NC0003425_Comments_20200226

SOUTHERN ENV IRON MENTAL LAW CENTER
Telephone [phone] WEST ROSEMARY STREET, SUITE 220 Facsimile 919-929-9421
CHAPEL HILL, NC 27516-2356
VIA US MAIL
February 19, 2020
RECEIVED
FEB 2 6 2020
Dr. Sergei Chernikov NCDEQ/DWR/NPDES
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Draft NPDES Wastewater Permit — Roxboro Steam Station, # NC0003425
Dear Dr. Chernikov:
On behalf of the Roanoke River Basin Association, please find enclosed comments on the draft
National Pollutant Discharge Elimination System permit noticed for public comment by the North Carolina
Department of Environmental Quality ("DEQ"); Division of Water Resources.
If you have any questions, please do not hesitate to get in touch.
Sincerely,
Jennifer Doucette
Legal Administrative Assistant
Southern Environmental Law Center
Enclosure
Charlottesville • Chapel Hill • Atlanta 6 Asheville • Birmingham • Charleston • Nashville • Richmond • Washington, DC

SOUTHERN ENVIRONMENTAL LAW CENTER
Telephone [phone] WEST ROSEMARY STREET, SUITE 220 Facsimile 919-929-9421
CHAPEL HILL. NC 27516-2356
February 19, 2020
VIA EMAIL AND U.S. MAIL
Dr. Sergei Chernikov
NCDEQ/DWR/NPDES
Water Quality Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
sergei. [e-mail]
RECEIVED
FEB 2 6 2020
NCDEQIDWRINPDES
Re: Draft NPDES Wastewater Permit — Roxboro Steam Station, # NC0003425
Dear Dr. Chernikov:
On behalf of the Roanoke River Basin Association, we submit the following comments
on the draft National Pollutant Discharge Elimination System ("NPDES") permit noticed for
public comment by the North Carolina Department of Environmental Quality ("DEQ"), Division
of Water Resources.
In 2016 and 2017, we submitted comments on prior drafts of this permit, and the
comments we submitted then remain applicable to this new draft, except as modified below.
DEQ should not allow Duke Energy to dump unlimited amounts of coal ash pollutants into Hyco
Lake and the other public waters at the Roxboro site, and should do more to protect against
impingment and entrainment at Duke Energy's cooling water intakes.
1. DEQ Must Protect Public Waters.
As explained in our 2016 and 2017 comments regarding previous drafts of this permit
and our 2018 comments regarding Duke Energy's request to expand the boundaries of its coal
ash lagoons, DEQ must protect tributary streams at Roxboro, and there is no justification for
expanding the waste boundaries of the East and West Ash Basins, as DEQ is now proposing to
do (as shown in the attachments to the draft permit, Fig. 1).
Similarly, there is no justification for continuing to allow Duke Energy to use Sargents
Creek and a bay of Hyco Lake as part of its wastewater treatment system. Sargents Creek is part
of the same water system as Hyco Lake, and fish can swim freely from the main body of Hyco
Lake into the bay referred to as the "heated water discharge pond." DEQ should regulate the
discharges into these waterways as external outfalls.
Charlottesville • Chapel Hill • Atlanta • Asheville • Birmingham • Charleston • Nashville • Richmond • Washington. DC
100% recycled paper

In addition, while some waters impounded for waste treatment pursuant to Section 404
may be temporarily removed from the definition of waters of the United States, see, e.g., Ohio
Valley Envd. Coal. v. Aracoma Coal Co., 556 F.3d 177, 215 (4th Cir. 2009), such waters may
not be permanently removed from the Clean Water Act's protections. DEQ should clarify in the
final permit that after the coal ash basins are closed and the plant is retired, these waterways will
be recognized as protected waters of the United States under the Clean Water Act.
2. DEQ Must Strengthen the Pollution Limits in this Permit.
The current draft permit contains virtually no pollution limits to protect Hyco Lake and
its tributaries. DEQ has made the already -inadequate limits of the prior draft permits from 2016
and 2017 even weaker in the current draft permit.
Hyco Lake is an important public resource that has been harmed over decades by the
Roxboro plant's pollution, including fish consumption advisories and multiple fish kills due to
selenium and other pollutants. Selenium concentrations of 3-8 µg/L are demonstrably toxic and
lethal to fish according to EPA.' Yet this permit would allow unlimited amounts of selenium and
many other pollutants from the coal ash basins to enter the main body of Hyco Lake.
Recent sampling of the lake shows that coal ash pollution from the Roxboro coal ash site
is continuing to have a significant impact:
• Arsenic concentrations in surface water and fish tissue (largemouth bass) were higher in
samples taken near the Roxboro plant compared with upstream samples. Arsenic
concentrations in sediments near the Roxboro plant increased in 2018 compared to 2017.
• Cadmium concentrations in sediments are higher near the Roxboro plant than upstream
samples, and these concentrations increased in 2018 compared to 2017.
• Copper concentrations in bluegill and largemouth bass were higher in 2018 than in
previous years since 2013.
• Mercury concentrations in sediments increased in 2018 compared to 2017. And mercury
concentrations in bluegill were higher near the Roxboro plant than upstream.
• Selenium concentrations in sediments near the Roxboro plant increased in 2018
compared to 2017. And selenium concentrations in fish samples are higher near the
plant; bluegill samples in particular are "significantly greater" than upstream.
See Duke Energy, Roxboro Steam Electric Plant 2017-18 Environmental Monitoring Report
(Nov. 2019), at pp. 11-14 and Appendices, Attachment 1.
' EPA, ENVIRONMENTAL ASSESSMENT FOR THE EFFLUENT LIMITATIONS GUIDELINES AND
STANDARDS FOR THE STEAM ELECTRIC POWER GENERATING POINT SOURCE CATEGORY, Docket
No. EPA-821-R-15-006 (Sept. 2015), at 3-5 (available at
https://www.epa.gov/sites/production/files/2015-10/documents/steam-electric-envir 10-20-
15.pdf. ) (hereinafter, ` ELG EA").
2

Despite these documented impacts from the Roxboro plant, DEQ is proposing to issue a
permit that would allow Duke Energy to discharge into the body of Hyco Lake with no limits at
all for any of the above -listed pollutants.
DEQ must strengthen the permit, as explained in our prior comments and as follows:
a. Outfall 003
Outfall 003 is the only "external" outfall recognized in the permit; it is an opening
between a bay of Hyco Lake and the main body of the lake, where discharges from Duke
Energy's coal ash lagoons, FGD treatment system, contaminated groundwater flow, seeps, and
unpermitted drains all flow out into the main body of Hyco Lake.
Yet this outfall contains no limits at all for coal ash pollutants, including arsenic,
mercury, selenium, and many others. DEQ must add protective limits for these pollutants for the
pumping out of Duke Energy's highly -contaminated wastewater. All of the technology -based
limits that apply to the "internal" outfalls at Roxboro should also apply at Outfall 003. Doing so
is necessary to ensure that the main body of the lake is protected from Duke Energy's coal ash
pollution with enforceable limits. The "internal" limits in this draft permit are not enough. The
coal ash pollution at Roxboro flows into the bay of Hyco Lake upstream of Outfall 003 via
multiple routes: surface water flows from permitted "internal" discharge points, chimney drains
not authorized in this permit, and flows of contaminated groundwater. If Duke Energy is not
discharging harmful amounts of coal ash pollutants via Outfall 003, it will be able to comply
with these limits; but if not, they must be in place and enforceable by the public to ensure Duke
Energy does not further contaminate Hyco Lake.
DEQ should also add limits for arsenic, selenium, and mercury for the additional reason
that DEQ has recognized a protective trigger is needed for the decanting and dewatering process.
The effluent limitations for this outfall properly state that "If any one of the pollutants (As, Se,
Hg) reaches 85% of the allowable level during the decanting/dewatering, the facility shall
immediately discontinue discharge of the wastewater and report it ...." This requirement is an
important safeguard against excessive pollution during decanting and dewatering. However, the
permit contains no limits for any of the listed pollutants at this outfall. Reaching 85% of "the
allowable level" is an impossibility —Duke Energy can discharge unlimited amounts of these
pollutants under the current draft permit. Thus, protective limits must be added in order to make
this important backstop effective.
The lack of coal ash pollution limits is particularly glaring because compared to the prior
drafts, the current draft would now allow Duke Energy to release unlimited amounts of thallium
into the main body of Hyco Lake through Outfall 003.
Thallium is a toxic pollutant, 40 C.F.R. § 401.15. According to the Agency for Toxic
Substances and Disease Registry, exposure to thallium can cause vomiting, diarrhea; temporary
hair loss; effects on the nervous system, lungs, heart, liver, and kidneys; and death.2 Animal data
z https://www.atsdr.cdc.Gov/toxfMs/tfasp?id=308&tid=49
3

suggest that the male reproductive system may be susceptible to damage by even low levels of
thallium.3 According to the Centers for Disease Control and Prevention, "thallium was used
historically as a rodenticide, but has since been banned in the United States due to its toxicity
from accidental exposure."4
The prior draft in 2017 imposed an average and daily maximum limit of 0.24 ug/L of
thallium. This limit matches the U.S. EPA's National Recommended Water Quality Criteria
(0.24 ug/L for thallium); these EPA criteria are published, peer -reviewed recommendations for
states and tribes.5 But now, DEQ is proposing to eliminate that limit and instead allow unlimited
thallium discharges into the main body of Hyco Lake. DEQ does not explain this change, but it
appears to be based on a decision to use the federal maximum contaminant level of 2 ug/L as the
basis for a water quality -based calculation of how much thallium Duke Energy could discharge
into Hyco Lake before the entire waterbody of the lake exceeded this level.
This approach is fatally flawed. First, DEQ is simply wrong to weaken effluent limits via
a water -quality -based approach. The Clean Water Act requires that NPDES permits impose
technology -based effluent limitations (TBELs) reflecting the "minimum level of control that
must be imposed in a permit" for each pollutant and each wastestream being discharged from the
ash ponds. 40 C.F.R. § 125.3(a). If TBELs have not been set by EPA, DEQ must set them on a
case -by -case basis. See id. at § .122.44(a)(1). Water -quality -based standards may only be used
where they are more stringent than the applicable technology -based standards. Id. § 122.44(d).
However, DEQ's approach is the opposite. DEQ appears to be using water -quality -based
standards as a weaker standard, undermining the Clean Water Act. DEQ's "reasonable potential
analysis" is based on the idea that if a discharge will not cause the surface water of the lake to
exceed water quality criteria —potentially rendering the entire lake unsafe or unusable —then the
discharge is permitted. In other words, DEQ relies on the dilution of the entirety of Hyco Lake
to allow Duke Energy to discharge as much pollution as it can without contaminating billions of
gallons of public waters. But the requirements of the Clean Water Act prohibit this approach.
Water -quality -based limits may be used only where they are more stringent than technology -
based limits, not where they are less stringent.
As to thallium in particular: DEQ acknowledges that it lacks "more substantive
information" on the toxicology of thallium. Attachment 2 at 3. If full information is not
available from EPA, and faced with the choice between a more -protective limit (as reflected in
the prior draft permit) and a less -protective, unlimited approach (as reflected in the current
permit), DEQ should choose the more protective option. In 2017, DEQ set the limit of 0.24 ug/L
for thallium because the agency deemed it necessary to protect the public and Hyco Lake;
replacing that limit with no limit at all while acknowledging a lack of definitive information is a
serious mistake —all the more so for a substance that has been banned from rat poison because it
is too toxic.
3 id.
4 https://www.cdc.gov/niosh/ershdb/emergencyresponsecard 29750026.html
5 See DWR Thallium Review, at 1 (Attachment 2).
4

The current draft also contains self-contradictory language regarding total residual
chlorine (TRC). The effluent limit is set at a daily maximum of 28 ug/L. But Note 3 to these
effluent limitations states that "[t]he Division shall consider all effluent TRC values reported
below 50 ug/L to be in compliance with the permit." This makes no sense —the effluent limit is
28 ug/L, so discharges above that level violate the permit. DEQ cannot "consider" discharges of
almost twice the effluent limit to be in compliance.
DEQ should also add a protective limit for bromide discharges from Outfall 003.
Bromide is naturally present in coal, and is highly soluble in water.6 EPA has concluded that
once discharged from steam electric power plants, reaction by bromide with other constituents in
water is cause for concern from a human health standpoint.7 The bromide ion in water can form
brominated disinfection byproducts when drinking water plants use certain processes including
chlorination and ozonation to disinfect the incoming source water for human consumption.
According to EPA, some of these byproducts from chlorinated water are associated with human
bladder cancer, and bromine -substituted disinfection byproducts (DBPs) "are generally thought
to have higher risks of cancer and other adverse human health effects compared to DBPs
containing chlorine instead of bromine..."8 Because bromides in surface waters can react with
organic matter in the surface water to form disinfection byproducts at drinking water treatment
plants downstream,9 monitoring and limits for bromides from the Roxboro facility are needed.
This issue is especially urgent for the Roxboro permit because drinking water systems
downstream of the Roxboro plant, such as Clarksville, VA10 (which withdraws water from Kerr
Lake) and South Hill, VA11 (which withdraws water from Lake Gaston), have total
trihalomethane levels above the federal maximum contaminant level. Yet DEQ is not even
requiring Duke Energy to monitor bromide discharges from the Roxboro plant —when it should
be enforcing protective limits.
b. Outfa11001
In the previous draft permit, Duke Energy and DEQ proposed to shield all of its pollution
of an unnamed tributary flowing to Hyco Lake by designating the stream as Outfall 001.
Fortunately, DEQ has rejected that approach in the current draft permit. Instead, DEQ has
located Outfall 001 partway along the rerouted stream flow from the ponded area adjacent to the
East Ash Basin that Duke Energy refers to as the "Eastern Extension"; the proposed outfall is
located where the rerouted flow from this area joins an unnamed tributary. However, there is
still no justification for any "Outfall 001" discharge, since Duke Energy does not treat any
wastewater that discharges in this location, and nothing about Duke Energy's operations at this
location has changed since the prior permit, which did not contain this outfall. This outfall is
6ELGEAat3-11.
' See id. at 3-10.
8 id.
9 See id. at 3-11.
10 Town Of Clarksville 2018 Annual Drinking Water Quality Report, hops://www.clarksvilleva.or wp-
content/uploads/2019/07/Town-of-Clarksville-Water-Quality-Report- .pdf, Attachment 3.
" Town of South Hill 2018 Consumer Confidence Drinking Water Quality Report,
hqs://www.southhillva.orWimaaes/documents/2018 CCR.pdf, Attachment 4.
5

simply a fictional addition to the permit to excuse Duke Energy's ongoing pollution of the waters
upstream of this location.
To make matters worse, DEQ is proposing to allow 340 ug/L of arsenic as a daily
maximum discharge at this proposed Outfall 001. This is 34 times higher than the limits in the
2016 and 2017 draft permits, and 34 times higher than the state water quality standard for
arsenic. There is no justification for this change.
Moreover, this daily limit appears to be an error: the monthly average for this outfall is
10 ug/L, which would make DEQ's allowance of 340 ug/L on a single day a mathematical
impossibility. DEQ should correct this mistake and return to the protective, technology -based
limits of 10 ug/L for arsenic set in the prior draft permits as both the daily maximum and
monthly average for this outfall.
DEQ is also proposing to allow Duke Energy to discharge unlimited amounts of sulfates,
an indicator pollutant for coal ash contamination and a serious risk in its own right. High
concentrations of sulfates in drinking water can cause diarrhea; the U.S. EPA has established a
secondary maximum contaminant level ("MCL") of 250 mg/L and a health -based advisory of
500 mg/L. The 2016 and 2017 draft permits contained monthly average and daily maximum
sulfate limits of 250 mg/L; there is no valid reason to abandon those limits here.
DEQ should also add limits for mercury, nickel, and lead. The effluent limitations for
this outfall state that "If any one of the pollutants (As, Se, Hg, Ni, and Pb) reaches 85% of the
allowable level during the decanting/dewatering, the facility shall immediately discontinue
discharge of the wastewater and report it ...." This requirement is an important safeguard
against excessive pollution during decanting and dewatering, yet the permit contains no limits
for mercury, nickel, or lead at this outfall. These limits must be added to give effect to this
provision.
c. Outfall 002
DEQ is failing to protect public waters because the draft permit contains no limits for any
coal ash pollutants from the ash basins, either during normal operations/decanting or dewatering.
The most highly -contaminated wastewater from the bottom of the lagoon will be pumped out
during these operations, and DEQ must put in place effluent limits that protect public waters, as
it has done at other sites like Riverbend and Sutton. There are no limits at all for any of the key
coal ash pollutants, including arsenic, mercury, selenium, and many others, at both this "internal"
Outfall 002 and at Outfall 003 within the main body of Hyco Lake. DEQ must fix this
fundamental flaw in the permit.
n

Moreover, DEQ has dramatically increased the decanting and dewatering rates allowed
by this draft permit, without demonstrating that Duke Energy can do it safely. The decanting rate
for pumping out the freestanding water in the Roxboro ash basins has been limited to one foot
per week in the 2016 and 2017 draft permits, consistent with EPA's guidance to DEQ for
avoiding rapid drawdown that can weaken earthen dams. DEQ previously concluded that a one -
foot per week drawdown rate is necessary to "maintain the integrity of the dams" at Duke
Energy's Sutton facility.
However, the current draft permit would allow a decanting rate of one foot per day,
without any dam safety justification.
In addition, DEQ has doubled the dewatering rate for the most toxic wastewater
saturating the ash in these basins. In 2016, the draft permit limited dewatering to 1 million
gallons per day (MGD), but this draft would allow 2 MGD.
These dramatically increased pumping flows are significant from a dam safety
perspective, and also because the permit contains no limits for coal ash pollutants from the
highly -polluted wastewater that will be pumped out of these coal ash basins, including arsenic
and selenium. As we explained in our prior comments, DEQ must consistently apply the limits it
has used in permits at other Duke Energy coal ash facilities (Riverbend and Sutton) to ensure that
decanted and dewatered wastewater from the lagoons is properly treated.
d. Outfall 006
DEQ is proposing to weaken the limits for coal pile runoff via Outfall 006 by removing
the monthly average limits for the suspended solids, total selenium, and oil and grease. These
limits provided an important check on Duke Energy's pollution. Now, the draft permit would
simply allow Duke Energy to discharge the daily maximum amount of these pollutants every
single day. This represents a dramatic increase in coal pollution.
For example, the 2017 permit limited Duke Energy's selenium discharges to a monthly
average of 5 ug/L. Now, that monthly average limit has been removed from the draft, so Duke
Energy could discharge the daily maximum of 56 ug/L every day. That amounts to more than a
tenfold increase in selenium pollution. Hyco Lake has suffered the effects of Duke Energy's
selenium contamination for too long, and there is no justification for this dramatic increase in
selenium and other pollutants from this outfall.
At a minimum, all the monthly average limits from the 2017 draft should be restored.
e. Outfalls 008, 009, 010, 012A and 012B
DEQ has removed the pH limit for these outfalls, which include sewage wastewater from
the plant, chemical metal cleaning wastes, and the flue gas desulphurization (FGD) system, and
low -volume wastes from new settling basins. There is no justification for this change. The prior
limit of 6 — 9 S.U. must be restored.
7

f. Outfall 008
Condition A.(7) for this outfall should be corrected to refer to Special Condition A.(22),
rather than A.(23).
g. Outfall 009
Condition A.(8) for this outfall defines a "discharge event" as being tied to "fly ash
containing metal cleaning waste ... discharged into the ash pond." However, fly ash is handled
dry at this facility and we understand that it is not discharged into the ash pond. The permit
should be clarified to prohibit fly ash from being discharged into the ash pond.
h. Outfalls 010 and O11
Duke Energy currently operates a biological treatment system for its FGD wastewaters,
which discharges via Outfall 010. Yet the limits proposed by DEQ for this existing system at
Outfall 010 would not go into effect until December 31, 2021. This makes no sense —the limits
for the existing system should go into effect upon issuance of the permit. There is absolutely no
reason to delay these limits, especially when draft permits for Roxboro have been proposed since
2016. Duke Energy has had many years to prepare to comply with FGD discharge limits, and
there is no excuse for delaying compliance with limits on its existing treatment system.
For the new FGD system discharge at Outfall 011, the Dec. 2021 compliance date is an
improvement over the prior draft permit's 2023 compliance date. However, the fundamental
problem remains that the limits for the new system are identical to those for the existing system,
despite the fact that the new system is supposed to be an improvement. In addition, the mercury
limits remain disproportionately high for the rural community around the Roxboro plant, in stark
contrast to the limits DEQ put in place for permits in the Charlotte and Wilmington metropolitan
areas. The Roxboro permit should be revised to match the mercury limits in place for the
Riverbend and Sutton facilities.
3. The Draft Permit Does Not Comply with Cooling Water Intake Requirements.
Section 316(b) of the Clean Water Act requires that cooling water intake structures at
pollution sources like Roxboro use the "best technology available for minimizing adverse
environmental impact." Id. § 1326(b). EPA implemented that Clean Water Act protection in
2014 by issuing the Cooling Water Intake Structure Rule. Final Regulations to Establish
Requirements for Cooling Water Intake Structures at Existing Facilities and Amended
Requirements at Phase I Facilities, 79 Fed. Reg. 48,300 (Aug. 15, 2014).
For power plants taking in more than 125 million gallons of water every day —a threshold
the Roxboro facility exceeds many times over —the rule requires utilities to submit additional
information analyzing how much the cooling water intake structure harms fish and shellfish
through entrainment and on reducing entrainment. 40 C.F.R. § 122.21(r)(7)-(13).
8

To protect against impingement, facilities must meet one of several options EPA has
declared "best technology available," including modified traveling screens, flow velocity
reductions, and operating a closed -cycle recirculating system. 40 C.F.R. § 125.94(c). For
entrainment, permitting agencies must establish a site -specific standard. Id. § 125.94(d).
a. The Draft Permit Would Allow Duke Energy to Unreasonably Delay
Submitting Required Information
First, there appears to be an error in the draft permit. Both the draft permit cover letter
and the Fact Sheet state that the date for submission of the required information is May 31, 2022.
Yet the text of the permit itself (Condition A.(25)) erroneously lists May 31, 2023 as the
deadline.
More fundamentally, DEQ must require Duke Energy to submit this required information
more promptly.
Duke Energy first proposed a schedule for submitting this information back in 2015.12 In
the 2016 Fact Sheet, DEQ proposed to allow Duke Energy to delay submitting the required
information until the next permit renewal. Now, four years after the 2016 draft permit, DEQ has
abandoned that flawed approach, yet is still proposing to give Duke Energy an additional three
years, until May 31, 2023 (or 2022), to submit the required information. DEQ should not reward
Duke Energy's delay tactics by continually extending the deadline for these submissions.
Duke Energy not only should have started these studies by now, but completed them.
The Rule provided "advance notice to affected facilities about permit application materials and
compliance schedules." See 79 Fed. Reg. 48,359. Duke Energy has known of its obligation to
gather and submit this information since the Cooling Water Intake Study Rule issued in 2014.
EPA calculated that facilities would need no more than 39 months to complete the studies and
another 3 months to obtain peer review. For that reason, EPA stated in rulemaking that "July 14,
2018 reflects the date after which all permit application requirements must be submitted as
specified at § 125.95." Id.
DEQ's proposed drawn -out timeline violates the Clean Water Act. Facilities with
permits expiring before July 14, 2018, may request an extension from permitting agencies that
would allow them to submit the required information "as soon as practicable." 79 Fed. Reg.
48,358; see also 40 C.F.R. § 125.95(a)(2). But since this permit renewal has been extended well
past July 2018, Duke Energy is not eligible for such an extension. And in any event, Duke
Energy does not need, and cannot lawfully receive, eight years or more to submit information
that should have taken less than four years to prepare and should have been submitted already.
12.Nathan Craig, Duke Energy, "Alternate Schedule Request" (Mar. 10, 2015),
hilps:Hedocs.deg.nc.gov/WaterResources/DocView.aspx?id=482704&dbid=0&repo=WaterResources (Attachment
5).
9

b. DEQ Must Require Additional Measures to Reduce Impingement and
Entrainment
Duke Energy claims its cooling system at Roxboro is a "closed -cycle" recirculation
system, but this draft and prior draft permits have recognized consistently that the cooling water
discharge from Roxboro is "once -through." E.g., 2020 Supplement to Permit Cover Sheet
(Heated Discharge Pond/Outfall 003); 2017 Fact Sheet at pp. 1-2; 2016 Fact Sheet at pp. 1-2.
Moreover, Duke Energy itself did not identify Roxboro as closed -cycle in its 2015 submission to
DEQ, supra n.10, in contrast to actual closed -cycle facilities like Mayo and Cliffside.
Nonetheless DEQ has rubber-stamped Duke Energy's aging once -through system as a
"closed -cycle recirculating system" and the best technology available for impingement. This
designation is a charade.
True closed -cycle systems reduce impingement and entrainment of fish and shellfish
because they drastically reduce water intake in comparison to a once -through system, using up to
95 percent less water. 79 Fed. Reg. 48,342, 48,345. Accordingly, "[a] facility employing a
closed -cycle recirculating system will typically reduce impingement by more than 95 percent."
Id. at 48,345. The Roxboro cooling water intake structure, which is designed for an intake of
1,114 MGD and sucked in more than half a billion gallons of water per day as of 2018, provides
no such benefits.
Duke Energy's use of Hyco Lake, a water of the United States, as a cooling water source
does not make its cooling water intake structure a closed -cycle system. The Rule allows some
cooling ponds that are impounded waters of the United States to qualify as a closed -cycle system
only if "the facility demonstrates to the satisfaction of the Director that make-up water
withdrawals attributed specifically to the cooling portion of the cooling system have been
minimized." 40 C.F.R. § 125.92(c)(2) (emphasis added).
But Duke Energy cannot qualify for this provision here. Far from showing that Duke
Energy claims minimizes its make-up water withdrawals, the company's submission, quoted in
the draft permit Fact Sheet, states only that "the source of all makeup water is the approximately
300 square mile Hyco Lake watershed. No other sources of makeup water are currently available
" Fact Sheet at 4. In other words, Duke Energy relies on the entire Hyco Lake watershed for
cooling water —and crucially for this provision of the regulation, Duke Energy is not doing
anything that minimizes the makeup water for the supposedly "closed -cycle" system it is
claiming, which is in fact a water of the United States and is supplied by nothing less than the
entire flow of the Hyco Lake watershed.
Duke Energy also claims it minimizes its cooling water withdrawals from Hyco Lake, but
this is not relevant for the regulatory designation Duke Energy is claiming, and in any event
Duke Energy's justifications fail. It claims Units 1-3 have design features to increase their
efficiency, yet admits that "Units 1 and 2 operate in a once -through cooling mode year round."
Fact Sheet at 3. And "Unit 3 operates in a once -through cooling mode part of the year," but
during the hotter months is routed to a cooling tower. Id. In other words, Duke Energy has the
ability to operate using a cooling tower to avoid once -through cooling. If Duke Energy were
10

truly minimizing its withdrawals, it would use this cooling tower system to eliminate once -
through cooling all year round.
Duke Energy also makes the absurd claim that because it runs the Roxboro generating
units at less than full capacity, it is somehow minimizing its water withdrawals. Fact Sheet at 4.
Of course, the reduced operation of the Roxboro generating units is based on completely
unrelated factors, such as the price of natural gas, that have nothing to do with conserving water.
The question is not how often Duke Energy runs the generating units, but rather whether it could
run them the same amount while using less water. At Roxboro, Duke Energy plainly could do
so, but chooses not to.
DEQ cannot allow Duke Energy to paint its aging system as the "best technology
available." Rather, it must require Duke Energy to comply with the impingement standard with
another, actually effective, control technology.
In addition to impingement, Duke Energy must also protect against entrainment. To that
end, DEQ must determine on a site -specific basis what is the best technology available to
minimize entrainment at Roxboro. 40 C.F.R. § 125.94(d). But DEQ has erroneously left out any
protections, interim or final, against entrainment.
The rule allowed interim requirements prior to July 2018. But for this permit in 2020,
DEQ must go beyond interim requirements and include final impingement and entrainment
protections in each permit. 40 C.F.R. § 125.98(b)(2). The rule is clear: if issued after July 14,
2018, "the permit must include conditions to implement and ensure compliance with the
impingement mortality standard at § 125.94(c) and the entrainment standard at § 125.94(d)." Id.
(emphasis added).
A true closed -cycle system relying on cooling towers would reduce water intake —and,
correspondingly, entrainment —by up to 95 percent. This technology is not new and has in fact
been available for decades. Other measures that would improve the situation include finer mesh
screens, limited velocity intakes, and fish recovery and return systems. Duke Energy uses these
measures at other sites, such as the Dan River makeup intake at Belews Creek, and should be
required to implement additional protections at Roxboro.
Sincerely,
k1�nD �
Nicholas S. Torrey
Senior Attorney
11

RECEIVED
ATTACHMENT 1 FEB 26 2020
NCDEQ/DWR/NPDES

ROXBORO STEAM ELECTRIC PLANT
2017-2018 ENVIRONMENTAL MONITORING REPORT
November 2019
Water Resources
DUKE ENERGY
Raleigh, North Carolina

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report.
Preface
This copy of the report is not a controlled document as detailed in the Environmental Services Biology
Program Quality Assurance Manual. Any changes made to the original of this report subsequent to
the date of issuance can be obtained from:
Water Resources
DUKE ENERGY
410 South Wilmington Street
Raleigh, North Carolina 27601
Duke Energy Progress i Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Table of Contents
Pa9c
Preface.........................................................................................................................................
i
Listof Tables...............................................................................................................................
iii
Listof Figures..............................................................................................................................
iii
Listof Appendices.......................................................................................................................
iii
Metric -English Conversion and Units of Measure......................................................................
v
Water Chemistry Abbreviations..................................................................................................
v
ExecutiveSummary.....................................................................................................................
vi
2017-2018 Environmental Monitoring Report............................................................................
1
HistoricalOverview...............................................................................................................
1
Reservoir Description............................................................................................................
3
Objectivesand Methods........................................................................................................
3
Environmental Monitoring Results for 2017-2018................................................................
9
Limnology........................................................................................................................
9
Temperature and Dissolved Oxygen.........................................................................
9
Water Clarity Constituents........................................................................................
10
Nutrients and Phytoplankton Biomass.......................................................................
10
Ions, Hardness, and Specific Conductance................................................................
10
Alkalinityand pH......................................................................................................
11
TraceElements................................................................................................................
11
Arsenic.......................................................................................................................
11
Cadmium....................................................................................................................
12
Copper.................................................................................................... I...................
12
Manganese.................................................................................................................
13
Mercury......................................................................................................................
13
Selenium....................................................................................................................
14
Thallium.....................................................................................................................
14
Fisheries...........................................................................................................................
15
Fish Species Composition..........................................................................................
15
Fish Abundance, Distribution, and Size Structure.....................................................
15
Balanced Indigenous Community..............................................................................
18
FishCommunity Health.............................................................................................
19
BiofoulingMonitoring.....................................................................................................
19
Summary and Conclusions..........................................................................................................
19
References....................................................................................................................................
20
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
List of Tables
Table Page
1 Hyco Reservoir environmental monitoring program ............................................... 6
2 Field sampling and laboratory methods utilized in the Hyco Reservoir
environmental monitoring program......................................................................... 7
3 Statistical analyses performed on data collected for the Hyco Reservoir
environmental monitoring program......................................................................... 8
List of Figures
Fi ug_re Page
1 Hyco Reservoir sampling locations......................................................................... 5
List of Appendices
Appendix Page
1 Depth profiles of water temperature, dissolved oxygen, pH, and specific
conductance at Hyco Reservoir during 2017........................................................... 22
2 Depth profiles of water temperature, dissolved oxygen, pH, and specific
conductance at Hyco Reservoir during 2018........................................................... 24
3 Means, ranges, and spatial trends of selected limnological variables from
surface waters of Hyco Reservoir during 2017....................................................... 26
4 Means, ranges, and spatial trends of selected limnological variables from
surface waters of Hyco Reservoir during 2018....................................................... 27
5 Concentrations of chemical variables in surface waters of
Hyco Reservoir during 2017.................................................................................... ? 8
6 Concentrations of chemical variables in surface waters of
Hyco Reservoir during 2018.................................................................................... 31
7 Long-term trends of selected parameters at Station B2 from Hyco Reservoir
from2009 through 2018.......................................................................................... 34
8 Long-term trends of selected parameters at Station C2 from Hyco Reservoir
from 2009 through 2018............................................................
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
9 Long-term trends of selected parameters at Station D2 from Hyco Reservoir
from 2009 through 2018..................................................................................
10 Long-term trends of selected parameters at Station F2 from Hyco Reservoir
from 2009 through 2018..........................................................................................
11 Means and standard errors of trace element concentrations in sediments and
fish by transect from Hyco Reservoir during 2017.........................................
12 Means and standard errors of trace element concentrations in sediments and
fish by transect from Hyco Reservoir during 2018.........................................
13 Long-term trends of selenium concentrations in Bluegill, Largemouth Bass, and
White Catfish muscle tissues at Transect C and Transect D from
Hyco Reservoir from 2009 through 2018..............................................................
14
15
16
17
18
19
20
21
22
23
24
Total number and weight of fish collected with electrofishing from Hyco
Reservoir during 2017 and 2018.............................................................................
Mean catch per hour of fish collected with electrofishing by transect from Hyco
Reservoir during 2017.............................................................................................
Mean catch per hour of fish collected with electrofishing by transect from Hyco
Reservoirduring 2018.............................................................................................
Length -frequency distributions of Bluegill by transect collected by
electrofishing from Hyco Reservoir during 2017 .............................
Length -frequency distributions of Bluegill by transect collected by
electrofishing from Hyco Reservoir during 2018 .............................
Length -frequency distributions of Largemouth Bass by transect collected by
electrofishing from Hyco Reservoir during 2017............................................
Length -frequency distributions of Largemouth Bass by transect collected by
electrofishing from Hyco Reservoir during 2018............................................
Length -frequency distributions of Gizzard Shad by transect collected by
electrofishing from Hyco Reservoir during 2017......................................
Length -frequency distributions of Gizzard Shad by transect collected by
electrofishing from Hyco Reservoir during 2018......................................
36
37
38
39
40
41
42
43
44
45
46
47
48
Relative weight values versus length for Bluegill, Gizzard Shad, and Largemouth Bass
collected by electrofishing from Hyco Reservoir during 2017 ............................... 50
Relative weight values versus length for Bluegill, Gizzard Shad, and Largemouth Bass
collected by electrofishing from Hyco Reservoir during 2018 ............................... 51
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
25 Proportional Size Distribution ranges for balanced populations of Bluegill versus
Largemouth Bass and Gizzard Shad versus Largemouth Bass collected from
Hyco Reservoir during 2017 and 2018.................................................................... 52
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Metric -English Conversion and Units of Measure
Length
1 micron (µm) = 4.0 x 10' inch
1 millimeter (mm) = 1000 µm = 0.04 inch
1 centimeter (cm) = 10 mm = 0.4 inch
1 meter (m) = 100 cm = 3.28 feet
1 kilometer (km) = 1000 m = 0.62 mile
Area
1 square meter (m2) = 10.76 square feet
1 hectare (ha) = 10,000 m2 = 2.47 acres
Volume
1 milliliter (ml) = 0.034 fluid ounce
1 liter = 1000 m1= 0.26 gallon
1 cubic meter = 35.3 cubic feet
Weight
1 microgram (µg) = 10"3 mg or
10-6 g = 3.5 x 10-8 ounce
1 milligram (mg) = 3.5 x 10"5 ounce
1 gram (g) = 1000 mg = 0.035 ounce
1 kilogram (kg) = 1000 g = 2.2 pounds
1 metric ton = 1000 kg = 1.1 tons
1 kg/hectare = 0.89 pound/acre
Temperature
Degrees Celsius (°C) = 5/9 (°F-32)
Specific Conductance
µS/cm = Microsiemens/centimeter
Turbidity
NTU = Nephelometric Turbidity Unit
Water Chemistry Abbreviations
Cl- - Chloride TDS - Total dissolved solids Al - Total aluminum
SO2-4 - Sulfate TSS - Total suspended solids As - Total arsenic
Ca221 - Total calcium TOC - Total organic carbon Cd - Total cadmium
Mg"
- Total magnesium TP
- Total phosphorus
Cu -
Total copper
Na'
- Total sodium TN -
- Total nitrogen
Hg -
Total mercury
TS - Total solids NH3-N - Ammonia nitrogen Se - Total selenium
NO3+ NO2-N - Nitrate +nitrite -
nitrogen
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Executive Summary
During 2017 and 2018, surface water temperatures, dissolved oxygen concentrations, pH,
specific conductance, and Secchi disk visibility remained within the ranges previously observed in
Hyco Reservoir depending on location. A number of limnological variables measured in the reservoir
surface waters including calcium, chloride, hardness, total dissolved solids, and specific conductance
have stabilized (i.e., trend not increasing) compared to previous years despite some seasonal variation
during 2017 and 2018, primarily due to lower power plant dispatch rates and operation of the Flue
Gas Desulfurization System.
Concentrations of target trace elements, including arsenic, cadmium, copper, mercury, and
selenium, measured in the reservoir surface waters remained below water quality criteria during 2017
and 2018. However, selenium concentrations in the muscle tissues of Bluegill, White Catfish, and
Largemouth Bass continued to be statistically greater at the monitoring location near the discharge
compared to the concentrations at the designated upstream comparison monitoring location during
2017. In 2018, only White Catfish had statistically greater selenium concentrations in muscle tissues
at the monitoring location near the discharge compared to the concentrations in the fish located at the
upstream monitoring location.
Despite receiving a thermal discharge, the fish community in Hyco Reservoir remained a self-
sustaining, balanced population of regionally common species during 2017 and 2018.
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Roxboro Steam Electric Plant
2017-2018 Environmental Monitoring Report
Historical Overview
Duke Energy Progress (DEP; formerly Carolina Power & Light) began construction of Hyco
Reservoir in 1963 to serve as a cooling water source and receiving water discharges from the Roxboro
Steam Electric Plant (Roxboro Plant). After reaching full pool in 1965, the reservoir was noted as a
popular fishery throughout the remainder of the 1960s and most of the 1970s. In 1980, a large-scale fish
kill was observed throughout much of the reservoir after the start-up of Unit 4. Biological monitoring
conducted by Company biologists showed continued declines in the fishery. Special experimental
bioassay studies were conducted and ultimately determined that elevated concentrations of selenium in
the water, food chain, and fish tissues were responsible (i.e., reproductive impairment) for the observed
sport fishery decline in Hyco Reservoir. As a result of elevated selenium concentrations in fish, the
North Carolina Division of Health Services, Department of Health and Human Services, issued an
advisory in August 1988 recommending limitations on human consumption of all fish species from Hyco
Reservoir. In 1989, DEP completed the constructed a dry ash handling system to reduce selenium input
into Hyco Reservoir.
After the startup of the dry ash handling system in late 1989, biological monitoring studies
conducted under the Roxboro Plant National Pollutant Discharge Elimination System (NPDES) permit
demonstrated the effectiveness of the dry fly ash handling system in limiting the amount of selenium
entering the reservoir (CP&L 1991 and 2001, PEC 2008). Selenium concentrations quickly decreased in
the reservoir after the dry fly ash handling system began operation and have remained below the North
Carolina water quality standard of 5µg/liter since 1990. Changes in the aquatic community also reflected
the reduced selenium loading into the reservoir. A gradual shift from selenium -tolerant fish species to
species more typical of southeastern piedmont impoundments was observed following the
commencement of dry ash handling operations.
The fish consumption advisory was modified several times during the recovery period to remove
species from the consumption advisory list as selenium concentrations in the edible flesh of each
individual fish species declined below the established threshold level (i.e., 25 µg/g dry weight at the time;
it was revised to 50 µg/g dry weight in the mid-2000s). In August 2001, the fish consumption advisory on
reservoir was completely rescinded. Hyco Reservoir limnological variables remained mostly unchanged
during the period from 2002 through 2006 and were within the range of values expected for a North
Duke Energy Progress 1 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Carolina piedmont impoundment. During 2007, the reservoir was subjected to the most extensive
drought on record (based on 110-year USGS streamflow records) in North Carolina, which affected water
levels severely. The water levels decreased from full pool of 124.9 meters National Geodetic Vertical
Datum (NGVD) during May 2007 to slightly above the critical elevation of 123.4 meters NGVD in
October 2007 when a substantial rain event reversed the decreasing trend in reservoir water levels. The
drought event and subsequent decrease in lake level was important given that impacts to plant operations
begin to occur when reservoir levels reach 123.4 meters NGDV. Despite minimal flushing of the
reservoir through most of 2007, no overall changes to limnological variables, including selenium
concentrations, were noted that year compared to previous years following dry fly ash operations.
However, an increase in the mean selenium concentrations was observed in muscle tissues of fish
collected near the power plant discharge to Hyco Reservoir. While no increase in selenium mass loading
to Hyco Reservoir occurred during this period due to plant operations, decreased reservoir flushing likely
allowed more selenium to enter the food web and thus influenced tissue concentrations in fish and other
trophic level species.
With the passage of the North Carolina Clean Smokestacks Act of 2002, coal-fired power plants
were required to reduce sulfur emissions 73 percent by 2013. To help meet the requirement fleet -wide,
Flue Gas Desulfurization (FGD) systems (one on each of the four units) were installed at the Roxboro
Plant and wastewater from these treatment systems began discharging in February of 2008. During the
period from 2008 until 2016, a number of limnological constituents including calcium, chloride,
hardness, and total dissolved solids gradually increased throughout the reservoir until recently. However,
trace elements such as arsenic, copper, and selenium in surface waters have continued to remain below
water quality criteria and/or below the laboratory reporting limits.
Beginning in 2014 with the lower cost of natural gas, the Roxboro Plant annual dispatch rates
decreased from the historical 70%-75% range to an average rate of 60% in 2014, 43% in 2015, and even
lower dispatch rates through 2018. The lower dispatch rates for the Roxboro Plant have resulted in
reduced discharges of constituents from the FGD systems as well as lower overall thermal discharge to
the reservoir. With the reduce thermal loading to the reservoir, impacts to the two non-native tilapia
species, Blue Tilapia and Redbelly Tilapia, have become apparent with reduce catch of these species
during fisheries sampling. Tilapia can help control certain vegetation such as naiad and pondweed It is
possible that the reservoir will experience nuisance aquatic vegetation problems as the growth control of
these plant species declines along with the tilapia.
Duke Energy Progress 2 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Reservoir Description
Hyco Reservoir, an impoundment of the Hyco River, is located approximately 5 km south of the
North Carolina/Virginia border in Person and Caswell Counties in the northern Piedmont of North
Carolina. After impoundment, the reservoir water level reached full pool elevation in 1965. Hyco
Reservoir serves as a cooling lake and source of water for the Roxboro Plant. The reservoir has a surface
area of 17.6 km2 (1760 ha); a volume of 9.62 x 107 m3; a drainage area of 471 km2; a mean depth of 6.1
in; a normal elevation of 125.1 in NGVD; an average inflow of 5.7 m3/second; and a mean residence time
of approximately 6 months. The land use along the 256-km shoreline is primarily residential and
secondarily industrial/agricultural. It is classified by the North Carolina Division of Resource as WS-V,
B. This is defined as suitable for primary recreation, aquatic life propagation and maintenance, wildlife,
and agriculture and is suitable for water supply for use by industry to supply to their employees, but not
to municipalities or counties with a raw drinking water supply source.
For environmental monitoring purposes, sampling transects and stations throughout the reservoir
were selected based on their location relative to the power plant effluents entering the main body of the
reservoir at Transect 4 (Figure 1). Transect B is located in the upper reservoir in the North Hyco arm and
Transects C and SHHW 1 are located in the upper reservoir in South Hyco arm. Transect F is located in
the lower reservoir adjacent to the spillway.
Objectives and Methods
The primary objective of the Roxboro Plant 2017-2018 environmental monitoring program was to
provide an assessment of the effect of power plant operations on the water and aquatic organisms of Hyco
Reservoir. Secondary objectives of the program were to document environmental factors impacting the
aquatic community that were .not attributable to the power plant, as well as the impact of non-native
aquatic plant and animal species on the reservoir. These objectives were consistent with the biological
monitoring requirements in the NPDES Permit NC0003425.
Limnology (water quality, water chemistry, and chlorophyll a) and trace elements in fish tissues
and sediments (Transects C and D only) were assessed in the reservoir (Figure 1; Tables 1 and 2), and the
results were analyzed using appropriate statistical methods (Table 3). The water chemistry analysis
portion of the limnological variables was performed by laboratories certified by the North Carolina
Department of Environmental Quality (NCDEQ) in water and wastewater testing. Trace element analyses
of sediment and tissues of fish were conducted by an external laboratory using approved analytical
Duke Energy Progress 3 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitorinci Report
methods (EPA methods 6020 and 7471). The accuracy and precision of laboratory analyses of water
chemistry and trace element data were determined with analytical standards, sample replicates, and
reference materials. For calculation of means in this report, concentrations less than the reporting limit
and not estimated were assumed to be at one-half the reporting limit.
Duke Energy Progress 4 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
A
B+ 2
C
reek
North Hyco River
0 0.5 1 2
Miles
® A 1
C
Person -Caswell
Lake Authority
South
Hyco River
Afterbay
Cane Creek
Reservoir
Spillway
i
9 111
E C. ♦ 6
A ~►►
B A
(Outfall #006) Auxiliary Intake, Main
Dam
Discharge is
(Outfall #003) . ♦__ Intake
Canal
4 Gypsum Storage Pad
E q
C �
BDry A
Ash
r i Landfill
/ *--Flush
/ Pond
Gypsum s
Settling Ash
Pond ; Pond
Bioreactor
N
3
A--* B V C
SHHW�
0 0.75 1.5 3
Kilometers
Figure 1. Hyco Reservoir sampling locations.
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Table 1. Hyco Reservoir environmental monitoring program.
Program Frequency Location
Water quality Alternate calendar months
(February, April, June, August, October,
December)
Water chemistry Alternate calendar months
(including trace (February, April, June, August, October,
elements in water) December)
Phytoplankton+ Alternate calendar months
(February, April, June, August, October,
December)
Chlorophyll a Alternate calendar months
(February, April, June, August, October,
December)
Zebra and quagga Alternate calendar months
mussels (February, April, June, August, October,
December)
Electrofishing Once every three calendar months
(March, June, September, December)
Trace elements Once per calendar year
(fish & sediments)
Stations B2, C2, D2, F2, SHHW1
(surface to bottom at 1-m
intervals)
Stations B2, C2, D2, F2, SHHW 1
(surface)
Stations B2, C2, D2, F2
Stations B2, C2, D2, F2
Main intake structure or water
quality station buoys
Stations Al, A3, B1, B3, C1, C3,
Dl, D5, Fl, F3
Transects C and D
+Phytoplankton samples were collected and preserved but were not identified because all chlorophyll a
concentrations measured during 2017 and 2018 were less than 40 mg/L.
Duke Energy Progress 6 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Table 2. Field sampling and laboratory methods utilized in the Hyco Reservoir environmental
monitoring program.
Method
Water quality Temperature, dissolved oxygen, pH, and specific conductance were measured with
calibrated multiparameter instruments. Measurements were taken from the surface
to the bottom at 1-m intervals in accordance with procedure NR-00096 Water
clarity was measured with a Secchi disk. Turbidity was measured with a HACH
model 2100Q turbidimeter in accordance with procedure WR-00070.
Water Surface samples were collected either directly or with a nonmetallic sampler,
chemistry transferred to appropriate containers, transported to the laboratory on ice, and
analyzed according to USEPA (1979) and APHA 2012.
Phytoplankton Samples were collected by two methods. Method one used equal amounts of
water from the surface, the Secchi disk transparency depth, and twice the Secchi
disk transparency depth collected with a Van Dorn beta sampler and mixed in a
plastic container. Method two used an integrated depth sampler to collect
representative photic zone composite samples from the surface to twice Secchi
disk transparency depth. The samples were placed in dark bottles, and transported
to the laboratory on ice.
Chlorophyll a Samples were collected by two methods. Method one used equal amounts of
water from the surface, the Secchi disk transparency depth, and twice the Secchi
disk transparency depth collected with a Van Dorn beta sampler and mixed in a
plastic container. Method two used an integrated depth sampler to collect
representative photic zone composite samples from the surface to twice Secchi
disk transparency depth. The samples were placed in 1000 mL dark bottles and
transported to the laboratory on ice. In the laboratory, 250-mL subsamples were
analyzed (NR-00103).
Electrofishing Fifteen -minute samples were collected at each station using a Smith -Root Type
7.5 gpp equipped, Wisconsin -design electrofishing boat with pulsed DC current.
Fish were identified, measured to nearest mm, weighed to nearest gram, examined
for presence of disease and deformities, and released based NR-00080, Rev 1.
Trace elements Water, sediments, and muscle tissue of selected fish were analyzed by standard
analytical techniques in the laboratory for selected trace metals and metalloids. All
media, except water, were homogenized and freeze-dried. All samples were
analyzed by an external laboratory using EPA methods 6020 and 7471. Quality
control was achieved by analytical standards, replicates, and certified reference
materials
Mussel surveys Hardened structures such as docks and buoys were visually inspected for the
presence of zebra mussels and quagga mussels during routine water quality
monitoring.
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Table 3. Statistical analyses performed on data collected for the Hyco Reservoir environmental
monitoring program.
Program Variable Statistical test(s)/model(s)+ Main effect(s)
Water quality Water temperature, specific
conductance, Secchi disk
transparency depth, and
selected chemical variables
Water chemistry Selected chemical variables
Phytoplankton Chlorophyll a
Trace elements Al, As, Cd, Cu, Hg,
Se (water)
As, Cd, Cu, Hg, Se
(sediment and fish)
ANOVA, block on month Station
ANOVA, block on month Station
ANOVA, block on month Station
ANOVA, block on month Station
ANOVA Transect
'Parametric and non -parametric (rank) one-way Analysis of Variance (ANOVA) statistical models were
used. A Type I error rate of 5% (a = 0.05) was used to judge the significance of all tests. Fisher's
protected least significant difference (LSD) test was applied to determine where differences in
means occurred for significant ANOVA models.
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Environmental Monitoring Results for 2017-2018
Limnology
Temperature and Dissolved Oxysen
• Thermal stratification, defined by changes of at least 2°C per meter of water depth, in Hyco Reservoir
was influenced by several factors during 2017 and 2018, including proximity to the plant discharge,
variable thermal loading from power plant discharges, summertime use of the auxiliary intake system,
and natural ambient conditions and streamflow (Appendices 1 and 2). In Southeastern reservoirs,
typically, a pronounced clinograde isotherm (thermocline) is observed throughout hotter months.
However, this pronounced thermal stratification pattern was not observed in Hyco Reservoir during
2017 and 2018, in keeping with historical observations. In 2017, no thermal stratification was present
in the reservoir during February, August, and December while only weak thermal stratification was
observed during April, June, and October. Similarly, during 2018, no thermal stratification was
observed during February and October and again, only weak thermal stratification was observed
during April, June, August and December. Surface water temperatures at Station D2 near the thermal
discharge ranged from 11.3°C in February to 30.6°C in October 2017 (Appendix 3). In 2018, Station
D2 ranged from 11.8 in February to 31.8 in August (Appendix 4). The coolest surface water
temperature in the reservoir during 2017 was 8.5°C in February at Station SHHW 1 and 8.0 during
February at Station C2 during 2018.
• The annual mean surface temperature at Station D2 was 23.4°C in 2017 and 22.6 in 2018
(Appendices 3 and 4). There were no significant differences in the annual mean surface temperatures
among all sampling stations either year, which is a departure from historical temperature patterns in
the reservoir. It is likely that lower power plant dispatch rates each year resulted in the similarities of
mean temperature measures throughout each year.
• All surface water dissolved oxygen concentrations were greater than 5 mg/L throughout Hyco
Reservoir during both 2017 and 2018 monitoring events (Appendices 1 and 2). Oxygen depletion
below 1 mg/L was observed in only the deeper hypolimnetic waters (typically below approximately 5
meters) of the reservoir during June and October of 2017 and June, August, and October of 2018.
This phenomenon usually occurs within monomictic reservoirs of the southeastern United States.
However, Hyco Reservoir does not exhibit strong oxygen depletion as with other reservoirs of the
southeast due to the use of an auxiliary intake for withdrawal of hypolimnetic cooling water by the
Roxboro Plant.
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Water Clarity Constituents
• Secchi disk transparency was similar among all stations in Hyco Reservoir during 2017 (Appendix 3),
however, minor statistical differences among the stations were noted during 2018 (Appendix 4).
Hyco Reservoir was moderately clear both years with Secchi disk visibility greater than one meter on
average except for the extreme upstream Station SHHW L Mean turbidity values, a related measure
of clarity, were also statistically similar among the reservoir stations during both 2017 and 2018. The
2017-2018 turbidity ranges were within ranges observed in previous years (DEP 2017).
Nutrients and Phytoplankton Biomass
• All aqueous nitrogen constituents during 2017-2018 including annual mean total ammonia, total
nitrogen, nitrite -nitrate nitrogen, and total kjeldahl nitrogen concentrations were similar among the
stations and varied by relatively small amounts (Appendices 3 and 4). These minor variations of
nutrient concentrations among the stations were not considered to be important to the trophic status of
the reservoir. Total phosphorus was also similar among the stations during 2017, however, varied
statistically during 2018 among the stations throughout the reservoir total organic carbon (TOC)
concentrations were low and consistent throughout the reservoir. Taken altogether, the nutrients and
TOC reflect the moderate trophic status of Hyco Reservoir (NCDEQ 2015).
• The annual mean chlorophyll a (a measure of phytoplankton biomass) concentration at Station D2
was statistically less than the concentrations at Stations B2, C2, and F2 during 2017 (Appendix 3).
During 2018, the annual mean chlorophyll a measurement at Station C2 statistically greater than that
at Station F2 but was similar to the mean concentrations at the remaining locations (Appendix 4).
Chlorophyll a was not measured at SHHW 1 as part of the monitoring plans. All chlorophyll a
measurements in Hyco Reservoir during 2017-2018 were below the North Carolina water quality
standard of 40 µg/L (15A NCAC 0213.0211, June 2019).
Ions, Hardness, Total Dissolved Solids, and Specific Conductance
• The annual mean concentrations of most of the major ions, specific conductance (magnitude), total
dissolved solids, and total hardness varied statistically among sampling stations during 2017 and 2018
(Appendices 3 and 4). These constituents generally followed a decreasing pattern in concentration
with the following order D2—F2>B2>3C2>SHHW1. The concentration and magnitude pattern has
been typically observed since the FGD operations commenced in 2008. Over a 10-year period from
2009-2018, fluctuations in concentration of select constituents observed throughout the reservoir
reflected various influencing hydrodynamic processes (i.e., inflow, vertical circulation, turnover) and
the inconsistent dispatching (i.e., discharge mass) of the Roxboro Plant (Appendices 5-10).
Duke Energy Progress 10 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Alkalinity and PH
• The annual mean total alkalinity concentrations during 2017 were similar among all the stations on
Hyco Reservoir with overlapping concentration ranges (Appendix 3). Individual values ranged from
17 to 38 mg/L in surface waters with the greatest measured value at Station SHHW 1. During 2018,
the total alkalinity concentrations varied statistically among the stations but these variations were
considered to be minor and of no biological importance (Appendix 4). The individual values ranged
from 23 to 37 mg/L during 2018. Waters less than 40 mg/L are considered to be soft waters (unrelated
to hardness) for biological purposes in terms of productivity (Boyd 1979). These alkalinity
concentrations coincide with the moderate trophic status of Hyco Reservoir.
• Hyco Reservoir generally exhibited annual median pH values slightly above neutral in most cases
with circumneutral ranges within approximately one pH unit of neutral throughout the reservoir
longitudinally and vertically during both 2017 and 2018 (Appendices 1-4). While no statistical
evaluations of pH for 2017 and 2018 were run, which would be inappropriate for log scale data,
annual median values both years were tightly grouped within a few tenths decimal fractions of each
other at the stations. Individual surface water pH values ranged from 6.8 at Station SHHW 1 to 8.9 at
Station C2 during 2017 and 7.0 at both Stations F2 and SHHW 1 to 8.7 at Station C2 during 2018.
Deeper waters of the reservoir generally displayed slightly decreasing pH values from surface waters
to bottom waters, reflecting different biological and limnological processes with depth.
Trace Elements
Arsenic
• Annual mean total arsenic concentrations at Station D2 and F2 were statistically greater compared to
the concentrations at the upper reservoir Station SHHW1 during 2017 (Appendix 3). Stations B2 and
C2 annual mean concentrations were intermediate and statistically similar to all other stations
throughout the reservoir. During 2018, a similar pattern was observed with the annual means at D2
and F2 being greatest in concentration among the stations (Appendix 4). While the lower reservoir
total arsenic concentrations had slightly elevated concentrations during both years due to the Roxboro
Plant FGD operations, all of the arsenic values measured in surface waters at all stations were well
below the North Carolina surface water quality 02B standard for human health (10 µg/L; fish
consumption). Long-term (10-year) trends of arsenic concentrations from 2009-2018 at all stations
exhibited small seasonal fluctuations in concentrations.
Duke Energy Progress 11 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
• The 2017 annual mean arsenic concentration in the sediments at Transect D near the Roxboro Plant
discharge was within concentration range considered to be background (3-13µg/g dry weight) but the
2018 annual mean concentration was elevated slightly above the .background concentration range
(Forstner and Wittmann 1981; Salomons and Forstner 1984; and Martin and Hartman 1984)
(Appendices 11 and 12). At Transect C during 2017, the annual mean arsenic concentration of 6.2
µg/g was below the Laboratory Reporting Limit (LRL) for that year. In 2018, the annual mean
arsenic concentration from samples collected at Transect C was 5.0 µg/g, again within the range of
background concentrations. Comparing the 2018 sediment concentrations by location showed
significant statistical differences. This pattern of arsenic in sediments continues that observed
historically in the reservoir (DEP 2017).
• The annual mean arsenic concentration in Largemouth Bass at Transect D was statistically greater
compared to the Transect C mean concentration during 2017 (Appendix 11). However, these mean
values were only a decimal fraction different when compared, and, when converted to wet weight
values they were below the EPA recreational fisherman screening level (i.e., 1.2 µg/g wet weight) for
human consumption (NCDENR 2013). Mean concentrations in White Catfish and Bluegill were
mostly below the LRL during 2017. Similarly, in 2018 only Largemouth Bass annual mean arsenic
concentrations were statistically different between Transect C and D (Appendix 12). The mean
arsenic values were almost identical at both transects when comparing 2017 and 2018 results for the
three fish species sampled, indicating a consistent concentration pattern. Again, the arsenic values in
2018 were below the EPA recreational fisherman screening level.
Cadmium
• Annual mean cadmium concentrations in sediments and fish tissues at Transect C and D during 2017
were all below the LRL (Appendix 11). In 2018, only sediments measurements for cadmium were
above the LRL (Appendix 12). The annual mean concentration at Transect D near the Roxboro Plant
discharge location was statistically greater than the mean concentration upstream at Transect C.
Copper
• The annual mean total copper concentrations in Hyco Reservoir surface waters were statistically
similar among all stations during both 2017 and 2018 (Appendices 3-9). The values were mostly
below 2.0 µg/L throughout the reservoir.
Duke Energy Progress 12 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
• The annual mean copper concentration in sediment near the power plant discharge (Transect D) was
statistically similar to the mean copper concentration at Transect C (South Hyco Creek arm) during
both 2017 and 2018 (Appendices 11 and 12).
• Copper concentrations in Bluegill, White Catfish, and Largemouth Bass muscle tissues during 2017
were comparable to those in recent years (DEP 2013, 2014, 2016, and 2017), however, the
concentrations measured in Bluegill muscle at Transect D and Largemouth Bass at both Transect C
and D were unexpectedly moderately elevated when compared to those same past years (Appendices
12 and 13). Copper levels in water and sediments at the two locations during 2018 did not suggest a
cause for the observed elevated copper in fish tissues. Even so, the copper concentrations measured
in the fish tissues were not elevated to the point of being biologically important.
Manganese
• Annual mean total manganese concentrations in surface waters of Hyco Reservoir were statistically
similar among all reservoir stations during 2017 but varied statistically during 2018 (Appendices 2-6).
Manganese concentrations ranged widely in the reservoir during both years with the greatest
concentrations observed in surface waters at Station D2 during December of 2017 and Station
SHHW 1 during August of 2018. These observations reflect biogeochemical processes governing
manganese that are variable from year to year and are unrelated to power plant operations.
Mercury
• The annual mean total mercury concentrations in surface waters were statistically similar among all
stations during both 2017 and 2018 (Appendices 3 and 4). Also, all of the individual total mercury
concentrations measured each year throughout the reservoir were below the North Carolina 15A
NCAC 02B water quality standard of 12 ng/L.
• Annual mean mercury concentrations in sediments at Transects C and D were less than the LRL of
3.6 µg/g during 2017 (Appendix 11). In 2018, a change in the laboratory methodology for mercury in
sediments led to valid measurements below 1 µg/g. The mean values were statistically greater at
Transect D compared to transect C during 2018 (Appendix 12). However, mean concentrations
measured at both locations were very low and were not considered to be biologically important.
• Annual mean mercury concentrations in Bluegill muscle tissues were statistically different between
Transect C and Transect D during 2017 and 2018 (Appendices 11 and 12). The mean mercury
Duke Energy Progress 1 13 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
concentrations in White Catfish and Largemouth Bass were similar between the two locations each
year. Converting the mercury measurements to fresh weight concentrations resulted in all annual
mean and individual measured mercury concentrations in muscle tissues during 2017 and 2018 being
below the North Carolina Health Director's screening value of 0.4 µg/g fresh weight and the EPA's
water quality criterion for methylmercury in fish tissues of 0.3 µg/g fresh weight (NCDENR 2013).
Selenium
• During both 2017 and 2018, the annual mean total selenium concentrations in surface waters of Hyco
Reservoir were statistically similar among all stations, continuing a finding observed in 2016 (DEP
2017) (Appendices 3 and 4). Further, all annual mean selenium concentrations were below 1 µg/L
reservoir -wide, which is well below the North Carolina 15A NCAC 02B water quality standard of 5
µg/L for freshwater.
• During 2017, the mean selenium concentrations in sediments were statistically similar between
Transects C and D while in 2018, the mean selenium concentrations were statistically greater at
Transect D than at Transect C (Appendices 11 and 12). All mean selenium concentrations in the
muscle tissues of Bluegill, White Catfish, and Largemouth Bass were statistically greater at Transect
D near the power plant discharge compared to upstream at Transect C during 2017. During 2018, the
mean concentrations in Bluegill muscle were significantly greater at Transect D compared to Transect
C. No differences in selenium concentrations of muscle tissue from White Catfish and Largemouth
Bass were noted in 2018. The selenium concentrations in the three species continued to trend lower
at Transect D since approximately 2013 (Appendix 13). All the selenium values (converted to wet
weight concentrations) in edible flesh during 10-year observation period from 2009 through 2018,
were well below the North Carolina human health consumption advisory level (10 µg/g wet weight).
Thallium
• All thallium measurements were below the LRL of 0.1 µg/L during 2017 and 2018 (Appendices 3-6).
Duke Energy Progress 14 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Fisheries
Fish Species Composition
• There were 24 fish species in 2017 and 21 fish species in 2018, belonging to seven families, collected
from Hyco Reservoir with electrofishing (Appendix 14). As a whole, the sunfish family
(Centrarchidae) dominated the fish population with six fish species present in the reservoir both years.
The bullhead catfishes (Ictaluridae), minnows (Cyprinidae) and Catostomidae (suckers) traded with
each other in number of species between 2017 and 2018. The fish assemblage observed in Hyco
Reservoir was typical of piedmont impoundments in the Southeast. Largemouth Bass was the
primary apex predator in the reservoir both years and Black Crappie and Channel Catfish were also
prevalent predators during 2017 and 2018. Yellow Perch were collected in reasonably good numbers.
The open water schooling species Gizzard Shad and Threadfin Shad were abundant in Hyco
Reservoir providing ample forage for the predator species during 2017 and 2018.
• As with most man-made reservoirs, the fish assemblage in Hyco Reservoir consisted of species
considered widely distributed and common in the Southeastern United States except for introduced
species including Blue Tilapia and Threadfin Shad (Appendices 15 and 16). The presence of these
introduced species in Hyco Reservoir was unrelated to the operation of the Roxboro Plant except for
the heated effluent which allowed for their overwintering. Blue Tilapia, in particular, are likely to
decline in numbers due to their intolerance of cold water temperatures as the Roxboro Plant continues
to be dispatched at lower rates. Threadfin Shad may also be somewhat affected due to their
intolerance of long-term exposure to low temperatures (Strawn 1965). The remaining fish species in
Hyco Reservoir were either indigenous or typically found in piedmont reservoirs of North Carolina.
• The greatest number of fish species was observed at Transect C both years with 19 species during
2017 and 16 species during 2018 (Appendices 15 and 16). The Transects followed a pattern of
species richness both years as follows: C>B>A>D=F. Transects D and F had the lowest species
richness likely due to limited shoreline habitat with more open water areas.
Fish Abundance, Distribution, and Size Structure
• Centrarchidae (sunfishes) were the most the abundant fish group in Hyco Reservoir followed in order
by Clupeidae (herrings), Ictaluridae (bullhead catfishes), Cyprinidae (minnows), Catastomidae
(suckers), Percidae (perches), and Cichlidae (tilapia) during 2017 and 2018 (Appendix 14). The
sunfish family comprised 78% of the total annual electrofishing catch in 2017 and 88% total annual
Duke Energy Progress 15 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
electrofishing catch in 2018. Herrings comprised 15% and 8% of the total fish catch while bullhead
catfishes comprised 2% both years of the total fish catch during 2017 and 2018, respectively.
• Bluegill was the single most abundant fish species present with 53% of the total catch during 2017
and 70% during 2018 (Appendix 14). Largemouth bass was the second most abundant fish species
during both 2017 and 2018 with 13% and 10% of the total fish numbers and comprising 33% and
46% of the of the total biomass, respectively. Gizzard Shad was the third most abundant species with
9% during 2017 and 5% during 2018 of the total catch each comprising 16% and 11% of the total
biomass. Total fish number and biomass reservoir -wide during 2017 and 2018 were consistent with
values observed in recent years (DEP 2017).
• Bluegill were most abundant based on electrofishing at Transects A (Cobbs Creek) and D during
2017 and at Transect B during 2018 (Appendix 15 and 16). The mean Bluegill electrofishing catch
by transect arranged in approximate decreasing order were Transects A>D>C>F>B during 2017.
During 2018, the mean Bluegill catch in approximate decreasing order was B>D>A>C>F.
• As in previous years (DEP 2017), Bluegill reproduction continued be good throughout the reservoir in
both 2017 and 2018 as indicated by their length -frequency distributions at all transects, except at
Transect B during 2017 (Appendices 17 and 18). Transect B is characterized as large flat open areas
with little cover for hiding from predators and likely the reason for fewer small Bluegill (< 80 mm)
being collected. Also, there is a limited amount of shoreline rip rap habitat in shallow areas of this
transect that can provide cover as well, therefore, small fish may be under represented annually in the
electrofishing catch. The size class distributions of Bluegill were similar among all transects except
at Transect B during 2017 where most fish were greater than 75 mm. This pattern of fewer small
Bluegill at Transect B is typical of the electrofishing catches at this reservoir location (DEP 2017).
However, in a departure from past monitoring, the electrofishing catch from 2018 at Transect B
exhibited a reasonably large number of smaller Bluegill. The appearance of many smaller individuals
is not understood completely but could suggest changes to the habitat (e.g., possible vegetation
growth) that are not apparent from the reservoir surface.
• The mean Relative Weight (Wr) values, which is an indirect measure of health condition, reservoir -
wide were 83 during both 2017 and 2018, respectively (Appendices 23 and 24). A Wr of 100 is
optimal for a species and suboptimal Wr values, in the absences of diseases or other health related
Duke Energy Progress 16 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
factors, may be related to competition for food and the mesotrophic status of Hyco Reservoir for this
numerically dominant species. Most fish do not achieve optimal condition in natural settings.
• Largemouth Bass of all size classes were well -represented throughout the reservoir during 2017 and
2018 (Appendices 15 and 16). Adequate reproductive success was noted both years as represented by
the presence of reasonable numbers of individual fish less than 150 mm at most transects. Transect D
near the power plant discharge had the most smaller fish present in electrofishing catches during 2017
while Transect A had the most in 2018. The average size of Largemouth Bass was consistent
throughout the reservoir within year and between years having an overall reservoir mean length of
267 mm for 2017 and 251 mm for 2018.
• The mean Wr for Largemouth Bass in Hyco Reservoir during 2017 (Wr =85) was slightly lower than
the mean Wr during 2018 (Wt=89) (Appendices 23 and 24). Again, the productivity level for the
reservoir as a mesotrophic system is probably one of the main influences of suboptimal condition of
fish, particularly an apex predator such as Largemouth Bass.
• Gizzard Shad were well represented and collected in similar numbers throughout Hyco Reservoir
during both years except at Transect F during 2018, where the numbers were somewhat lower
(Appendices 15 and 16). Consistent with previous years, Gizzard Shad collected from the reservoir
were mostly greater than 200 mm each year. Generally, young -of -year Gizzard Shad are not
efficiently collected by electrofishing due to the inherent geartype bias against smaller schooling fish.
However, occasionally, schools of small Gizzard Shad are encountered during electrofishing
sampling such as occurred at Transect C during 2018. This event illustrates the random nature of
encountering a large school of small shad at a particular location while sampling. It is likely that
isolated schools like this are randomly located throughout Hyco Reservoir but are seldom
encountered.
• The mean Wr values of 88 and 92 for Gizzard Shad in Hyco reservoir during 2017 and 2018,
respectively, were considered to be reasonably good in terms of health condition (Appendices 23
and 24). This factor along with good numbers collected throughout the reservoir, as noted above,
represents a substantial prey base for predator species and a basic sustainability requirement of
aquatic communities.
Duke Energy Progress 17 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
• Redear Sunfish was reasonably well distributed throughout Hyco Reservoir during 2017 and 2018
(Appendices 15 and 16). Green Sunfish was more abundant downstream of the power plant discharge
while Yellow Perch, Black Crappie, and Satinfin Shiner were collected in greater numbers upstream
of the plant during each year.
Balanced, Indigenous Community
• Hyco Reservoir represents a balanced, self-sustaining community. To demonstrate balance, an aquatic
population/community must contain both predator and prey species in relative balanced numbers to
each other reflecting the overall trophic status of the system. Both fish groups must be reproducing
and recruiting adequately to produce the proper balance. Several regionally common predator species
including adult Largemouth Bass, Black Crappie, and Channel Catfish continued to exist in Hyco
Reservoir during 2017 and 2018 (Appendices 14-17). The apex predator Largemouth Bass, an
integral part of the aquatic community, exhibited both adequate reproduction and recruitment for a
self-sustaining population based on the presence of sufficient numbers of young -of -year (generally <
150 mm fish) and year class 1+ fish (generally > 150 mm to 250 mm fish) throughout the reservoir..
Many forage species existed throughout the reservoir as well, including the primary prey species
Bluegill and sustaining prey species Gizzard Shad and Threadfin Shad. Bluegill exhibited the
necessary presence of young -of -year (generally < 80 mm fish) and year class 1+ fish (generally > 80
mm to 125 mm fish) (Appendices 17 and 18). Gizzard Shad and Threadfin Shad were also present in
the reservoir with good numbers of adult fish each year. Without adequate reproduction and
recruitment of this prey species, the adult shad would not continue to be present in similar numbers
compared to previous years. Also, as noted above, a random encounter with a large school of small
Gizzard Shad at Transect C during 2018 supports the likelihood of adequate reproduction recruitment
of this species in the reservoir.
• Fish populations in good balance can indicated by comparing the Proportional Size Distribution
(PSD) index values of select predator and prey species. PSD values for balanced populations of
Largemouth Bass range from 40 to 70 and for Bluegill from 20 to 60 (Gabelhouse 1984). In Hyco
Reservoir, a balanced population for Largemouth Bass population during 2017 and 2018 existed in
the reservoir while Bluegill population was balanced in 2017 but fell out of the range for 'balanced
populations during 2018 (Appendix 25). No balance range has been determined for Gizzard Shad
populations but plotting the PSD values for both Largemouth Bass and Gizzard Shad during 2017 and
2018 shows an interesting relationship of the stock and quality size fish of each species in Hyco
Duke Energy Progress 18 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Reservoir.
Fish Community Health
• No significant disease or pathological anomalies were observed in fish collected by Company
Biologists during 2017 or 2018. Winter kills of tilapia were observed in both 2017 and 2018 but were
expected with the low dispatch of the Roxboro Plant. No other fish kills were observed or reported
from Hyco Reservoir during 2017 and 2018.
Biofouling Monitoring
• No zebra mussels (Dreissena polymorpha) or quagga mussels .(D. bugensis) were found in Hyco
Reservoir during 2017 and 2018. These mussels are potentially serious biofouling organisms to power
plant operations. Neither species has been collected from Hyco Reservoir. Asiatic clams (Corbicula
fluminea) are known to exist in Hyco Reservoir as in many other Southeastern reservoirs; however,
no significant power plant operational issues have been caused by their presence.
Summary and Conclusions
Hyco Reservoir thermal stratification patterns and water temperature extremes continued to be
dependent on the local meteorological conditions, the proximity to the discharge canal outfall area,
the influence of the circulating water of the auxiliary intake system, and the inverted siphon (part of
the old discharge canal to Cobbs Creek) on the South Hyco Creek arm of the reservoir during 2017
and 2018. The 2017-2018 annual mean reservoir temperatures in surface waters continued to be
within the ranges typically observed in Hyco Reservoir.
Despite low dispatch of the Roxboro Plant, FGD system operations continued to affect several
water chemistry parameters nearer the power plant discharge compared to those at historical
background stations in Hyco Reservoir during 2017 and 2018. However, concentrations of a number
of constituents have decreased with decreasing FGD discharges over the last several years.
In fish tissues, selenium concentrations continued to trend down in Bluegill, White Catfish, and
Largemouth Bass in both 2017 and 2018. The edible flesh selenium concentrations of all fish species
sampled remained well below the North Carolina consumption advisory level of 10 µg/g wet weight
(50 µg/g dry weight).
Fish species composition, abundance, and distribution in Hyco Reservoir during 2017 and.2018
Duke Energy Progress 19 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
were similar to that of previous years. Bluegill remained the dominate fish species followed by
Largemouth Bass, Gizzard Shad, Redear Sunfish, and Black Crappie within the reservoir both years.
The fish community tended to be slightly less diverse in the open -water habitat of the middle and
downstream portions of the reservoir compared to the upper, riverine-like areas of Hyco Reservoir.
Hyco Reservoir, a man-made water body, contained a fish community that was balanced, and self-
sustaining, which indicates a balanced aquatic community characteristic of a mesotrophic piedmont
impoundments located in Southeastern United States.
References
APHA. 2012. Standard methods for the examination of water and wastewater. 22th Ed. American
Public Health Association, Washington, DC.
Boyd 1979. Water quality in warmwater fish ponds. Agricultural Experiment Station, Auburn
University, Aurburn, AL.
CP&L. 1991. Roxboro Steam Electric Plant 1990 environmental monitoring report. Carolina Power &
Light Company, New Hill, NC.
. 2001. Roxboro Steam Electric Plant 2000 environmental monitoring report. Carolina Power &
Light Company, New Hill, NC.
DEP. 2013. Roxboro Steam Electric Plant 2012 environmental monitoring report. Duke Energy Progress,
Raleigh, NC.
DEP. 2014. Roxboro Steam Electric Plant 2013 environmental monitoring report. Duke Energy Progress,
Raleigh, NC.
DEP. 2016. Roxboro Steam Electric Plant 2014-2015 environmental monitoring report. Duke Energy
Progress, Raleigh, NC.
DEP. 2017. Roxboro Steam Electric Plant 2016 environmental monitoring report. Duke Energy Progress,
Raleigh, NC.
Duke Energy Progress 20 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Gabelhouse, D. W., Jr. 1984. A length -categorization system to asses fish stocks. N. Amer. J. Fish.
Manag. 4:371-384.
North Carolina Administrative Code. 2019. Title 15A NACA 02B Water Quality Standards for Surface
Waters. June 10, 2019.
NCDENR. 2013. Standard Operating Procedures; Fish Tissue Assessments. North Carolina Department
of Environment and Natural Resources. Intensive Survey Branch. Raleigh, NC.
NCDEQ. 2015. Roanoke River basinwide assessment report. North Carolina Department of
Environmental Quality. Intensive Survey Branch. Raleigh, NC.
Page, L. M., H. Espinsoa-P6rez, L T. Findley, C. R. Gilbert, R. N. Lea, N. E. Mandrak, R. L. Mayden,
and J. S. Nelson. 2013. Common and scientific names of fishes from the United States, Canada,
and Mexico. 7th edition. American Fisheries Society, Special Publication 34, Bethesda, Maryland.
PEC. 2008. Roxboro Steam Electric Plant 2007 environmental monitoring report. Progress Energy
Carolinas, Raleigh, NC.
Salomons, W., and U. Forstner. 1984. Metals in the hydrocycle. Springer-Verlag, New York, NY.
Strawn, K. 1965. Resistance of Threadfin Shad to low temperatures. Proceedings of the Annual
Conference Southeastern Association of Game and Fish Commissioners 17(1963):290-293.
USEPA. 1979. Methods for the chemical analysis of water and wastes. U.S. Environmental
Protection Agency, EPA-60/4-79-020, Cincinnati, OH.
Duke Energy Progress 21 Water Resources

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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 1. (continued)
August 29, 2017
Temperature
Dissolved oxygen
pH
Specific conductance
Depth
B2 C2
D2
F2
SHHW1
B2
C2
D2
F2 SHHW1
B2
C2
D2
F2
SRUM
B2
C2
D2
F2
SHHW1
0.2
27.4 26.6
27.9
27.6
24.7
7.1
6.4
6.8
6.7 7.4
7.4
7.2
7.3
7.3
7.4
175
118
206
180
105
1.0
27.4 26.2
27.9
27.6
24.7
7.1
6.3
6.8
6.6 7.3
7.4
7.2
7.3
7.3
7.3
175
118
206
180
105
2.0
27.4 26.2
. 27.9
27.6
24.7
7.1
6.3
6.7
6.6 7.1
7.4
7.2
7.3
7.3
7.3
175
118
206
180
105
3.0
27.4 26.2
27.8
26.8
7.1
6.3
6.7
6.6
7.4
7.2
7.3
7.3
175
118
207
179
4.0
27.4 26.2
27.8
7.1
6.3
6.7
7.4
7.2
7.3
175
118
207
5.0
27.3 26.1
27.8
7.1
5.9
6.7
7.4
7.1
7.3
174
118
207
6.0
27.0
27.8
6.9
6.7
7.3
7.3
174
207
7.0
27.7
6.8
7.3
211
8.0
27.7
6.8
7.3
211
9.0
27.8
6.8
7.3
209
10.0
27.6
6.8
7.3
213
October 11, 2017
Temperature
Dissolved oxygen
pH
Specific conductance
Depth
B2
C2
D2
F2 SHHWI
B2
C2
D2
F2 SHHW1
B2
C2
D2
F2 SHHW1
B2
C2
D2
F2
SIUM
0.2
26.2
26.7
30.6
27.3 26.3
9.4
10.6
7.0
8.4 9.8
8.3
8.9
7.7
8.0 8.5
199
144
214
206
122
1.0
26.1
25.8
30.1
26.6 24.4
9.4
10.8
6.9
8.3 10.0
8.4
8.9
7.6
7.9 8.6
199
142
212
206
122
2.0
25.7
24.4
29.5
26.4 22.8
9.2
8.6
6.9
7.8 1.5
8.3
8.1
7.6
7.8 7.2
199
148
210
206
137
3.0
25.1
23.3
28.5
26.2
8.2
5.7
7.0
7.1
7.8
7.6
7.6
7.6
197
146
208
205
4.0
24.5
22.6
26.3
7.2
1.8
6.8
7.5
7.1
7.5
194
140
206
5.0
23.7
22.1
25.8
3.7
0.3
6.5
7.0
7.1
7.4
194
144
205
6.0
23.5
25.6
2.3
5.7
6.9
7.4
194
203
7.0
24.8
4.3
7.2
260
8.0
24.2
3.3
7.1
200
9.0
23.6
2.0
7.0
200
10.0
23.5
0.5
7.2
204
December 6, 2017
Temperature
Dissolved oxygen
pH
Specific conductance
Depth
B2
C2
D2
F2
SHHW1
B2
C2
D2
F2 SHHW1
B2
C2
D2
F2
SHHW1
B2 C2 D2
F2
SHHW1
0.2
12.8
11.2
16.1
14.5
10.6
10.2
10.3
8.1
9.4
11.0
7.5
7.3
7.2
7.4
7.6
204 175 217
208
159
1.0
12.8
11.2
16.1
14.5
10.6
10.2
10.3
8.1
9.3
10.9
7.5
7.3
7.2
7.4
7.5
204 175 216
208
159
2.0
12.8
11.1
16.1
14.5
10.5
10.2
10.3
8.0
9.2
10.8
7.5
7.3
7.2
7.4
7.5
204 175 - 216
208
157
3.0
12.7
11.0
15.7
14.5
10.5
10.1
10.1
7.4
9.2
10.9
7.5
7.2
7.1
7.4
7.5
204 172 213
208
158
4.0
12.5
10.7
15.4
9.5
9.4
7.4
7.3
7.1
7.1
202 172 211
5.0
12.3
10.7
15.4
8.9
9.4
7.4
7.2
7.1
7.1
202 172 211
6.0
11.9
15.2
7.5
7.3
7.1
7.1
196 210
7.0
15.2
7.2
7.0
210
8.0
15.0
6.9
7.0
209
9.0
14.0
6.3
7.0
206
10.0
13.3
5.1
7.0
204
Duke Energy Progress 23 Water Resources

C
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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 2. (cont.)
August 1, 2018
Temperature
Dissolved oxygen
pH
Specific conductance
Depth
B2 C2
D2
F2
SHHW1
B2
C2
D2
F2
SHHWl
B2
C2
D2
F2
SHHW1
B2
C2
D2
F2
SEEM
0.2
29.3 29.2
31.8
30.1
29.4
6.7
7.6
7.0
7.6
6.6
7.5
7.8
7.4
7.5
7.4
160
114
186
171
111
1.0
29.3 29.2
31.7
30.0
29.3
6.7
7.6
7.0
7.6
6.5
7.4
7.7
7.4
7.5
7.4
160
114
186
172
111
2.0
29.3 29.1
31.6
29.9
28.8
6.7
7.4
6.8
7.5
4.0
7.5
7.7
7.4
7.5
7.1
160
114
186
173
112
3.0
29.3 28.8
31.5
29.8
28.6
6.7
6.3
6.4
7.5
2.1
7.4
7.3
7.2
7.4
6.9
160
116
185
171
115
4.0
29.3 26.1
30.1
6.6
0.3
4.3
7.4
6.7
7.0
160
148
174
5.0
29.2 22.4
29.6
6.5
0.3
3.1
7.4
6.8
6.8
160
201
170
6.0
28.6 19.1
29.2
0.5
0.4
2.3
6.9
6.5
6.8
159
230
168
7.0
28.1
28.6
0.4
0.8
6.9
6.7
171
163
8.0
27.8
0.2
6.8
166
9.0
24.4
0.3
7.4
218
10.0
20.6
0.3
7.7
267
October 2, 2018
Temperature Dissolved oxygen pH Specific conductance
Depth B2 C2 D2 F2 SHHWl B2 C2 D2 F2 SHHW1 B2 C2 D2 F2 SHHW1 B2 C2 D2 F2 SHHW1
0.2
26.7
26.7
28.7
27.3
25.6
10.
10.8
6.2
8.5
10.5
8.4
8.7
7.1
7.7
8.4
165
93
175
180
92
1.0
26.6
26.1
28.7
27.2
25.1
10.
10.7
6.4
8.5
10.3
8.5
8.7
7.1
7.6
8.4
165
92
174
179
90
2.0
26.1
25.5
28.5
27.1
24.0
10.
9.8
6.4
8.4
6.9
8.4
8.4
7.1
7.6
7.6
165
92
173
179
92
3.0
25.4
24.5
27.1
26.3
8.3
6.1
3.8
6.3
7.7
7.5
6.9
7.2
162
91
164
177
4.0
25.3
24.1
26.5
8.1
2.5
3.1
7.5
7.1
6.8
157
90
160
5.0
25.2
23.8
25.8
7.8
0.4
1.3
7.4
6.9
6.7
161
107
144
6.0
24.8
25.4
3.0
0.7
7.0
6.6
143
126
7.0
25.2
0.6
6.6
122
8.0
25.0
0.4
6.6
118
9.0
24.6
0.2
6.6
102
10.0
23.9
0.1
6.7
132
December 5, 2018
Temperature
Dissolved oxygen
pH
Specific conductance
Depth
B2
C2
D2
6B
SHHW1
B2
C2
D2
6B SHHW1
B2
C2
D2
6B
SHHWl
B2
C2
D2
F2
SHHWl
0.2
11.0
8.3
19.6
13.4
8.3
9.8
10.0
8.3
8.2
9.7
7.4
7.2
7.1
7.0
7.1
94
72
116
108
82
1.0
11.0
8.3
19.3
13.4
8.3
9.8
10.0
8.2
8.2
9.7
7.2
7.1
7.1
7.0
7.1
94
72
116
108
82
2.0
11.0
8.3
19.2
13.4
8.3
9.8
10.0
8.2
8.2
9.7
7.2
7.1
7.1
7.0
7.1
94
72
116
108
82
3.0
11.0
8.2
18.0
13.4
8.3
9.8
10.0
8.1
8.2
9.7
7.1
7.0
7.1
7.0
7.3
94
72
111
108
82
4.0
10.9
8.1
16.4
9.8
10.0
7.8
7.1
7.0
7.0
91
72
109
5.0
8.7
8.0
12.6
9.4
10.0
7.7
7.0
6.9
6.9
79
73
103
6.0
7.7
11.5
8.7
7.7
7.0
6.9
72
102
7.0
11.7
7.8
6.9
100
8.0
11.3
6.7
6.9
82
9.0
9.6
6.8
6.8
81
10.0
9.4
6.8
6.8
80
Duke Energy Progress 25 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 3. Means, ranges, and spatial trends of selected limnological variables from surface
waters of Hyco Reservoir during 2017 +&
Station B2
Station C2
Station D2
Station F2
Station SHHW I
Variable
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Temperature (°C)
20.7
12.8-28.1
20.5
11.2-27.9
23.4
11.3-30.6
21.8
14.5-29.4
29.9
8.5-28.0
Dissolved oxygen (mg/L)
9.0
7.1-10.2
9.2
6.4-10.6
7.8
6.8-10.2
8.6
6.7-10.8
9.4
7.4-11.0
pH (median value)
7.5
7.2-8.3
7.3
6.9-8.9
7.3
6.9-7.7
7.4
7.1-8.0
7.6
6.8-8.5
Total dissolved solids(mg/L)
109'b
73-145
82'b
47-123
123'
86-153
122'
88-141
74b
59-118
Turbidity (NTU)
19
2-64
17
5-40
8
2-21
5
2-15
15
6-24
Secchi disk transparency (m)
1.3
0.5-1.9
0.7
0.5-1.1
1.5
0.6-2.3
1.6
0.8-2.3
0.7
0.7-0.7
Chlorophyll a (µg1L)
8.5'b
6.3-16
18'
4.8-37
3.9b
1.5-5.1
5.2'b
3.6-7.5
N/A
Nutrients (mg/L)
Ammonia-N
0.01
< 0.01-0.03
0.01
< 0.01-0.03
0.02
< 0.01-0.05
0.01
< 0.01-0.02
< 0.01
N/A
Nitrate + Nitrite N
0.04
< 0.02-0.11
0.08
< 0.02-0.26
0.08
< 0.02-0.19
0.05
< 0.02-0.13
0.06
< 0.02-0.23
Total nitrogen
0.31
<0.12-0.75
0.48
0.28-0.85
0.34
0.21-0.56
0.28
0.12-0.53
0.45
0.28-0.78
Total Kjeldahl Nitrogen
0.20
< 0.10-0.35
0.37
0.23-0.65
0.22
< 0.10-0.41
0.19
0.12-0.25
0.36
0.22-0.51
Total phosphorus
0.043
< 0.005-0.110
0.041
0.022-0.071
0.043
0.006-0.170
0.016
< 0.005-0.035
0.040
0.021-0.063
Total organic carbon (mg/L)
7.1
4.9-10.9
6.8
4.9-8.5
5.8
4.6-6.9
5.8
4.6-7.4
7.0
5.1-8.3
Ions (mg/L)
Calcium
13e6
6.4-19
10'b
5.7-16
16'
10-20
16'b
11-19
9b
6.3-15
Chloride
19'b
6.0-30
1Ob
3.0-23
25'
14-32
24'
15-31
8.1b
2.9-20
Magnesium
5.9b
3.1-8.2
4.3b
2.7-6.9
7.3'
5.0-8.7
7.0'
5.2-8.5
4.Ob
2.8-6.4
Sodium
< 5.0
N/A
< 5.0
N/A
< 5 0
N/A
< 5.0
N/A
< 5.0
N/A
Sulfate
14a6
6-20
8.21
3.8-15.8
19,
14-22
18'
15-21
7.lb
4.2-13.3
Total alkalinity (mg/L as
25
17-31
26
20-34
26
23-30
26
18-30
29
24-38
CaCO3)
Hardness (mg equiv. CaCO3/L)
57'b
29-81
4lb
26-68
71'
46-86
68'
49-83
39'
27-63
Specific conductance (µS/cm)
153'b
75-204
116'b
70-175
182'
125-217
173'
130-208
108b
75-159
Trace elements (µg(L)
Arsenic
i.1'b
0.6-1.5
0.8'b
0.4-1.1
1.4'
1.0-1.8
1.4'
0.9-1.7
0.6b
0.3-0.9
Boron
400e6
94-772
192b
< 50-580
562'
309-838
535'
317-780 .;;
127b
< 50-422
Copper
2.1
1.1-4.2
1.7
0.6-2.7
1.7
1.0-2.6
1.6
0.9-2.1
1.3
< 1.0-2.3
Manganese
61
31-96
88
43-143
151
82-276
101
49-210
127
59-200
Mercury¢
1.98
< 0.50-9.28
1.51
< 0.50-7.08
1.14
< 0.50-3.32
0.85
< 0.50-2.46
1.17
< 0.50-4.59
Selenium
0.6
< 0.5-1.1
< 0.5
< 0.5
0.7
0.6-1.0
0.7
< 0.5-1.1
< 0.5
N/A
Thallium
< 0.1
N/A
< 0.1
N/A
< 0.1
N/A
< 0.1
N/A
< 0.1
N/A
'Unless otherwise noted, all measurements were taken from the surface. Fisher's protected Least Significant Difference (LSD) test was
applied only if the overall F test for the treatment was significant. Means followed by different superscripts were significantly
different from each other (P = 0.05). The rows where significant differences occurred are shaded. Data were rounded to conform
to significant digit requirements. Rounding may obscure mean differences. The variable pH was reported as a median value and
was not subjected to statistical analysis. Sample size equaled 6 unless otherwise noted. Statistical testing was conducted on surface
water means only. N/A means not applicable and NS means not sampled.
',Less than values (<) indicate the Lower Reporting Limit (LRL) for the variable. The LRL is a statistically determined limit beyond which
chemical concentrations cannot be reliably quantified. Statistical analyses were utilized only when mean concentrations were
above the highest analytical LRL and where LRL values occurred, means were calculated by utilizing one half of the absolute
value of each LRL.
§Mercury was measured in nanograms per liter (ng/L).
Duke Energy Progress 26 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 4. Means, ranges, and spatial trends of selected limnological variables from surface
waters of Hyco Reservoir during 2018 "'
Station B2
Station C2
Station D2
Station F2
Station SHHW1
Variable
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Mean
Range
Temperature (°C)
20.1
9.7-29.3
19.3
8.0-29.2
22.6
11.8-31.8
21.3
12.6-30.1
21.8
8.3-29.4
Dissolved oxygen (mg/L)
9.9
6.7-12.6
9.9
7.6-11.4
8.6
7.0-11.1
9.1
7.6-11.4
9.8
6.6-12.5
pH (median value)
7.8
7.4-8.4
7.1
7.4-8.7
7.4
7.1-7.8
7.7
7.0-8.0
7.7
7.0-8.4
Turbidity (NTU)
15
3-35
13
5-25
7.3
2.2-22.9
6.1
1.6-23.2
18
10-36
Secchi disk transparency (m)
1.0°b
0.4-1.7
0.8'b
0.5-1.0
1.3b
0.7-1.9
1.7'
0.7-2.6
0.6b
0.5-0.7
Total dissolved solids (mg/L)
120'
98-155
81'
73-88
137'
101-175
137'
108-183
84b
72-105
Turbidity (NTU)
15
3-35
13
5-25
7
2-23
6
2-23
18
10-36
Chlorophyll a (µg/L)
15 °b
7.8-31
22'
7.2-45
6.5'b
2.1-17
4.9b
1.5-9.0
N/A
Nutrients (mg/L)
Ammonia-N
0.02
<0.01-0.05
0.02
<0.01-0.09
0.04
<0.01-0.13
0.03
<0.01-0.11
0.02
<0.01-0.07
Nitrate + Nitrite N
0.05
<0.02-0.15
0.07
<0.02-0.23
0.10
<0.02-0.22
0.06
<0.02-0.17
0.09
<0.02-0.27
Total nitrogen
0.55
0.21-1.30
0.56
0.19-0.77
0.48
0.20-0.82
0.44
<0.12-0.74
0.57
0.37-0.83
Total Kjeldahl Nitrogen
0.50
0.11-1.20
0.49
0.10-0.77
0.38
<0.10-0.61
0.40
<0.10-0.73
0.49
0.25-0.67
Total phosphorus
0.0521b
0.027-0.095
0.047e'
0.034-0.072
0.028b
0.015-0.061
0.023b
0.009-0.060
0.057'
0.044-0.068
Total organic carbon (mg/L)
7.5
5.8-9.2
8.2
5.5-11.5
6.5
4.8-8.1
6.1
4.8-8.1
7.7
6.0-11.5
Ions (mg/L)
Calcium
12'b
8.0-20
7.3'
5.5-10
16'
9.5-23
16'
9.6-23
7.3b
6.3-8.6
Chloride
18a6
9-32
6.9b
4.0-12.8
27
12-44
27'
11-44
5.8b
4.1-9.5
Magnesium
5.4°b
3.5-7.8
3.3b
2.5-4.4
7.0'
4.2-9.7
6.8'
4.0-9.7
3.3b
2.9-3.8
Sodium
< 5
N/A
< 5
N/A
< 5
N/A
< 5
N/A
< 5
N/A
Sulfate
14'
8-21
5.7b
4.0-9.3
19,
10-27
19,
9-27
5.2b
3.7-8.8
Total alkalinity (mg/L as
271b
23-30
30'b
25-35
27'b
25-28
27b
25-28
32'
28-37
CaCO3)
Hardness (mg equiv. CaCO3/L)
53°b
34-81
32b
24-44
68'
41-98
67'
40-98
32'
28-37
Specific conductance (µS/cm)
139°b
87-210
133°b
72-238
1881
116-260
185'
108-256
94"
82-111
Trace elements (µg/L)
Arsenic
0.9.b
0.6-1.3
0.56
< 0.5-0.9
1.1'
0.8-1.5
1.1'
0.8-1.4
0.5b
< 0.5-Lo
Boron
367"
181-674
721
< 50-142
592'
277-1070
584'
239-1020
36b
< 50-94
Copper
1.9
1.2-2.8
1.5
0.9-1.8
1.6
1.1-2.2
1.5
1.0-2.2
1.5
0.8-2.2
Manganese
56b
24-81
73°b
47-108
97a6
62-149
64°b
34-123
119,
87-186
Mercuryt(ng/L)
2.14
<0.50-4.54
2.71
0.91-4.73
1.78
0.99-4.16
1.75
0.91-4.31
2.68
1.19-5.45
Selenium
< 0.5
N/A
< 0.5
N/A
0.8
0.6-1.2
0.8
0.6-1.4
< 0.5
N/A
Thallium
< 0.1-
N/A
< 0.1
N/A
< 0.1
N/A
< 0.1
N/A
< 0.1
N/A
*Unless otherwise noted, all measurements were taken from the surface. Fisher's protected Least Significant Difference (LSD) test was
applied only if the overall F test for the treatment was significant. Means followed by different superscripts were significantly
different from each other (P = 0.05). The rows where significant differences occurred are shaded. Data were rounded to conform
to significant digit requirements. Rounding may obscure mean differences. The variable pH was reported as a median value and
was not subjected to statistical analysis. Sample size equaled 6 unless otherwise noted. Statistical testing was conducted on surface
water means only. N/A means not applicable and NS means not sampled.
'Less than values (<) indicate the Lower Reporting Limit (LRL) for the variable. The LRL is a statistically determined limit beyond which
chemical concentrations cannot be reliably quantified. Statistical analyses were utilized only when mean concentrations were
above the highest analytical LRL and where LRL values occurred, means were calculated by utilizing one half of the absolute
value of each LRL.
§Mercury was measured in nanograms per liter (ng/L).
Duke Energy Progress 27 Water Resources

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Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 5. (cont.)
Station SHHW1
Month
TDS
Turbidity
Secchi
Chlorophyll a
NH3-N
NOi + NOi -N
TN
TP
TN:TP
TOC
depth
Feb
59
22
< 0.01
0.23
0.78
0.050
16
5.8
Apr
59
24
< 0.01
0.11
0.33
0.063
5.2
8.3
Jun
59
10
0.7
< 0.01
< 0.02
0.28
0.033
8.5
7.8
Aug
68
20
< 0.01
< 0.02
0.51
0.021
24
7.4
Oct
81
11
0.7
< 0.01
< 0.02
0.49
0.041
12
7.7
Dec
118
5.9
< 0.01
< 0.02
0.32
0.031
10
5.1
Month
Cat+
Cl-
Mgt+
Na
S042"
Alkalinity
Hardness
As
B
Cu
Feb
7.1
4.5
3.4
< 5.0
6.2
26
32
0.3 < 50
1.8
Apr
6.5
3.4
3.1
< 5.0
5.3
24
29
0.4 < 50
2.3
Jun
6.3
2.9
2.8
< 5.0
4.2
24
27
0.5 < 50
1.5
Aug
8.8
7.4
4.0
< 5.0
6.9
30
38
0.9 114
1.1
Oct
10.7
11
4.5
5.4
6.6
38
45
0.7 151
0.8
Dec
14.6
20
6.4
5.2
13
34
63
0.8 422
<
1.0
Month
Hg§
Se
Mn
TI
Feb
2.1
< 0.5
126
< 0.10
Apr
1.1
< 0.5
128
< 0.10
Jun
0.8
< 0.5
101
< 0.10
Aug
0.6
< 0.5
200
< 0.10
Oct
0.1
< 0.5
149
< 0.10
Dec
0.1
<0.10
+Units are in mg/L except for most trace elements (µg/L) turbidity (NTU), total alkalinity (mg/L as
CaCO3), and hardness (calculated as mg equivalents CaCO3/L). Less than values (<) indicate the
Lower Reporting Limit (LRL) for the variable. The LRL is a statistically determined limit beyond
which chemical concentrations cannot be reliably reported. NS means not sampled.
"All variables are surface measurements.
§Mercury was measured in nanograms per liter (ng/L).
Duke Energy Progress 30 Water Resources

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Roxboro Steam Electric Plant
2017-2018 Environmental Monitoring
Report
Appendix 6. (cont.)
Station SHHW1
Month
TDS Turbidity
Secchi
Chlorophyll a NH3-N NOs + NOi -N TN TP TN:TP
TOC
depth
Feb
105 36
0.5
0.03 0.20 0.45 0.061 7.4
6.1
Apr
72 18
0.6
< 0.01 0.02 0.37 0.044 8.4
7.1
Jun
77 9.6
0.7
0.02 < 0.02 0.54
7.5
Aug
84 11
0.6
< 0.01 < 0.02 0.58 0.060 9.7
7.7
Oct
81 11
< 0.01 < 0.02 0.67 0.068 9.9
12
Dec
83 22
0.6
0.07 0.27 0.83 0.053 16
6.0
Month
Cat+ CI'
Mgt+
Na SO4' Alkalinity Hardness As B
Cu
Feb
8.1 9.5
3.7
6.6 8.8 28 35 < 0.5 < 50
2.2
Apr
6.3 5.2
3.0
5.4 5.4 28 28 0.4 < 50
1.5
Jun
7.4 4.1
3.2
< 5.0 3.9 33 31 0.6 < 50
1.5
Aug
8.6 7.2
3.8
5.5 4.7 37 37 1.0 94
0.8
Oct
7.0 4.7
3.3
< 5.0 3.7 33 31 0.6 < 50
1.2
Dec
6.4 4.1
2.9
< 5.0 4.7 30 28 0.3 < 50
1.5
Month
Hg§ Se
Mn
TI TKN
Feb
5.4
115
< 0.10 0.3
Apr
2.1 < 0.5
87
< 0.10 0.4
Jun
2.3 < 0.5
95
< 0.10 0.5
Aug
1.2 < 0.5
186
< 0.10 0.6
Oct
1.8 < 0.5
126
< 0.10 0.7
Dec
3.3 < 0.5
106
< 0.10 0.6
+Units
are in mg/L except
for most trace elements (µg/L) turbidity (NTU ), total alkalinity (mg/L as
CaCO3), and hardness (calculated as mg equivalents CaM fl. Less than values (<) indicate
the
Lower Reporting Limit (LRL) for the variable. The LRL is a statistically determined limit beyond
which chemical concentrations cannot be reliably reported. NS means not sampled.
"All variables are surface measurements.
Mercury was measured in nanograms per liter (ng/L).
Duke Energy Progress 33 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Chloride
200
J 175
m
150
c
0 125
c 100
m
CO 75
0
U 50
25
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Hardness
250
200
J
150
c
0
100
c
N
U
co 50
U
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Copper
15
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Dissolved Solids
500
J
m 400
E
0 300
m
c
v 200
c
0
U 100
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Arsenic
Pi
a 4
1
c 3
0
c 2
U
c
O 1
U
01
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
5
J 4
OI
S
Total Selenium
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Appendix 7. Long-term trends of selected parameters at Station B2 from Hyco Reservoir from
2009 through 2018.
Duke Energy Progress 34 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Chloride Total Dissolved Solids
100
rn
E 75
C
0
@ 50
c
m
U
C
(j 25
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Hardness
225
200 — — - — -- - —-------------------------------------- ---
E175 —------- -------- --------------------------------------------
C 150 - — - -- ---- -- - — - —
0
100 - — - - — — --—------- ----
c 75 -- — - - -- ---
O
U50 - - -------- -- - ------- ---- -----
---------- 25 — - - — — — -
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
25
20
p 15
10
C
0
U 5
Total Copper
2009 2010 2011 2012 22 2014 2015 2016 2017 2018
Year
soo
rn
500
E
C 400
0
2 300
m
c 200
O
U
100
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Arsenic
5
&4
o3
m
N2
U
C
O
M
0 r+
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Selenium
5
4
C
0 3
C
C 2
O
U
1
0 �
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Appendix 8. Long-term trends of selected parameters at Station C2 from Hyco Reservoir from
2009 through 2018.
Duke Energy Progress 35 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Chloride
150
rn 125
E
c 100
O
75
c
N
C 50
0
U
25
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
250
a200
E
0 150
(0
y 100
U
c
0
U 50
rn
s
Hardness
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Copper
15
0 1-.......� T
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Dissolved Solids
500
E 400
O
.g 300
c
u 200
c
0
U
100
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Arsenic
s
J
=14
c
O 3
(0
C
N
C 2
O
U
1
0 +.,
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Selenium
5
4
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Appendix 9. Long-term trends of selected parameters at Station D2 from Hyco Reservoir from
2009 through 2018.
Duke Energy Progress 36 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Chloride
150
125
C 100
O
25
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Hardness
250
J
E 200
C
150
C
U 100
C
O
U
50
0
2009 2010 2011 2012 2012 2014 2015 2016 2017 2018
Year
Total Copper
20
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Dissolved Solids
Fre II�
J
rn 300
E
C
(D
0
0 100
U
0
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Arsenic
5
o.
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Total Selenium
5
0.
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
Appendix 10. Long-term trends of selected parameters at Station F2 from Hyco Reservoir from
2009 through 2018.
Duke Energy Progress 37 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 11. Means and standard errors of trace element concentrations ()ig/g dry weight) in
sediments and fish by transect from Hyco Reservoir during 2017. (Values in
parentheses are the corresponding wet weight values.)H
Matrix
n
Transect
Element
Arsenic
Cadmium
Copper
Mercury
Selenium
Sediments
3
C
<6.2
<2.9 (1.1)
75 (28)t 0.5 (0.2)
< 3.6 (1.3)
2.2 (0.8) t 0.2 (0.07)
3
1)
6.2 (3.9)+ 1.6 (1.0)
<2.9(1.8)
85(53)t2.6(1.6)
<3.6(2.2)
2.7(1.7)+0.1(0.09)
Fish muscle
White Catfish
C
<0.2(0.04)
<2.0(0.4)
0.6 (0.1)± 0.3 (0.05)
0.6 (0.1)± 0.06 (0.011)
3.1b(0.6)t0.9(0.08)
D
<0.2(0.04)
<2.0(0.4)
0.9 (0.2) ± 0.3 (0.05)
0.5(0.1)t0.06(0.01)
6.31(1.1)t0.4(0.3)
Bluegill
10
C
<0.2(0.04)
<2.0(0.3)
2.61(0.5)t0.7(0.1)
0.9°(0.2)t0.06(0.011)
4.16(0.7)t0.6(0.1)
10
D
0.6 (0.1) f 0.1 (0.03)
< 2.0 (0.4)
0.4b (0.07) t 0.08 (0.02)
0.4b (0.07) f 0.04 (0.008)
9.9° (0.5) t 1.9 (0.1)
Largemouth Bass
10
C
0.5b (0.1) t 0.08 (0.02)
< 2.0 (0.4)
0.3 (0.2) t 0.09 (0.02)
1.1 (0.2) f 0.08 (0.02)
4.26 (0.9) f 0.2 (0.04)
10
D
0.8° (0.2) t 0.06 (0.01) 1
< 2.0 (0.4)
0.3 (0.07) t 0.06 (0.013)
1.1 (0.2) t 0.1 (0.02)
8.61(1.7) t 0.5 (0.1)
+ To convert to mean dry weight concentrations, divide the mean wet weight concentration by the
appropriate mean dry -to -fresh weight ratio as follows: sediments-Transect C-0.36, Transect
D-0.62, White Catfish muscle-0.18, Bluegill muscle-0.19, and Largemouth Bass muscle-
0.20.
'[Standard errors and statistical analyses are given when mean concentrations were at or above the
laboratory reporting limit. Laboratory reporting limits varied between samples. Means separation
procedures were applied only if the overall test for transect was significant. Means for each
element followed by different superscripts were significantly different at the P = 0.05 level and
were shaded gray to denote significant results between transects.
Duke Energy Progress 38 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 12. Means and standard errors of trace element concentrations (µg/g dry weight) in
sediments and fish by transect from Hyco Reservoir during 2018. (Values in
parentheses are the corresponding wet weight values.)%
Matrix
n
l ranscct
Element
Arsenic
Cadmium
Copper
Mercury
Selenium
Sediments
C'
5.0b (1.9) f 0.03 (0.01)
0.09b (0.03) f 0.002 (0.001)
56 (21) t 0.8 (0.3)
0.08b (0.03) t 0.002 (0.001)
4.4b (2.0) t 0.2 (0.08)
16° (5.8) t 0.7 (0.25)
0.14° (0.05) f 0.01 (0.004)
88 (32) t 2.5 (0.91)
0.16° (0.06) f 0.007 (0.002)
7.6° (3.0) f 0.4 (0.2)
Fish muscle
White Catfish
4
C
<0.5(<0.1)
<0.5(<0.1)
<4.7(<0.9)
0.7(0.1)f0.2(0.01)
1.8 (0.3) ± 0.1 (0.02)
6
I>
<0.5(<0.1)
<0.5(<0.1)
3.9(0.7)t1.7(0.3)
0.4 (0.1) ± 0.07 (0.01)
3.4 (0.6) ± 1.2 (0.2)
Bluegill
8
c
<0.5(<0.1)
<0.5(<0.1)
<4.7(0.9)
0.4-(0.07)t0.03(0.01)
1.9b(0.4)f0.2(0.04)
10
I>
0.7 (0.1)± 0.09 (0.02)
<0.5(<0.1)
10 (1.9) :L 3.8 (0.7)
0.3b(0.05)t0.02(0.004)
7.2-(1.4)t0.4(0.09)
Largemouth
Bass
10
C
0.5b(0.1)t0.05(0.01)
<0.5(<0.1)
13 (2.5) ± 4.1 (0.8)
1.1(0.2)t0.07(0.01)
3.1 (0.6)± 0.08 (0.02)
10
D
0.8- (0.2) t 0.08 (0.02)
< 0.5 (< 0.1)
13 (2.5) t 2.0 (0.4)
1.1 (0.2) t 0.1 (0.02)
5.5 (1.0) t 0.4 (0.08)
To convert to mean dry weight concentrations, divide the mean wet weight concentration by the
appropriate mean dry -to -fresh weight ratio as follows: sediments-0.36, White Catfish muscle-
0.19, Bluegill muscle-0.19, and Largemouth Bass muscle-0.19.
'[Standard errors and statistical analyses are given when mean concentrations were at or above the
laboratory reporting limit. Laboratory reporting limits varied between samples. Means separation
procedures were applied only if the overall test for transect was significant. Means for each
element followed by different superscripts were significantly different at the P = 0.05 level and
were shaded gray to denote significant results between transects.
Duke Energy Progress 39 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
25
nn
20
3
c 15
0
U
E 10
3
C
lu v
5
0
25
0
'ii
tw
n
15
U
C
4010
E
3 5
v
a
iffe
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
-4-Transect C -E-Transect D
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
-f-Transect C-FTransect D
White Catfish
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
Year
--0-Transect C -E-Transect D
Appendix 13. Long-term trends of selenium concentrations (dw) in Bluegill, Largemouth Bass,
and White Catfish muscle tissues at Transect C and Transect D from Hyco
Reservoir from 2009 through 2018.
Duke Energy Progress 40 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 14. Total number and weight (kilograms) of fish collected with electrofishing from
Hyco Reservoir during 2017 and 2018.
2017
2018
Scientific name'
Common name
Total Number
Total weight
Total number
Total weight
lupeidae
Herrings
Dorosoma cepedianum
Gizzard Shad
228
51.1
168
30.1
Dorosoma petenense
Threadfin Shad
152
0.6
75
0.2
y rinidae
Minnows
Notemigonus crysoleucas
Golden Shiner
2
0.1
2
< 0.1
Cyprinella analostana
Satinfin Shiner
40
0.1
30
0.1
Notropis hudsonius
Spottail Shiner
0
0.0
6
< 0.1
Cyprinus carpio
Common Carp
2
10.5
1
7.0
atostomidae
Suckers
Erimyzon oblongus
Creek Chubsucker
1
0.3
3
1.0
Moxostoma collapsum
Notchlip Redhorse
29
31.2
13
12.8
Moxostoma erythrurum
Golden Redhorse
7
3.3
2
1.6
Moxostoma pappillosum
V-lip Redhorse
2
1.1
0
0.0
Moxostoma commersonii
White Sucker
1
0.4
0
0.0
ctaluridae
Bullhead catfishes
Ameiurus catus
White Catfish
12
4.7
34
0.7
Ameiurus platycephalus
Flat Bullhead
10
0.9
5
0.7
ktalurus punctatus
Channel Catfish
39
35.0
25
27.1
Ameiurus natalis
Snail Bullhead
1
< 0.1
1
0.3
entrarchidae
Sunfishes
Lepomis cyanellus
Green Sunfish
38
0.9
20
0.4
Lepomis gulosus
Warmouth
5
0.2
4
0.2
Lepomis macrochirus
Bluegill
1385
29.4
2,233
29.2
Lepomis microlophus
Redear Sunfish
191
25.9
160
24.6
Lepomis hybrid
Hybrid Sunfish
11
0.7
1
0.4
Micropterus salmoides
Largemouth Bass
349
106.1
330
120.8
Pomoxis nigromaculatus
Black Crappie
60
13.1
45
4.7
ercidae
Perches
Perca flavescens
Yellow Perch
31
0.9
34
0.8
Morone chrysops
White Bass
2
0.8
0
0.0
Etheostoma nigrum
Johnny Darter
1
0.1
0
0.0
ichlidae
Cichlids
Tilapia aurea
Blue Tilapia
5
1.5
4
0.5
Total'
2,606
319.0
3,173
263.4
Total Species
24
21
P-
'Taxonomic nomenclature follows Page et al. (2013).
ITotals include only fish identified to species level.
Duke Energy Progress 41 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 15. Mean catch per hour (CPUE) of fish collected with electrofishing by transect from
Hyco Reservoir during 2017.
Common Name
Transect
Reservoir mean
A
B
C
D
F
Gizzard Shad
19
42
12
22
20
22
Threadfin Shad
2
< 1
74
0
0
15
Satinfin Shiner
7
2
10
0
0
4
Golden Shiner
0
0
1
0
0
< 1
Common Carp
0
< 1
0
< 1
0
< 1
Creek Chubsucker
0
0
< 1
0
0
< 1
Notchlip Redhorse
0
2
12
0
0
3
Golden Redhorse
< 1
3
< 1
0
0
< 1
V-lip Redhorse
0
< 1
< 1
0
0
< 1
White Sucker
0
0
< 1
0
0
< 1
White Catfish
1
3
1
< 1
0
1
Flat Bullhead
< 1
0
3
0
2
< 1
Snail Bullhead
0
0
0
0
< 1
< 1
Channel Catfish
l
4
8
2
3
4
Yellow Bullhead
< 1
0
0
0
0
< 1
Green Sunfish
1
0
3
6
9
4
Warmouth
< 1
0
0
1
< 1
< 1
Bluegill
203
42
155
199
77
135
Redbreast Sunfish
0
< 1
0
0
0
< 1
Redear Sunfish
21
38
16
10
9
19
Hybrid Sunfish
0
0
0
4
2
1
Largemouth Bass
36
26
40
34
35
34
Black Crappie
9
12
8
0
< 1
6
Yellow Perch
< 1
< 1
14
0
0
3
White Bass
0
0
1
0
0
< 1
Blue Tilapia
0
< 1
0
2
0
< 1
Johnny Darter
0
< 1
0
0
0
< 1
Total CPUE'
302
175
360
281
159
254
Total number of species9l
15
17
19
10
10
26
'Total catch per unit effort (CPUE) may vary from column sums due to rounding.
9ITotal number of species does not include hybrid sunfish.
Duke Energy Progress 42 Water Resources

Roxboro Steam Electric Plant 2017-2018 Environmental Monitoring Report
Appendix 16. Mean catch per hour (CPUE) of fish collected with electrofishing by transect from
Hyco Reservoir during 2018.
Common Name
Transect
Reservoir mean
A
B
C
D
F
Gizzard Shad
18
22
24
16
6
17
Threadfin Shad
1
3
14
6
14
8
Satinfin Shiner
6
2
6
0
0
3
Spottail Shiner
0
2
1
0
0
< 1
Golden Shiner
0
< 1
0
0
0
< I
Common carp
0
0
< 1
0
0
< 1
Creek Chubsucker
1
< 1
0
0
0
< 1
Notchlip Redhorse
0
< 1
6
0
0
1
Golden Redhorse
1
0
0
0
0
< 1
White Catfish
< 1
1
0
< 1
< 1
< 1
Flat Bullhead
1
0
0
0
2
< 1
Snail Bullhead
0
0
< 1
0
2
< 1
Channel Catfish
< 1
5
2
3
2
2
Green Sunfish
0
0
2
1
7
2
Warmouth
0
0
< 1
< 1
1
< 1
Bluegill
221
367
182
258
126
227
Redbreast Sunfish
0
0
< 1
0
0
< 1
Redear Sunfish
24
34
4
15
6
16
Hybrid Sunfish
0
0
< 1
2
0
< 1
Largemouth Bass
34
16
44
42
30
34
Black Crappie
12
10
2
< 1
0
5
Yellow Perch
2
8
2
4
2
4
Blue Tilapia
0
0
0
2
0
< 1
Total CPUE'
322
472
293
350
196
323
Total number of speciesT
13
14
16
12
12
22
Total catch per unit effort (CPUE) may vary from column sums due to rounding.
9'Total number of species does not include hybrid sunfish.
Duke Energy Progress 43 Water Resources

RECF-IVE()
FEB 2 6 1010
NCDEQIDWR/NPDES
ATTACHMENT 2

Thallium (CAS # 7440-28-0)
Health Effects Summary
Human health effects associated with low environmental exposures to thallium are unknown. Severe
neurological, gastrointestinal, cardiovascular, and respiratory effects leading to death as well as alopecia
(hair loss) have been reported in humans and animals following large, acute doses. Changes in blood
chemistry, kidney and adrenal weights, and sperm quality in addition to alopecia, developmental delays
and increased mortality have been reported in animal studies following oral administration of thallium
compounds.
Necessity for Assessment of Thallium Criteria
The Division of Water Resources (DWR) relies upon the US Environmental Protection Agency (US EPA)
Section 304(a) publications, when they are available, to assess and control the releases of toxics to the
environment. These publications, collectively known as the National Recommended Water Quality
Criteria (NRWQC), are published, peer -reviewed recommendations for states and tribes. DWR staff
routinely review the NRWQC for possible development of state standards. For thallium, we noted that
the thallium criterion has not been updated since approximately 2003. The current thallium values for
Water Supply (0.24 µg/L) and Fish Consumption (0.47 µg/L)' do not reflect recent published literature
and science. In 2015, the US EPA updated 94 chemical pollutants' to reflect the latest scientific
information and federal policies. They did not update the human health criterion for thallium citing
"outstanding technical issues". DWR reviewed recent publications for evaluation and consideration of a
more appropriate criterion.
Examination of Literature
US EPA's Integrated Risk Information System (IRIS, 1988)3 established oral reference doses (RfDs) for
soluble thallium (1) compounds ranging from 0.000068 to 0.00009 mg/kg-day. An oral RfD assesses the
risk for health effects other than cancer and gene mutations. These RfDs were withdrawn and replaced
with a "qualitative discussion" in 2009 due to the limitations in the toxicology database and poor quality
of the toxicology studies available for thallium°. These RfDs form the basis of the NRWQC and are,
therefore, questioned for use in a state criterion.
IRIS determined there are inadequate data to assess the carcinogenic potential of thallium. A cancer
potency factor is not available. Therefore, a human exposure concentration associated with an
incremental lifetime cancer risk estimate cannot be calculated.
' https://www.epa.gov/wqc/national-recommended-water-quality-criteria-human-health-criteria-table
' https://www.epa.gov/wqc/human-health-water-quality-criteria-and-methods-toxics
3 https://cfpub.epa.gov/ncea/iris/iris documents/documents/subst/1012 summary.pdf
4 https://cfpub.epa.gov/ncea/iris/iris documents/documents/toxreviews/1012tr.pdf
1 1 P a g e

US EPA's National Center for Environmental Assessment (NCEA, 2012)5 declined calculating a chronic,
oral provisional peer -reviewed toxicity value (PPRTV) due to the lack of good quality toxicology studies
available for thallium. They chose instead to derive the following screening provisional RfD's (p-RfD's),
provided in an Appendix to the document:
Screening Chronic p-RfD for thallium (1) sulfate 0.00002 mg/kg-day
Screening Chronic p-RfD for soluble thallium 0.00001 mg/kg-day
These values have a caveat that reads: "Users of screening toxicity values in an appendix to a PPRTV
assessment should understand that there is considerably more uncertainty associated with the
derivation of a supplemental screening toxicity value than for a value presented in the body of the
assessment." (USEPA, 2012) The screening levels for thallium sulfate"and soluble thallium are not
appropriate for developing standards due to the high level of uncertainty associated with such values.
The Agency for Toxic Substances and Disease Registry, US Public Health Service (ATSDR, 1992) declined
to establish a chronic Minimum Risk Level (MRL) for thallium due to a lack of adequate data.6
A federal Maximum Contaminant Level (MCL) of 2 µg/L has been established for thallium under the Safe
Drinking Water Act' along with a Maximum Contaminant Level Goal (MCLG) of 0.5 µg/L. The MCL and
MCLG are based on a 90-day gavage study in rats (Stoltz et al., 1986). In this study, the only grossly
observed finding at necropsy thought to be treatment -related was alopecia; however, based on the
absence of microscopic histopathologic changes, US EPA identified a no observed adverse effect level
(NOAEL) of 0.2 mg/kg-day. Due to uncertainties in the NOAEL, US EPA incorporated a 3000-fold
uncertainty factor (10 for use of a subchronic study, 10 for intra-species variability, 10 for interspecies
variability, and 3 to account for inadequate testing of other endpoints of toxicity.) Based on this NOAEL,
a Drinking Water Equivalent Level (DWEL) of 2.45 µg Thallium/L was calculated and rounded to 2 µg TI/L.
The federal MCL is the same as the DWEL, and is expressed as 0.002 mg/L (2 µg/L). The MCLG
incorporates a Relative Source Contribution (RSC) of 20% to account for exposure routes other than
drinking water.
The US Department of Health and Human Services, National Toxicology. Program (NTP) nominated
Thallium and Thallium salts (N21607-6/2016) for toxicological review$. (Note: We were not able to
determine the status of the progress.)
The US EPA NRWQC Human Health Calculation Matrix9 lists a Bioconcentration Factor (BCF) of 116; It
appears that the BCF factor used in the NRWQC is from US EPA's 1980 Ambient Water Quality Criteria
for Thallium (440/5-80-074) and is based upon three studies from 197510. (Zitko, et al). Current
accumulation studies are performed differently than those in 1975, however, we have no additional
information to base a modification to this value.
Recommended Surface Water Criteria for Thallium
5 https://hhpprtv.ornl.gov/ and https://hhpprtv.ornl.gov/issue papers/ThalliumSolubleSalts.pdf
6 https://www.atsdr.cdc.gov/toxprofiles/TP.asp?id=309&tid=49
' https://www epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations
8 https•//ntp niehs nih.gov/ntp/a bout ntp/bsc/2016/Tune/meetingmaterials/thalliumcompounds 508 pdf
9 https://nepis.epa.gov/Exe/ZVPDF.cgi/200031EI.PDF?Dockev=200031EI.PDF
io https://nepis.epa.gov/Exe/ZyPDF.cgi/2000LNGQ.PDF?Dockev=2000LNGQ.PDF
2 1 P a g e

The US EPA National Recommended Water Quality Criteria for thallium does not appear to be
supportable, as the values were based on a EPA IRIS RfD (Reference Cite: IRIS 09/01/90) and the
reference has been withdrawn and replaced with a "qualitative discussion". No new toxicological
information relevant to the derivation of a North Carolina specific criterion is available.
Staff of the Classifications and Standards/Rules Review Branch recommend the use of the federal MCL of
2 µg/L for thallium in all surface waters of the state, as allowed in 15A NCAC 02B, until such time that
more substantive information becomes available.
References:
Agency for Toxic Substances and Disease Registry. Toxicological Profile for Thallium. 1992.
http://www.atsdr.cdc.gov/
MRI (Midwest Research Institute). 1988. Toxicity of thallium (1) sulfate (CAS NO. 7446-18-6) in Sprague
Dawley rats. Volume 2: Subchronic (90-day) study [revised final report]. Docket ID: EPA-HQ-ORD-2008-
0057-0002 and EPA-HQ-ORD-2008-0057-0003.
US Department of Health and Human Services:
https://ntp.niehs.nih.gov/testing/noms/search/summary/nm-n2l607.html#top
U.S. EPA Drinking Water Standards and Health Advisories. 2018. Office of Water (EPA 822-F-18-001)
https•//www epa gov/sites/production/files/2018-03/documents/dwtable2018.pdf
US EPA National Recommended Water Quality Criteria: 2002 Human Health Calculation Matrix (EPA-
822-R-02-012) https://nepis.epa.gov/Exe/ZyPDF.cgi/20003[EI.PDF?Dockey=200031EI.PDF
U.S. EPA. Provisional Peer Reviewed Toxicity Values for Thallium and Compounds. 2012. Office of
Research and Development, National Center for Environmental Assessment
https://hhpprtv.ornl.gov/quickview/pprtv papers.php
U.S. EPA Integrated Risk Information System. Chemical Assessment Summary for Thallium (1), soluble
salts. 2009. http://www.epa.gov/iris (accessed March 06, 2018).
Zitko V, Carson WV.1975 Accumulation of thallium in clams and mussels. Bull Environ Contam Toxicol
14:530-533
April 17, 2018
3(Page

ATTACHMENT 3

201 B Annunt Drinking Water Duality Report
TOWNOFCIL KSWLLE
PWSIO N0. 5117310
INTRODUCTION
This ANpa NotingWatw Ouarry Rpari Id 'panda year 2010 a destgnad tO Imam }w nowt }om dlnWng wales quaory
Om goal Is to provpe you win a sale aN cmanda in, slay o, dm.rg wrier and we or, Yes to underand IN edme an.
Re fo prom -our ywater mo ry 1N puahry or your amkmg ware, mud meat an. alp Ieaeel aa o—'anions neu.tere l by
IN Virginia Dpelm.nl of Hedih (VOH(
II yes mare pashas about "a report as want mawme,l Inlatnaron mom, arty aspect of your &Inking wale a wail to snow
tees to pimp", In Ncrs,ms Ina! may enact IN wain, of your ""no ware, paste cannot "'It"d EHOn Publl[ SarvlpM
iN Imes and Iaaron of regu,arM scNdllal Irwn Councls mcehngs are as lol,ows
TANdi••d I A n7'l0am al Ma Tawn N.Ilaulldine
GENERAL INFORMATION
All dmRng 111, k1ho ng milled &mhmg wale may reaearnat N espvTed to'dean at lead lined Sol 'IS Of sane Nrx
Tvnlnanls The meeance of conlamrnanrs Eons rM r,ecossanty,nd'ate lhal water poses. NaR, rrsh Mae lnlamahm deity
dNered by caning In, Envschn lPrdacbm Age,cy's Safe Drinking Water wends,(800-42SRp1).
San. paade may N more --We to con ornows m ask, wafer men me general —I.- ,min ad-l-waswed
Plasmas such as Persons wnn edrcv u pig ChemdN by, parsals -no have a gme organ Iranspa's pr ova wnn
HIVIAID6 le .,be, mina. Wdem drams rs. sane W., ana'lams can tie pamcularry as ,as non 'fact-, Tice peep.
should scent ad"e sooul Winking Ova er hen look health date mickes EPAr DC guitlN,ns at eappopriae means to lessen
p
Ilse ,Ias of 'lad ool by crypozpadan and dNr on. —;'.al cmfani... a are avalMde has In. 5•M1 Drinking We.'
NW(8g0 264?Sl).
IN nodes of among wrier (bah lap water and o elk waled Include Iwas. 10kas dleame. poste. laser a livings aN
Ovals As wale travels me, IN Sm Face of land or Through The ground, Il dssdver normally-octurong minerals Sol some cam.
red08CIIve mderala antl Can p<M W suoslapce3 Fan the presence of anmal3 a Fan !,moan adrvlly
Con, o ds mat may N pasenl m Swrn ware Irt�—
Ml nd [ontaminan,. each he mods ant butan, onto may came ham sewage treebnem plan%septic syamn
egr'ulluraliNedandpaprms ano.scel.
' Inagensc cpnbsonamnh, such as al lh and mete, Which can be neurdy-o[c-fig Or male it- urban mom WAIN IUNR,
.-11., or domed' waeewee, dsrnarge O no gas pWu 1- m nog a km,mg
• Formal and rerbiades. Which mry come tram a variety Of sources such es aernaftere. urbn Nam w w runoff, and
• Organic cnemlcds cdn,minann, includnp rydhent and vdeNa ago,, chemicas, which are bypredu[N of ,NusMa pro
pr s and petroleum oduction. and den aim cane Iran gas stations urwn atmmweal rape. and adds' system
�Rediaa[dva canteminn,, which to be set, / ecdanng or be the results of ail and gas production end bral vh e..
In maw to endue toss bear wake, sale To*ink EPA meadOes lagr0mons a ,mil the amours of loan wnlanlhadsln
Wgle pro— by pmlc w a aydms, Food and Drug Adn,nrslrason arg,ishon san ohstl Imes Ta Combanmml5 m bOtll13d
ter. whit, "' prowN,N name mdedpn for mm,c health
SOURCE AND TREATMENT OF YOUR DRINKING WATER
The.bace d you! d nkag esol a surface wata as OesCrbed Dhow
Raw wear MfNa, I ... IN M Bunn. lelnd L9, Mal obtain. I, •ate mom M. Dan and Remain, (Stmnln) RhM.
Tr went of the one want consists a chernal w hhon, caagJaNnf1mcoleoon, selling, Mbaoon, Omfidabon end charm idim.
All oI mesa prmcesss wok togelha 10 rdnae IN p y,"t chenm2,. ana mdogioal Coadonmmbz fd make IN wee sale to,
arnk g
tN Vng,da Dpmmmi of Heallh measicled a Sol water assessment of m, system In 2016 ire move, was dMamlned
to N of h,gh suacpllplily to conla"napn ueng the creole, devekmd ov the stale m as maimed Samoa Water Asseas'eol
Program
TN asse.dhml eporl =,,Is of maps Show,ng the swlm war assessmenl area m rnvnlay of kpown IaN use ac kake of
9 n ell 'her lnm of any known <memmatm wnhln tN,sl 5,eMls TN repot d —lade oy canacurg IN Tavn
ofGkirkry W al (a3a)37h.B177 v an w oliedvllikoe ao
DEFINITIONS
Cadanrners, in yes, dmRng wSt., Ase,ci mmaa.d accdang 1. Fedora, ana St.,. ragutaama The laneIN rep
page .hows th. rotors a ommodtdinp la [aendv yam 2013. In the tame ana Nsewhve in his rpat You we6nd mern,fms
endsobrendsonsyoumightndbalson nth. IN, had, ng denmh pis al Vr dlai W help you belle uoddround Men twine.
Arm-kncl (NDf -lab analysis macales Ina! II,a donlam,nanl Is nOl present
Pn. per mhbn (ppmJ a Mlayrams per riles amyl) - anepan Pe mtlkon ca,e5pagb 10 arts m,nme In two years a a slrgm
pmu, m SI0000
note year bled, food) a sec ograms pv Ne . me pan per bhp, conasywrtas to are minme ,n 2000 most or a single penny
m S t0D0).()00
Picocwes pv Ind (pCvil' Plcowrws per lav Is a mcesad ol,N raaoacbmlY In wee,
Acton L.-(AL). IN mncemrallm of a cmtenearl wheh. iIe ooken.Irggv.Ircelmdnl a die rewne'nte wNci, a wales
".I -must an.
T,Nhom, r bniqus IT � a hw.Ym p'odel mb.NO tO ons—,Is kv 1 or a cmlaminem,n d'krg wake,
Men mum Conessrnanl Level a MCL-the hq-l1—Ol a CmlamInam Ina, Is aedwea,n ankmg wee MCL a ore se All die
Io IN MCLGs as leesge using the bee avrkINS IreemenT 1.1n gy
Masi m Cdnlem,nanl Lelml Goal or MCLG Ins lace oI a comamInanl ,n Wmkng wale) NOW winch Ihan IS Ids known o,
expected rskto Nall, MCLG'sallowloramarg-lseay
Mamnum Rendual DsmlecldnlLoval Goals MROLG-,N level of drnkvg wa enleclanl ,low wh'h lha.Isnkmwn do
Nissan.espedied nak to Nissan. kill do not ofieq the baN6N of use of dienlactents as [nee ork.b M cantellinn,.
Maumum Residual Dsroleclanl loyal or MRDL- IN NgNsl lent of a donfecaml allowed,n Winking water iN sc,mlwng
w,dmce ana a0alkm or a denfedmnl is rtecem,y fa comrol 0l mrcrof Cor,m,nads. '
i Ma —,heirs s (rHM) a,a a goal W fwr cN hall that are lamed el an She w,fw,m or ago akcs when comoe a
dNr the nobanls used to contra mrddbal cornameems In &inking wm h rood wan naturally dcculllrg organ' BN ImgSn
'site, In wale,
L—ton. Running Aoo.al vaagdaiwi (Li mne fN.v.r.p. of pe ararylv2l 1e 01Ia spmpes lae kana pn'par
mernat IdaNn delrg IN miondi Ire calends, quaN,,
.. r......
s
.e..w ewe. e..,.�..0
1).Turbiain a. manme.1N doudna.a of thewets and a ana bane 111 A good indicate ofhowmll IN IM.m rsson oy.l
a Imdimlrq
21 6an. pam,e wN am, on canmrung Irmrmoss. es I1.1—S .1IN MCL der mom ream may ekake-c. pr—a
wmier n,we smal a rste —sym ant may have aera n'ese rsk of gar career
31 lraemam Too-oke (Tit -Boom IOCr del Wrtnq Treatment process R.I. in., ass gee' Ihan aW eal Io
iWameal afi to cdrphance coals
d( Oe10.anplesesceedm Achm Levis
We cishor ay mined, la various ComanmademlNwale VLOOY to mael au,egNMOryegmemnrs TNmgelTzmrylNae
--in. IMalaked S. dkve, Oldefecllm Many dha cmtaminanbs laraNn naiy2adbm wva wl masenfawveOelow
the Machin forts of IN lab equlgn9e
MW of iNresmis in the,ale are Iran Nog amain Kl B Howeve IN elate allows us la moire la Sank,.co,owsanls bn
Ihan inn par year aazuse me <aKnlra,Ions of Ibass Catlamnanta ad not clang. frapremry
That Em,rmmen,al P,oacNn Agency stye MCL s at very drngwt levels In oevell ollTg Tha simserabSEPA...moss Ina IN
Overage mall looks 2liters oI Wee each day lomughwl a 70.yee Ii, span EPA generally sal. MCLS at,ve, Thal wet .San
,nod mWk W Nakl enedb Im Sdms ComaTlNOls or . ma,rvlenHiwusap010 One'-amllLm chance al Nwng IN OesCnped
Nanh eaed Id she mrsenlNras
TI pose I aevatW shot of lead can Cause rs i Nalco madams dspeaaliy Or megrem wane alma young comes, Lead
In a king Walet is Iran'evials and rmlondot assOdead wah serv'elmes and have punting Clarkzv,l, Wale,
Thalmem Plain s tespm.me Ia moW&ng high pooh, dnnkmg weer but canna antra IN vale, of —beaks used in punt
iag cmnp.... to. When year watv no been st far.evva hour, Year can th dmixe the galena Ia Mad aspotaa by hAkag
,cow tap ra 30 Viddrat 1.2 moods a mS.I . oacanes [rid of, I— a e,.edy rompealure before usrg wow he drinking or
mMmg II you a,, caeaned prom man m ywr watea. you may wd, to have yaks water laded Infondlton m kBd m W,nkmg
water lading methms and Slags you can lake lO m,nmrzel exposure a avatable Iron the See Drinking Wear H.IIIN I-0
426e701 ce a, Min IAvww eon dav/saleweelhaad
VIOLATION INFORMATION
The Channeled W.,r TreNnt Plant had . violation In th. ncond sod third quarter of 2010.1 TTHM. that were over
the MCL of 00 pp.. An .Ildltlan.l vkdellm we. .lee laaued In the loudh q,,M,r for A RAA vlol.6an pl TTHMI over to
MCL of N ppm.
III.... the, this Information wM .II the .Mel wN drink our wa,r and n you hev. any q...11... If .... .on,ot Rich
and MRS. st (434) 37e-0169
The Drinking Wale, Dually Repw was Preened by Richard Ellmt. Dassid, of Opaekns, Town of ClarksvlN. P 0 Rox I147
Clek-ed VA 23927 Phone 434-37"11

ATTACHMENT 4

Results of Water Quality Analysis
Table 1 Roanoke River Service Authority Results
Contaminant
MCLG
MCL
Level Found
Rantle
V.iolatior
Sample Date •
Typical Source of Contamination
Turbidity (NTU)
NA
TT=1 NTU
0.10 Max.
0.03-0.10
No
Continuous testinc
Soil Runoff.
100.0%
See Footnote #1
MAX
RRSA Plant
Fluoride (ppm)
4
4
avg= 0.67
0.60-0.78
No
Tested daily on
Erosion of natural deposits; Water
finished water at
additive which promotes strong teeth;
RRSA plant once
Desired level 0.90
per shift.
Gross Alpha
0
15
<0.5
NA
No
2/6/2013
erosion of natural deposits.
Ci/L
every 8 yrs
Radium -combine
0
5
<0.6
NA
No
2n12013
erosion of natural deposits.
Ci/L
every 8 yrs
TOC -Total (ppm)
NA
TT>1.0
Lowest Running
1.68-1.91
No
monthy on raw
Naturally present in environment
Organic Carbon
Av = 1.68
& treated water
See footnote #2
Nitrate (ppb)
10
10
0.13
NA
No
Feb 2018 Annualli
Runoff from fertilizer use
RRSA Plant
I leaching from septic tanks; sewage
Barium pm
2
2
0.02
NA
No
ITestedAnnually .1
erosion of natural deposit
Table 2 South Hill System Results
Copper (ppm)
1.3
AL=1.3
0.2
ND-0.03
No
9/16/2017
Corrosion of household plumbing;
See Footnote #3
90th Percentile
every 3 yrs
erosion of natural deposits.
Lead (ppb)
15
AL=15
<2
ND-34.3
No
9/16/2017
Corrosion of household plumbing;
See Footnote #3
90th Percentile
eve 3 s
erosion of natural deposits.
TTHM (ppb)
NA
80
90
23-98
Yes
Quarterly
By-product of drinking water
Trihalomethanes
4 Qtr.RunAvg.
2 sites
chlorination.
HAA5 (ppb)
NA
60
23
2.2-45
No
Quarterly
By-product of drinking water
Haloacetic Acids
4 Qtr.Run Avg.
2 sites
chlorination.
Chlorine (ppm)
MRDL=
4
MRDLG=
4
1.05
0.44-1.68
No
6 sites
monthly
Water additive used to control
microbes.
AL* Action Level N/A= Not Applicable TT= Treatment Technique ND= Non Detect < Symbol = Less Than, > Symbol
Greater Than.
Note # I; Treatment Technique (TT) requires that at least 95% of the monthly samples must be below 0.30 NTU.
Note # 2: Total Organic Carbon (TOC) has no health effect. However, total organic carbon provides a medium for the formation of disinfec-
tid'n'byprodutvs. These byproducts include Trihalomethanes (THMs) and Haloacetic Acids (HAASs). Drinking water containing these byprod-
u.cts in excess of the MCL may lead to adverse health effects, liver and kidney problems, or nervous system effects, and may lead to an increased
risk of cancer;_
Note #3: None of the 20 sites tested for lead and copper exceeded the copper action level and only one site exceeded the lead action level.
MCLs are set at a very stringent level by the U.S. Environmental Protection Agency. In developing the standards the EPA assumes that the aver-
age adult drinks 2 liters of water each day throughout a 70 year life span. The EPA generally sets MCLs at levels that will result in adverse health
affect for some contaminants or a one -in -ten -thousand to one -in -a -million chance of having the described health effect for other contaminants.
Violation Information: The Town exceeded the maximum contaminant level for total trihalomethanes (TTHMs) at one of
the two locations required to be sampled during the first three calendar quarters of 2018. Violation notices were previously
distributed explaining that this is not an immediate health risk. The Town is increasing flushing and is working with The Roa-
noke River Service Authority to correct the situation.
For a copy of this report in pdf form visit the town website, www.southhiliva.org/town-of-sh/forms-applications-other-
downloads/plans-documents/286.2018-consumer-confidence-drinking-water-quality-reporttfile
Want to learn more about drinking water, go to www.drinktap.org presented by AWWA.
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Introduction:
This Annual Consumer Confidence Drinking Water Re-
port is for the calendar year 2018 and is designed to in-
form you about your drinking water quality. Our goal is to
provide you with a safe and dependable supply of drinking
water, and we want you to understand the efforts we
make to protect your water supply. The quality of your
drinking water must meet state and federal requirements
administered by the Virginia Department of Health
(VDH)-
Educational Information:
All drinking water, including bottled water,, may reasonably
be expected to contain at least small amounts of some
contaminants. The presence of contaminants does not
necessarily indicate that the water poses a health risk.
Some people may be more vulnerable to contaminants in
drinking water than the general population. Immune com-
promised persons such as a person undergoing chemo-
therapy, persons who have undergone organ transplants,
people with HIV/AIDS or other immune system disor-
ders, some elderly, and infants can be particularly at risk
for infections. Those persons should seek the advice
about drinking water from their health care providers.
EPA/CDC guidelines on appropriate means to lessen the
risk of infection by cryptosporidium and other microbio-
logical contaminants are also available by contacting the
Safe Drinking Water Hotline at (800-426-4791).
The sources of drinking water (both tap water and bottled
water) include rivers, lakes, streams, ponds, reservoirs,
springs, and wells. As water travels over the surface or
through the ground, it dissolves naturally occurring miner-
als and in some cases, radioactive material, and can pick up
substances resulting from the presence of animals or from
human activity. Contaminants that may be present in
source water include: (1) Microbial contaminants, such as
viruses and bacteria, which may come from sewage treat-
ment plants, septic systems, agricultural livestock opera-
tions, and wildlife. (2) Inorganic contaminants. such as salts
and metals, which can be naturally occurring or result from
urban storm runoff, industrial or domestic wastewater .
discharges, oil and gas production, mining, or farming. (3)
Pesticides and herbicides, which may come from a variety
of sources such as agriculture, urban storm water runoff,
and residential uses. (4) Organic chemical contaminants,
including synthetic and volatile organic chemicals, which are
byproducts of industrial processes and petroleum produc-
tion, and can also come from gas stations, urban storm
water runoff and septic systems. (5) Radioactive contami-
nants, which can be naturally occurring or be the result of
oil and gas production and mining activities. To ensure
that tap water is safe to drink EPA prescribes regulations
which limit the amount of certain contaminants in water
provided by public water systems. The Food and Drug
Administration regulations establish limits for contaminants
imbottled water which must provide the same protection
for public health.
If present, elevated levels of lead can cause serious health
problems, especially for pregnant women and young chil-
dren. Lead in drinking water is primarily from materials and
components associated with service lines and home plumb-
ing. The Town of South Hill is responsible for providing
high quality drinking water but cannot control the variety of
materials used in plumbing components. When your water
has been sitting for several hours, you can minimize the
potential for lead exposure by flushing your tap for IS to
30 seconds or until it becomes cold or reaches a steady
temperature before using water for drinking or cooking. If
you are concerned about lead in your water, testing meth-
ods and steps you can take to minimize exposure are avail-
able from the Safe Drinking Water Hotline or at
httpJ/www.epa.gov/safewater/lead.
SOURCE OF YOUR DRINKING WATER
The source of your drinking water is surface water as de-
scribed below.
The Town of South Hill purchases water from the Roanoke
River Service Authority (RRSA). The water source is lo-
cated on Lake Gaston on the Roanoke River., Treat-
ment of the raw water consists of chemicaladdition, coagu-
lation, flocculation, settling (superpulsator), filtration, fluori-.
dation, and chlorination. ;All of these processes work to-
gether to remove physical, chemical, and biological contam-
inants to make water safe for drinking.,
A Source Water Assessment of our water source has
been conducted by the Virginia Department of Health.
The Lake/River was determined to be of high suscepti-
tg to contamination using criteria developed by the
state in its approved Water Assessment Program. The
assessment report consists of maps showing the source
water assessment area, an inventory of known land use
activities of concern and documentation of any known
contamination within the last 5 years. Additional infor-
mation is available by contacting the RRSA (434-689-
7772).
DEFINITIONS:
Contaminants in your drinking water are routinely moni-
tored according to Federal and State Regulations. The
tables on the back shows the results of monitoring con-
ducted for calendar year 2018. In the table and elsewhere
in this report you will find terms and abbreviations you
might not be familiar with. The following definitions are
provided to help you better understand these terms.
Action Level (AU- The concentration of a contaminant
which, if exceeded, triggers treatment or other re-
quirements which a water system must follow.
Non detects (ND)- Lab analysis indicates that the con-
taminant is not present within the detection limits of
the instrument used.
Parts per million (ppm) or milligrams per liter (mg/L)-
One part per million corresponds to one minute.in
two years or one penny in $10,000.
Parts per billion (ppb) or micrograms per liter NA)
One part per billion corresponds to one minute in
2,000 years or a single penny in $10,000,000.
Picocuries per liter (pCf/L)- Picocuries per liter is a
measure of radioactivity in water.
Nebhelometric Turbidity Unit (NTU)= Nephelometric
turbidity is a measure of cloudiness of the water.
Turbidity in excess of 5.0 NTU is just noticeable to
the average person. '
Maximum Contaminant Level Goal (MCLQ Is the level
of contaminant in drinking water below which there
is no known or expected risk to health. MCLGs
allow for a margin of safety.
Maximum Contaminant Level (MCL-Is the highest
level of a contaminant that is allowed in drinking
water. MCLs are set as close to the MCLGs as fea-
sible using the best available treatment technology.
Maximum Residual Disinfection Level Goal (MRDL
The level of drinking water disinfectant below which
there is no known or expected health risk.
MRDLGs do not affect the benefits of the use of
disinfectants to control microbial contaminants.
Maximum Residual Disinfection Level (MRDL)
The highest level of a disinfectant allowed in drinking
water. There is convincing evidence that the addi-
tion of a disinfectant is necessary for the control of
microbial contaminants.
r i ' — Is a measure of the cloudiness of the wa-
ter and is used because it is a good indicator of how
well the filtration system is functioning. Samples for
Turbidity are taken at the Water Treatment Plant.
Treatment Technique (TT)= A required process in-
tended to reduce the level of a contaminant in
drinking water.
Environmental Protection Agency (EPA)
Center for Decease Control (CDC)

ATTACHMENT 5

It,
`C ENERGY
March 10, 2015
North Carolina Department of
Environment and Natural Resources
Division of Water Resources
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: 316(b) Alternate Schedule Request
Duke Energy Carolina, LLC and Duke Energy Progress, LLC
Attention Sergei Chernikov:
Environmental Services
Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address:
Mail Code EC13K/ P.Q. Box 1006
Charlotte, NC 28201-1006
RECEIVEDIDENWDWR
,�o I l 20115
Water Q Secryor
Permiltttng
Final regulations to establish requirements for cooling water intake structures at existing facilities were
published in the Federal Register on August 15, 2014 (i.e. regulations implementing §316(b) of the Clean
Water Act) with an effective date of October 14, 2014. The regulation applies to stations that
commenced construction prior to or on January 17, 2002 and have a design intake flow greater than 2
million gallons per day (MGD), utilize 25% of the water withdrawn for cooling purposes and are point
sources per the NDPES program. The stations Duke Energy has identified as being subject to the rule are
provided in Table 1.
The regulation requires the submission of information listed in 40 CFR 122.21(r). The extent of the
information that is required to be submitted per station is based on the actual intake flow (AIF). For
stations that have an AIF less than or equal to 125 million gallons per day (MGD), the regulation requires
the following information to be submitted:
§122.21(r)(2) Source Water Physical Data
§122.21(r)(3) Cooling Water Intake Structure Data
§122.21(r)(4) Source Water Baseline Biological Characterization Data
§122.21(r)(5) Cooling Water System Data
§122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard
§122.21(r)(7) Entrainment Performance Studies
§122.21(r)(8) Operational Status

For stations that have an AIF greater than 125 MGD, the regulation requires the above information to be
submitted and, unless waived, the following additional information:
§122.21(r)(9) Entrainment Characterization Study
§122.21(r)(10) Comprehensive Technical Feasibility and Cost Evaluation Study
§122.21(r)(11) Benefits Valuation Study
§122.21(r)(12) Non -water Quality and Other Environmental Impacts Study
The timing of the submission of the above information is connected to the timing of the NPDES permit
renewal application for the station. The regulation states that for a station whose current effective
NPDES permit expires after July 14, 2018, information required to be submitted must be included with
the subsequent NPDES permit renewal application. For stations whose current effective permit expires
on or before July 14, 2018, the owner may submit a request to the permit Director for an alternate
schedule for the submission of the above information'.
As shown in Table 1, every Duke Energy station in North Carolina either has an effective permit that
expires prior to July 14, 2018 or has a NPDES permit that has been administratively continued while the
permit is in the renewal process. Duke Energy hereby requests an alternate schedule for each of these
stations. The requested submittal date for the 316(b) information is provided in Table 1.
As indicated in Table 1, the Duke Energy stations that have an AIF greater than 125 MGD, with the
exception of Brunswick Nuclear Station, are located on reservoirs. Under the remanded Phase II 316(b)
Rule, stations located on reservoirs were not required to conduct entrainment monitoring. These
stations, therefore, will have to conduct 2-years of entrainment monitoring to complete the
§122.21(r)(9) submission. Entrainment monitoring has been conducted at the Brunswick Nuclear
Station; however, Duke Energy will need to evaluate whether the data collected is sufficient to satisfy
the requirements in the recently finalized rule.
The data collected during the 2-years of monitoring are necessary to complete the benefits valuation
study (§122.21(r)(11)); therefore, this submittal cannot be finalized until after the entrainment
monitoring is completed and results analyzed. Furthermore, the regulations require the Comprehensive
Technical Feasibility and Cost Evaluation, Benefits Evaluation and the Non -water Quality and Other
Environmental Impacts to be peer reviewed. Duke Energy estimates that approximately five years will be
needed to complete all the necessary studies and submission, based on the following:
1 year for the development of the Entrainment Characterization Study plans, which includes
preparing the plans, and review and approval of the plans by NCDENR.
— 2 years to conduct the entrainment monitoring.
1 year to complete the Entrainment Characterization Study Report, Comprehensive Technical
Feasibility and Cost Evaluation Study, Benefits Valuation Study and Non -water Quality and Other
Environmental Impacts Study.
— 1 year to complete the Peer Review.
This timeframe is very similar to the schedule presented in the proposed rule. Upon submission of the
above information, North Carolina Department of Natural Resources (NCDENR) determines what, if any,
1 Refer to § 125.95(a)(1) and (2)

controls are necessary to address entrainment. Once BTA for entrainment is determined, a compliance
schedule will be developed to complete §122.21(r)(6) Chosen Method(s) of Compliance with
Impingement Mortality Standard.
The stations with an AIF less than or equal to 125 MGD have fewer submittal requirements; however,
these stations were either not subject to the remanded rule or have undergone extensive changes to
the operation since they were last evaluated. As a result, Duke Energy will need to develop a new
submittal for each of these stations. Duke Energy will attempt to use available historical information;
however, additional field work may be needed at some sites to complete the Source Water Physical
Data and Baseline Biological Characterization Data submissions. EPA concluded that 39 months will be
adequate for facilities with an AIF less than 125 MGD to complete all the required submissions. Given
the requirements will be implemented through the NDPES permit, Duke Energy request these submittals
are due with the NPDES permit renewal applications due after July 14, 2018.
If you have any questions or comments, please contact myself at 704-382-9622 or nathan.craie@duke-
enerey.com.
Si rely, /�
c. �Y
ath n Crai
Senior Environmental Specialist
Duke Energy
Attachment

4
Table 1: 316(b) Alternate Schedule Request
Duke Energy Carolinas, LLC and duke Energy Progress, CLC
PIAMT
"Ism Nrrmdt
Cooing Method
Actual Immtaq Flow
Gnaws! 11PDE5
Requested Deb to Sew M
AntkfPebd Neat NPDES
Akemob Sdedade Request
SubMthl RaquYe+nnot sedns
Number
Etylretson Date
316(b) Infice aDom
(hemp ExpJretlon Data
welted
Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES
r(2) -qS), r(7 r(13
once -through cooling (OTC]
Permit application due after July 14, 2019. assuming a Sywr expiration date From the
r(6) to be submitted after BTA for
BRUNSWICK
NC0007D64
estuary
AIF > 125 MGD
11/30/2016
61W021
11/29/2021
expiration date of the amrent NPDES permit.
entrainment is determined
Duke Energy would like to request the 316(b) submittals to be due with the subsequem WOES
r(2) -r(S), r(7)- d13
cooling water reservoir defined as
4.5-yean from the effective
Permit appllotlon, assuming a S-year expiration date from the eMectl a date of the renewed
0) to be submitted after BTA to
OXBORO
NCW03425
waters of the U.S.
Alf from reservoir > 125 MGD
3/31/2012
date of the renewed permit
TBO
permit.
entrainment is determined
Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES
r12) -r(S), r(7)- r(13)
cooling water reservolr defined as
4.5-years from the effective
Permit application, assuming a 5-year expiration data from the effected date of the renewed
16) to be submitted after BTA for
HEVILLE
NC000D396
waters of the U.S.
Alf from resenmir > 125 MGD
12/31/2010
date of the renewed permit
781)
permit
entrainment Is determined
A renewal application was submitted rm Aug. 14. 2014. An altemate schedule request for the
316(b) submittals was submitted on Jan. 9, 2015. Duke Energy requested the 316(h) submittals
r(2) -r(5), r(7)-113)
cooling water reservolr defined as
to be due with the subsequent NPDES permit application due after July 14. 2019, assuming a 5-
d6) to be submitted after BTA fo
GUIRE
NCOD24392
waters of the U.S.
AIF from reservoir> 12S MGO
2/28/2015
W112019
2/27/2020
year expiration date from the explratlon date of the current NPDES permit.
entnl—m Is determined
An alternate schedule request was submitted with the NPDES applkatbn renewal submitted on
Oct. 9 2014. Duke Energy requested the 3161b) submittals to be due with the subsequent
r(2) -r(5), r(7)- 013)
cooling water reservoir defined as
NPDES permit renewal application due after Jury 14, 2018. assuming a Sitar expiration date
r16) to be submitted after BTA for
ALLEN
NC00O4979
waters of the U.S.
Alf from reservoir > 12S MGD
SM12015
1Z/112019
S129/Z020
From Me expiration date of the curer permit.
entrainment Is determined
An alternate sdmedulr request wes submitted with the NPDES application renewal submitted on
.
Oct. 9 2014. Duke Energy requested the 311ilb) submttab to be due with the subsequent
12) -r(SJ, r(7)- r(13
cooling water reservoir de0nad as
NPDES permit renewal application due after July 14, 2018. assuming a 5-year expiration date
r(6) to be submitted after BTA for
ARSHALL
NCO004997
waters of the U-S.
MF from reservoir> 125 MGD
4/3O/2DI5
10/31/2019
4/28/20Z0
from the expratbn dote of the current Permit.
entralmmem Is detensured
Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES
r(21 ♦(S), r(7} r(13
cooling water nn.rwlr d.AnW as
Permit application due after July 14, I011, assuming a S-year explmtlon dab from the
r(6) to be submitted after BTA for
tEWS CREEK
NC0024406
waters of the U.S.
AJF from reserwk > 125 MGD
2/28/2017
9/31/2021
2/17/2022
expiration date of the current NPDES permit.
entrainment is cltermioned
Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES
cooling pond Iclasslnotion as
Alf from coding pond > 225
4.5-years from the effective
Permit appli-tiion due after July 14, MR. assuming a S-".' expiration date from the
11TON
NCO001422
Waters of the US In review)
MGO
12/31/2016-
date of the permit
TBD
expiration date of the current NPDES permit
TRIO p a minimum r(2) - r(B)
Duke Energy would like to request the 316(b) submittals to be due with the subsegtem NPDES
closed -cycle cooling (coding
4.5-years from the effectve
Permit application, assuming a 5-yew expiration date from the effective date of the renewed
MAYO
NC0039377
towers)
Alf < 125 MGD
3/31/2012
date of the renewed permit
TBO
permit.
r(2) -48)
Duke Energy would like to request the 326(b) submittals to be due with the subsequent NPDES
closed -cycle cooling 1coollng
4.5-years from the ~hr.
Permit applkatbn, assuming a 5-year expiration date from the effective date of the renewed
EARON HARRIS
NC00395B6
tower)
Alf < 125 MGD
7/31/2011
date of the nenewed permit
TRD
permit.
r12) -r(B)
Duke Energy world like to request the 316(b) submittals to be due with the subsequent NPDES
closadcWle cooling (cooling
P. appllcaton due after July 14, 201a, assuming a S-yeor expintion date from the
CLIFFSIDE
NC00050B8
tower)
Alf <125 MG
7/31/2DIS
I/3 M2D
7/291202D
expiration date of the current NPDES permit.
Dula Energy would like to request the 316(b) submittals to be due within 3-yean of the
-
closedcyck cooling (cooling
effective date of the renewed NPDES permit Assuming an effettFm date of 9/31/2O16. this date
SUCK
NC00O4774
towers)
Alf <1Z5 MGO
313VMIS
8/31/2019
8/30/2021
ld be a/31/2019.
Duke Energy would like to request the 316(b) submittals to be due within 3-years of the
ciosedcycle cooling (cooling
-
aflecttve dot. of the renewed NPDES permit Assuming an eflectbe date of 4/3/2017, this date
DAN RIVER
NODO03468
towers)
Alf < IZS MG
4/30/2017
4/3/2020
4/29/2022
would be 4/3/2020.
rQ) -r(B
Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES
closed<vcle cooling (cooling pond
4.5iears from the ~No
permit application, assuming a Sitar expiration date from the eftect1w date of the renewed
F-LEE
NCOW 3417
no defined as watersof the U.S.)
Alf < 125 MG
5/31/2013
date of the renewed permit
TRIO
permit.
rj2) -481
A NPDES apol-tion for Sutton was submitted to NCDENR on Feb. 23, 2015. Duke Energy requested the 3161b) submittals to be due with the next NPDES permit application, assuming a 5-y.ar permit term.
The Smith Energy Complex receives water from a local municipality; therefore, the station Is not sub)ect to the rule