NC0004987_Study Plan for Fish Tissue Monitoring_20221027

�� Marshall Steam Station.
DUKE Duke Energy.
ENERGY 8320 E. Hwy 150
Terrell, NC 28682
828 478-7820
Oct. 24, 2022
NC DEQ, Division of Water Resources NC DEQ, Division of Water Resources
WQ Permitting Section — NPDES Water Sciences Section
1617 Mail Service Center 1621 Mail Services Center Raleigh, NC 27699-1617 Raleigh, NC 27699-1621 RECEIVED
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Attn: Sergei Chernikov Attn: Cyndi Karoly
O C T 2 7 2022
Subject: Duke Energy Carolinas, LLC
Marshall Steam Station NCDEQIDWRINPDES
NPDES Permit NC0004987
Study Plan for Fish Tissue Monitoring in Lake Norman Near Marshall
Steam Station
Greetings,
This transmittal includes a copy of the revised Study Plan for Fish Tissue Monitoring in Lake
Norman Near Marshall Steam Station (i.e., Sampling Plan) for review and approval by the North
Carolina Department of Environmental Quality (NC DEQ) as required by the Marshall Steam
Station NPDES Permit NC0004987. In accordance with Section A. (25.) of the permit (excerpt
below), the Sampling Plan is being submitted within 180 days from the May 1, 2022 effective
date of the reissued permit. The submitted plan is a revision of the currently NCDEQ-approved
sampling Plan dated September 2019.
"The facility shall conduct fish tissue monitoring annually and submit the results with the NPDES
permit renewal application. The objective of the monitoring is to evaluate potential uptake of
pollutants by fish tissue near the Ash Pond discharge. The parameters analyzed in fish tissue
shall be arsenic selenium, and mercury. The monitoring shall be conducted in accordance with
the Sampling Plan approved by the Division. The plan should be submitted to the Division within
180 days from the effective date of the permit. Upon approval, the plan becomes an enforceable
part of the permit."
We look forward to your review and approval of the enclosed Sampling Plan. If you have any
questions related to this submittal, please contact either Scott LaSala at 828-478-7820 or
joseph.lasaladuke-enerqy.com or Julie Stahl at 980-875-3834 or iulie.stahl(a duke-
energy.com.
1 certify, under penalty of law, that this document and all attachments were prepared under my direction of
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is,

is DUKE Marshall Steam Station.
Duke Energy.
ley ENERGY 8320 E. Hwy 150
Terrell, NC 28682
828 478-7820
to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing
violations.
Sincerely
Jeffrey FI. a.-►
General Mafiager
Marshall Steam Station
Enclosure
bc: w/attachment Don Safrit, Duke Energy EHS — Permitting & Compliance
Scott La Sala, Duke Energy EHS — Environmental Field Support
Julie Stahl, Duke Energy EHS — Surface Water Sciences
UPS - Sergei Chernikov, DWR Permitting 1Z8955X40398826392
Cyndi Karoly, DWR Water Sciences 1Z8955X40398153001

Study Plan for Fish Tissue Monitoring in Lake
Norman Near Marshall Steam Station
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MARSHALL STEAM STATION
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NPDES No. NC0004987
Duke Energy Environmental Sciences
Huntersville, NC
Octber 2022
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ENERGY

Study Plan for Fish Tissue Monitoring in Lake Norman Near Marshall Steam Station
Marshall Steam Station
Contents
1 Introduction 2
2 Site Descriptions and Sampling Areas 2
3 Target Species 2
4 Field Sampling Methods 3
5 Laboratory Processing and Elements Analysis 3
6 Data Analysis and Reporting 3
7 References 4
Figures
Figure 1. Sampling areas for monitoring trace elements in fish tissue in Lake Norman. 5
1

Study Plan for Fish Tissue Monitoring in Lake Norman Near Marshall Steam Station
Marshall Steam Station
1 Introduction
Duke Energy Carolinas(DEC; Duke Energy)owns and operates the Marshall Steam Station (Marshall)
located on Lake Norman in Catawba County,Terrell, North Carolina. Marshall's National Pollutant
Discharge Elimination System (NPDES) Permit(No. NC0004987) requires DEC to monitor annually the
trace elements arsenic,selenium, and mercury in Lake Norman fish muscle tissue to evaluate potential
uptake of pollutants near the Marshall Ash Pond discharge.This monitoring must be performed in
accordance with a study plan approved by the North Carolina Division of Environmental Quality
(NCDEQ).
Duke Energy is submitting this fish tissue monitoring study plan as required by Part I,A(25)of NPDES
Permit No. NC0004987 which became effective May 1, 2022.This study plan outlines the scope and
methodology of fish tissue monitoring in Lake Norman for NCDEQ approval. Duke Energy recognizes this
plan may require modification based on information gained during study implementation.Any such
modifications shall be subject to NCDEQ approval.
2 Site Descriptions and Sampling Areas
Target fish will be collected from two areas(UP and DI)on Lake Norman (Figure 1).Area UP is situated
between approximately 4 kilometers and 10 kilometers upstream of the Marshall discharge.Area UP is a
reference location for monitoring background trace element concentrations in fish muscle tissue.Area
DI is in the vicinity of the Marshall discharge canal for monitoring potential near-field uptake and
assimilation of elements in fish muscle tissue.The sampling areas are consistent with Marshall's
historical reference and near-field sample areas outlined in previous NCDEQ-approved study plans (Duke
Energy 2014,2018). During previous study periods,a downstream area had also been sampled (Duke
Energy 2014).This third area has been removed from this study plan because the data did not provide
appreciable insight into the element concentrations in fish tissues from Lake Norman (see Duke Energy
2021).
3 Target Species
The proposed target species are based on prior sampling experience,species availability, recreational
importance as game or food fish, and general trophic level.Attempts will be made to collect six
individual black bass(Micropterus)and sunfish (Lepomis)from each sampling area. Other similar species
may be retained if the primary target species are unavailable.
Specimens retained for individual analysis will be considered of sufficient size for human consumption
(>60 g). Where possible,the smallest individual sampled will not be less than 75%of the total length of
the largest fish within each species group,as recommended by the United States Environmental
Protection Agency(USEPA 2000). Conformance with this guideline will depend upon the availability of
size classes at a sampling area attempts.
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Study Plan for Fish Tissue Monitoring in Lake Norman Near Marshall Steam Station
Marshall Steam Station
4 Field Sampling Methods
The following active and passive gear types may be employed to efficiently collect target species: boat
electrofishing(pulsed DC current), hoop nets, gill nets, angling, and trotlines. Standard sampling
methods will be used for each gear type as outlined in the American Fisheries Techniques Manual (Zale
et al. 2012). Nets and trotlines will be checked at approximately 24-hour intervals during the sampling
period.
Individual fish retained for trace elements analysis will be identified to species, measured for total
length to the nearest millimeter,weighed to the nearest gram, marked with a unique tag identifier, and
immediately placed in a labeled (date,transect,station, etc.) bag. Bags of fish will then be stored on ice
while in the field. Samples will be processed (see Section 5.0 ) or frozen within 24 hours of sample
collection. Only fresh fish that exhibit no external signs of deterioration will be retained for analysis. Fish
that have visible, open wounds that could allow contamination will not be retained. Sample bags will be
labeled with sample location and sample date.
Sampling and fish collections will follow the appropriate Duke Energy environmental services field
procedures including ESFP-SW-0200 Electrofishing Field Procedure, ESFP-SW-0202 Netting Field
Procedure, ESFP-SW-0210 Angling Procedure, and ESFP-SW-0600 Trace Elements Field Procedure.
5 Laboratory Processing and Elements Analysis
Fish muscle tissue will be processed in the laboratory for metals analysis according to the most current
version of Duke Energy environmental services field procedures ESFP-SW-0601 Trace Element Sample
Preparation and ESFP-SW-0602 Trace Element Analysis Procedure.The approved Standard Operating
Procedure is on file with NCDEQ as part of Duke Energy's biological certification. Sample custody and
tracking of samples will be performed using chain-of-custody forms. Quality of vendor laboratory data, if
applicable, will be ensured with National Institute of Standards and Technology tissue standards.The
residual processed sample will be archived for at least two years in the event re-analysis is needed.
6 Data Analysis and Reporting
Arsenic, mercury, and selenium concentrations resulting from individual fish tissue analyses will be
converted to µg/g fresh weight and evaluated against the USEPA screening values. Results and
evaluation of samples collected during the permit period will be presented in a Fish Tissue Monitoring
report.The report will be submitted to the NCDEQ with the subsequent NPDES permit renewal
application as required by the current NPDES Permit (No. NC0004987).
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Study Plan for Fish Tissue Monitoring in Lake Norman Near Marshall Steam Station
Marshall Steam Station
7 References
Duke Energy. 2014. Marshall Steam Station: Monitoring of Arsenic, Selenium, and Mercury in Fish Tissue
from Lake Norman, NC. (2014). Duke Energy, Huntersville, NC.
Duke Energy. 2018. Fish Tissue Monitoring of Lake Norman Study Plan. Duke Energy. Huntersville, NC.
Duke Energy. 2021. Marshall Steam Station: Fish Tissue Monitoringof Lake Norman. 2015-2020 . Duke
gY ( )
Energy, Huntersville, NC.
USEPA. 2000. Guidance for assessing chemical contaminant data for use in fish advisories,vol. 1. Fish
sampling and analysis, third edition. EPA 823-B-00-007. US EPA, Office of Water. Washington,
DC.
Zale, A.V., D.L. Parrish, and T.M. Sutton, editors. 2012. Fisheries techniques, third edition. American
Fisheries Society. Bethesda, MD.
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Study Plan for Fish Tissue Monitoring in Lake Norman Near Marshall Steam Station
Marshall Steam Station
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Figure 1. Sampling areas for monitoring trace elements in fish tissue in Lake Norman.
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