuary by boat (CP&L 1980).
The fine -mesh screens reduce entrainment. Larvae that would have been entrained are
returned alive by the fish return system to the Cape Fear Estuary in substantial numbers (Duke
Energy 2014). Based on site-specific survival estimates, approximately 45 to 49 percent of the
larvae are returned alive to the estuary (Duke Energy 2014). The most valuable commercial
taxa, flounder, shrimp, and swimming crab larvae, exhibited the highest survival rate (>87
percent).
Duke Energy 1 10

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
40.21.
�ASiiS4rsdA��:';S In)o _� x riA.em wviceuY4wt•W�'xecC Av4+xo
'~�!-�t•h. A ♦LTJ
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1 4� cif .w Dn�laJ 'k' �- '�• 0. wt e. ncwnm M•e aur
tom, � t j
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• � � + t �� �y�'+'�ig�\�c�E`AS p� �� �� I F. ewJ ltlVh'+aCP.esuT� + �ikt r
53 <ti}\`� � �:-� n � aarseweu�w�w svamxr aucts^�i
, o.•t tn'Sxt.cxU+v1 c?w.d3W
' " „ h'�. � �\ •\J/
,L�.�
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NI
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- �! � -�• t I,n:.� � _ . _ _ r.cr.r.sA. £r � �v,.sra
-.wfF,oa:. lenaae cdyw.,auucasxas,
/
J/j
le
A/J "�
t/
f'f " .�'
J{ `?i i e J a t :-i�^•y 'F:.;aRnY"G� nPf6c+R-�ye_rY 1 a
a � �({ \ �r.. y._:Y._,..-' ..._3".a.....-H.�...... s•i4mea-naz.natmtt<c<,iAr sexas�
' L.EGTa!'N A.A,'^lV�GFI. GANAL Gt•.��'i 5C4'10ry
' aS�/'F 4Yh w' uory
'� ssi R3r4z.1 E*a'srs
Figure 2-6. Plan View of Fish Return System at Brunswick Steam Electric Plant
Duke Energy 111

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
M. -
Environmental
Environmental studies associated with the BSEP began in 1968, before the plant began
withdrawing water from the .estuary. Comprehensive physical, chemical, and biological studies
of the estuary and near -shore regions were conducted in the mid- and late -1970s. These
original studies were followed by a long-term monitoring program through the early 1990s that
monitored fish and shellfish populations within the estuary and documented the effectiveness of
the intake modifications to reduce entrainment and impingement of organisms. Beginning in
1994, the biological monitoring program was reduced with the concurrence of the North Carolina
Department of Environment and Natural Resources (NCDENR) (Duke Energy 2014). Based on
almost two decades of operation with no detectable adverse impacts on fish and shellfish
populations in the Cape Fear Estuary, the monitoring program was modified to concentrate on
the impingement and entrainment of organisms. Fish population special studies conducted in
the estuarine nursery areas during 1999, 2001, and 2002, indicated no decline in the
abundance of species compared to long-term data collected from the 1980s through 1993.
Results from biological monitoring from 2010 to 20122 provide entrainment rates of larval fish
and shellfish (Table 3-1) and longer term trends (Figure 3-1; 1979-2012) for selected
representative species to evaluate the effectiveness of the NPDES-required intake modifications
(i.e., intake canal diversion structure, fish return system, seasonal reductions in water flow, and
1 -mm slot size fine mesh screens on 42 of 50 intake traveling screens) (Duke Energy 2014).
Biological monitoring data for 2013-2015 will be reported later this year.
2 Biological monitoring continued past 2012, however the 2010-2012 data is the most recent publicly available information.
Duke Energy 1 12

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
LAD
Table 3-1. Number of Larval Organisms Collected During Entrainment Sampling at the
Brunswick Steam Electric Plant, 2010-2012 (Source: Duke Energy 2014)
Elops saurus
Ladyfish
1
2
4
Megalop .aflanticaI
Tarpon
i
0
0
1
Myrophis punctatus
Specked Worm Eel
2
6
1
Alosa,medioctis
i Hickory Shad
1'
t€
0
i=0
Brevoortia tyrannus
Atlantic Menhaden
47
544
33
Anchoa spp.
i An
2,8
';�
459
h754
Synodus foetens
Inshore Lizardfish
6
1
1
z Urophycis spp.
h Unidentified hake
`
1
0.
0
Urophycis regia
Spotted Hake
0
1
0
Menidia spp.
[ Silversides
6 �.. ..
154.
µ'f
7 i. �...,v..�...__,
53
_r
76
_]
Syngnathus spp.
Unidentified Pipefish
0
1
0
Syngnathus.fuscus
i Northern Pipefish
L:
0
;! ""
0
11
1
Syngnathus louisianae
Chain Pipefish
4
0
1
Prinoritus spp.
:, Searobin
!
12
—
0
2
Morone spp.
Temperate bass
1
0
1
Caranx hippos
Crevalle Jack
Trachinotus falcatus
Permit
1
0
0
O►thopristis chrysoptera
= Pigfish
26
7 "
15 _
Lagodon rhomboids
Pinfish
93
89
114
Archosargus probatocephalus Sheepshead - "
0
0
2
Bairdiella chrysoura
Silver Perch
279
31
55
Cynoscion nebulosus
`Spotted Seatrout
�
_ i
57
0
9
w
Cynoscion regalis
Weakfish
18
2
18
Leiostomusxanthurus
' Spot
806
1,192
`
458
Menticirrhus spp.
Kingfish spp.
32
0
0
Micropogonias undulates
' Atlantic Croaker
919
1135
Sciaenops ocellatus
Red Drum
0
0
6
Pogoniascromis -
Black Drum
j
-1
3
0
Stellifer lanceolatus
Star Drum
2
0
0
Chaetodipterus faber"!
Atlantic Spadefish2
"
�0
0
Mugil cephalus
Striped Mullet
3
12
40
MUgil curema
gr
AWhiteMullet
7
.0
0=
Duke Energy 1 13

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Blennidae- Combtooth Blennies
20
25 25
Gerreidae' t:Mojarras w,
Dormitator maculatus Fat Sleeper
0
2 2
e3
4=Gobionelfus s Gob"
Gobiosoma spp. Goby-
869
231 940
? Gobiosoinaibosc`" �-!taNaked�Gob°„
Citharichthys,spp. ` Whiff
5
4 0
3_
r",z u
Paralichfh e -s` Flounder-'� ;". `-�
'"z"
Y.,. P,P, "' 1
Trinectes maculates Hogchoker
28
5 9
Gotiiesozsfruinosus�. _'V-. ;ur
-;
Symphurus spp. Tonguefish
5
3 3
Spheroiilesrnaculates�NortliernPuffer
<3`
a ?
- Unidentified Fish
1
1 << -0
mR(Postlarvae);'�=��=139
� "227n_'l�.•;:y.gg=-,",.
Trachypeneus constrictus T -con or Hardback Shrimp
24
' 14- 18 ,
._: _ d
Portunldae- �rSyirirnr'riin �cratis�
5"
�� 3 `�' _ ,44^ �4
Portunidae- Swimming crab megalops
72
120 122
-t TALvORGANISII S_`,'
G
6,482:=_�
� ,..._
" ` 3"19T, Y
; "
. �" ,
Duke Energy 1 14

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Figure 3-1. Annual Number of Total Organisms Entrained at Brunswick Steam Electric
Plant and Percent Reduction from Baseline Entrainment Estimates, 1979-2004 (Source:
Duke Energy 2014)
Entrainment sampling was conducted in the discharge weir (Figures 2-1, 2-2, and 2-3).
Densities calculated for all larval organisms were averaged to obtain a mean number per 1,000
cubic meters (m) of water entrained through the plant per sampling date (Duke Energy 2014).
An assessment of the overall decrease in entrainment due to fine -mesh screens, fish return
system, and reductions in plant cooling water flow was conducted using historical entrainment
data from 1979 through 2012 (Table 3-2). Data collected in 1983 was excluded from the
analysis since fine -mesh screens and the fish return system were not fully operational for a
portion of that year (Duke Energy 2014). Data that originated prior to 1983 can be used to
estimate the annual number of organisms entrained during a period with no controls in place
(i.e., no fine -mesh screens, fish return system, or limitations of cooling water flow). Mean daily
entrainment densities were multiplied by design cooling water flow and summed to obtain an
annual estimate of total number entrained (Table 3-2). A calculated annual baseline entrainment
rate was obtained by averaging the annual number entrained for years 1979 through 1981.
Therefore, the estimated annual number entrained each year after 1983 was subtracted from
the annual baseline (1979-1981) to obtain a percentage reduction from baseline due to the
installation of fine -mesh screens, fish return system, and reducing cooling water flow (Duke
Energy 2014).
Duke Energy 1 15
9000
100
8000
`t
7000
_, •- "'' !�,
$0
o
0000
t
1
v
a)
5000
- -- — --_ -_ ---- -- – — – - _ =
so
V
4000
40
d)
w
3000
L
L
L_
2000
20
a
1000
Z
0
0
M O T N M It W) W co O O T N M tri CO r— O M O r N M �t
t� OD 00 00 00 c0 CO 00 COO O O O 6') CA 67 6) fA 67 O) 6) O O O O O
6) 67 O) O O O O O O 6) O O 6) O 67 O O Q) O C) 67 O O O O O
T T T T T T T T T T T T T T T T T T T T T N N N N N
--�— Number entrained --= Baseline E
—�— Percent Reduction Target Reduction
Figure 3-1. Annual Number of Total Organisms Entrained at Brunswick Steam Electric
Plant and Percent Reduction from Baseline Entrainment Estimates, 1979-2004 (Source:
Duke Energy 2014)
Entrainment sampling was conducted in the discharge weir (Figures 2-1, 2-2, and 2-3).
Densities calculated for all larval organisms were averaged to obtain a mean number per 1,000
cubic meters (m) of water entrained through the plant per sampling date (Duke Energy 2014).
An assessment of the overall decrease in entrainment due to fine -mesh screens, fish return
system, and reductions in plant cooling water flow was conducted using historical entrainment
data from 1979 through 2012 (Table 3-2). Data collected in 1983 was excluded from the
analysis since fine -mesh screens and the fish return system were not fully operational for a
portion of that year (Duke Energy 2014). Data that originated prior to 1983 can be used to
estimate the annual number of organisms entrained during a period with no controls in place
(i.e., no fine -mesh screens, fish return system, or limitations of cooling water flow). Mean daily
entrainment densities were multiplied by design cooling water flow and summed to obtain an
annual estimate of total number entrained (Table 3-2). A calculated annual baseline entrainment
rate was obtained by averaging the annual number entrained for years 1979 through 1981.
Therefore, the estimated annual number entrained each year after 1983 was subtracted from
the annual baseline (1979-1981) to obtain a percentage reduction from baseline due to the
installation of fine -mesh screens, fish return system, and reducing cooling water flow (Duke
Energy 2014).
Duke Energy 1 15

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
M&... � 41"
Table 3-2. Mean Annual Percent Reduction in the Number of Representative Taxa
Entrained at Brunswick Steam Electric Plant, 1934-2012 (Source: Duke Energy 2014)
Vial ♦y.'Y \�f'M#%<'-..`€ .qrv�7'-�'
"Anchovies
78
Atlantic` -Menhaden ---
Spot
59
C aker
8
Trout
63
Mullet- [
l
89" l
'Flounder
91
G o omaspp�i .-
80
Shrimp (post -larvae)
84
�_
s'-Potunid'crab`.megalops,=s
95
TOTALORGANISMS
76
Gobiosoma spp., Spot (Leiostomus xanthurus), and anchovies (Anchoa spp.) were the most
abundant taxa collected in entrainment samples from 2010-2012. Portunid crab megalops,
Pinfish (Lagodon rhomboides), Microgobius spp. (a genus of gobies), shrimp post -larvae,
silversides (Menidia spp.), and Atlantic Croaker (Micropogonias undulatus) were also among the
ten most abundant taxa entrained one or more years from 2010-2012. Microgobius spp.
typically have not been numerous enough to include among the top ten species. The large
numbers of Microgobius spp. collected during 2012 may have been influenced by the
consistently higher salinities in the Cape Fear Estuary during 2011 and 2012 that in turn may
have enhanced the preferred high salinity habitat for this species (Duke Energy 2014).
Seasonal variations for larvae entrained in 2012 represent the seasonal patterns expected and
observed for 2010 and 2011. Atlantic Menhaden, Spot, Atlantic Croaker, Pinfish, Flounder, and
mullet (family Mugilidae), which are all ocean -spawned species, were most abundant during
winter and early spring. Penaeid shrimp larvae were present as early as January but were most
abundant during spring, summer, and early fall (Duke Energy 2014).
Estuarine -spawned species (e.g., anchovies, Gobiosoma spp., Microgobius spp., and
silversides) were most abundant during the spring and summer. Pigfish (Orthopristis
chrysoptera), Seatrout (family Sciaenidae) and Silver Perch (Bairdiella chrysoura) were present
during the spring and summer. Some portunid crab megalops larvae were collected sporadically
throughout the year but peak abundance occurred during the fall and coincided with Blue Crab
(Callinectes sapidus) spawning (Duke Energy 2014).
Duke Energy 1 16

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant 01
`, �:` `' o`�� r z.' i!o- .a '� ,�f erg' �➢ ".:
The U.S. Fish and Wildlife's (USFWS) map -based search tool (Information for Planning and
Conservation; IPAC) was consulted to generate a resource report and determine the potential
presence of Federally -listed species within the Cape Fear Estuary and the surrounding land
(Figure 4-1, USFWS 2016). There are two rare, threatened, or endangered (RTE) fish species
within the Cape Fear Estuary: Atlantic Sturgeon (Acipenser oxyrinchus) and Shortnose
Sturgeon (Acipenser brevirostrum). There is no critical habitat designation for these two fish
species in the Cape Fear Estuary. The fish diversion structure minimizes the number of fish that
enter the BSEP intake canal and thus, reduces the number of aquatic organisms that are
impinged on the traveling screens. No Atlantic Sturgeon have been impinged since CP&L
installed the fish diversion structure in 1982 (USNRC 2012).
There are five RTE turtle species within the Cape Fear Estuary (Table 4-1). There are critical
habitat designations in the Cape Fear Estuary for four of the five RTE turtle species (Green Sea
Turtle [Chelonia mydas], Hawksbill Sea Turtle [Eretmochelys imbricate], Leatherback Sea Turtle
[Dermochelys coriacea], and Loggerhead Sea Turtle [Caretta caretta]). No critical habitat for
these species is designated within the zone of influence of the intake.
Polling
Lutea
ily
F�aih`
'
Chill,
t
" �"
a
fy y
%Jisk. $50ai3tl
t aI om
tic
Figure 4-1. Geographical Boundary of the IPAC Search
Duke Energy 1 17

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
W
Table 4-1. Rare, Threatened, or Endangered Species and Potential to Occur Near
Brunswick Steam Electric Plant
,Shortnose Sturgeon - Endangered _ - Unknown ° Unlikely' 'No �-
77 _
ere" kei� :Un
like)
�No='
"Atlantic`Stur'�eon=�=-3.>'�=r='Endan` dss;�
'Leatherback Sea Turtle Endangered _ Low likelihood' Likely4 .'Yes
Kem" s . itlle .Sea=Turtle: E ndaner'ed
-
V-77
_aike I 5 ,-,
L
4Yes `�
Y.-
4
Loggerhead Sea Turtle -Threatened Like lye Likely Yes
771
��Green"Sea Turtle- Threatened�� �=Yes�-=�"�>�
mss
v.
df �;
Hawksbill.Sea Turtle -,Endangeretl Low likelihood Likelys Yes
Nine adult Shortnose Sturgeon were captured in the Cape Fear River between 1987 and 1998. However, no Shortnose
Sturgeon has been collected at the BSEP (CP&L 2004).
2 No sturgeon species have been collected at BSEP.
3 Rarely enters estuary (CP&L 1998). In a letter dated 21 May 2003, the NCDNR indicated that the only record of rare
species at BSEP was the Carolina diamondback terrapin (NMFS 2003).
" Leatherback and Hawksbill Sea Turtles may also be adversely affected, but their occurrence in the action area is far less
likely (NMFS 2000).
5 Collected in intake canal (CP&L 1998).
6 Collected in intake canal (CP&L 1998).
Collected in intake canal (CP&L 1998).
e Rarely enters estuary (CP&L 1998).
9 Leatherback and Hawksbill Sea Turtles may also be adversely affected, but their occurrence in the action area is far less
likely (NFMS 2000).
Biological opinions issued by National Marine Fisheries Service (NMFS) found little potential for
adverse impact to either species of sturgeon at BSEP since the installation of the diversion
structure at the head of the canal (NMFS 2000). Shortnose Sturgeon was not included in the list
of species requiring action to prevent impacts because the population in the Cape Fear River
was small and they inhabit portions of the river upstream of the BSEP intake canal. Further, no
Shortnose Sturgeon had been collected in decades of sampling at BSEP (Progress Energy
undated). The Atlantic Sturgeon is relatively common in the lower Cape Fear River (Moser and
Ross 1995). Juvenile Atlantic Sturgeon prefer water greater than 10 meters deep near the
saltwater and freshwater interface.
The presence of federally protected sea turtles in the intake canal was documented prior to the
installation of the diversion structure. Turtles can move into the intake canal when there is an
infiltration of water around the diversion structure or when a screen fails. The BSEP has a
permit issued annually by the North Carolina Wildlife Resources Commission (NCWRC) for the
capture, tagging, and relocation of sea turtles that move into the intake canal through breaches
in the diversion structure. Operation of the water intake system of the BSEP is not likely to
jeopardize the continued existence of the Loggerhead, Leatherback, Green, Hawksbill, or
Duke Energy 1 18

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
i iMP
Kemp's Ridley Sea Turtles (NMFS 2000). This conclusion is based on the proposed action's
(operation of the cooling water system) anticipated effects on each of these species being
limited to the incidental take, through death or injury, of a small number of immature sea turtles
per year over the next 20 years (NMFS 2000).
Duke Energy 1 19

Entrainment Characterization Study Plan FN
Steam Electric Plant
5 Basis for Sampling Design
The goals of the ECSP are consistent with the long-term goals of the on-going entrainment
monitoring at BSEP. The existing program has evolved based on analysis of the multi-decadal
dataset and with consultation from the State of North Carolina. As a result, implementing a few
minor modifications to the existing sampling program was determined as the best approach for
collecting samples to satisfy the requirements of the Rule.
The recommended approach for the BSEP (described in greater detail in Section 6) is to collect
samples at the discharge weirs where the underground discharge lines surface at the head of
the discharge canal (see Figure 2-3). Two round 0.5-m plankton nets mounted sided -by -side
with 505 -pm mesh will be lowered into one of the two discharge weirs just below the water
surface. The water will be fished for five minutes.
The discharge weirs at BSEP are an ideal location for collecting samples and offer several
advantages over sampling at the intake including:
• The geometry of the discharge flumes allows easy access to the full cooling water flow.
• The discharge weir location is safer to access than the intake structures.
• All collected organisms have been entrained.
• The water at the discharge is well mixed and eliminates the potential for non-random
distribution of organisms.
• The well mixed flow at the discharge reduces the potential for gear avoidance.
Sampling at the discharge, however, is not without disadvantages. The greatest disadvantage is
potential loss or damage to organisms passing through the cooling water system or extruded
through the nets in the high velocity discharge. The collection gear used for entrainment
sampling has remained unchanged since 1984 (Duke Energy 2014). Depth -integrated samples
collected from the intake point were compared to samples collected at the discharge point;
species composition and densities were not statistically different. Samples collected at the
discharge point had the advantage of being well mixed and, therefore, sampling from different
depths to obtain a representative sample was not required (Copeland et al. 1976).
Entrainment sampling will occur once a month beginning in January 1, 2016 and will continue
through December 31, 2017. Two periods of peak abundance were identified in historical
entrainment; a winter peak consisting mainly of Spot, Atlantic Croaker, flounder, Atlantic
Menhaden, mullet and Brown Shrimp and a summer peak consisting mainly of seatrout,
anchovies, gobies and Pink and White Shrimp (CP&L 1985).
Each sample collection event will be conducted over a 24-hour period with sample sets
collected in six, 5 -minute intervals. The sampling frequency selected for this entrainment study
will provide fish taxa, density distribution, and seasonal/diel variation data over a two year
period.
Factors important to meeting the §122.21(r)(9) requirements, along with a basis for how those
requirements will be addressed for the BSEP are summarized in Table 5-1.
Duke Energy 1 20

Entrainment Characterization Study Plan ���
Brunswick Steam Electric Plant
Table 5-1. Summary of Approach for Development of §122.21(r)(9) Required Entrainment
Characterizations
Two years of data and annual
Entrainment samples will be collected January4hrough December 2016
variation
(Year 1) and January through December 2017 (Year 2)
"b
6h,e`-1
`omro`sitions-basedfh
Eval—uation ofmonthlyspeces°and-life°stage`c , p ,
".Seasonal Variation'
-
Year 1 and-.6ac2=studies`
Each 24 -hr sampling event will be split into six 4 -Flour intervals in.the
Diel variation
Year 1 and Year 2 studies.to capture diel variation
=Weather- information,and water tem° eratur`e will;be collected=during;`, R
v-
1 Variation relatedto climate,.
_ . °,, -"
each sampling event- ogevaluate,differences,in-,entrairiment--rates -
weather
k
-
_ based°on these.factors-:"
Variation related to`spawning, feeding
Year 1 and Year 2 data will -be analyzed to ,determine species -and -life
and water column migrations
stage. variations over time along with spawning and feeding,variation-
I
The resolution of to ono c d e t g
i"
="
Id"enti ii 'ion-bfdowest taxon "ossible
P
{ , ""g a - , ,y --
throw" h re "ular evaluations;of catch':data,vvlth;tfie- oal of reducin
.:t, 9 9 9" g
" l percent'of unidentified organisms°an'd-increasing; resolution,of-genera,
and Fid° her tazonomie�d"esi nations°
9 9
Data must be representative of each
Sampling at the discharge weirris expected to be�representative,of the
intake
total facility
i"'Howaheaocatiori-of�tF�e`infake-in:fhe`���Samolirig"at.the dischargeweir-.represents.`all'flowtithfougfithe;facility
water body arevaccounted for Y" v;
and will-account<for intake location °
, ,
F
Document flow associated with the
The facility will monitor flows ,for the years of sampling and that data will
data collections
be documented in the final report
I °Methods,in=whieh,I,atent,morfalitywill ;" :. i Latent mortality wil°Knot`ki`e evaluated as apart of the rstudy;`therefo
jbeidenfifled,rriethotls,a�e
riot prov'id'etl a
Data must be appropriate for a
Data will be expressed as taxon and life stage specific densities which
quantitative survey
car;, be multiplied by flow to support quantification of entrainment rates
Duke Energy 1 21

Entrainment Characterization Study Plan ���
Brunswick Steam Electric Plant
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) for field work, as
well as one for laboratory analysis, will be used to direct work. The SOP will be modified to
reflect the expanded scope of work resulting from making additions to the existing long-term
monitoring program identified in this ECSP. The SOPs will lay out detailed field sampling
procedures, laboratory procedures, data quality assurance and quality control (QA/QC), and
database management procedures. This will ensure consistent field sampling and laboratory
methods and that the data developed will have a similar format to data collected at other
facilities in Duke Energy's fleet where entrainment sampling is required.
6.2 Sample Collection
Entrainment samples will be collected once per month from January 1 through December 31 in
2016 and 2017 (12 sampling events in each year). Samples will be collected only when the
facility is in operation and discharging cooling water. Typically, samples will be collected from
one discharge weir only. The once 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. In addition, data from the previous 5 years will be used to supplement the
newly collected data to help minimize the outlier effects and provide a better estimate of
entrainment.
Data from yearly sampling from 1979 to 2004 were used to demonstrate that estimates of
entrainment based on weekly data were similar to those generated based on a monthly
sampling frequency. Of relevance to this discussion are the similarities in estimates generated
from weekly sampling (blue line) and monthly sampling (green line)' (Figure 6-1). Based on
these data and consultation with North Carolina Department of Environmental Quality (NCDEQ),
Duke Energy decreased the sampling frequency from weekly to monthly.
3 While not relevant to determining sample frequency, Figure 6-1 also shows the reduction in entrainment (black line) associated
with the technological and operational changes (fine -mesh screen panels and seasonal flow reduction) as compared to historical
entrainment (red line).
Duke Energy 1 22

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Figure 6-1. Cumulative Distribution of Sampling Results. Note the Similarity in
Entrainment Estimates Derived from Utilizing Data Collected Weekly (Blue Line) and Data
Collected Monthly (Green Line)
During each 24-hour sampling event, one of the discharge weirs will be sampled just below the
water surface within the following discrete 4 -hour time intervals: 0900, 1200, 1500, 2100, 2400,
and 0300 Eastern Standard Time (EST) (one hour later during Eastern Daylight Time [EDT]).
Sampling time may deviate up to 15 minutes from the scheduled time without adversely
affecting results. Each sampling event consists of six, 5 -minute samples stratified by
photoperiod and tide. During the year, a total of 72 samples will be collected for a program total
of 144 samples over the two year study period (Table 6-1).
Table 6-1. Entrainment Sampling Details
Sample Location One of the two discharge weirs
Sampling Events (Days)? T my -four (24) sampling events; once per month; January 1
through December 31, 2016 and between January 1 through i
December 31, 2017 i
Daily Collection Schedule Samples collected every 4 hours in a 24-hour period (six, 5 -minute
paired collections / 24-hour period)
;Targeted Organisms "I Fish eggs, larvae,,andjuveniles _v _
Duke Energy 1 23
100
W
8®
�-
60r
40
50th Percentile
80th Percentile
Nu. %
Nu.
%
20
Baseline 9.45
18.46
(�
Weekly 1.44 84.7
4.13
77.6
Monthly 2.38 74.9
5.06
72.6
0
Post -baseline 1.79 81.1
4.79
74.0
0
10 20 30
40 50 60 70 80 90 100 110
120 130
140 150
Number entrained (millions)
�— Baseline
Weekly Monthly Post -baseline
Figure 6-1. Cumulative Distribution of Sampling Results. Note the Similarity in
Entrainment Estimates Derived from Utilizing Data Collected Weekly (Blue Line) and Data
Collected Monthly (Green Line)
During each 24-hour sampling event, one of the discharge weirs will be sampled just below the
water surface within the following discrete 4 -hour time intervals: 0900, 1200, 1500, 2100, 2400,
and 0300 Eastern Standard Time (EST) (one hour later during Eastern Daylight Time [EDT]).
Sampling time may deviate up to 15 minutes from the scheduled time without adversely
affecting results. Each sampling event consists of six, 5 -minute samples stratified by
photoperiod and tide. During the year, a total of 72 samples will be collected for a program total
of 144 samples over the two year study period (Table 6-1).
Table 6-1. Entrainment Sampling Details
Sample Location One of the two discharge weirs
Sampling Events (Days)? T my -four (24) sampling events; once per month; January 1
through December 31, 2016 and between January 1 through i
December 31, 2017 i
Daily Collection Schedule Samples collected every 4 hours in a 24-hour period (six, 5 -minute
paired collections / 24-hour period)
;Targeted Organisms "I Fish eggs, larvae,,andjuveniles _v _
Duke Energy 1 23

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant c
e W -
Depths Samples collected from just below water surface are representative
of any vertical distribution at the intake because the cooling water
and organisms are well mixed after going through the cooling water
system
`Sample D,ur'atiori i .,P nkton nets will be fished forafive minutes. `
r ISR
Number of Samples per Sampling Six (6) paired, samples per sampling day
Event (Day)
;Total Numkier of=Samp",les .y I rTwelve (12) -sampling events/year x=12 samples,[6 pairedysa g
r' event (days) -x 2 years =-288 samples)
Entrainment samples will be collected just below water surface at one of the two discharge
weirs (Figure 6-2). Two identical 0.5 -meter round 505 -Nm mesh plankton nets will be mounted
side-by-side on a stainless tow bar and will be fished in one of the discharge weirs. Unless there
is a reason that one weir is unavailable for sampling (e.g., during a unit outage), then alternate
weirs will be sampled each month. The plankton nets will be lowered and raised into position
with a boom system (Figure 6-3).
At the time of sampling, water temperature, salinity, volume sampled, and sampling flume will
be recorded. In addition, the units in operation and actual intake flow rates will be obtained from
operations before the data are analyzed.
At the completion of the sampling event, the nets will be retrieved as quickly as possible and the
flowmeter readings will be recorded. General OceanicsT"' mechanical flowmeters will be
mounted in the mouth of each net to measure flow. If the difference between the flowmeter
readings from each net is greater than 2,000 revolutions, the samples will be re -collected. The
plankton nets will be washed thoroughly using wash buckets and organisms will be collected in
cups. The cups will be emptied into appropriate sample containers. Larval densities will be
averaged to obtain a mean number per 1,000 m3 of water entrained through the plant per
sampling event.
Duke Energy 1 24

Entrainment Characterization Study Plan a��
Brunswick Steam Electric Plant
Figure 6-2. Aerial View of Sampling Location at Brunswick Steam Electric Plant (Image
Modified from: Google Earth)
Figure 6-3. Photograph of Entrainment Sampling of the Discharge Weir at Brunswick
Steam Electric Plant (Source: Duke Energy 2014)
Duke Energy] 25

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
6.3 Sample Sorting and Processing
Samples are first rinsed with water in a 505 -Nm (or smaller) mesh sieve to remove excess
formalin. The samples are then placed in trays and with the aid of a magnifier and/or light,
organisms are removed from the samples. The Sorter's initials and dates are inputted into the
Sample Log/QC Report 9 (FRM-00842). Similar organisms are placed together in vials
containing approximately three percent formalin. All vials from one sample are placed together
and labeled for further processing. The number of vials for each sample is recorded on the
Sample Log/QC Report Form along with the number of organisms sorted.
During periods of high concentrations of small fish (two to five millimeters), usually during the
summer months, samples may be sorted twice. The decision to have all samples sorted a
second time is made by the lead scientist.
Once all vials for one sample are obtained, the Identifier initials and dates the Sample Log/QC
Report Form. When identification is complete, the Identifier records the date completed and the
number of organisms found. Most organisms will be identified to the lowest practical taxa (using
taxonomic keys and processing guidelines) and recorded on the Brunswick Fisheries
Investigations Form (FRM-00838). Prior to 1984, length frequencies were obtained for up to 30
individuals per sample. From 1984 to 2012, all species had only the minimum and maximum
lengths recorded. From 2012 to present, 30 length measurements are taken from the historically
dominant or important species. Remaining specimens are counted and the value 9999 is
recorded in the length column. Portunidae megalops are counted only and 9999 is recorded in
the length column. Because of the extensive historical morphometric datasets, current
standards (i.e., 30 length measurements were taken form the historically dominant or important
species) will continue during 2016 and 2017 sampling.
After all samples in a set are processed, at least 10 percent of the set is randomly selected for
reprocessing (for the purposes of this procedure a set of entrainment samples is defined as one
per unit per sampling trip). A unique computer-generated table of random numbers is used for
each program. This table is different from the random number table used to select samples for
sorting QC. If a sample selected for identification QC contains zero organisms, an alternate
sample is selected from the table. The processor for QC (someone other than original Identifier)
initials and dates the Sample Log/QC Report. The two data sheets are compared.
Discrepancies such as misidentification, errors in counting, or significant differences in
measurements are noted on the Larval Fish Identification Discrepancies Form (FRM-00843).
The program leader or designee then compares the number of errors and makes a judgment on
whether or not the sample set passes or fails. Errors are not corrected if the set passes QC. The
program leader decides whether all or part of the set should be reprocessed if the set fails.
Eggs were initially identified during the 1970s. Because the Representative Important Species
(RIS) spawn offshore and their eggs were rarely collected, egg identification activities were
removed from the program. In order to remain consistent with the Rule, fish eggs will be
removed from the sample during the sorting phase and placed in vials labeled with a unique ID
associated with the date and time of their collection. These eggs will be sent to the Normandeau
Duke Energy 1 26

Entrainment Characterization Study Plan MBrunswick Steam Electric Plant
Associates, Inc. laboratory in Bedford, NH where taxonomists will identify samples to the lowest
practical taxon. Up to 10 eggs of each taxon will be measured for minimum and maximum
diameter.
6.4 Data Management and Analysis
During each sampling event, water temperature, salinity, flowmeter readings, flowmeter
numbers, water quality instrument numbers, and unit sampled, are recorded on the Entrainment
Header Log (FRM-00837). This information is entered on the Brunswick Fisheries Investigations
Form (FRM-00838). Data sheets are inspected for completeness prior to data entry. Data are
entered into Microsoft Excel spreadsheets and are reviewed by a second person to confirm their
accuracy. A more extensive automated QC is completed within Excel and is uploaded to the
server/mainframe prior to data analysis.
6.5 Laboratory Quality Control
Sample residue is reserved for quality control checks, where at least 10 percent of the set is
randomly selected (using a computer-generated random number for each program). Sample
residue is reprocessed by someone other than the original sorter. The QC Sorter initials and
dates the Sample Log/QC Report Form. The number of organisms found in the QC sort is used
to calculate the percent accuracy using the following equation:
# Organisms in Original Sort
# Organisms in Original Sort(s) + # Organisms in QC Sort
The set passes if the accuracy (calculated to the nearest tenth of a percent) is 90 percent or
more. If the accuracy is under 90 percent, the set fails and the remaining samples in the set
(excluding those samples used for the QC sort) must be resorted. All organisms found in this
sort are added to those found in the preceding sort. The set is run through the QC process until
it passes. Organisms recovered from the samples selected for a QC check are discarded if the
set passes.
6.6 Reporting
At the completion of the study, a report describing the study program, including 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 document the work done. Estimates of entrainment by species, life stage,
month, and diel period under design, and recorded intake flows, will also be included. The report
will be organized with supporting information and details (e.g., field data, SOP, lab results) in
attached appendices, as needed.
Duke Energy 1 27

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
7 References
M
Carolina Power and Light Company (CP&L). 2004. 1980. Brunswick Steam Electric Plant Cape
Fear Studies: Interpretive Report. Southport, North Carolina.
. 1985. Brunswick Steam Electric Plant Cape Fear Studies: Interpretive Report. New Hill,
North Carolina.
1998. Memo from C. Wheeler to J. W. Johnson, J. C. Nukles, Jr. and A. Eaddy forwarding
the Threatened and Endangered Species Self -Assessment Report.
2000. CP&L Integrated Resource Plan. September 1.
Applicant's Environmental Report — Operating License Renewal Stage, Brunswick Steam
Electric Plant, Units 1 and 2. Docket Nos. 50-325 and 50-324, Southport, North Carolina.
Copeland, B. J., J.M. Miller, W. Watson, R. Hodson, W.S. Birkhead, and J. Schneider. 1976.
Meroplankton: Problems of Sampling and Analysis of Entrainment, in (L.D. Jensen, ed.)
Third National Workshop on Entrainment and Impingement, Ecological Analysts, Inc.,
Melville, NY.
Duke Energy. 2014. Brunswick Steam Electric Plant 2010-2012 Biological Monitoring Report.
Duke Energy Progress Inc., Water and Natural Resources. Raleigh, North Carolina. June
2014.
Moser, M.L. and S.W. Ross. 1995. Habitat Use and Movements of Shortnose and Atlantic
Sturgeons in the Lower Cape Fear River, North Carolina. Transactions of the American
Fisheries Society 124(2): 225-234.
National Marine Fisheries Service (NMFS). 2000. Endangered Species Act — Section 7
Consultation Biological Opinion for the Operation of the Cooling Water Intake System at the
Brunswick Steam Electric Plant, Carolina Power and Light Company.
Progress Energy. 2011. Brunswick Steam Electric Plant 2009 Biological Monitoring Report.
Progress Energy Service Company, LLC, Environmental Services Section. Raleigh, North
Carolina. March 2011.
. Undated. Applicant's Environmental Report: Operating License Renewal Stage,
Brunswick Steam Electric Plant, Unit 1 (License No. DPR-71) and Unit 2 (License No. DPR-
62).
Progress Energy Carolinas, Inc. (PEC). 2003. Brunswick Steam Electric Plant 2003 Biological
Monitoring Report. Environmental Services Section. New Hill, North Carolina.
Duke Energy 1 28

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
FN
U.S. Atomic Energy Commission (USAEC). 1974. Final Environmental Statement Related to the
Continued Construction and Proposed Issuance of an Operating License for the Brunswick
Steam Electric Plant Units 1 and 2. Carolina Power and Light Company. Dockets Nos. 50-
324 and 50-325. Washington, DC.
U.S. Energy Information Administration (USEIA). 2015. Form EIA -923 Detailed Data.
https://www.eia.gov/electricity/data/eia923/. Accessed on February 11, 2016.
U.S. Fish and Wildlife Service (USFWS). 2016. Information for Planning and Conservation
(IPAC). https:Hecos.fws.gov/ipac/. Accessed April 6, 2016.
U.S. Nuclear Regulatory Commission (USNRC). 2006. Generic Environmental Impact
Statement for License Renewal of Nuclear Plants, Supplement 25, Regarding Brunswick
Steam Electric Plant, Unit 1 and Unit 2. Washington, D.C. April 2006.
. 2012. Biological Assessment, Brunswick Steam Electric Plant: Units 1 and 2 and
Continued Operation.
Duke Energy 1 29

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
APPENDIX A - Select Species Spawning and Early Life History Data
Table A-1. Spawning and Early Life History of Fish Species Present at Brunswick Steam Electric Plant
W
t Eggs are buoyant.
li Spavun in shelf They are distinguished
waters that are from other eggs by Newly hatched
y I their large size (i.e., 38,000 to 700,000 ,larvae are 4.5
Atlantic ' November to ; 100 to 200 4{ ' 1.5 to 1.8 mm �{ ova per fish, mm in length, I
meters offshore, Open water f I� i i
Menhaden ;; March 11 �I diameter), broad !� depending on size � growing to 5.7
!, �l probably within EI perivitelline space, offish mm within four
70 meters of theli
surface I it small oil globule (i.e., days of hatching „
i 0.105 to 0.17 mm),
and long embryo
Bay anchovy is a
Spawn where
The approximately 1-
batch (serial)
spawner.
water depth is
Bay Year-round
mm fertilized eggs are
Pelagic, slightly
p -ies
Common
Sawnrn•
period 9
Saw
pa nrng
Nest
Eggs
Fecundf ` Rates
t.arvae Size
" Refere ces
Name
season producing
tat
Struewre
a mean of 1,129
0.035 -inch floating or
of female length
ova per batch
t Eggs are buoyant.
li Spavun in shelf They are distinguished
waters that are from other eggs by Newly hatched
y I their large size (i.e., 38,000 to 700,000 ,larvae are 4.5
Atlantic ' November to ; 100 to 200 4{ ' 1.5 to 1.8 mm �{ ova per fish, mm in length, I
meters offshore, Open water f I� i i
Menhaden ;; March 11 �I diameter), broad !� depending on size � growing to 5.7
!, �l probably within EI perivitelline space, offish mm within four
70 meters of theli
surface I it small oil globule (i.e., days of hatching „
i 0.105 to 0.17 mm),
and long embryo
Bay anchovy is a
Spawn where
The approximately 1-
batch (serial)
spawner.
water depth is
Bay Year-round
mm fertilized eggs are
Pelagic, slightly
Individual females Larvae are 1.8 to
less than 20 Open water
Anchovy spawning
ellipsoid with
spawn at least 50 2.0 mm long at
meters, salinities
segmented yolk -mass
times each hatch
from 0-32 ppt
and no oil globules
season producing
per 5 to 7 inches
and lack fin
a mean of 1,129
0.035 -inch floating or
of female length
ova per batch
t Eggs are buoyant.
li Spavun in shelf They are distinguished
waters that are from other eggs by Newly hatched
y I their large size (i.e., 38,000 to 700,000 ,larvae are 4.5
Atlantic ' November to ; 100 to 200 4{ ' 1.5 to 1.8 mm �{ ova per fish, mm in length, I
meters offshore, Open water f I� i i
Menhaden ;; March 11 �I diameter), broad !� depending on size � growing to 5.7
!, �l probably within EI perivitelline space, offish mm within four
70 meters of theli
surface I it small oil globule (i.e., days of hatching „
i 0.105 to 0.17 mm),
and long embryo
Houde and Zastrow
undated
Rodgers and Van Den !
Avyle 1989
I
Sink 2011
Duke Energy 1 30
Newly hatched
Fecundity
larvae are
Protracted
estimates range
approximately
spawning
Atlantic Croaker
from 41,000 eggs
0.06 inches long
Atlantic season that
Spawn offshore Open water Produces 0.024- to
per 5 to 7 inches
and lack fin
Croaker lasts from
0.035 -inch floating or
of female length
buds,
October to
semi -buoyant eggs
to 180,000 eggs
mouthparts,
March
for a 15.5 -inch
digestive tracts,
female
and eye
pigmentation
Houde and Zastrow
undated
Rodgers and Van Den !
Avyle 1989
I
Sink 2011
Duke Energy 1 30

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
M
"'.uL''re ' ,0„a 'w `` Y,,, • "fie o i7,
-W q- - -
Spawn �lnthe
[p I tl Initial growth is
relatively deep
{ rapid while
Spawning water of the i Fecundity
+ I � i � larvae remain in
[� occurs from outer continental ,, estimates range
!! October through ' shelf, though �, ! Eggs are pelagic and fromi offshore waters. I
Spot �; i+ Open water i� Growth then l Hill 2005
March, peaking I some evidently 9' (1 buoyanti approximately slows in the early +i
m December �, spawn in j ;' 77,000 to 84,000
i jl I period of
i and January i� nearshore eggs per season
i I i
waters and estuarine i
+ E 1
{ �residency 4 estuaries
In non -tidal
areas, estuaries Eggs are spherical,
and lagoons, generally with one oil
Protracted near tidal droplet, but Fecundity
spawning passes, and occasionally two or increases with
season which outside three. Eggs have been size. The Hatched larvae
Spotted estuaries. Johnson and Seaman
extends from Open water reported to be approximate range from 1.3 to
Seatrout late April Spawning occurs demersal and pelagic range is 15,000 to 1.6 mm 1986
through early at night in bays depending upon 1,100,000 eggs
October or lagoons and in salinity. At higher per female
deeper channels salinities eggs are
and depressions buoyant
adjacent to
grassy flats
'� ------ Spawn in and--
°� around the edge i 'I Eggs are transparent
Ij of the continental I and pale yellow, non -
Estimated
Protracted shelf off the i' adhesive, and fecundity is 0.5 to .
Hatched larvae i
i' a 2.0 million eggs i�
Striped i) spawning i, coasts of North spherical with an I E are
i j Open water ,� i� per female, 11 Bester undated
Mullet i season from' Carolina, South ij average diameter of I I approximately
i 1 ; depending upon
October to April !j Carolina, ,l ' 0.72 mm. Each egg �I size of the 2.4 mm in length
�+ ! Georgia, and the (' contains an oil globule, i {j
� east coast of fmaking it buoyant jl individual
- — - Florida
Duke Energy 1 31

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
ARM
-
\
,.��;e```;'; �v^,,, `,, e® .^;;>;z ";xtx&k.,.# • ;,',„s, . �. ,�. ,a,�^ n�..,+, ,^,,,,` aaa.e,;sy,c,.s,M,; ,.,\., ,
Spawn in late
Southern fall and early Sandy bottoms
Flounder winter but some offshore
spawn in early
spring
Open water Buoyant eggs that
float to the surface
Females typically
spawn every three
to seven days
over a period of
approximately two
months, typically
producing 17,000
to 100,000 eggs
in each session
Adult female
i Eggs are roughly 1 I� Pinfish between
i' mm in diameter,
1 Late fall through r3 i�� 1111 and 152 mm
Pinfish f; Offshore Open water usually with a single oil '
i early spring } i i' globule and a narrow �� contained an
perivitelline space ave eggsage of 21,600
Probably occurs Ovarian eggs round,
Late May to at sea, however
Blackcheek October with a spawning in Open water largest measured 0.5 Information not
Tonguefish mm with 6-10 oil available
peak in June
large estuaries is
significant
droplets
-- - --- ---- - - --
Ij - -- --
I� Spawn in deep
--- -- - –
I, –
i
waters along the
I'
11
Eggs are pelagic and
buoyant and 0.7 to 0.8
i
i Early spring1,
Spotted (? (April through
Hake
continental
slope, primarily
off southern
IR Open Water
! mm in diameter with a
�!, 0.04 to 0.12 mm
Unknown
May)
!i Georges Bank
(' perivitelline space and
l� }I a 0.19 to 0.28 mm oil
and the Middle
Atlantic Bight
globule
ii
Yolk -sac larvae
began
metamorphosing
to postlarvae at 8
to 11 mm long
Reagan and Wingo
1985
Hatched larvae —
averaged 2.3 I
mm in length. 6
The yolk -sac, I
I visible 24 hours Masterson 2008 '
after hatching, is E
completely
absorbed once i f
larvae reached a
size of 2.7 mm
Larvae range
from 1.3 mm to Martin 1978
at least 10 mm
I
Unknown li Chang et al. 1999
i
Duke Energy 1 32

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Atlantic
Silverside
Spawn in the
Spawning
`;: intertidal zone of =
= extends from
nearly all major .,
late March
"estuaries and; Open water
through June
tributaries within
sh"allow°waters
offshore"" .. �"
their geographic
Newly hatched
IarVae'are •`"•_,
approximately 5, .
-range - -
r-yys div ueineisdi,
adhesive, and found in i
shallow waters of
estuarine intertidal
zones. Eggs range" a The average Larvae range in
from 0.9 to= 1.2 mm in y number of eggs :i size from 5.5 to,
diameter. 'Eggs are ;, spawned in a 15.0 mm in total i' Fay et al. 1983
transparent, yellow to season is 4,500 to 3 length
green'and'have five to ;' 5,000 per female
twelve large oil
globules and i]
numerous small
globules
F�?
Duke Energy[ 33
Eggs arespherical,
Rough
Silverside,'
Spring through" '
Fall'" ' ° " "
sh"allow°waters
offshore"" .. �"
almost transparent, .
dem"ersaI 'adhering °"' "' ' Information' not
Open waters"
together,irflarge-, ��. � � available
Newly hatched
IarVae'are •`"•_,
approximately 5, .
Smith 1914
, T
„ .
uclusters, which are "" „ .
mrnin.length
,..., carried inshore to
iriteitidal zones ° -,"..a, "3 °
� �.... ° .. ... •.- �
,,,," ... ,_-
Duke Energy[ 33

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Table A-2. Spawning and Early Life History of Crab Species Present at Brunswick Steam Electric Plant
M)<
Duke Energy 1 34
mate only once in;
The megalops larva
their lives. After
is more crablike in
mating; females;.appearance
" Measures'.
than the
Althougha-female
migrate to high-
approximately 0.25
zoeae; its carapace
,will mate only once,
Tidal fresh
salinity waters in
mm upon hatching.
is broader than its
�'
i� `she will produce
areas. Salinity,;:
lower estuaries,
They bear little
length and has biting
;,, many fertilized egg;
is important
sounds, and near=claws
morphological "
and pointed
;
masses during her
but
shore spawning
'; -They
resemblance to :
joints at the ends of
I, "
the legs. The,-"
,, lifetime from this
requirements
areas. over-
adults, are filter
�i
single mating
Blue Crab vary, by life
winter,before
and live a
megalops swims
(seven broods in Zinski 2006
stages.
spawning by
planktonic existence.
freely, but generally
:; one year from a
Generally
burrowing in the .
1.
Zoeal development
;' stays near the
i� `single mating and
' optimum is 3-
;, mud. Females
may require 1 to 49
is bottom in nearshore
up to 18 broods
to 15 -parts
usually spawn two
;
'days, depen"ding on
1, or lower'"estuarine
ii"
over a two- to two
per thousand
to nine months after
mating. Spawning,
`salinity and
;; high -salinity areas.
'; There are usually
and ahalf--year
occurs from March
temperature
seven zoeal stages
Period)
through October, t
;' and one postlarval or
with•peaksfrom
megalopal, stage
i
April to August
• t'
ii
Duke Energy 1 34

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
W
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Entrainment Characterization Study Plan
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Table A-3. Spawning and Early Life History of Shrimp Species Present at Brunswick Steam Electric Plant
011
.k�",...;;�F: vn,.,q;.:S
P
rkl ,
,,i'uµ-
7
The larvae go through
approximately 10 different
The male transfers a packet
phases before they start to
A single
look like adult shrimp. They
of sperm called a
move into estuaries where they
produces
inhabit seagrass beds, tidal
spermatophore to the female
marshes and creeks as they
Prefers shallow, warm,
Spawn in the
and it is attached to the
Atlantic
low salinity waters to
spring along the
female's underside. Eggs are
White
approximately 90 feet
coast from the
ejected by the female and
Shrimp
deep with organic -rich,
beach to several
fertilized as they pass the
muddy bottoms
miles offshore
spermatophore. The eggs
sink to the bottom of the
ocean, where they hatch
within 24 hours
-
-------------
fi Pink shrimp are++,
j
'j associated with shell
it
occurs
j
The eggs are approximately
Ii
'sand, sand, coral -mud,
Spawning
in oceanic waters
0.23 to 0.33 mm in diameter
Pink
t or mud bottoms.
i Subadults prefer shell
1i at depths of 4 to
and are demersal. Coloration
Shrimp
;! sand and loose peat
!! 48 meters and
I; probably in
!j is generally an opaque
13 yellow -brownish but the
i4 and adults prefer
(I deeper waters
chorion may appear bluish
fi calcareous sediments
,� also
under certain light reflections
(j but are also found on
;_
hard sand bottoms;
E?
I
The larvae go through
approximately 10 different
phases before they start to
A single
look like adult shrimp. They
female
move into estuaries where they
produces
inhabit seagrass beds, tidal
between NWF 2016
marshes and creeks as they
500,000 and
continue to mature. After
1 million
approximately two to three
months, the larvae will reach
eggs
adult size and move towards
the ocean
Pink shrimp larvae have
exhibited five nauplii stages,
three protozoeal stages, and
two to five mysis stages. Larval 1
development is generally 15 to !; j
21 days (i Unknown 1 Bielsa et al. 1983
11
Postlarvae enter estuarine and
coastal bay nursery areas at 8
mm total length. Peaks of
abundance occur in spring and
late fall k �i
j{
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Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
M
Species S aWning fecundity°
Common Habitat p g Eggs Larvae' References
Period,
°
° Rates .
n
Name
coastal areas during late winter
and spring
•s.
Larson et al. 1989
Duke Energy 1 37
Hatching usually occurs within `.
',',24 hours but is inhibited at
Spawn offshore
!i salinities below 27 parts per
at depths, usually
thousand or above 35 parts, per
'+
t4 thousand. Planktonic larvae'
Prefer loose peat and
exceeding 18 "
;: ' develop offshore through five'
sandy mud althoughnaupliar,
meters with
three protozoeal, and ,
Brown they frequent other
spawning
occurring most of
•,,Eggs•aredemersal, non -
three Mysis stage's before "
adhesive, spherical, and .0.26 , Unknown
Shrimp substrates such as
the year. The
metamorphosis to postlarvae.
to 0.28 mm in diameter
sand, silt, or clay mixed
:;-Larval development, takes
with rock fragments
majority of9'approximately
spawning may.
11 days °
occur into early
s Postlarvae are transported by
fall.
:! surface ocean currents'to
coastal areas during late winter
and spring
•s.
Larson et al. 1989
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Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Life History References
01
Bester, Cathleen. Undated. Striped Mullet. Florida Museum of Natural History, University of
Florida. http://www.flmnh.ufl.edu/fish/discover/species-profiles/mugil-cephalus. Accessed
on February 15, 2016.
Biella, L.M., W.H. Murdich, and R.F. Labisky. 1983. Species Profiles: Life Histories and
Environmental Requirements of Coastal Fishes and Invertebrates (South Florida) — Pink
Shrimp. U.S. Fish and Wildlife Service. FWS/OBS-82/11.17. U.S. Army Corps of Engineers,
TR EL -82-4. 21 pp.
Chang, S., W.W. Morse, and P.L. Berrien. 1999. Essential Fish Habitat Source Document:
White Hake (Urophycis tenuis) Life History and Habitat Characteristics. National
Marine Fisheries Service, James J. Howard Marine Sciences Lab. Highlands, New Jersey.
September 1999.
Fay, C.W., R.J. Neves, and G.B. Pardue. 1983. Species Profiles: Life Histories and
Environmental Requirements of Coastal Fishes and Invertebrates (Mid -Atlantic): Atlantic
Silverside. U.S. Fish and Wildlife Service, Division of Biological Services. FWS/OBS-
82/11.10. U.S. Army Corps of Engineers, TR EL -82-4. 15 pp.
Guillory, V., P. Prejean, M. Bourgeois, J. Burdon, and J. Merrell. 1996. A Biological and
Fisheries Profile of the Blue Crab. Louisiana Department of Wildlife and Fisheries. Baton
Rouge, Louisiana.
Hill, K. 2005. Species Inventory: Spot. Smithsonian Marine Station. June 9, 2005.
Houde, E.D. and C.E. Zastrow. Undated. Bay Anchovy, Anchoa mitchilli. University of Maryland,
Center for Environmental and Estuarine Studies. Solomons, Maryland.
Johnson, D.R. and W. Seaman, Jr. 1986. Species Profiles: Life Histories and Environmental
Requirements of Coastal Fishes and Invertebrates (South Florida), Spotted Seatrout. U.S.
Fish and Wildlife Service. Biol. Rep. 82(11.43). U.S. Army Corps of Engineers, TR EL -82-4.
18 pp.
Larson, S.C., M.J. Van Den Avyle, and E.L. Bozeman, Jr. 1989. Species Profiles: Life Histories
and Environmental Requirements of Coastal Fishes and Invertebrates (South Atlantic),
Brown Shrimp. U.S. Fish and Wildlife Service. Biol. Rep. 82(11.90). U.S. Army Corps of
Engineers TR EL -82-4. 14 pp.
Martin, Douglas F. 1978. Develop of Fishes of the Mid -Atlantic Bight, An Atlas of Egg, Larval,
and Juvenile Stages. Volume VI, Stromateidae through Ogcocephalidae.
Chesapeake Biological Laboratory, Center for Environmental and Estuarine Studies.
Solomons, Maryland. January 1978.
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Entrainment Characterization Study Plan L��
Brunswick Steam Electric Plant r
Masterson, J. 2008. Species Inventory: Pinfish. Smithsonian Marine Station. September 1,
2008.
National Wildlife Federation (NWF). 2016. Atlantic White Shrimp.
https://www.nwf.org/Wildlife/Wildlife-Library/Invertebrates/Atlantic-White- Shrimp.aspx.
Accessed February 15, 2016.
Puglisi, Melany P. 2008. Smithsonian Marine Station. October 1, 2008.
http://www.sms.si.edu/irlspec/Callinectes similis.htm. Accessed February 15, 2016.
Reagan, R.E., and W.M. Wingo. 1985. Species Profiles: Life Histories and Environmental
Requirements of Coastal Fishes and Invertebrates (Gulf of Mexico), Southern Flounder.
U.S. Fish and Wildlife Service. Biol. Rep. 82(11.30). U.S. Army Corps of Engineers TR EL-
82-4. 9 pp.
Rodgers, G.S. and M.J. Van Den Avyle. 1989. Species Profiles: Life Histories and
Environmental Requirements of Coastal Fishes and Invertebrates (Mid-Atlantic), Atlantic
Menhaden. U.S. Fish and Wildlife Service. Biol. Rep. 82(11.108). U.S. Army Corps of
Engineers TR EL-82-4. 23 pp.
Sink, Todd. 2011. Species Profile: Atlantic Croaker. Southern Regional Aquaculture Center.
SRAC Publication No. 7208. August 2011.
Smith, Hugh M. 1914. Bulletin of the United States, Bureau of Fisheries. Volume XXXIV. Rough
Silverside. 420-423 pp.
Zinski, Steven C. 2006. Blue Crab Life Cycle. https://www.bluecrab.info/lifecycle.html. Accessed
February 15, 2016.
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Entrainment Characterization Study Plan I��
Brunswick Steam Electric Plant
APPENDIX R — Response to Informal Review
Comments
While not required to be peer reviewed under the Rule, Duke Energy engaged Fisheries Biology
subject matter experts to informally review this ECSP. The purpose of the informal review was
to afford the 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 BTA determination process required in
§122.21(r)(10)-(12).
In order to help focus the review, charge questions were developed (Table B-1). 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
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, (i
2 will the proposed sampling period �j Yes/No
f+ (months) provide the ability to !�
understand seasonal variations in
-entrainment?
Is the sampling equipment proposed
3) appropriate to collect entrainable Yes/No
organisms at this type of intake
structure?
Does the plan lay out QA/QC�I
14) :i requirements clearly? Are these ; Yes/No i
requirements adequate?
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Entrainment Characterization Study Plan
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01
Identifying eggs and larvae to species is
often difficult and sometimes
impossible. Does the sampling plan
5) provide sufficient measures to preserve Yes/No
organism integrity and support
,identification to the lowest taxon
practicable?
Will the study design provide sufficient
data to support a benefits analysis of
7) entrainment reducing technologies Yes/No
required to be evaluated by the Rule ;
including biological performance as
required in 40 CFR 122.21(r)(11)?
Does the study design meet the
6)
requirements of the Rule at 406CFR
Yes/No
so, what needs to be added or clarified?
Will the study design provide sufficient
data to support a benefits analysis of
7) entrainment reducing technologies Yes/No
required to be evaluated by the Rule ;
including biological performance as
required in 40 CFR 122.21(r)(11)?
After receipt of the peer reviewer's comments, the following responses were developed and the
ECSPs were updated to reflect those changes. Comments were divided into four categories as
follows:
• Category 1: Comments that are clearly applicable (i.e., relevant under the charge and
improve the quality of the work product). These comments were incorporated into the
ECSP.
• Category 2: Comments that represent a misunderstanding by Informal Reviewers. These
comments were not incorporated into the ECSP.
• Category 3: Comments that are minor and do not materially change or lend additional
value to the ECSP (e.g., comments that were meant as "FYI', 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.
Table B-2 presents the site-specific responses to comments received on the Brunswick ECSP.
Duke Energy 141
Are there any deficiencies °in -the- study
Plan that might prevent you or. others
8)
I
(e.g., Regulators) from understanding
what is being proposed for sampling? If
Yes/No
I`
so, what needs to be added or clarified?
After receipt of the peer reviewer's comments, the following responses were developed and the
ECSPs were updated to reflect those changes. Comments were divided into four categories as
follows:
• Category 1: Comments that are clearly applicable (i.e., relevant under the charge and
improve the quality of the work product). These comments were incorporated into the
ECSP.
• Category 2: Comments that represent a misunderstanding by Informal Reviewers. These
comments were not incorporated into the ECSP.
• Category 3: Comments that are minor and do not materially change or lend additional
value to the ECSP (e.g., comments that were meant as "FYI', 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.
Table B-2 presents the site-specific responses to comments received on the Brunswick ECSP.
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Entrainment Characterization Study Plan
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Table B-2. Peer Reviewer Responses to Directed Charge Questions
Responseent
It is unclear why the age of the data would be relevant to
the findings. Transit through power plant cooling systems
can subject organisms to elevated temperature and physical
stresses that can damage organisms and make them more
As stated in the Plan, collections in the discharge will integrate all depths difficult to identify. Since the conditions of plant passage
of water and organisms actually entrained. have not changed in the intervening years, the data should
continue to be relevant.
A question remains, though, whether the sampling of the discharge fully
represents the numbers entrained, due to damages in the pumping and
piping. The text says the intake vs discharge was compared and
differences found to be non-significant. But the study was a long time
ago (1976) and may be questioned due to its age. Considering the
extensive effort at QA/QC for the samples once collected, it seems worth
doing a QA test (perhaps a few at different times of year) to ensure that
they discharge samples are really representative.
Site-specific studies conducted at BSEP determined that
samples collected in the discharge were not significantly
different from those collected at the intake and therefore
sampling at the discharge was appropriate and has been
the basis of sampling for decades. There is no reason to
assume that findings from new QA studies would be
different from what was observed previously given that the
facility configuration exclusive of the fine -mesh screens has
not changed. Therefore, Duke Energy does not, at this time,
propose to conduct new studies to compare intake to
discharge entrainment estimates.
Figure 6-1, which is intended to justify the monthly collections, isn't clear.
2 What constitutes the "baselihe".and "post -baseline'? The figure needs Text and figure caption were updated to clarify.
explanation either in the text of a more complete legend.
0
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Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
1 3
4 4
3
The double nets are fine. The mesh size is larger than most are now
using, though. May need to justify the larger mesh.
There is detailed QA/QC for handling the samples once collected, but
not for whether the sample at the discharge is truly representative.
There are historical, operational, and biological justifications
for continuing to use 505 --Nm mesh nets for sampling
entrainment at Brunswick. All previous entrainment and
larval survival studies conducted at Brunswick have used
505 --Nm mesh. Similarly, the ocean and estuary sampling
conducted historically has used this size mesh. Continuing
to use 505 --Nm mesh will allow a direct application of
previous data to support 122.21(r) evaluations.
From an operational standpoint, results of clogging studies
led to time limits on sampling with 505 --pm mesh.
Presumably using a finer -mesh would exacerbate clogging
issues and require shorter sampling durations.
There is also biological justification for the use 505—pm
mesh at Brunswick. The numerically dominant fish, shrimp,
and crabs collected at Brunswick are spawned in the near -
shore ocean or offshore. The majority of these fish larvae
are old enough to exhibit fin -ray development when
recruited to the estuary. As such, these larvae are large and
robust enough to avoid extrusion through the 505 --Nm
mesh. The numerically dominant estuarine spawners
(anchovies, gobies, and silversides) have egg diameters
that are 0.7 to 1.2 mm. In addition, gobies and silversides
have demersal and adhesive eggs that are less likely to
become involved with the intake. All three groups of
estuarine spawning species have value as forage base, but
are unlikely to contribute substantially to the social benefit of
fish protection because they lack commercial and
recreational value.
;l
ti
�i Refer to the response to Question 1 above.
ii
i
Dr. Coutant responded to the question, "Does the sampling plan provide
5 sufficient measures to preserve organism integrity and support NA
identification to the lowest taxon practicable?" with a "Yes" and provided
no additional comment.
MPC
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Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Two ears? Yes, but on page 23, 2ndparagraph after the bullets it
i; Y P 9 says R '
the project runs from January 2016 to December 31, implying a one-year
1 6 I study. Table 5-1 is clear that the ending is Dec 31, 2017. Need to fix the k� text. Text has been fixed. See response to Question 1 above.
i
' See#1 above re. representative.
Other criteria are well described as being met.
1 and 4 7 1 believe so, especially if the plan is revised somewhat in light of review.
The Study Plan has been updated with respect to reviewer
comments with the exception of Question 1.
FN
Duke Energy 1 44
The deficiencies are mostly in describing the intake system (which may
J
be a problem for the regulators or others not familiar with the intake) and
i;
NA; comment
i
editorial details.
ESCP was corrected to ECSP in Section 1.2, line 2. We
3
from the body of
{ j
1. Section 1.2, line 2: ESCP should be ECSP. But I suggest
I; have left ECSP as an acronym for Entrainment
the comments
spelling out the Entrainment Characterization Study Plan
Characterization Study Plan to be consistent with ECSPs
transmittal email
';
throughout. Few things are more aggravating for a reviewer
;; submitted of the other eight facilities in the Carolinas.
�
than a bunch of acronyms that put the document in code.
I
2. The description of the intake system isn't clear in many places
(see Page 4, middle paragraph, line 6; Figure 1; Section 2.2,
1s' paragraph, line 5). It's not clear whether the canal intake is
on the ship channel because the figures show it coming off the
NA; comment
side channel. It would be helpful for a regulator if the text
3
from the body of
better explained that the intake channel extends beyond the
Section 2 has been rewritten for clarity.
the comments
side channel out to the main ship channel. The text refers
transmittal email
repeatedly to Snows Marsh, but it is not labeled on any of the
figures. It would be helpful to have it labeled on each figure
that the text refers to it (see Section 2.2.1). Figure 3-2 could
include labels that would clear up much of the above.
'
NA; comment
from the bodyof
�
'� --- -'—--------_-
Section 2 has been rewritten for clarity and new figures and
3
the comments
3. Figures 2-2 and 2-3 are not called out in the text.
references have been added.
transmittal email
NA; comment
from the body of
4. The placement of the Fish Diversion Structure isn't clear,
3
the comments
especially in light of confusion noted above. What is meant by
Section 2 has been rewritten for clarity.
transmittal email
the "canal proper"? Just a few additional words would help.
NA; comment
5. In section 2.2.1, mention of the trash racks, blocker panels
from the body of
(what are these?) and fixed screens would be helped by a
fI After further discussion with Duke Energy, the blocker
3 {
the comments
i
diagram. What happens at the Fish Diversion Structure is
panels are the bar racks. This has been revised in the
transmittal email
;
pretty important to what gets into the intake. The text should
discussion of the diversion structure.
reference figures 2-3 and 2-4.
FN
Duke Energy 1 44

Entrainment Characterization Study Plan
Brunswick Steam Electric Plant
Category Charge No.^-'v�, h,,;4 q±Comment1,' Response`and Resolution
NA; comment
3 from the body of
the comments
transmittal email
I NA; comment
3 from the body of
the comments
transmittal email
6. Section 2.2.2, 1" paragraph: should refer to Figure 2-3; 2nd Section 2 has been rewritten for clarity.
paragraph needs to refer to Figure 2-5.
Figures 2-6 to 2-9. Engineering drawings are not the best for No response required'
showing what you want (too detailed), but may be ok.�--_--
NA; comment
from the body of g. Figure 3-1 label: Note form should be from Section 2 has been rewritten for clarity.
the comments
transmittal email '
NA; comment
! from the body of
3 the comments
transmittal email
9. Good historical summary and Section 4.
No response, required- —�
VP
Duke Energy 1 45