NC0024406_Ash Basin Discharge Relocation_19830117

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Resources&Community D ee • ;•
Jaries C Hunt, Jr., Governor• -• T�,
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 17, 1983
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Mr. S. B. Hager, Chief Engineer
Civil/Environmental Division
Duke Power Company
General Offices
422 South Church Street
Charlotte, North Carolina 28242
RE: Belews Creek Steam Station
Ash Basin Discharge Relocation
Proposed Water Quality Monitoring Program
NPDES Permit No. NCO024406
Dear Mr. Hager:
The staff of the Water Quality Section of the Division have thoroughly
reviewed and evaluated the proposed environmental monitoring program as
submitted by Duke Power Company on December 20, 1982. As you are aware,
this program will be an integral mechanism necessary to monitor and evaluate
any possible changes of aquatic conditions that might result from the pro-
posed relocation of the ash basin discharge.
The most recent proposed monitoring plan was very comprehensive and
encompassed most of the areas that will be essential to the project. A
review of this plan does indicate the need for a few additional inclusions
to ensure -that the data base for review is adequate.
The comments and recommendations will be discussed by Phase I, II and
III of the proposal.
PHASE I: Phase I addresses baseline sampling prior to discharge of
the ash basin to the river system.
A) Sediments: The frequency of sampling is considered adequate at
all sites. The current proposed plan requires that only selenium and arsenic
be analyzed. Whereas, these are the most concerning elemental analysis, it
is suggested thatcad` mom, copper, zinc_agd mercury be inc ISf.���'n6+ is phase
of analysis. Previous evaluations accomplished by Duke �ram' a as in
an increase in solubility of other elements unq� co i.tions bj
acidification. In addition, the ash basin will be di rgiTtb9 di rent
water environment than Belews Lake. To ensure that aNtio�l�a �dp1%r�ihwnts.
P. 0. Box 27687 Raleigh, N. C. 27611-7687
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Mr. S. B. Hager - 2 - January 17, 1983
other than Se and As, are not potential problems in this phase of the
plan.
B) Water Chemistry: It is recommended that the frequency of sampling
at sites 716.0&724'0.'0 be increased to bi-monthly (BM) to ensure an adequate
baseline for comparison and evaluation purposes. As explained in the previous
comments it is also recommended that the water chemistry parametric average
be expanded to include cadmium, copper, zinc and mercury. Review of the
literature states that Se and other elements exhibit an affinity for organic
matter. Thus, it is also suggested that Total Organic Carbon (TOC) be in-
cluded in this phase of the sampling program at all sites where water chemistry
is currently proposed.
(C) Benthos and Fish: The frequency and site locations appear adequate.
Again., as for the reasons previously stated it is recommended that elemental
analysis be expanded to include cadmium, copper, zinc and mercury. The current
proposal does not indicate proper explanation as to what components of the
fish are to be analyzed. It is suggested that body burden analysis be
accomplished on viscera and muscle tissue separately rather than whole fish
and that the results be expressed as dry weight. This will allow for com-
parison to data collected previously from the Belews Lake area.
This section of Phase I of the plan does not indicate what stages of
the life cycles of the fish populations is to be sampled. It is recommended
that various stages of life cycles be evaluated for the elemental analysis
such as eggs, laval stage and adult.
The benthos and fish section of this phase should be expanded to include
phytoplankton and periphyton identification, enumeration and elemental analysis.
In view of other situations within North Carolina in which coal fired power
plants discharges have impacted the aquatic ecosytems, it will be necessary to
evaluate and analyze. The frequency suggested would be Sp/S/F at all of the
sites indicated for Benthos and Fish analysis.
This section of the Phase I should also include evaluation of the
zooplankton commilnity. Zooplankton has been indicated as a very efficient
bio -accumulate of trace elements. Thus, data should be collected on identi-
fication, enumeration and elemental analyses on this aspect of the aquatic
food chain.
D) Benthos & Fish (Qualitative data): This section of the plan appears
adequate and no changes are recommended.
Site Locations: The divisional staff as well as representatives -from the
State of Virginia have expressed the need for an additional site in the Dan-
ville area. Water chemistry and sediments should be analyzed at this site.
Mr. M. R. Childrey (804-799-6695) of the Virginia State Health Department has
indicated his cooperation to assist in this site location.®
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This will conclude our comments and recommendations� PhagCr 1
of
proposed monitoring plU
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+ Mr. S. B. Hager - 3-- January 17, 1983
PHASE II: As Phase I is to establish baseline, Phase II should re-
flect similar design for parametric coverage to begin assessing any possible
impact after initiation of the discharge to the river. The recommendations
as previously discussed should be incorporated into Phase II of the monitoring
plan.
PHASE III: The details and parametric coverage of Phase III will be
dependent upon the results of Phases I and II. Therefore the plan as presented
is adequate. Comment at this time would seem premature until the data from
Phases I and II are thoroughly evaluated.
Due to the important nature of this monitoring program we hope the
cooperative effort shown previously will continue. We would like to express
our appreciation for the efforts of your staff relating to this matter,
especially those of Dr. Dave Anderson and Dr. Peter Cumbie whose insight has
been most beneficial.
If there are any comments or questions please feel free to contact
Mr. Steve Tedder, Supervisor, Technical Services Unit at 919-733-5083.
cc: Mr. J. R. Hendrick
Dr. David Anderson
Mr. Russel Radford
Mr. Forrest Westall
Mr. Bill Mills -
Mr. Scott VanHorn
Mr. -Steve Tedder
Sincerely,
(to. —
W. Lee Fleming Chief
Water Quality ection
A N' ®C
1984
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