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Home My WebLink AboutNC0024392_ECSP_20160909DUKE ENERGY. May 2, 2016 Mr. Charles H. Weaver Jr. North Carolina Department of Environmental Quality Division of Water Resources NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Duke Energy McGuire Nuclear Station 12700 Hagen Feny Road lluntersville, NC 28078 RECc!`dEf� idCi!cQJCNIVR MAlf () 9 JIE Water Quality Perrnitting Section Subject: McGuire Nuclear Station - NPDES Permit NCO024392 Draft 316(b) Entrainment Characterization Study Plan (ECSP) Dear Mr. Weaver The final 316(b) rule for existing facilities requires facilities with an actual intake flow (AIF) greater than 125 MGD to complete §122.21(r)(9) Entrainment Characterization Study, which requires a minimum of two years of entrainment data collection. The enclosed Entrainment Characterization Study (ECSP) describes the sampling design and site-specific approach to be used at McGuire Nuclear Station to fulfill the entrainment sampling requirements of §122.21(r)(9). While not required to undergo a peer -review, drafts of the ECSP were sent to subject matter experts in fisheries biology for an independent review. The enclosed document includes the comments from the independent review and Duke Energy's responses to those comments. Duke Energy welcomes any comments from North Carolina Department of Environmental Quality (NCDEQ) on the ECSP. If comments are not received within 30 -days, Duke Energy will assume the ECSP is satisfactory. If you have any questions or comments, please contact Nathan Craig at nathan.craigcu)duke- energy.com or 704-382-9622 or John Williamson at 980-875-5894. Sincerely, Steven D. Capps Duke Energy McGuire Nuclear Station Site Vice President Enclosure FN RECEIVEMCDEG;'DWR MAY 0 9 2LJi6 Water nua!ity Permitting Section Entrainment Characterization Study Plan Prepared for: DUKE ENERGY Prepared by: HDR Engineering, Inc. April 25, 2016 Entrainment Characterization Study Plan McGuire Nuclear Station Contents 1 Introduction.................................................................................................................... 1.1 Regulatory Background........................................................................................ 1.2 Study Plan Objectives and Document Organization .............................................. 2 Generating Station Description...................................................................................... 2.1 Source Waterbody................................................................................................ 2.1.1 Lake Norman........................................................................................... 2.2 Station and Cooling Water Intake Description....................................................... 2.2.1 Intake Structures...................................................................................... 2.2.1.1 Surface Intake (Upper Level Intake Structure) ......................................... 2.2.1.2 Subsurface Intake (Low Level Intake Structure) ....................................... 3 Historical Studies........................................................................................................... 4 Threatened and Endangered Species............................................................................ 5 Basis for Sampling Design............................................................................................. 6 Entrainment Characterization Study Plan....................................................................... 6.1 Introduction.......................................................................................................... 6.2 Sample Collection................................................................................................. 6.2.1 Location................................................................................................... 6.3 Sample Sorting and Processing............................................................................ 6.4 Data Management..................................................................................... 6.5 Data Analysis............................................................................................ 6.6 Field and Laboratory Audits....................................................................... 6.7 Laboratory Quality Control......................................................................... 6.8 Reporting.................................................................................................. 6.9 Safety Policy............................................................................................. 7 References ......................................................................................................... FN ................ 1 ................ 1 ................ 3 ................ 3 ................ 4 ................ 4 ................ 6 ....... I........ 6 ................ 6 ................ 8 1........I.... 10 .............. 10 .............. 11 .............. 15 .............. 15 .............. 16 .............. 17 .............. 22 .............. 23 .............. 23 .............. 24 .............. 25 .............. 25 .............. 25 .............. 26 APPENDIX 1 — Select Species Spawning and Early Life History Data .................................................... 27 APPENDIX B — Response to Informal Review Comments...................................................................... 31 APPENDIX C — Comparison of Pumps and Nets for Sampling Ichthyoplankton...................................... 39 Duke Energy I i Entrainment Characterization Study Plan McGuire Nuclear Station Tables FN Table 1-1. §316(b) Rule for Existing Facilities Submittal Requirements Summary....................................2 Table 2-1. McGuire Nuclear Station Design Intake Flow Rate by Unit and Average Daily Water Withdrawal from Lake Norman, 2013-2014..............................................................................................6 Table 5-1. Advantages and Disadvantages of Hoop Nets or Towed Ichthyoplankton Nets and Pumped Samplers for Estimating Ichthyoplankton Density in Cooling Water Intake Structures (some information adaptedfrom EPRI 2014)...................................................................................................................... 13 Table 5-2. Summary of Approach for Development of §122.21(r)(9) Required Entrainment Characterizations................................................................................................................................... 15 Table 6-1. Entrainment Sampling Details lit: Table A-1. Life Histories of Selected Species Expected to be Present near McGuire Nuclear Station ..... 28 Table B-1. Directed Charge Questions Table B-2. Peer Reviewer Responses to Directed Charge Questions 31 33 Table C-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for Estimating Ichthyoplankton Density in Cooling Water Intake Structures (some information adapted from EPRI 2014) _.. _ _..... ......... _........... . ............................................................................................... 41 Table C-2. Total Number (N) and Mean Densities (MD) (mean number of shad/ 1,000 m) of All Shad Collected with Comparison Gear and Shad <28 mm Total Length Collected with a Tucker Trawl on Lake Norman, North Carolina, 6-10 June 1982, with Average Volume of Water Filtered per Sample (m3) (Leonard and Vaughn 1985).................................................................................................................. 50 Table C-3. Summary of Major Studies Designed to Comparatively Evaluate the Sampling Efficiency of Various Large -Volume Pumps and Tow Nets (Taggart and Leggett 1984) .............................................. 52 Duke Energy I ii Entrainment Characterization Study Plan McGuire Nuclear Station Figures FN Figure 2.1. McGuire Nuclear Station Vicinity Map (Source: Duke Energy undated)...................................5 Figure 2-2. Plan View of McGuire Nuclear Station CWIS (Source: Alden 2004) ........................................7 Figure 2-3, Section View of McGuire Nuclear Station Shoreline Intake Structure (Source: Alden 2004) .... 7 Figure 2-4. Site Configuration of McGuire Nuclear Station (Source: Duke Energy undated) ...................... 9 Figure 4.1. Geographical Boundary of the IPAC Search......................................................................... 11 Figure 6-1. Schematic of Floatation and Anchoring System for In -Water Sampler Deployment at McGuire NuclearStation......................................................................................................................................18 Figure 6-2. In -water Sampler Shown Prior to Its Installation...................................................................19 Figure 6-3. Proposed Location for Collection Tank and Pump and Associated Piping to the Sampling LocationUpstream of Unit 2................................................................................................................... 20 Figure 6-4. Example Entrainment Pump Sampling System Configuration...............................................21 Duke Energy I iii Entrainment Characterization Study Plan McGuire Nuclear Station Acronyms and Abbreviations FN °C........................................................................................................................ degrees Celsius ° ................ degrees Fahrenheit AIF..................................................................................................................Actual Intake Flow AOQL..........................................................................................Average Outgoing Quality Limit BTA.................................................................................................... Best Technology Available CCW.................................................................................................... Condenser Cooling Water cfs............................................................................................................... cubic feet per second CSP................................................................................................... Continuous Sampling Plan CWIS.......................................................................................... Cooling Water Intake Structure DIF................................................................................................................. Design Intake Flow Director ................................................National Pollutant Discharge Elimination System Director Duke Energy................................................................................... Duke Energy Carolinas, LLC EI................................................................................................................................... Elevation ECSP...........................................................................Entrainment Characterization Study Plan EPRI....................................................................................... Electric Power Research Institute gpm.................................................................................................................gallons per minute HDR......................................................................................................... HDR Engineering, Inc. LLI...................................................................................................................... Low Level Intake 3 m'.............................................................................................................................. cubic meter MW............................................................................................................................... Megawatt PM............................................................................................................. micrometer or micron mm............................................................................................................................... millimeter MGD....................................................................................................... Million Gallons per Day MIL-STD............................................................................................................ Military -Standard NPDES............................................................ National Pollutant Discharge Elimination System Normandeau................................................................................. Normandeau Associates, Inc. NRC........................................................................................... Nuclear Regulatory Commission QA.................................................................................................................. Quality Assurance QC........................................................................................................................ Quality Control RTE.........................................................................................Rare, Threatened, or Endangered SOP............................................................................................ Standard Operating Procedure ULI.................................................................................................................. Upper Level Intake Duke Energy 11v Entrainment Characterization Study Plan L�i McGuire Nuclear Station r ` 1 Introduction 1.1 Regulatory Background The Clean Water Act was enacted in 1972 and introduced the National Pollutant Discharge Elimination System (NPDES) permit program. Facilities with NPDES permits are subject to §316(b) of the Act, which requires that the location, design, construction and capacity of cooling water intake structures (CWIS) reflect best technology available (BTA) for minimizing adverse environmental impacts. Cooling water intakes can cause adverse environmental impacts by drawing early life -stage fish and shellfish or their eggs into and through cooling water systems (entrainment) or trapping juvenile or adult fish against the screens at the opening of an intake structure (impingement). On August 15, 2014, the final §316(b) rule for existing facilities was published in the Federal Register. The rule applies to existing power generating facilities with design intake flows (DIF) that withdraw more than 2 million gallons per day (MGD) from waters of the United States, use at least 25 percent of that water that they withdraw exclusively for cooling purposes, and have or require an NPDES permit. The final rule supersedes the Phase II rule, which regulated large electrical generating facilities until it was remanded in 2007, and the remanded existing -facility aspects of the previously promulgated Phase III rule. The final rule became effective on October 14, 2014. Facilities subject to the new rule are required to develop and submit technical material, identified at §122.21(r)(2)-(14), that will be used by the NPDES Director (Director) to make a BTA determination for the facility (Table 1-1). The specific information required to be submitted and compliance schedule are dependent on actual intake flow rates (AIF) at the facility and NPDES permit renewal date. Existing facilities with an AIF ? 125 MGD are required to address both impingement and entrainment and provide explicit entrainment studies which may involve extensive field and economic studies (§122.21(r)(9)-(13)). Existing facilities with AIF < 125 MGD have fewer application submittals. For such facilities, the Director must still determine a BTA for entrainment on a site-specific basis and the applicant may supply information relevant to the Director's decision. Facilities are required to submit §316(b) application materials to their Director along with their next permit renewal, unless that permit renewal takes place prior to July 14, 2018, in which case an alternate schedule may be negotiated. Duke Energy Carolinas, LLC's (Duke Energy) McGuire Nuclear Station is subject to the existing facility rule an, based on its current configuration and operation, is anticipated to be required to develop and submit each of the §122.21(r)(2)-(13) submittal requirements with its next permit renewal in accordance with the rule's technical and schedule requirements. Within the §122.21(r)(2)-(13) requirements, (r)(4), (7), (9), (10) and (11) have specific requirements related to entrainment evaluations (refer to Table 1-1 for additional detail). This document provides an Entrainment Characterization Study Plan (ECSP) to support §316(b) compliance at the facility with consideration of these specific requirements. As a part of development of this Study Plan, Duke Energy submitted an earlier draft of this document to review by a subject matter expert in the field of fisheries (see Appendix B) and identified to the State as a peer reviewer. Duke Energy I 1 Entrainment Characterization Study Plan McGuire Nuclear Station FN While the equipment and methods contained in this Study Plan were developed with the intent to be implemented as written, changes to the Study Plan may be required based on facility requirements and/or situations encountered during execution. Table 1-1. §316(b) Rule for Existing Facilities Submittal Requirements Summary (2) Source Water Characterization of the source water body including intake area of influence Physical Data (3) Cooling Water Intake Characterization of cooling water system; includes drawings and narrative; description of operation; Structure Data water balance Source Water Characterization of biological community in the vicinity of the intake; life history summaries; (4) Baseline Biological susceptibility to impingement and entrainment; must include existing data; identification of missing Characterization data data; threatened and endangered species and designated critical habitat summary for action area; Standard identifies fragile fish and shellfish species list (<30 percent impingement survival) Cooling Water Narrative description of cooling water system and intake structure; proportion of design flow used; (5) System Data water reuse summary; proportion of source water body withdrawn (monthly); seasonal operation summary; existing impingement mortality and entrainment reduction measures; flow/MW efficiency Chosen Method of Provides facility's proposed approach to meet the impingement mortality requirement (chosen from Compliance with (6) seven available options); provides detailed study plan for monitoring compliance, if required by Impingement Mortality selected compliance option; addresses entrapment where required Standard Entrainment Provides summary of relevant entrainment studies (latent mortality, technology efficacy); can be (7) Performance studies from the facility or elsewhere with justification; studies should not be more than 10 years old without justification; new studies are not required. Provides operational status for each unit; age and capacity utilizations for the past five years; (8) Operational Status upgrades within last 15 years; uprates and Nuclear Regulatory Commission relicensing status for nuclear facilities; decommissioning and replacement plans; current and future operation as it relates to actual and design intake flow Requires at least two years of data to sufficiently characterize annual, seasonal, and diel variations in entrainment, including variations related to climate, weather, spawning, feeding, and water column migration; facilities may use historical data that are representative of current operation of the facility and conditions at the site with documentation regarding the continued relevance of the data Entrainment (9) Characterization to document total entrainment and entrainment mortality; includes identifications to the lowest taxon Study possible; data must be representative of each intake; must document how the location of the intake in the water body and water column are accounted for; must document intake flows associated with the data collection; documentation in the study must include the method in which latent mortality would be identified (including QAQC); sampling and data must be appropriate for a quantitative survey Comprehensive (10) Technical Feasibility Provides an evaluation of technical feasibility and incremental costs of entrainment technologies; & Cost Evaluation Net Present Value of facility compliance costs and social costs to be provided; requires peer review Study Provides a discussion of monetized and non -monetized water quality benefits of candidate entrainment technologies from (r)(10) using data in (r)(9); benefits to be quantified physical or Benefits Valuation biological units and monetized using appropriate economic valuation methods; includes changes in (11) Study fish stock and harvest levels and description of monetization; must evaluate thermal discharges, facility capacity, operations, and reliability; discussion of previous mitigation efforts and affects; benefits to environment and community; social benefits analysis based on principle of willingness -to - pay; requires peer review Non -Water Quality Provides a discussion of non -water quality factors (air emissions and their health and environmental 12 Environmental and ( ) Other Impacts impacts, energypenalty,thermal discharge, noise, safety,rid reliability,consumptive water use, g g p Assessment etc.) attributable to the entrainment technologies; requires peer review Duke Energy 1 2 Entrainment Characterization Study Plan L��i McGuire Nuclear Station r ` DescriptionsSubmittal Requirements I Submilitaill Documentation of external peer review, by qualified experts, of submittals (r) (10), (11), and (12). (13) Peer Review Peer Reviews must be approved by the NPDES Director and present their credentials. The applicant must explain why it disregarded any significant peer reviewer recommendations. (14) New Units Identify the chosen compliance method for the new unit 1.2 Study Plan Objectives and Document Organization The ECSP is developed to support McGuire Nuclear Station's §316(b) compliance through development of a site-specific plan with the following key objectives in mind: 1. Collect data to support development of §122.21(r)(9) which requires at least two years of entrainment studies be conducted at the facility; 2. Collect data to support development of §122.21(r)(7) which allows for summaries of relevant technology efficacy studies conducted at the facility; and 3. Collect data to support Duke Energy's objective of having data sufficient to evaluate biological efficacy of potential alternative intake technologies that may require site specific evaluations and support social cost -benefit analyses as a part of the §122.21(r)(10)-(12) compliance evaluations While not a primary objective, the entrainment data gathered will help support the development of §122.21(r)(4) which requires characterization of the biological community in the vicinity of the CW IS that includes a listing of species and life stages most susceptible to entrainment at the facility. To meet these objectives, this document provides summaries of the station's configuration and operation (Section 2), historical biological sampling efforts conducted at the facility that are relevant to cooling water intake evaluations (Section 3), a summary of Threatened and Endangered Species identified near the facility (Section 4), a sampling program design based on this information (Section 5), recommended study methods including gear type, schedule, frequency, and quality control procedures (Section 6), references cited (Section 7), life history information on species likely to be entrained that supports reducing the sampling period from 12 -months per year to 8 -months per year (Appendix A), documentation of the subject matter expert review of an earlier draft of this study plan (Appendix B), and a white paper on the use of pumped samplers in entrainment monitoring (Appendix C). 2 Generating Station Description This section presents background information on the source waterbody (Lake Norman) from which McGuire Nuclear Station withdraws cooling water and details the design and operation of the CW IS. Duke Energy 1 3 Entrainment Characterization Study Plan McGuire Nuclear Station 2.1 Source Waterbody 2.1.1 Lake Norman FN McGuire Nuclear Station is located on Lake Norman, an impoundment of the Catawba River formed by the Cowans Ford Dam in 1963 (Figure 2.1). The Catawba River Basin lies in the south-central portion of western North Carolina and originates in the eastern slopes of the Blue Ridge Mountains in Old Fort, McDowell County, North Carolina. From its source, the Catawba River flows eastward, then southward toward the City of Charlotte. The Catawba River Basin and the Broad River Basin join to form the headwaters of the Santee -Cooper River system. Lake Norman and the Cowans Ford Dam are part of the Catawba Chain of Lakes system formed by 11 Duke Energy hydroelectric dams. Construction of the hydroelectric developments on the Catawba River began in the early 1900s. Cowans Ford Dam on Lake Norman was the final hydroelectric power plant completed in 1963. Lake Norman is the largest reservoir in the chain of lakes and is situated between Lookout Shoals Lake to the north and drains into Mountain Island Lake to the south. The surface area of Lake Norman is approximately 32,510 acres, its mean depth is 33.5 feet, and it drains a 1,790 -square mile watershed (NCDENR 2003). Lake Norman is 34 miles long from the tailrace of Lookout Shoals Lake downstream to Cowans Ford Dam (NCDENR and NCWRC 2001).Other power generating facilities on Lake Norman are the 325 -megawatt (MW) Cowans Ford Hydroelectric Station and the 2,078 -MW Marshall Steam Station in Sherrills Ford, North Carolina, located 16 miles upstream from McGuire Nuclear Station. Duke Energy 1 4 Entrainment Characterization Study Plan McGuire Nuclear Station 1 / N Ili Wx AIR NC - -- --- -- NC -- 'rte S -- Legend tv 20 Miles Figure 2.1. McGuire Nuclear Station Vicinity Map (Source: Duke Energy undated) Duke Energy 1 5 Entrainment Characterization Study Plan L�i McGuire Nuclear Station r ` 2.2 Station and Cooling Water Intake Description McGuire Nuclear Station consists of two nuclear -fired units with a combined electric generating capacity of 2,278 MW. Unit 1 and Unit 2, each rated at 1,139 MW began commercial operation in 1981 and 1984, respectively. McGuire Nuclear Station uses a once -through cooling system that operated between 85 and 90 percent between 2013 and 2014 (Table 2-1). Cooling water for McGuire Nuclear Station is withdrawn from Lake Norman through a dual intake system with surface and subsurface structures. Table 2-1. McGuire Nuclear Station Design Intake Flow Rate by Unit and Average Daily Water Withdrawal from Lake Norman, 2013-2014 1 1,302 1,274 1,211 2 1,302 1,373 1,284 Service Water 22 12 24 (RN) Facility 2,626 2,659 2,519 2.2.1 Intake Structures 2.2.1.1 Surface Intake (Upper Level Intake Structure) The Upper Level Intake (ULI) structure is located in a man-made embayment approximately 2,400 feet east of Cowans Ford Dam (Duke Energy undated). The ULI structure withdraws water from between elevation 715 feet and 745 feet. McGuire Nuclear Station has two power generating units with four condenser cooling water pumps per unit (Figure 2-2). There are two traveling screens per pump, for a total of 16 screens (Figure 2-3). The intake screens are backwashed with untreated lake water on an intermittent basis. The cleaning frequency is determined by the amount of debris on the screens (typically once per week). Screen wash water is returned to Lake Norman at the intake bay (Duke Energy 2009). During the summer all four pumps in each unit are used when the facility operates at near 100 percent capacity and the intake water temperatures are at their warmest. Three pumps may be used during the winter when colder intake water temperatures are prevalent (Duke Energy 2014). Condensers are cleaned with an Amertap system. There are eight Amertap pumps per unit (Duke Energy 2014). Asiatic clams are a concern in sections of the main condenser cooling water system (Duke Energy 2014). Figure 2-4 illustrates the site configuration and location of the intake structures. Duke Energy 1 6 Entrainment Characterization Study Plan McGuire Nuclear Station 1 'figure 2-2. Plan View of McGuire Nuclear Station CWIS (Source: Alden 2004 FN Figure 2-3. Section View of McGuire Nuclear Station Shoreline Intake Structure (Source: Alden 2004) Duke Energy 1 7 Entrainment Characterization Study Plan L�i McGuire Nuclear Station r ` 2.2.1.2 Subsurface Intake (Low Level Intake Structure) The Low Level Intake (LLI) structure is located near the base of the dam (Figure 2-4) and withdraws water from between elevation 654 feet and 670 feet (Duke Energy undated). There are three screen panels with 3/ -inch mesh (fish fence) with a cross-sectional area of 1,700 square feet. The LLI structure is designed to take cool water from the lower level of Lake Norman and mix it with warmer water at the ULI structure during the warmer summer months. The original LLI design could supply cooling water to both Units 1 and 2. The three LLI pumps supplying water to Unit 2 have since been retired. The three remaining LLI pumps supply cooling water to Unit 1 by discharging upstream of the traveling water screens located near four circulating water pumps. Each LLI pump is rated at 216 MGD (150,000 GPM). During 2 -pump operation, the LLI structure provides 432 MGD of cooling water to Unit 1. During 3 -pump operation, the LLI structure provides 648 MGD of cooling water to Unit 1. LLI pump operation is coordinated with Marshall Steam Station since both stations can access the hypolimnion. Duke Energy has an agreement with NC Wildlife Resources Commission to operate the LLI as needed to meet NPDES thermal discharge limits contingent upon suitable water quality for fish habitat. When dissolved oxygen is less than 2 milligrams per liter and water temperature is greater than 70 degrees Fahrenheit (°F) (i.e., suitable fish habitat is no longer available) and fish have moved out of the immediate area, Duke Energy can operate the LLI pumps as needed. In recent years, the LLI pumps have operated 4-7 days per year (typically during the warmer summer months) for thermal compliance and have not been used for thermal efficiency gains. Duke Energy 1 8 Entrainment Characterization Study Plan McGuire Nuclear Station tow peva _� I 1 r S•.tutture ''�� J',. -;Unit. t• _�_J; r' t 4 Nuclear tt 1 t •\it �- Conventional Station •, t Wastewater _ { t Treatmen:System Standby Nuclei r % Wastewater Service Water Pond `� I^ Collection f i 1I Basin (" _ �.' Imo-'"= =�:-s•.y,�.+�s�_J / �-f `I - _ _ _ - - - r � { ' 't` 11 525kV 1 Swnchyard !I I 230kV t __ I — ` Switchyard { 500 0 500 1000 Feet r , FN Figure 2-4. Site Configuration of McGuire Nuclear Station (Source: Duke Energy undated) Duke Energy 1 9 N � ' ;p R RaS.uS ta- -yi'n 4,- *a. - -i iLake_ Norman Cowan r Low Level r =-__ _��•,, /J��•-` Discharge Canal t Dord •' Intake Upper�\"��/////// j -- __ --- -^-� _-• ii-, _r ---Structure p�qk inta a \ f i Structure �•'� �— - Discharge Structure tow peva _� I 1 r S•.tutture ''�� J',. -;Unit. t• _�_J; r' t 4 Nuclear tt 1 t •\it �- Conventional Station •, t Wastewater _ { t Treatmen:System Standby Nuclei r % Wastewater Service Water Pond `� I^ Collection f i 1I Basin (" _ �.' Imo-'"= =�:-s•.y,�.+�s�_J / �-f `I - _ _ _ - - - r � { ' 't` 11 525kV 1 Swnchyard !I I 230kV t __ I — ` Switchyard { 500 0 500 1000 Feet r , FN Figure 2-4. Site Configuration of McGuire Nuclear Station (Source: Duke Energy undated) Duke Energy 1 9 Entrainment Characterization Study Plan McGuire Nuclear Station 3 Historical Studies FN No ongoing or historical entrainment studies have been performed at the McGuire Nuclear Station. However, Duke Energy conducted a historic estimate of entrainment. The estimate was based on the species composition collected biweekly during periods when larval fish were present between 1974 and 1977 (NRC 2002). Species known to spawn in the McGuire Nuclear Station's intake cove are Threadfin Shad (Dorosoma petenense), Yellow Perch (Perca flavescens), Bluegill (Lepomis macrochirus), and crappie (Pomoxis spp.). Larvae were collected in the upper intake area, at a depth of 15 m (49 ft). Ichthyoplankton losses to entrainment were primarily Threadfin Shad eggs and larvae. Entrainment losses have not had measurable effect on the Threadfin Shad due to this species' high fecundity and the presence of suitable spawning habitat outside the influence of the intake structures. Most fish species that reside near the McGuire Nuclear Station spawn in shallow shoreline areas and produce demersal adhesive eggs that would not be subject to entrainment. During the warmer summer months, the LLI pumps can supply 15 to 22 percent (i.e., 2 -pumps or 3 -pumps operating, respectively) of McGuire Nuclear Station's cooling water needs using cooler water from the hypolimnion. It is noted, however, that the LLI pumps are only used approximately 4 — 7 days per summer, on average. Larval fish entrainment is expected to be reduced when the LLI pumps are operational because few ichthyoplankton are present in the cold and low -oxygen waters of the hypolimnion. 4 Threatened and Endangered Species The U.S. Fish and Wildlife's (USFWS) map -based search tool (Information for Planning and Conservation; IPAC) was consulted to generate a resource report and determine the potential presence of Federally -listed species within Lake Norman and the surrounding land (Figure 4-1; USFWS 2016). The only aquatic species identified was the endangered Carolina Heelsplitter (Lasmigona decorata). However, the Carolina Heelsplitter is usually found in mud, muddysand, or muddy gravel substrates along stable, well -shaded stream banks (USFWS 1996). The habitat near McGuire's intake is not suitable to Carolina Heelsplitter and it is not anticipated to reside anywhere near the McGuire CWIS. Duke Energy 1 10 Entrainment Characterization Study Plan McGuire Nuclear Station Figure 4.1. Geographical Boundary of the IPAC Search 5 Basis for Sampling Design FN HDR Engineering, Inc. (HDR) and Normandeau Associates, Inc. (Normandeau) participated in a site visit to the McGuire Nuclear Station on April 21, 2015 to evaluate potential entrainment sampling options at the CWIS and to determine if pumped samples from the CWIS would be a practicable sampling method based on best professional judgment and previous experience with entrainment sampling. Sampling in the intake was selected over sampling at the discharge. Sampling at the intake with a pumped sampler minimizes damage to or loss of organisms that can occur if samples are collected at the discharge side of the condenser cooling water system. In addition, properly designed and operated pumped systems have shown collection efficiency of 95 percent or greater for fish eggs and larvae with little or no organism damage (EPRI 2014). Sampling the discharge at McGuire was not deemed feasible because of the submerged discharge into the canal. Two primary methods that have been historically used to estimate ichthyoplankton entrainment at power plant intakes are utilizing streamed/towed nets and collecting pumped samples. Traditional ichthyoplankton nets can be used to filter water as it enters the intake. These nets can be streamed in or towed through the flows entering the intake to collect organisms. Alternatively, pumps can be used to convey water from the intake structure to a fine -mesh net onshore. Onshore nets are suspended in a buffering tank to minimize damage and extrusion of eggs and larvae. Duke Energy 1 11 Entrainment Characterization Study Plan FN Nuclear Station Each method has advantages and disadvantages and a comparison of the two methods are summarized in Table 5-1. Pumped sampling was selected as the preferred sampling method for the McGuire Nuclear Station. The primary advantages of utilizing pumps at this location include metering precise sample flows, longer sample collection times, reduce the potential to miss samples due to inclement weather or other events, and increase the ability for technicians to safely observe net filtering and other aspects of the data collection. Pumped samplers are among the preferred gear types accepted by the EPA and have been used extensively to successfully monitor entrainment at power plant intakes for decades (see Appendix C). Their versatility includes being utilized in fresh, estuarine, and marine water environments. Properly designed and operated systems can be accurate and effective. While no sampling method is perfect, we believe pumped samplers offer the best, most cost-effective, and consistent sampling method available for McGuire Nuclear Station. Duke Energy 1 12 Entramment characterization Study Plan McGure Nuclear Station 0 Table 5-1. Advantages and Disadvantages of Hoop Nets or Towed Ichthyoplankton Nets and Pumped Samplers for Estimating Ichthyoplankton Density in Cooling Water Intake Structures (some information adapted from EPRI 2014) 4 T , r'. Can be difficult to deploy and retrieve in the confined space of intake structures — precludes the use of some net types (e.g., standard bongo. neuslon nets. or Tucker trawls). Depending on deployment method, may require mod cations to intake structures (e.g., frame - mounted nets in frame guides). - Less precise flow metering than pumped samplers. Large volumes are sampled quickly — capturing less temporal variability as compared to pumped Large volumes are sampled quickly (less manpower required for the same number of pumped samples. Hoop Nets Deployed in the Intake or samples). Relatively small nets needed to fit in the intake structure offer a small spatial sample. Multiple nets Towed Upstream d the Intake _ If net frames are not used, then there is limited to no modifications to the intake required for can be used to increase sampled area at the cost d additional samples to be processed in the deployment. laboratory. No potential for mechanical damage associated with pump passage. Tow speeds in the range of 1-2 meters per second (commonly used during ichthyoplanklon sampling) is above the intake velocities at the majority of intakes. Some active avoidance possible by larger motile fife stage (e.g., late larvae and early juvenile). Larger hoops can be used to decrease potential for avoidance, but would require a larger deployment area, since length is proportional to opening diameter in property sized nets'. Greater potential for extrusion than pumped samples (no buffering tank). Boat deployed nets are subject to weather delays and associated safety concerns. - 11X1 m samples are collected over roughly 2 hours increasing the potential to capture temporal variability in ichthyoplankton densities not observed in net samples. Limited modRcabons to intake structures are required to install — usually just anchoring points for the sample pipe. In-line flow metering offers greater precision in measuring the volumes of flow sampled. Some active avoidance possible by larger motile life stage (e.g., late larvae and early juvenile). Some potential for mechanical damage. However, correctly designed systems can offer <5% Improperly designed samplers can lead to damage to organisms during sampling. Pumped Samplers in the Intake damage or destruction of eggs and larvae. Samples a smaller portion of the spatial variability, because pump inlets are generally smaller than Fixed pipe allows precise control over water depth and orientation to intake flows. net openings. Less potential for extrusion than nets, because the filtering net sits in a buffering tank. Lower potential for missed samples due to severe weather. Allows technicians to observe sample collections and minimize potential for invalid samples (e.g., use of 330 -um nets increases potential for net occlusion and frequent net change olds may be required during certain times of the year). ' A general rule of thumb, as described in EPRI 2014states that the total effective open area of the netting (percent open area x area of netting) should be at least twice the area of the net mouth opening. Others have suggested a net length to mouth opening diameter ratio of three or more. Duke Energy 1 13 Entrainment Characterization Study Plan L�i McGuire Nuclear Station r ` Despite some potential disadvantages, pumped samples collected at the intake structure remains a better option than sampling at the discharge structure because: (1) organisms will be less damaged due to passage through the plant (resulting in a higher probability of taxonomic identification); (2) access to the intakes is easier logistically; (3) lower velocities will result in less extrusion of larvae and/or damage to nets; and (4) safety issues and inclement weather will not be major factors resulting in lost sampling dates. The recommended approach for McGuire Nuclear Station (described in greater detail in Section 6), is to pump water from the forebay of the intake structure which allows the sampled water to come from the portion of the water column subject to station withdrawals. The sampling system will utilize a rigid pipe with three orifices that will allow simultaneous withdrawal from just below the bottom of the curtain wall (— EI. 750), near the bottom of the intake structure (— EI. 720), and a point mid -way between the other two (-- El. 735). The approach to deploy the in -water samples will utilize an anchoring and floatation system which eliminates the need for structural modifications in order to secure the in -water sampler to the intake structure'. Entrainment sampling will be conducted twice per month between March 1 and October 31 in 2016 and 2017. This period corresponds to when fish eggs and larvae are likely present in Lake Norman based on spawning characteristics of the species most likely to be entrained (see Appendix 1). To account for potential shifts in spawning time periods, the sampling program will be performed adaptively in response to entrainment densities. For example, if the densities of entrainable organisms remain high during October 2016 sampling, additional sampling events will be added to the program in 2016 and the sampling period in 2017 will be extended accordingly. Similarly, if densities of entrainable organisms are high in early March 2016 when the program is initiated, the 2017 sampling plan will be extended to begin earlier (e.g., February). As a result, the adaptive management plan will provide the greatest potential to collect representative samples throughout the entrainment season. Each sample collection event will be conducted over a 24-hour period with sample sets collected in four, 6 -hour intervals resulting in eight discrete samples per month. The sample frequency selected for this entrainment study will provide fish taxa, density distribution, and seasonal/diel variation data over a two year period. Factors important to meeting the §122.21(r)(9) requirements, along with a basis for how those requirements will be addressed for McGuire Nuclear Station are summarized in Table 5-2. ' Nuclear regulations require an extensive review for any modification to nuclear safety related equipment, which includes the cooling water intake structure. These reviews can take up to three -years to complete. Given the timeframe and two-year duration of the entrainment sampling, alternatives avoiding intake modifications were preferable Duke Energy 1 14 Entrainment Characterization Study Plan McGuire Nuclear Station FN Table 5-2. Summary of Approach for Development of §122.21(r)(9) Required Entrainment Characterizations .r e IWIIIIIIIIIIIII 1 .1911 a 1 I I!;; it 41111111111111111 Two years of data and annual Evaluation of species and life stage composition and densities based variation on March through October 2016 (Year 1) and March through October 2017 (Year 2) entrainment studies Seasonal variation Evaluation of monthly species and life stage compositions based on the Year 1 and Year 2 studies; Diel variation Evaluation of densities in 6 -hour intervals in the Year 1 and Year 2 studies Variation related to climate and Evaluation of Year 1 and Year 2 data relative to water temperature weather and weather events (e.g., rain events) Variation related to spawning, Evaluation of Year 1 and Year 2 data to determine species and life feeding and water column stage period of occurrence for spawning and feeding variation; migrations Mixed depth samples will account for depth variability by species and life stage for water column migrations The resolution of taxonomic and life stage designations will be Identification of lowest taxon monitored through regular evaluations of catch data with the goal of possible reducing percent of unidentified organisms and increasing resolution of genera and higher taxonomic designations Data must be representative of each Sampling near the centerline of Unit 2 is expected to be intake representative of the total CW IS Sampling of just below the bottom of the curtain wall, near the How the location of the intake in the bottom of the intake structure, and a point mid -way between the water body are accounted for other two near the surface is assumed to be the best method for accounting for intake location Document flow associated with the Facility will monitor flows for period of sampling for use in the final data collections report produced after sampling Methods in which latent mortality will Latent mortality will not be evaluated as a part of the study and be identified therefore methods are not provided Data must be appropriate for a Data will be expressed as taxon and life stage specific densities quantitative survey which can be multiplied by flow to support quantification of entrainment 6 Entrainment Characterization Study Plan 6.1 Introduction This section of the ECSP provides methods, materials, and procedures for entrainment sample collection and processing. A site-specific Standard Operating Procedure (SOP) will be developed to serve as a companion document to the ECSP. The SOP will specify detailed field sampling procedures, laboratory procedures, data quality assurance and quality control ' Bi -monthly samples will be combined to derive a single monthly entrainment estimates Duke Energy 1 15 Entrainment Characterization Study Plan L��i McGuire Nuclear Station r c (QA/QC), and database management. This will ensure field sampling and laboratory methods are adhered to and will provide a base level of consistency with other plants in Duke Energy's fleet where entrainment sampling is required. 6.2 Sample Collection Entrainment samples will be collected twice per month from March 1 through October 31 in 2016 and 2017 (16 sampling events in each year). Based on life history data of species likely to be entrained at McGuire Nuclear Station (see Appendix A), the vast majority of entrainable- sized organisms in Lake Norman should be present during this timeframe. The proposed monitoring program will start in March to collect the earliest entrainable life stages (e.g., eggs) and will continue through the end of October when spawning activity is expected to be completed. Coordination with station operator will be necessary to ensure pumps are scheduled to operate for the duration of the sampling period in order to obtain representative density measurements. The twice per month sampling frequency should be sufficient to adequately describe seasonal patterns in entrainment as requested in the final §316(b) rule for existing facilities. During each 24-hour sampling event, five feet upstream of the bar racks and near the centerline of Unit 2 will be sampled within the following discrete 6 -hour time intervals: 2100-0300 (night), 0300-0900 (morning), 0900-1500 (day) and 1500-2100 hours (evening). During each 24-hour sampling event, collections will be taken within each of the above 6 -hour sampling window resulting in four samples during each sampling event. In the crepuscular periods, target sample collection times will be 1 hour preceding and 1 hour following sunrise and sunset. During the entrainment season, a total of 64 samples will be collected for a program total of 128 samples for the two years of study (Table 6-1). Table 6-1. Entrainment Sampling Details Units to be Sampled Five feet upstream of the bar racks and near the centerline of Unit 2 Sampling Events (Days) Thirty-two (32) sampling events; twice per month; March 1 and October 31, 2016 and between March 1 and October 31, 2017 Daily Collection Schedule Samples collected within every 6 hours in a 24-hour period (4 collections / 24-hour period) Targeted Organisms Fish eggs, larvae, and juveniles Depths Depth integrated sample using selective withdrawal from near surface, mid -depth, and near bottom. Sample Duration Approximate 100 m3 samples collected within each 6 -hour sampling interval. Duke Energy 1 16 Entrainment Characterization Study Plan L�i McGuire Nuclear Station r ` Number of Samples per Sampling Four samples per sampling day Event (Day) Total Number of Samples Sixteen (16) sampling events/year x 4 samples/sampling event (days) x 2 years = 128 samples' 6.2.1 Location Entrainment samples will be collected approximately five feet upstream of the bar racks and near the centerline of Unit 2. No outages are scheduled for Unit 2 during the 2016 sampling period. The sampler location could be moved if necessary in 2017 (based on the outage schedule). The base of the sampling pipe would be anchored to the bottom of the lake with two feet of 3/8 -inch stainless steel chain attached to a 150 -pound pyramid anchor. The top of the pipe would be suspended from a 14 -inch diameter hard plastic trawl float, providing approximately 40 pounds of buoyancy. The top of the pipe and the float would be approximately 10 feet below the surface. This would provide constant lift to maintain an upright orientation of the pipe during pool level fluctuations and will significantly reduce the effects of wind driven waves on the sampling system. A tether line with a 4 -inch float would run from the submerged float to the surface. Two anchor lines would be attached to an aluminum strongback to provide additional support and to reduce the potential for the pipe to flex over its length (-35 feet). These anchor lines would run upstream at approximately 45 degree angles. Pyramid anchors (75 -pounds each) would be set with small surface buoys attached for adjusting tension on the anchor lines (Figure 6-1). This anchoring system has successfully been used to deploy water quality monitoring equipment with no change in position in high water velocity systems such as the Piscataqua River in New Hampshire where tidal currents can be as high as 4 knots (7 fps) and water height can vary as much as 9 feet due to the tidal range (Normandeau 2015). The in - water sampler prior to deployment is shown in Figure 6-2. Note that the strongback does not interfere with flow entering the sampling orifices. ° This number may increase in Year Two based on the results of Year One sampling Duke Energy 1 17 Entrainment Characterization Study Plan McGuire Nuclear Station Elev 770 ft V Surface Buoy Surface Buoys - NWL Elev. 745 ft 1 Y y Sub -surface Buoy LWL Elev.: 745 ft 1- - Foam Filled Bulkhead — 3 -in. Schedule 80 PVC or ABS Pipe Alumrnum Strongback Elev.: 745 fl Sample Intake Ports (3) 1 FLOW Float 3" Flex Hose FN Shore �UU 0 ,,— 150 Ib Pyramid Anchor 75 Ib Anchors Elev.: 715 ft 1 Bottom Elev.: 710 - 712 ft CONCEPTUAL VIEW - NOT TO SCALE Figure 6-1. Schematic of Floatation and Anchoring System for In -Water Sampler Deployment at McGuire Nuclear Station Duke Energy 1 18 Entrainment Characterization Study Plan L�i McGuire Nuclear Station r c Figure 6-2. In -water Sampler Shown Prior to Its Installation A flexible hose will run from the in -water sampler, across the lake bottom, and up far northeast side of the intake structure. A quick -connect terminus will be connected to the far end of the deck railing. When sampling, a motorized cart with the sampling pump and a second cart with the sampling tank will be taken from a shipping container located near the intake structure and attached to the terminal end of the sampling pipe (Figure 6-3). The pad carts with the sampling pump and tank will require approximately 10 -feet by 6 -feet space. Duke Energy 1 19 Entrainment Characterization Study Plan McGuire Nuclear Station r L�� Figure 6-3. Proposed Location for Collection Tank and Pump and Associated Piping to the Sampling Location Upstream of Unit 2 During each six -hour sampling window, one sample, aggregated by depth, with a target volume of 100 m3 will be collected. In total, each sampling event will include four discrete 6 -hour samples. The volume sampled will be measured using an in-line flowmeter. Depending upon pump flow rates, this sample will require approximately 2 hours to collect with additional time required to wash down nets and prepare the samples for shipping. These samples will be processed discretely to investigate diel variability in ichthyoplankton composition and abundance. Pumped water from the sampler will be filtered through 330 -pm plankton nets suspended in a water -filled tank to reduce velocity and turbulence and prevent extrusion of larvae through the mesh. A larger mesh (e.g., 505 -Nm) may be used if net clogging precludes sampling with 330 - pm mesh. An example ichthyoplankton sampler is shown in Figure 6-4. The proposed propane powered pump has been used successfully at other power plant intake structures to collect entrainment samples with little or no damage to eggs and larvae (Figure 6-4). Pump specifications are provided below: • Capacity: 240 gpm; • Range: 5 gpm — 380 gpm • 7.5 horsepower • Inlet diameter: 3 inches • 230/460 volts Duke Energy 1 20 Entrainment Characterization Study Plan McGuire Nuclear Station r LN • 18/9 amps • 3 Phase • Length: 36 inches • Self priming • Suction lift: approximately 25 feet • Impeller: Urethane coated steel • Weight: 230 lbs. The net mouth will be suspended above the water line in the tank to prevent overflow and loss of organisms in the event of tank overflow. In an effort to minimize organism damage the net will be washed down at least twice during each 100 m3 pumped sample collection. Washdowns will be combined in the field to provide a single concentrated 100 m3 sample. If high debris buildup leads to net clogging then more frequent net washdowns may be required. The net and collection cup will be carefully rinsed into sample jars with preprinted labels and preserved in 5- 10% formalin solution containing Rose Bengal stain. Total sample volume, total sample duration, intake water temperature, dissolved oxygen, pH, and conductivity will be recorded on pre-printed field data sheets. Samples will be transported back to the laboratory for analysis under a required chain -of -custody provided in the SOP. JOINT MUST SWIVEL APPROX 90 (POSSIBLY MORE WOODEN CRADLES (lyp 2) STAINLESS STEEL BANDS (typ 21 NLINE FLOW TOTALIZING 3" 0 PVC VALVE h9ETER (PVC SADDLE MOUNT) SAMPLE FLOW RATE -230 Spm 3'0ADAPTER SOCKET 3 0 OVERFLOW DRAIN 1 330p ICHTHYO-NET i I 3" 0 PVC 330p 170 v.al (PASSIVE DISCHARGE) I COD END POLYETHYLENE l BUCKET "'t. TANK I` I 3 0 PVC NIPPLE 3' O PVC -- IDISCHARGE THROUGH NEL 3" 0 RADIAL FLEX HOSE 3 O QUICK -CONNECT 3'" O PVC VALVE NOT TO SCALE Figure 6-4. Example Entrainment Pump Sampling System Configuration Duke Energy 1 21 Entrainment Characterization Study Plan ��i McGuire Nuclear Station ` 6.3 Sample Sorting and Processing Upon arrival in the laboratory, all ichthyoplankton samples will be logged on an Ichthyoplankton Sample Control Sheet/Sorting Form. Because Lake Norman is a freshwater reservoir, we do not anticipate shellfish larvae, as defined as commercially important crustaceans or bivalves, will be present in the samples. Therefore, procedures for identifying shellfish larvae are not presented. Before sorting, ichthyoplankton samples will be rinsed using a U.S. Standard Sieve with a mesh size opening of less than or equal to 330 atm to remove excess detritus and formalin. All fish eggs and larvae retained on the sieve will be hand -sorted from the debris with the aid of an illuminated magnifier. Samples that are estimated to contain more than 400 fish eggs and larvae (all taxa combined) will be split with a plankton splitter and to a subsample quota of about 200 eggs and larvae combined and then analyzed. The number of eggs and larvae present in the sample will be recorded. If possible, long -dead and/or non-viable eggs will be identified using appropriate and well-defined techniques identified in the SOP and categorized in the database accordingly. For example, the SOP may require that eggs collected live be whole, show signs of fertilization and not be covered with fungus at the time of their entrainment. Ichthyoplankton from each sample will be placed in individually labeled vials and preserved in 5 to 10 percent formalin prior to taxonomic analysis. Examples of organisms identified as long -dead or non- viable will be stored in separate vials. Fish eggs, larvae, and juveniles will be identified using a dissecting scope equipped with a polarizing lens. Identifications will be made to the lowest practical taxonomic level using current references and taxonomic keys (e.g., Auer 1982, Wallus et al. 1990, Kay et al. 1994, Simon and Wallus 2004, EPRI Larval Fish Identification Key hftp://www.larvalfishid.com/). Larvae and juveniles will be categorized as follows: • Yolk -sac larvae: Phase of development from the moment of hatching to complete absorption of the yolk; • Post yolk -sac larvae: Phase of development from complete absorption of yolk to development of the full complement of adult fin rays and absorption of finfold; • Juvenile: Complete fin ray development and (infold absorption; • Eggs: Are required to be whole, show signs of fertilization, and not be covered with fungus to be considered live. Ichthyoplankton larval life stage will be identified as "larvae" if they are damaged to the point that they cannot be confidently classified as yolk -sac or post yolk -sac. For each diel (6 -hour) sample, the following morphometric data will be collected: • Up to 10 yolk -sac, post yolk -sac and "larvae" of each fish species will be measured for total length, greatest soft tissue body depth, and head capsule depth to the nearest 0.1 mm. Among dorso -ventrally compressed organisms whose body or head capsule width exceeds the body or head capsule depth, soft tissue body and head capsule width will also be measured to the nearest 0.1 mm. Duke Energy 1 22 Entrainment Characterization Study Plan McGuire Nuclear Station FN • Up to 10 eggs of each taxon will be measured for minimum and maximum diameter to the nearest 0.1 mm. Only whole organisms will be subject to morphometric evaluations. If more than 10 eggs or larvae are present, a random subset of each species and life stage will be measured. Length measurements will be performed with a calibrated ocular micrometer or other calibrated tool (e.g., ImageToolTM Software). Organism identification will be cross-checked using the QC procedure described below. 6.4 Data Management Field and laboratory data will be recorded on forms compatible for computer entry and data processing activities will be recorded on log sheets for each batch of data. A digital image of the datasheet will be taken in the field prior to the datasheets leaving the site. Data sheets will be inspected for completeness prior to data entry. The data will be entered using a double data entry software, a feature that ensures entry errors will be caught and corrected as the operators key the data. Using this procedure, data sets are entered twice in succession and the software compares the first and second entries and identifies any discrepancies. Discrepancies must be resolved before the second data entry can continue. Keyed data sets will be error checked. If any errors are encountered, they will be corrected in the database. Once the database is cleared of errors, the data file compared to the data sheets will be audited to ensure an Average Outgoing Quality Limit (AOQL) of 1% (2! 99% accuracy). The data set will then be ready for the production of summary tables, which will be proofed to confirm that the summary program worked properly. The data editor will sign and date each proofed summary table and include notations as to which values were verified. 6.5 Data Analysis Data analysis will be performed using the QAQC'ed database and will include summaries of proposed vs actual samples collected, sample volumes, entrainment densities, morphometric measurements, and water quality parameters. Generally, minimum, average or median, and maximum values will be provided by sample event or month. Collection densities, expressed as number per 100 m3, will be calculated from entrainment catch data for each taxon and life stage by month of sampling, sample event (i.e., including all samples collected within a 24-hour period), and by six hour diel intervals (e.g., 2100-0300 [night], 0300-0900 [morning], 0900-1500 [day] and 1500-2100 hours [evening]) across all sampling events. Average concentration of organisms per unit volume in the hth stratum (i.e., month, sample event or six hour interval), xis will be calculated as: ,� nn Xh = — YXhi nn r=1 where: Duke Energy 1 23 Entrainment Characterization Study Plan McGuire Nuclear Station nh = the number of samples in the h 1 stratum xhi is the ith observation in the hth stratum. OR Next, these densities will used to estimate the total entrainment at cooling water intake based on design and actual intake flows. The estimated total entrainment will be calculated in the following manner. First, the average concentration of organisms per unit volume in the hth month will calculated using the equation provided above. The total number entrained (E) during the sampled months will then then calculated as: where: H E= EVh Xh h=1 H = total number of months sampled Vh = volume of water withdrawn by the station in the hth stratum. 6.6 Field and Laboratory Audits Prior to the first scheduled sampling, an experienced senior staff member will accompany and train field personnel, including: protocols for site access and contact with facility personnel; safety requirements as contained in the Health and Safety Plan, implementation of the field SOP including the operation of the pump samplers, sample collection, sample preservation, proper datasheet documentation, chain -of -custody, and shipping. At this time, a readiness review will be conducted to ensure that trained personnel, required equipment, and procedural controls are in place. In addition, equipment will be tested to ensure its proper operation. After the initiation of sampling, two trained QA staff members (one each from Normandeau and HDR) will conduct an independent QA audit to ensure that the SOP is being implemented correctly. Results of the audit will be summarized in a technical memo. This memo will categorize deviations from the SOP into three categories: (1) those that do not affect the quality of the data, (2) those that may affect the quality of the data, and (3) those that affect the quality of the data. Variances from approved procedures will be documented and corrected, either by modifying the SOP to address systematic problems or by testing and/or retraining staff, as necessary. Any changes to the SOP will be discussed with and agreed upon by Duke Energy representatives before being implemented in the field. Partway through the sampling program a trained QA staff member from HDR will conduct an independent QA audit following the same procedures to provide on-site training, to observe sampling activities, and to verify that the project's SOP is being followed. In addition, senior staff will observe initial laboratory and data management activities to verify the same. Implementation of the laboratory SOP will be overseen by a senior Normandeau laboratory manager who will also ensure that staff technicians have been properly trained. Once during each year of sampling, an independent QA trained HDR employee will conduct an audit to Duke Energy 1 24 Entrainment Characterization Study Plan FN Nuclear Station ensure that the SOP is followed. These audits will include safety, sampling procedures, sample processing, and identification. Audit reports will be prepared and any substantial shortcomings identified will be addressed prior to the next sampling event. Samples from the first collection event will be analyzed prior to the initiation of the second event to ensure that organisms are being collected with limited damage to allow identification. 6.7 Laboratory Quality Control Quality control methods for split, sort and identification of ichthyoplankton will be checked using a continuous sampling plan (CSP) to assure an AOQL of 10% (>!90% accuracy). Identification checks will be inspected using a QC procedure derived from MIL -STD (military -standard) 12356 (single and multiple level continuous sampling procedures and tables for inspection by attributes). Detailed methods for quality control will be provided in the SOP developed by Normandeau. The QC checks will be recorded on appropriate datasheets and these records will be maintained for review. Samples will be stored for a minimum of three years after the end of the project or longer if Duke Energy requests additional storage time. 6.8 Reporting During the study, monthly progress reports will outline the status of the on-going sampling and laboratory processing. At the end of the first year of study, a report describing preliminary results of testing will be provided to Duke. This first-year report will include entrainment estimates by month and diel period using design intake flow. At the completion of the study, a comprehensive report describing all aspects of the study program (facility description, study design, sampling methods, data analysis methods, and results) will be generated. The final report will include all tables, figures, photographs and engineering drawings as necessary to fully document the evaluations conducted. Included will be estimates of entrainment by species, life stage, month, and diel period under design and actual intake flows. The report will be organized with supporting information and detail in attached appendices, as needed. 6.9 Safety Policy All work performed under the direction of Duke Energy on Duke Energy properties and/or on properties owned or operated by third parties (i.e., not owned or operated by the contractor or Duke Energy) will be performed using safe work practices that are at least equivalent to those required for Duke Energy personnel and of any third party owner or operator. At a minimum, all contractors are expected to be aware of, and adhere to, Duke Energy's Corporate Safety Policy, and other location -specific safety policies and procedures. Duke Energy 1 25 Entrainment Characterization Study Plan McGuire Nuclear Station 7 References FN Alden Research Laboratory, Inc. (Alden). 2004. Draft Evaluation of the McGuire Nuclear Generating Station with Respect to the Environmental Protection Agency's 316(b) Rules for Existing Facilities. Auer, N.A. (ed.). 1982. Identification of Larval Fishes of the Great Lakes Basin with Emphasis on the Lake Michigan Drainage. Great Lakes Fisheries Committee Special Publication 82-3, Ann Arbor, MI. 744 pp. Duke Energy. 2014. NPDES Permit Renewal Application. 2009. NPDES Permit Renewal Application. undated. McGuire Nuclear Station Environmental Report for Nuclear Operating License Renewal Stage. Electric Power Research Institute (EPRI). 2014. Entrainment Abundance Monitoring Technical Support Document: Updated for the New Clean Water Act §316(b) Rule. EPRI, Palo Alto, CA 3002001425. Kay, L.K., R. Wallus, and B.L. Yeager. 1994. Reproductive Biology and Early Life History of Fishes in the Ohio Drainage. Volume 2: Catostomidae. Tennessee Valley Authority, Chattanooga, TN. Normandeau Associates, Inc. (Normandeau). 2015. In -water Sampler Memo. Transmitted from Normandeau to HDR, Inc. October 15, 2015. North Carolina Department of Environment and Natural Resources (NCDENR). 2003. Basinwide Assessment Report, Catawba River Basin. Division of Water Quality, Water Quality Section, Environmental Sciences Branch. June 2003. North Carolina Department of Environment and Natural Resources and North Carolina Wildlife Resources Commission (NCDENR and NCWRC). 2001. Catawba River Basin Natural Resources Plan. October 2001. Simon, T.P. and R. Wallus. 2004. Reproductive Biology and Early Life History of Fishes in the Ohio River Drainage, Volume 3: Ictaluridae — Catfish and Madtoms. CRC Press. 204 pp. U.S. Fish and Wildlife Service (USFWS). 2016. Information for Planning and Conservation (IPAC). https://ecos.fws.gov/ipac/. Accessed January 15, 2016. 1996. Recovery Plan for Carolina Heelsplitter (Lasmigona decorata). U.S. Fish and Wildlife Service, Southeast Region, Atlanta, GA. 30 pp. Wallus, R., B.L. Yeager, and T.P. Simon. 1990. Reproductive Biology of Early Life History Fishes in the Ohio River Drainage, Volume 1: Acipenseridae through Esocidae. Tennessee Valley Authority, Chattanooga, TN. 273 pp. Duke Energy 1 26 Entrainment Characterization Study Plan McGuire Nuclear Station FN APPENDIX 1 — Select Species Spawning and Early Life History Data Sampling for entrainment year-round at McGuire Nuclear Station is expected to be a poor allocation of resources, since few if any eggs or larvae are likely to be present in Lake Norman during the winter months. Several species were identified as likely to be present in entrainment samples and life history information for these species is summarized here and supports a sampling period of March through October. It is important to note that low densities of entrainable organisms at the outset and conclusion of the sampling period are unlikely to change the estimates of entrainment and do not warrant the additional sampling costs necessary to extend the sampling season. Duke Energy 1 27 Entrainment Characterization Study Plan McGuire Nuclear Station Table A-1. Life Histories of Selected Species Expected to be Present near McGuire Nuclear Station 0 Bluegill Spring and Early Shallow Saucer-shaped Adhesive Up to 60,000 <50 mm YS 4-6 1, 4, 7 (Lepomis Summer waters with depressions in sand or eggs mm macrochirus) sand and gravel typically one to Water gravels. two feet in diameter and PYS 7 - Temperatures 70- a few inches deep. 14 mm 75 °F Alewife Spring and Early Shallow water Deposit eggs over any Demersal 10,000 to (Alosa Summer. Water substrate and 360,000 eggs pseudoharengus) Temperatures 60- adhesive 75 °F Average diameter: 0.9 mm Threadfin Shad Spring and Early Eggs Open water Demersal 2,000 to (Dorosoma Summer. Water scattered over and 24,000 eggs petenense) Temperatures 60- plants or loose adhesive 80 °F sediments. <50 mm YS 2.5- 2, 3, 6, 7 5mm PYS 4- 12 mm <100 mm YS 3-7 1, 4, 5, 7 mm PYS 6- 20 mm Blue Catfish Late Spring and Streams or Depressions in soft Adhesive 900 to 1,350 <100 mm 4 to 9 (lctalurus furcatus) Early Summer. reserviors sediment eggs/kg of mm Water bottoms with Average bodyweight Temperatures 70- cover. diameter: 75 °F 3.0 mm 1.4 Duke Energy 1 28 Entrainment Characterization Study Plan 01McGuire Nuclear Station Channel Catfish Late Spring and Streams or Eggs are deposited in Adhesive Up to 21,000 <100 mm YS 6- 1, 4, 6, 7 (lctalurus Early Summer. reservoirs crevices with hollow eggs 15 mm punctatus) Water bottoms with woody debris and Average Temperatures 70- cover. undercut banks. Nest diameter: 85 (°F). can be made directly in 2.4-3.0 mm mud bottoms. White Perch Late Spring and Shallow water Eggs are deposited over Adhesive 20,000 to <75 mm YS 4- 1, 6, 7 (Morone Early Summer sands and gravel. 150,000 eggs 20 mm americana) Average diameter: PYS 8- 0.75 mm 21 mm Duke Energy 1 29 Entrainment Characterization Study Plan McGuire Nuclear Station References FN 1) Rohde, F.C., R.G. Arndt, D.L. Lindquist, and J.F. Parnell. 1994. Freshwater Fishes of the Carolinas, Virginia, Maryland, & Delaware. The University of North Carolina Press. Chapel Hill, NC 2) Nigro, A.A. and J.J. Ney. 1982. Reproduction and Early -Life History Accommodations of Landlocked Alewives in a Southern Range Extension. Transactions of the American Fisheries Society 111:559-569. 3) Pardue, G.B. 1983. Habitat Suitability Index Models: Alewife and Blueback Herring. Fish and Wildlife Service, U.S. Department of the Interior. Washington, D.C. FWS/OBS- 82/10.58. September 1983. 4) Hendrickson, Dean A., and Adam E. Cohen. 2015. "Fishes of Texas Project Database (Version 2.0)" doi:10.17603/C3WC70. Accessed (insert date). 5) Ross, S. T. 2001. The Inland Fishes of Mississippi. University Press of Mississippi, Jackson. 6) Animal Diversity Web. hftp:/fanimaidiversity.org/ 7) Auer, N.A. 1982. Identification of Larval Fishes of the Great Lakes Basin with Emphasis on the Lake Michigan Drainage. Great Lakes Fishery Commission, Ann Arbor, MI 48105. Special Pub. 82-3 744 pp. Duke Energy 1 30 Entrainment Characterization Study Plan McGuire Nuclear Station r LN APPENDIX B — Response to Informal Review Comments While not required to be peer reviewed under the Rule, Duke Energy engaged subject matter experts to informally review this Entrainment Characterization Study Plan. The purpose of the informal review was to afford the Biology Peer Reviewer the opportunity to evaluate the entrainment study objectives and methodology, and to comment if the proposed methods do not meet industry standards. Duke Energy's intent was to ensure that if data were collected as detailed in the ECSP that the data would be sufficient for the intended use in the Best Technology Available (BTA) determination process required in §122.21(r)(10)-(12), and would not be questioned at a later time. In order to help focus the review, charge questions were developed (Table B-1). The primary goal was to develop a study that meets the objectives of the Rule -required Entrainment Characterization Study. Table B-1. Directed Charge Questions Will the proposed sampling depth(s) Yes/No 1) and location provide for a representative sample of the water column? Considering fish and shellfish known or Yes/No expected to be in the source waterbody, 2) will the proposed sampling period (months) provide the ability to understand seasonal variations in entrainment? Is the sampling equipment proposed Yes/No 3) appropriate to collect entrainable organisms at this type of intake structure? Does the plan lay out QA/QC Yes/No 4) requirements dearly? Are these requirements adequate? Identifying eggs and larvae to species is Yes/No often difficult and sometime impossible. Does the sampling plan provide 5) sufficient measures to preserve organism integrity and support identification to the lowest taxon practicable? Does the study design meet the Yes/No 6) requirements of the Rule at 40 CFR 122.21(r)(9)? Duke Energy 1 31 Entrainment Characterization Study Plan McGuire Nuclear Station Will the study design provide sufficient Yes/No data to support a benefits analysis of 7) entrainment reducing technologies required to be evaluated by the Rule including biological performance as required in 40 CFR 122.21(r)(11)? Are there any deficiencies in the study Yes/No plan that might prevent you or others 8) (e.g., Regulators) from understanding what is being proposed for sampling? If so, what needs to be added or clarified? OR After receipt of the peer reviewer's comments, the following responses were developed and the ECSPs were updated to reflect those changes. Comments were divided into four categories as follows: • Category 1: Comments that are clearly applicable (i.e., relevant under the charge and improve the quality of the work product). These comments were incorporated into the ECSP. • Category 2: Comments that represent a misunderstanding by Informal Reviewers. These comments were not incorporated into the ECSP. • Category 3: Comments that are minor and do not materially change or lend additional value to the ECSP (e.g., comments that were meant as "FYI", or meant as preferential suggestions, or are beyond the scope of the charge). These comments may or may not have been incorporated into the ECSP at the discretion of the Report Originator. • Category 4: Major Peer Reviewer comments that the Report Originators do not agree with and choose not to incorporate into the ECSP. Table B-2 presents the site-specific responses to comments received on the McGuire Nuclear Station ECSP. Duke Energy 1 32 Entrainment Characterization Study Plan McGuire Nuclear Station 0 Table B-2. Peer Reviewer Responses to Directed Charge Questions The depth distribution of the three openings on the in -water sampler is appropriate to adequately integrate any vertical variation in distribution of eggs or larvae (but see comments regarding potential effects of orifice size on sampling efficiency in response to question 3). I agree that the proposed location directly in front of Unit 2 should be representative for the CWIS. Attaching an aluminum strongback brace to the sampling pipe should help minimize bowing and vibration of the pipe. However, as drawn in Figure 6-1 the positioning of the aluminum strongback structure directly in front of the sampling orifice openings may create turbulence or lead to visual avoidance behavior that would alter collection rates. I think it would be better to have the brace run along the back side of the pipe. I suspect that sampling efficiency might also vary depending on the orientation of the orifice openings relative to the flow of water coming into the intake structure (e.g., facing into the current, away from it, or cross -current). If so, it would be important that the orientation of the sampling pipe not change (i.e.. the pipe turn side to side) under different wind and wave conditions. Attention to how the pipe is attached to the main anchor as well as how the anchor lines are attached to the pipe and how they are oriented (spread out from each other) ought to adequately address this. The addition of some fins to the strongback attached to the back of the pipe would likely help stabilize the pipe's orientation and keep it facing directly into the current (similar to a weather vane). Spreading the anchor lines 45 degrees apart rather than nearly straight upstream would likely help. Given the force on the pipe, I recommend making each cable Y-shaped, with two widely -spaced attachment points on the strongback brace. It is important that flow volume (and therefore contribution to the total sample volume) be equal through all three openings, and the proposed design should accomplish that However, flow velocity at the orifice opening may affect sampling efficiency. If each orifice samples the same amount of water, but samples organisms with different efficiencies, then the combined sample of entrained organisms will not reflect equal contributions from all three depths. No response required No response required The bracing has to be upstream of the sample pipe, so that it can be anchored into the force of the oncoming flow. See new Figure 6.2 that shows how the impact of the strongback is minimized. Anchoring and bracing of the in -water sample was based on the BPJ of the Normandeau who has had extensive experience deploying these systems hydraulic conditions more severe that what is anticipated to occur at McGuire. The orifices remain oriented into the oncoming flow. The orifice diameter sizes at McGuire are 2.75, 2.375, and 2.25 inches. The through -orifice velocity at all three openings will be on the order of 5 feet per second and well above the swimming capability of entrainable-sized organisms. Duke Energy 133 Entrainment Characterization Study Plan McGuire Nuclear Station Charge No. To achieve equal flow volumes through orifices of different sizes, the flow velocity will also have to vary among the orifices. This could affect capture efficiency, given escape behaviors and rheotaxis exhibited by larval fish. If the differences are fairly small it may not matter. But some assurance is needed that the setup will sample the organisms equally, not just the water. If necessary, test runs could be done in the lab, sampling larvae of a known density out of a tank. The 3 -inch diameter flexible hose will have a volume of about 0.5 m3 per 100 m of hose. The pump should be run long enough to clear the full volume of the hose before actual sample collection begins. FN The through -orifice velocity at all three openings will on the order of 5 feet per second and well above the swimming capability of entrainable-sized organisms. It would be difficult to simulate the flow field conditions from a power plant in a laboratory setting. Presumably one would want to test at the approach velocities similar to levels in the field. This would require a test flume with flow control to achieve the desired test velocities. Since one would be removing organisms and water while sampling, one would have to develop a method to replace the removed organisms and water. If you use a recirculating flume, so only the volume of water removed would need to be replaced, then that replacement water would have to seeded with organisms of a known number. The test pump would be removing 240 gallons per minute, so your total capacity in your flume would likely need to be at least 5x this volume, if not much higher (otherwise the pump sampler would be inducing flows not the circulating pump on the flume). If you want to test different species, life stages and/or organism sizes, then several tests would be required. What at first glance appears to be a simple test, is actually quite complicated. Yes. Pumps will be run to clear pipes prior to initiation of sampling. The proposed sampling period and frequency are appropriate to encompass the periods when fish eggs and larvae are likely to be present, and to provide information on seasonal patterns of entrainment (but see concerns regarding the need for sample No response necessary. replication in response to question 3). The spawning and life history information table provided in Appendix 1 does a nice job of conveying the relevant information. Duke Energy 1 34 Entrainment Characterization Study Plan McGuire Nuclear Station Charge No. 4 4 4 Pump sampling has been used in a variety of settings to sample zooplankton and fish early life history stages. However, sampling efficiency of pump sampling is likely to be different (likely lower) than traditional net sampling approaches. Traditional net deployment and retrieval methods may not be feasible in the intake bays, but if a judicious number of samples could be collected with another method, at a time when densities are relatively high). that would go a long way toward addressing any concerns about if, or how much, this method underestimates actual entrainment. If such comparisons are already available from other studies, so much the better; note them. Another approach that might allow a useful comparison would be to collect samples using a Schindler-Patalas trap. However, this gear samples a very small volume of water, so even at peak densities it may not be feasible. Orifices will vary in size to allow equal flow from each depth, It is important that flow (and therefore contribution to the total sample volume) be equal through all three openings, but orifice size and flow velocity at the orifice opening are both likely to affect sampling efficiency. If each orifice samples the same amount of water, but samples organisms with different efficiencies, then the combined sample of entrained organisms will not reflect equal contributions from all three depths. What sizes will the orifices be, and what will the flow velocity be at the opening? Both could affect capture efficiency, given escape behaviors and rheotaxis exhibited by larval fish. If the differences are fairly small it may not matter. But some assurance is needed that the setup will sample the organisms equally, not just the water. If necessary, test runs could be done in the lab, sampling larvae of a known density out of a tank. The proposal notes that "properly designed and operated pumped -systems have shown collection efficiencies of 95 percent or greater for fish eggs and larvae with little or no organism damage (EPRI 2014)." However, it wasn't clear how this was measured and if it directly applies to this situation. It would be helpful if you could elaborate a bit. FN See Pumped Sampler White Paper (Appendix C) The orifice diameter sizes at McGuire are 2.75, 2.375, and 2.25 inches. The through -orifice velocity at all three openings will be greater than 13 feet per second and well above the swimming capability of entrainable-sized organisms. The orifice diameter sizes at McGuire are 2.75, 2.375, and 2.25 inches. The through -orifice velocity at all three openings will be greater than 13 feet per second and well above the swimming capability of entrainable-sized organisms. The two components of the system most likely to contribute to damaging organisms are passage through the pump and turbulence in the sampling tank. The urethane coated recessed impellers in the pump selected for use at McGuire has been shown to contribute minimal damage to organisms. Similarly, a net in a barrel, as proposed here dissipated kinetic energy and still turbulence and is the preferred design for most pumped sampling systems. Duke Energy 1 35 Entrainment Characterization Study Plan McGuire Nuclear Station Charge No. The lab and field SOP and audit plans are generally sound. However, an Average Outgoing Quality Limit (AOQL) of 1% (z 99% accuracy) strikes me as rather liberal for data entry. It seems to me that an error rate of one error per 100 entries is too high. How does it compare to the observed error rate on similar work (I expect actual accuracy is typically better than that)? If it is feasible to commit to a lower error rate that would be preferred. Likewise, an AOQL of 10 percent for organism identification seems pretty high to me (I expect the error rate will be lower than that for experienced personnel). I recognize that identifying fish eggs and larvae is tricky, so I fully expect some individuals to end up in broader categories (e.g., unidentified shad or unidentified larvae) — I don't consider that an identification error. But I would expect organisms identifiable to a given taxonomic level to be correctly classified more than 90% of the time. Again, what is the observed error rate on similar analyses? Maybe my expectations are too high. FN Typically the average outgoing quality (AOQ) is better than the AOQL. Both this and the AOQL for larval identification are industry standard for entrainment sampling. The sampling plans implemented under our proposed QC procedures have a specified average outgoing quality limit (AOQL) of 10 percent, which represents the maximum fraction of all items (e.g., measurements, taxonomic identifications or counts) that could be defective as a worst case. A defective item could be a measurement or count that falls outside of a specified tolerance limit (e.g., plus or minus 1 to 10 percent). Typically the average outgoing quality (AOQ) is better than the AOQL. Items are inspected using a QC procedure derived from MIL -STD (military -standard) 1235B (single and multiple level continuous sampling procedures and tables for inspection by attributes) to the 10 percent AOQL . Both this and the AOQL for data entry are industry standard for entrainment sampling. The data security and chain -of -custody plan is good, and taking a 3 4 digital image of each data sheet before leaving the field adds an No response required extra level of protection. Given that regulatory compliance is sometimes the subject of Duke Energy will have discretion as to how long they would like to 3 4 litigation, I think that retaining samples for only three years is not hold on to samples. At the end of 3 years, if Duke Energy feels sufficient. My sense is that something on the order of seven years holding onto samples longer would be worth the cost of storage, would be a better safeguard. then they can chose to hold them longer. Adequate information is provided to document that the specific 3 5 pump(s) to be used are of the type that will not cause organism No response required damage as noted in EPRI (2014). Proposed preservation methods will fix organisms in a manner 3 5 that will maintain their morphological integrity for identification No response required purposes. Duke Energy 1 36 Entrainment Characterization Study Plan McGuire Nuclear Station 4 Charge No. 11 The Rule requires "sufficient data to characterize annual, seasonal, and diel variations in entrainment, including but not limited to variations related to climate and weather differences, spawning, feeding, and water column migration." The proposed sampling plan calls for collecting a single, large sample in each sampling period. I believe that this collection plan will provide data representative of the entrainment at the intakes, but determining if apparent patterns or differences are real (as the requirements seem to call for) requires some measure of variability in the estimates. That requires replicates. The number of samples collected over the course of the project will be sufficient to detect annual variation between the two years, but seasonal, diel and weather effects would be confounded with each other. Additional replication is necessary in order to determine if any of these factors affect entrainment. For example, one could not separate weather effects from temporal differences in this sampling design. If it is necessary to be able to show whether or not there are effects of weather, enough samples will be needed to use weather variables (e.g., water temperature, cloud cover) as covariates to test for effects. That said, I think this issue could be addressed with a modicum of additional effort. The simplest approach would be to divide each 2 -hour sample into at least three, preferably four, samples collected immediately one after the other. The collection cup (or entire net) could be swapped out after a sample and processed while the next sample is being collected. This replication would allow straightforward statistical analysis to determine if these factors (or their interaction) affects entrainment. The individual samples could still be combined into one composite sample if warranted, but the inverse isn't true. 01 The final Rule does not require replication nor is there an obligation to provide confidence intervals or bounds around the entrainment estimates generated. The study must be sufficient to show diel, monthly, and annual variation, which this study plan addresses. We interpret the Rule as requiring sufficient sampling to collect data over the range of conditions that are likely to occur and to prevent bias through selective sampling. For example, you could not propose to sample only during the day, because you would miss any density differences due to diel variability. You could not propose to sample only on sunny days, because you would miss any density differences due to weather. You could not propose to sample only from near the bottom of the intake, because you would miss any density differences due to vertical stratification in the water column. We believe that the way in which these data will be used do not justify extensive replication. Relationships between weather, climate, spawning, and feeding (as a few examples) and entrainment rates are not going to change the determination of best technology available for entrainment reduction or the outcome of any social cost / social benefit calculations. In addition, the study plan includes some replication. Each sampling event is divided into four independent samples based on time of collection. In addition sampling events occur twice in each month. If necessary, confidence intervals can be generated based on these 8 samples within a month. Determination of whether confidence intervals are beneficial can be made at the end of the program. We disagree that splitting each 2 -hour sample into smaller sub - samples requires only a small additional effort. While it is true that the extra effort in the field would be minimal (extra net wash -downs, extra datasheets to fill out), the effort (and associated labor costs) in the laboratory would increase proportionally. So splitting the 2 -hour samples into four sub -samples will quadruple the lab costs. Duke Energy 1 37 Entrainment Characterization Study Plan McGuire Nuclear Station FN Replication is important for density estimates, but it would not be necessary to have morphometric measurements on a full compliment of individuals from each replicate; one pooled sample We are measuring 10 individuals from each taxon and life stage in 6 for each six -hour period would suffice. A total of up to 10 each 6 -hour sample. individuals of each taxon could be drawn at random from all the individuals collected in all replicates combined within one six -hour sampling period. Any vertical migration should be adequately integrated by the multi -depth sampling scheme, and the temporal pattern of sampling should detect the seasonality of spawning. It is unclear to me what "feeding variation" refers to or how sampling will 3 6 assess it, but it is also unclear to me how that is relevant for this No response necessary. assessment. If this refers to changes in feeding behavior over the diel period or seasonally that would increase or decrease vulnerability to entrainment, then 1 believe such effects would be adequately captured by the proposed sampling scheme. With minor modifications as noted in responses to other 3 7 questions, this study design should provide a sound basis to No response necessary. support the required benefits analysis. In general the proposal is clearly written and understandable, with 3 8 only minor exceptions. Some points to be added or elaborated No response necessary. upon, or deficiencies in the design, have been noted above. I trust that the carts used for the sampling equipment will be sufficiently heavy to avoid tipping due to the weight of the 3 8 deployed hose, and that they will have an adequate brake system Yes. We agree. We want no carts in Lake Norman. or otherwise be sufficiently immobilized to assure that they don't go in the drink! Duke Energy 1 38 Entrainment Characterization Study Plan McGuire Nuclear Station APPENDIX C — Comparison of Pumps and Nets for Sampling Ichthyoplankton F)R Duke Energy 1 39 Entrainment Characterization Study Plan McGuire Nuclear Station FN Comparison of Pumps and Nets for Sampling Ichthyoplankton Prepared by: FN 440 S. Church Street, Suite 900 Charlotte, NC 28202-2075 February 19, 2016 Introduction As a part of Duke Energy compliance projects associated with the 2014 Clean Water Act §316(b) rule for existing facilities (Final Rule), the company submitted draft ECSPs to informal review by subject matter experts. In the comments received on the draft ECSPs and during discussions at a peer review kick off meetings, there was a concern among the biological reviewers that the proposed pumped ichthyoplankton sampling method could impart a systematic bias compared to nets for estimating power plant entrainment. In particular, there was a concern that pumped samples could underestimate entrainment and that additional gear efficiency testing could potentially be undertaken periodically throughout the entrainment sampling period to determine if a bias exists and quantify the magnitude of difference if it exists. As a preliminary step, HDR conducted a literature review. The sections that follow provide background, the methods and results for the literature review, and conclusions. Background Two primary methods have been historically used to estimate ichthyoplankton entrainment at power plant intakes: streamed/towed nets and pumped samplers. Traditional ichthyoplankton nets can be used to filter water as it enters the intake or exits the discharge and collect organisms. Alternatively, pumps can be used to convey water to a fine -mesh net onshore. Onshore nets are typically suspended in a buffering tank to minimize damage and extrusion of eggs and larvae. Each method has advantages and disadvantages and a comparison of the two methods are summarized in Table C-1. The primary advantages of utilizing pumps include ability to meter precise sample volumes, longer sample collection times, reduction in the potential to miss samples due to inclement weather or other events, and increased ability for technicians to safely observe net filtering and other aspects of the data collection. Their versatility includes being utilized in fresh, estuarine, and marine water environments. Properly designed and operated systems can be accurate and effective. While no sampling method is perfect, pumped samplers ' Held at HDR offices in Charlotte, NC, January 28-29, 2016. Duke Energy 1 40 Entrainment Characterization Study Plan FN Nuclear Station were determined to offer the best, most cost-effective, and consistent sampling method for Duke Energy and therefore were included in the draft ECSPs. Pumped samplers have been used in sampling plankton as far back as 1887 (Gibbons and Fraser 1937; Aron 1958; both as cited in Taggart and Leggett 1984) and have a long history of successful application for collecting ichthyoplankton samples at power plants (Bowles and Merriner 1978; as cited in EPRI 2014). Pumped samplers are among the preferred gear types accepted by EPA and have been used extensively to successfully monitor entrainment at power plant intakes for decades. At present, HDR is aware of on-going or state approved plans for pumped entrainment sampling at power plants to support the Final Rule in at least seven states: Florida, Wisconsin, New York, Pennsylvania, New Hampshire', Massachusetts, and Virginia. If this list of states is expanded to include sampling under the remanded Phase II Rule, then the list of states would be expanded to include Connecticut, Louisiana, Texas, Ohio, Michigan, New Jersey, and Maryland. In addition, there may be other states that HDR is unaware of, that have also approved this approach. Still other States could be added to the list as more power generating companies begin entrainment studies over the next few years under the Final Rule. Table C-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for Estimating Ichthyoplankton Density in Cooling Water Intake Structures (some information adapted from EPRI 2014) Gear Type Advantages Disadvantages - Can be difficult to deploy and retrieve in the confined space of intake structures — precludes the use of some net types (e.g., standard bongo, neuston nets, or Tucker trawls). - Depending on deployment method, may require modifications to intake structures - Large volumes are sampled quickly (less (e.g., frame -mounted nets in frame guides). manpower required for the same number of - Less precise flow metering than pumped pumped samples). samplers. Hoop Nets Deployed in the - If net frames are not used, then there is - Large volumes are sampled quickly — Intake limited to no modifications to the intake capturing less temporal variability in a single required for deployment. sample as compared to pumped samples. - No potential for mechanical damage - Relatively small nets needed to fit in the associated with pump passage. intake structure offer a small spatial sample. Multiple nets can be used to increase sampled area at the cost of additional samples to be processed in the laboratory. - Tow speeds in the range of 1-2 meters per second (commonly used during ichthyoplankton sampling) is above the intake velocities at the majority of intakes. New York State applies a more stringent standard than the Final Rule under the New York State Department of Environmental Conservation Policy CP -52 for Best Technology Available (BTA) for Cooling Water Intake Structures. The states of New Hampshire and Massachusetts do not have delegated authority to issue NPDES permits and are administered by EPA Region 1. Duke Energy 1 41 Entrainment Characterization Study Plan McGuire Nuclear Station FN " A general rule of thumb, as described in EPRI 2014, states that the total effective open area of the netting (percent open area x area of netting) should be at least twice the area of the net mouth opening- Others have suggested a net length to mouth opening diameter ratio of three or more. Duke Energy 1 42 Gear Type Advantages Disadvantages - Some active avoidance possible by larger motile life stage (e.g., late larvae and early juvenile). Larger hoops can be used to decrease potential for avoidance, but would require a larger deployment area, since length is proportional to opening diameter in properly sized nets. - Greater potential for extrusion than pumped samples (no buffering tank). - Boat deployed nets are subject to weather delays and associated safety concerns. - May be restricted to relatively deep areas that are free of floating debris, submerged snags, and other obstructions - Sample durations are typically longer increasing the potential to capture temporal variability in ichthyoplankton densities not observed in net samples. - Limited modifications to intake or discharge structures are required to install — usually just anchoring points for the sample pipe. - In-line flow metering offers greater precision in measuring the volumes of flow sampled. - Some active avoidance possible by larger - Some potential for mechanical damage. motile life stages (e.g., late larvae and early However, correctly designed systems can juvenile). Pumped offer <5% damage or destruction of eggs and larvae. - Improperly designed samplers can lead to Samplers in the damage to organisms during sampling. Intake - Fixed pipe allows precise control over water - Samples a smaller portion of the spatial depth and orientation to intake flows. variability, because pump inlets are - Less potential for extrusion than nets, generally smaller than net openings. because the filtering net sits in a buffering tank. - Lower potential for missed samples due to severe weather. - Allows technicians to observe sample collections and minimize potential for invalid samples (e.g., use of 330 -um nets increases potential for net occlusion and frequent net change outs may be required during certain times of the year). " A general rule of thumb, as described in EPRI 2014, states that the total effective open area of the netting (percent open area x area of netting) should be at least twice the area of the net mouth opening- Others have suggested a net length to mouth opening diameter ratio of three or more. Duke Energy 1 42 Entrainment Characterization Study Plan McGuire Nuclear Station Literature Review Methods FN HDR conducted a literature review to assemble and assess the available data on the comparative effectiveness of pumped entrainment samplers and nets to estimate power plant entrainment. Available data were identified via online electronic searches for published articles and government and industry reports. The electronic literature search used Google, Google Scholar, and the ProQuest Aquatic Science Collection database accessed through the University of Massachusetts, Amherst. In addition, we consulted the EPRI technical support document on entrainment abundance monitoring (EPRI 2014) to identify relevant literature. The literature search revealed a short list of relevant citations and abstracts. Several of these were available in HDR's corporate library and some were obtained from the publishers. For some of the industry gray literature and less common symposium papers, we relied on abstracts or summaries presented in other documents (primarily EPRI 2014). Below is an annotated bibliography of several of the key references that were reviewed. To the extent practical, these studies were critiqued and the results and findings put in the context of the goals of entrainment monitoring at the Duke Energy facilities. Annotated Bibliography Cada, G.F. and J.M. Loar. 1982. Relative Effectiveness of Two Ichthyoplankton Sampling Techniques. Canadian Journal of Fisheries and Aquatic Sciences 39(6): 811-814. Cada and Loar (1982) collected triplicate pump and towed -net samples during both day and night near the water's surface to detect differences in the effectiveness of a pumped sampler and towed nets for collecting ichthyoplankton. The effectiveness of 1.1 m3/min (290 gallons per minute [gpm]) pump' was compared to a 2 m long (6.6 feet), 0.5-m (1.6 -feet) diameter, 243 -pm mesh conical plankton net in the headwaters of Watts Bar Reservoir in eastern Tennessee. The net was towed for 5 minutes at velocities between 120 and 189 cm/s (4 to 6 feet per second), which resulted in sample volumes of 85 to 100 m3. The pump system used a 7.6 -cm (3 -inch) diameter intake hose that had a cylindrical trash screen with 6.4 _CM2 (1 -inch) openings. This hose inlet was placed 0.25 m (10 inches) below the surface and slowly moved through the water. Both gear collected clupeid larvae (Threadfin Shad [Dorosoma petenense) and Gizzard Shad [Dorosoma cepedianum]) between 4 and 17 mm (0.16 to 0.67 inches) although larvae greater than 10 mm (0.4 inches) long were collected in relatively low numbers. Clupeid larvae 4-10 mm (0.16 to 0.4 inches) long were collected in sufficient numbers to make meaningful statistical comparisons based on date, station, diel period (day vs. night), and fish length. Due to the difficulty in differentiating small Dorosoma spp. both species were combined for the analysis. The differences in the mean densities of most length groups between nighttime pump and tow 'By comparison, the pumps proposed for use for entrainment sampling at Duke Energy facilities have a target capacity of 240 gp m with a range from 5 to 380 gpm depending upon head. Duke Energy 1 43 Entrainment Characterization Study Plan McGuire Nuclear Station FN samples were not statistically significant. However, the pump collected significantly more 4 -mm larvae and the towed net collected more 5- to 10 -mm larvae during the day. Cada and Loar (1982) concluded that based on sampler intake velocities and the potential for avoidance, it would generally be expected that pumps are more effective than fixed nets, that towed nets are more effective than low volume pumps, and that high volume pumps are equally or more effective than towed nets in collecting ichthyoplankton. The lack of differences between densities of ichthyoplankton at night suggests that gear avoidance is associated with a visual escape response and not a tactile response to changes in hydraulic conditions. The authors caution that any gear comparisons should account for sizes of sampled organisms and how that could impact performance and that care should be used when using pumped samplers, because pumps may not adequately sample all entrainable organisms. These results should be used with caution and may not be representative of what would be observed with a fixed entrainment sampler at a cooling water intake. First, Cada and Loar (1982) moved the pump inlet though the water which could alter the flow fields relative to what would be observed around a static system. Second, the distance from the boat that these two systems were deployed is unknown. Theoretically, boat -induced hydraulics, noise, and/or shadow could have induced differential behavioral responses between the two gear types if deployment distances were different. Third, the inlet to the pump had a trash screen with 1 -inch openings. The authors did not describe the size of the trash screen. This screen and its wake could have acted as visual avoidance stimuli. Elder, J.A., J.W. Icanberry, D.J. Smith, D.G. Henriet, and C.E. Steitz. 1979. Assessment of a Large Capacity Fish Pump for Sampling Ichthyoplankton for Power -plant Entrainment Studies. California Cooperative Oceanic Fisheries Investigation 20: 143-145 A centrifugal, single -port bucket -style pump that delivered 3.0 m3/min (793 gpm) at a 3-m (10 - feet) head and in excess of 4.3 m3/min (1,136 gpm) at lower heads was evaluated for sampling entrainment. These pumps were originally designed for hatchery and aquaculture use and were reported by the manufacturer to lift 30 -cm (12 -inch) trout 3 m (10 feet) above water surface with 99.5 percent survival. The pump discharged into a 505 -pm mesh net with a cod -end bucket suspended in a 2 m3 (528 gallon) box. The inlet to the pump was a 15.2 -cm (6 -inch) diameter pipe. The exit pipe was larger (25.4 -cm [10 -inch] diameter) to reduce velocity entering the net. This pump sampler was compared to the sampling efficiency of a 1.0-m [3.3 -feet] 505 -Nm nylon mesh net towed across the mouth of the intakes near where the pump was operating. During 20 paired samples, there were no statistical differences in larval fish densities captured by the net and the pump. There were statistically higher densities of Opossum Shrimp (Neomysis spp.) collected by the pump than by the nets. Damage to pumped specimens was limited. Specimens collected by pump remained highly identifiable and were in the same physical condition as net - captured specimens. Given that the pumps evaluated by Elder et al. (1979) had a much higher capacity than those proposed for use at the Duke Energy facilities, it is difficult to make a direct comparison, but the results indicate that a pumped sampler could be as efficient as nets for sampling entrainment. Duke Energy 1 44 Entrainment Characterization Study Plan McGuire Nuclear Station FN Gale, W. R, and H. W. Mohr, Jr. 1978. Larval Fish Drift in a Large River with a Comparison of Sampling Methods. Transactions of the American Fisheries Society 107:46-55. While this study was primarily designed to test the drift of larvae in the Susquehanna River (1974-1975), use of a pumped sampler and nets simultaneously allows for a comparison of the two gear types. Samples were collected from April 10 to October 10, 1974 with boat mounted nets. The nets were made of nylon and had 0.4 x 0.8 -mm mesh and 24 x 54 -cm (9.4 x 21.3 - inch) rectangular mouths. Simultaneous samples were collected at near each shore and the main channel (about 80 m [262 feet] from the west shore) at set intervals (0800-1000 h and 2300-0100 h). Five-minute fixed net samples were collected from a stationary boat and push -net samples were collected propelling the boat slowly downstream for abut 300 m (984 feet). From March through August 1974 a high capacity trash pump, raised and lowered by a hand winch, was used to collect samples. Replicate pump samples were collected about 50 cm from the surface and 10-20 cm (4-8 inches) from the bottom at 3 -hour intervals for a 24-hour period near the middle of the river. Flow rate was about 2,500 liters per minute (660 gpm). Based on surface samples only,"' the pumped and fixed net samples collected about the same number of larvae per 10 m3 and no statistical differences were detected. Harris, R.P. L. Fortier, and R.K. Young. 1986. A Large -Volume Pump System for Studies of the Vertical Distribution of Fish Larvae under Open Sea Conditions. Journal of the Marine Biological Association of the United Kingdom 66(4): 845-854. Harris et al. (1986) evaluated a pumped sampler for application in an open ocean setting. The pump was 2.8 m3/min (740 gpm) submersible, centrifugal pump designed for pumping waste water. Comparative efficiency trials by day and night showed that the pump was generally as efficient, or in some cases more efficient, in capturing larvae than towed 200 -pm WP2 nets'' although there was some evidence of visual avoidance by particular larval size classes during daylight. The authors indicated that fine -scale temporal and spatial resolution is necessary to study the distribution of larval fish and that large -volume pumps, sampling at rates in excess of 1 m3/min (264 gpm) can be used as an alternative to conventional nets. The design and application of the pump sampler used by Harris et al. (1986) is substantially different (e.g., 15 - cm [6 -inch] intake line; boat -mounted and sampled while in motion; and marine open -water ecosystem) than what is being proposed for use at the Duke Energy facilities. For this reason, the results have limited direct applicability to the Duke Energy fleet. "' Sampler efficiency was only presented for surface sampler in Gale and Mohr 1978. " The WP2 Net is a vertical plankton net with messenger operated closing mechanism based on the design of the UNESCO Working Party 2. Duke Energy 1 45 Entrainment Characterization Study Plan McGuire Nuclear Station r LN King, L. R., B. A. Smith, R. L. Kellogg and E. S. Perry. 1981. Comparison of Ichthyoplankton Collected with a Pump and Stationary Plankton Nets in a Power Plant Discharge Canal. Fifth National Workshop on Entrainment and Impingement. San Francisco, CA, May 1980. Loren D. Jensen, Ed. King et al. (1981) compared the performance of pumped samples and nets in the discharge canal at Indian Point Generating Station on the Hudson River. Simultaneous ichthyoplankton sampling was completed using a 15 -cm (6 -inch) pump/larval table system and stationary 0.5-m (1.6 -feet) diameter conical plankton nets. A total of 79 paired samples were collected on 6 days in June and July 1978. The average density of total ichthyoplankton collected was 3.O/m3 for pump samples and 3.3/m3 for net samples. No significant differences (P > 0.05) were detected between density estimates for total ichthyoplankton determined from pump and net samples for eggs, yolk -sac larvae, post yolk -sac larvae, and juveniles. Thirteen out of 14 taxa compared showed no significant difference between pump and net collections. The pump and net collection systems were equally effective for estimating densities of most ichthyoplankton. Petering, R W and M.J. Van Den Avyle. 1988. Relative Efficiency of a Pump for Sampling Larval Gizzard and Threadfin Shad. Transactions of the American Fisheries Society 117: 78-83. Efficiency of a pump sampler and a plankton net were compared based on monthly nighttime collections on Lake Oconee, Georgia'' from April through August 1982. The two samplers were used on the same night or on two consecutive nights. The gasoline -powered pump had a 1.18 m3/sec (312 gpm) capacity. Pumped samples were discharged into a 297 -Nm mesh net suspend over the side of a boat. A cylindrical metal sieve with 8 mm (5/16 inch) holes was attached to the inlet of the pump to exclude large debris. Three, 10 -minute samples were collected by slowly raising and lowering the intake hose in the upper 2-m (6.6 feet) of the water column. Sample volumes were assumed to be 11.8 m3 (3,117 gpm) based on manufacturer's pumping specifications. Triplicate samples (75 m) were collected with a towed net that was 0.25-m2 (2.7 feet) with 0.5-m (5.4 foot) square opening that was towed at 1.0 m/s (3.3 feet per second) for 5 minutes. Net samples contained seven fish taxa whereas only two were collected by pumps; however, Gizzard Shad and Threadfin Shad accounted for more than 97 percent of the specimens caught in both samplers. The authors conclude that the pumped sampler collected fewer taxa and that the estimates of shad density were lower and less precise than net samples. There are serious concerns with this study design that call into question the authors' findings. First, when calculating organism density, the authors used pump flow rates as defined by the manufacturer's specifications rather than metering the flow. The authors evaluated the pump in the laboratory and determined that the intake rates were typically within 10 percent of advertised values, but no methods or results for the laboratory evaluation are provided to allow a critique. This lack of metering casts doubt on the accuracy of the entrainment estimates. Second, similar ' A 7,709 -hectare pumped storage reservoir in central Georgia. Not to be confused with Duke Energy's Oconee Nuclear Station on Lake Keowee in South Carolina. Duke Energy 1 46 Entrainment Characterization Study Plan �ii McGuire Nuclear Station J c to Cada and Loar (1982), the inlet to the pumped sampler was screened and moved through the water. The screening could atter the localized hydraulics (e.g., increase in velocity entering the screening), which may be perceived and avoided by later larvae and early juveniles with sufficient swimming capacity. Moving the inlet through the water could also induce hydraulic changes perceptible to fish. It is also unknown if, or to what extent, entrainment rates with the pumped sampler could have been affected by its proximity to a moving boat. Finally, samples were not necessarily collected on the same night with both gear types. Daily variability in ichthyoplankton density was likely an unaccounted for confounding factor. Leithiser, R.M., K.F. Ehrlich, and A.B. Thum. 1979. Comparison of a High Volume Pump and Conventional Plankton Nets for Collecting Fish Larvae Entrained in Power Plant Cooling Systems. Journal of the Fisheries Research Board of Canada, 1979, 36(1): 81-84 Leithiser et al. (1979) compared a high volume pump to conventional ichthyoplankton nets for entrainment monitoring. The pumping system had a capacity of about 2.5 M3 /sec (660 gpm). No information was given about the size of the piping on the suction end of the pump. The nets used by Leithiser et al. (1979) were 0.5-m (363 -pm) and 1.0-m (335 -{gym mesh) conical plankton nets. The average density of large larvae (> 5 mm Total Length [TL)) was significantly greater with the pumped sampler than what was observed with the 1-m plankton nets. Compared to the pump, both sizes of plankton nets (0.5 and 1.0 m diameter) in each test greatly under sampled larvae over 5.0 mm TL. The data suggest that the pump and plankton nets sampled the small larvae equally well, but that the larger larvae were better able to avoid the plankton net than the pump inlet. Leithiser et al. (1979) collected samples in the power plant intake canal at different approach velocities. While it was expected that larval avoidance would decrease with increasing channel velocity, this was not observed with either the pumped or net samples, but the number of channel velocities tested were limited. The authors concluded that the high volume pump was a more effective larval fish sampler than the conventional plankton nets. It is important to note that on the California coast where these studies were undertaken, there are greater densities of small larvae (< 5 mm TL) than would be expected in southeastern Piedmont reservoirs, which would make the differences between these two gear types more dramatic at the Duke Energy facilities. It is unclear how these results can be transferred directly to what is being proposed at the Duke Energy facilities because of the higher flow rate used in this study (660 gpm vs. 240 gpm). Duke Energy 1 47 Entrainment Characterization Study Plan McGuire Nuclear Station I LN Leonard, T.J. and G.E. Vaughn. 1985. A Comparison of Four Gear Types to Measure Entrainment of Larval Fish. Proceedings of the Annual Conference of the Southeast Association of Fish and Wildlife Agencies 39: 288-297. A study was undertaken at the McGuire Nuclear Station on Lake Norman, North Carolina. The purpose of this program was to determine the relative efficiency, reliability, and cost of four different systems for measuring larval fish entrainment into the cooling water system: 1) a tap valve in the condenser, 2) a pump -net system, 3) a fine -mesh screen; and 4) a stationary net. Night samples were collected on five consecutive nights 6-10 June 1982, which was anticipated to coincide with the peak abundance of Threadfin Shad and Gizzard Shad. The stationary net was a single 0.5-m conical net (2.5-m [8 -feet] long, 800 -pm mesh) was suspended from a barge located 7 m [23 feet] upstream of the intake. A flow meter was placed in the mouth of the net to monitor the volume of water sampled. The net was fished by quickly lowering the net to the bottom of the intake structure and raising it in 1-m intervals over the 9.5- m high effective opening to the intake. Rapidly lowering and raising of the net caused the net to collapse, preventing the flow meter from recording flow during the decent and retrieval. On the first night the net was raised at 1-m (3 -feet) increments at 2 -minute intervals, but this resulted in less than desirable volumes sampled and on subsequent nights the net was raised at 1-m (3 - feet) increments at 3 -minute intervals for the remainder of the study, resulting in an average sampling duration of 27 minutes. The fine -mesh screen was a 9 -cm (3.5 -inch) deep rectangular wooden frame that had a 50.8 x 57.5 -cm (20 x 22.6 -inch) mouth opening covered on one side with 800 -pm mesh. This panel was attached to a traveling screen in the intake bay being sampled. The traveling screen was rotated manually to position the fine -mesh panel into the flow. The screen was rotated so that the fine -mesh panel was raised in approximate 1-m (3 -feet) increments at 4 minute intervals, resulting in an average duration of 38 minutes. Once at the water surface, the screen was rotated without stopping to retrieve the sample. The pumped sample was collected using a 10.1 -cm (4 -inch) diameter centrifugal pump (2,270 L/min [600 gpm] pumping capacity at 0.6 m head). Water was withdrawn through a 10.1 - cm (4 -inch) diameter flex hose and discharged via a 10.1 -cm (4 -inch) PVC pipe into a plankton net. An ultrasonic flow meter was used to measure flow through the discharge pipe. The hose was lowered as close to the bar racks as possible and raised at 1-m (3 -feet) increments at 3 - minute intervals starting at just above the bottom of the intake opening. Water from the pump was discharged just below the water surface into a 2.4-m (8 -feet) long, 794-prn mesh suspended from the side of the barge. Water was sampled through a 7.6 -cm (3 -inch) gate valve on the condenser and discharged into an 800 -Nm mesh plankton net suspended in a 208-L (55 -gallon) drum. Two consecutive samples averaging 192 minutes each were collected on each night. Though longer duration than the other sampling techniques, the volumes of water sampled were similar. All four gear types were compared to Tucker trawls taken from the intake embayment and used to estimate density and length frequency distributions of larvae potentially susceptible to Duke Energy 1 48 Entrainment Characterization Study Plan L�i McGuire Nuclear Station r C entrainment. The Tucker trawl had 710 -Nm mesh with a 1 m2 (10.8 feet2) effective opening. Samples were collected perpendicular to the intake (starting as near as possible to the intake). Samples were collected at two depths — surface to the top of the intake structure opening (about 4.6 m [15 feet]) and from the intake opening to the bottom of the intake structure (4.6 m [15 feet] to 14 m [50 feet]). Each stratum was towed obliquely. Trawl durations were 2 to 5.5 minutes and collected every two hours starting at about 30 minutes after sunset and extending until sampling with all the other gear types was completed. Two or three sets of tows were made on each night. Results were variable by gear type (Table C-2). Few shad were collected by pumped sampler on 6 and 7 June due to a ripped seam in the net. Trawl samples from the upper stratum were greater in number than the lower stratum. While not identified by the authors, it should be noted that it is difficult to measure the flow sampled with the fine -mesh screen approach. Differential open area between the fine -mesh overlay and the surrounding coarse -mesh panels would likely have resulted in flow diverting to the coarse -mesh panels or gaps between panels, side seals, and the screen boot preventing accurate measurement of volumes sampled. In most cases, the samples collected at the condenser tap were higher than what was observed in the lower trawls. There were no significant differences in ichthyoplankton density by date (P = 0.83), but there were differences by gear type. Mean densities of the pumped samples were not significantly different from the tap samples (P = 0.60). Stationary nets and fine -mesh screen collections were significantly different from one another and from the pumped and tap collected samples (P < 0.05). Length frequencies between the pump and tap samples were not significantly different from one another. Mechanical damage from collection was minimal for all four techniques with the highest observed damage associated with pump passage (3 percent unidentifiable). Tap sampling was considered for use at McGuire for the 2016 entrainment program, but was eliminated because of concerns with access to secure locations within the power plant. This study indicates that the selected method for entrainment monitoring (pumped sampling) is statistically no different than measuring ichthyoplankton density at the condenser tap and better than a streamed net. Duke Energy 1 49 Entrainment Characterization Study Plan FN Nuclear Station Table C-2. Total Number (N) and Mean Densities (MD) (mean number of shad/ 1,000 m) of All Shad Collected with Comparison Gear and Shad <28 mm Total Length Collected with a Tucker Trawl on Lake Norman, North Carolina, 6-10 June 1982, with Average Volume of Water Filtered per Sample (m) (Leonard and Vaughn 1985) Jun 6 0 0.0 2 -- a 1 ° -- ` 5 56.4 164 195.3 27 27.9 Jun 7 0 0.0 8 34.0 6° -- ` 12 182.0 590 410.5 190 70.7 Jun 8 1 4.7 15 53.0 38 91.1 10 103.0 659 536.4 75 43.1 Jun 9 1 7.0 11 43.0 80 196.9 25 346.1 511 666.1 86 76.4 Jun 10 0 5.0 10 32.1 36 82.4 4 82.0 279 406.5 134 85.7 Total 2 0.0 46 161 56 2,203 512 Ave. Sample 29 92 65 38 206 317 Volume (m3) a - Unable to calculate volume ° - Number not considered valid due to malfunctioning equipment `- Density not calculated on invalid data Taggart, C.T. and W.C. Leggett. 1984. Efficiency of Large -Volume Plankton Pumps, and Evaluation of a Design Suitable for Deployment from Small Boats. Canadian Journal of Fisheries and Aquatic Sciences 41(10) 1428-1435. Taggart and Leggett (1984) identified and evaluated five major studies that compared the efficiency of large -volume pumps (defined as withdrawing > 0.5 m3/min [132 gpm]) and nets (Table C-3). In addition the authors evaluated a boat mounted large -volume pumping system. Taggart and Leggett (1984) found, in general, that among the reviewed studies, densities of organisms sampled with the pumps was equal to or greater than the densities in the towed net samples, but there were differences based on length classes and time of day. The authors pointed out that the gear configurations relative to towed net diameters, pump intake diameter, the presence of intake screens, intake velocities and mesh sizes were highly variable between the studies, which made it difficult to compare. The authors were particularly critical of the lack of accurate flow measurement used in many of these studies. Despite these challenges, no systematic biases were detected. In addition to the literature review, Taggart and Leggett (1984) tested a large -volume pump system with standard plankton nets. The boat mounted system used a 22.2 -cm (8.7 -inch) impeller that could pump up to 1.7 m3/min (450 gpm) depending upon head. Divers confirmed the inlet was oriented into the direction of travel. Simultaneously to pump sampling, a 0.5-m (1.6 -feet) diameter 2-m (6.6 feet) long 80- and 153 -pm mesh standard plankton nets were also Duke Energy[ 50 Entrainment Characterization Study Plan FN Nuclear Station fished. Three sets of comparisons were made. In 1981 an 80 -atm net was towed immediately below the surface 2 m (6.6 feet) behind the pump intake. In 1982 and 1983 a 153 -Nm net was towed immediately below the surface 13-15 m (43-50 feet) astern of the pump sampler. The pump intake was maintained at a depth of 0.25 m (0.8 feet) for all comparisons. The authors concluded that the nets and pumped sampler were equally effective in capturing Capelin (Mallotus villosus) larvae (5 -mm length), Atlantic Herring (Clupea harengus) larvae (9 - mm length), large copepods (>750 pm), small jellyfish, and hyperiid amphipods, despite only sampling 8 percent of the water volume sampled by the nets. In addition, the pump was more efficient at collecting crab zoea and megalops larvae and efficiency of collecting euphausiids and chaetognaths increased as their natural densities increased. Nets were superior in the capture of fish eggs (primarily Cunner, Tautogolabrus adspersus), possibly due to the vertical distribution of eggs in the water column. The average length of capelin larvae captured by pumping was consistently 0.2 mm longer than that of larvae taken in nets, but the length— frequency distribution of larvae sampled was similar to that of larvae entering the pelagic environment. The very fine meshes and small organism sizes likely contributed to the high collection efficiency of the pumped sampler used by Taggart and Leggett (1984) as other studies reviewed here indicate it is the larger more motile life stages that tend to be collected more efficiently by nets than by pumped samplers. Like other studies that have towed the pumped sampler inlet through the water, it is unclear whether these results are directly applicable to the application being implemented by Duke Energy. Despite these uncertainties, this study seems to support use of pumped samples for estimating ichthyoplankton and zooplankton densities. Duke Energy 1 51 Entrainment Characterization Study Plan McGuire Nuclear Station FN Table C-3. Summary of Major Studies Designed to Comparatively Evaluate the Sampling Efficiency of Various Large -Volume Pumps and Tow Nets (Taggart and Leggett 1984). Reference Type and mesh size (µm) Pump flow (m'lmin) Suction Diameter Velocity (m) (m/s) Tow net and mesh size (µm) Tow or current speed (M/s) - Pump Net Volume sampled (m') Pump Net Gear comparison protocol Aron 1958 Centrifugal, 1.514 0.076 5.55 0.5 -m -dia. std., 1.7' 1.7' 15 200 50 paired hauls "near 544 silk 476 nitex surface" (marine) Portnerand Rohde Tandem propeller, 8.6 0.20 4.60 0.5 -m -dia. std., Local current 86' 44' 111 paired stationary 1977 5W nitex 500 nitex 0.4 samples at 4.5, 8, and 9 m (riverine) Gale and Mohr Open impeller 2.5 0.10 5.30 0.24 x 0.54-m-rect., Local current 7 stationary sets of 4 pump 1978 centrifugal, 400 x 800 nitex "moderate -strung" - - and 8 net replicates 4W x 8W nitex (0.24)" (0.92)° at surface and bottom (riverinc) Leithiser et al. Fish transfer, 2.1 0.15 1.92 (a)1 -m-&. cyl.-Cone, Local current (a) 62 121 (a) 10 stationary pairs at 1979 335 nitex 335 nitex (a) 0.26 0.5-1.5 m depth (riverine) (h) as in (a) and (b) 0.30 (b) 64 414 (b) as in (a) above 0.5-m dia. std., 64 105 363 nitex Cada and Loar Open impeller 1.10 0.076 4.04 0.5 -m -dia. "Slowly" 1.2-1.9 17 85 -IW 3 sets of 3 replicates not 1982 243 nitex (0.021)' (1.1)° Hcnsen net, paired in time at 243 nitex 0- 0.5 m depth (riverine) 'Estimated from data provided in paper referenced. "Measured at intake, which differs in size from suction hose. Duke Energy 1 52 Entrainment Characterization Study Plan McGuire Nuclear Station Results FN The literature review, as described in detail above, indicates that there have been several studies that have compared the effectiveness of pumps and net sampling. In general, the results have been equivocal with no clear pattern of one gear type out performing the other. The most extensive power plant entrainment gear comparison studies were undertaken at the Indian Point Generating Station on the Hudson River (EA 1978; 1979; 1981; King et al. 1981; NAI 1982; 1987 — as cited in EPRI 2014)''. The results of these studies indicated no consistent differences in estimated densities between the two gear types (EPRI 2014). There is some indication that at relative low velocities, high-volume pumped samples collect higher densities of ichthyoplankton than nets (Leithiser et al. 1979). In a southeastern reservoir (Tennessee), Cada and Loar (1982) found that for most length classes there were no significant differences in density between pump and net samples. The data suggest that avoidance is more common during daylight hours in clear water when organisms can observe and avoid the gear. At night and/or in turbid water avoidance is minimized (Cada and Loar 1982; Harris et al. 1986). Petering and Van Den Avyle (1988) collected significantly lower densities of fish larvae in a Georgia reservoir using a pumped sampler as compared to nets, but there are concerns with the methods and gear, as described in detail above, that could account for some of these differences. Leonard and Vaughn (1985) sampled Threadfin Shad and Gizzard Shad using pumps, a streamed net, a fine -mesh panel on a traveling screen, and a tap at the condenser at the McGuire Nuclear Station and reported the highest density at the condenser tap where the water was well mixed. Leonard and Vaughn (1985) reported the highest rate of damaged larvae from the pumped samples, but damage was <_ 3 percent. Gear avoidance occurs with both pumps and nets and increases with increasing fish length, which is likely a result of increased swimming ability, maturing fish sensory systems, and avoidance behavior. Caution should be used when applying the results of specific previous gear efficiency studies to the Duke Energy entrainment program because of the variability in gear types and sampling techniques used in these studies (e.g., net type and shape; mesh sizes and material; methods of gear deployment; deployment location; flow metering; inlet orifice size, shape, and orientation; inlet velocity; impeller size, shape and material; mechanism for suction [vacuum, diaphragm, centrifugal]; and pumping capacity). Instead, the weight -of -evidence across scientifically sound studies should be used which supports pumped samples as being generally equal in terms of collection efficiency to towed and streamed nets. Conclusions Nets and pumps are the two primary methods by which ichthyoplankton densities are estimated at power plant intakes. Pumped samplers have been used successfully in a wide variety of deployment conditions at power plants in the U.S. routinely since the 1970s. This method has " During the peer review kick off meeting, a biological peer reviewer mentioned an Indian Point Generating study evaluating the effectiveness of fine -mesh wedgewire screens to reduce entrainment. As part of that study, samples were collected by nets and pumps. That study was not reviewed here for several reasons: a) the study was not designed to compare gear types, b) the sampler used for pump sampling at Indian Point was a unique design that is dissimilar from what is being proposed at the Duke Energy facilities; and c) Indian Point is part of on-going 316(b) -related litigation and those study reports are not readily available to the public. Duke Energy 1 53 Entrainment Characterization Study Plan FN Nuclear Station been well vetted by regulatory agencies including in the northeastern U.S., which along with California, has historically applied the most stringent 316(b) requirements in the nation. In addition, pumped samplers continue to be accepted for 316(b) monitoring as evidenced by the list of states where these samplers are deployed or approved to be deployed to support 316(b) evaluations under the final Rule. Importantly, the final Rule became effective October 14, 2014 and many facilities have not yet chosen the method by which they intend to sample entrainment and the list of states approving pumped samplers is likely to increase. Studies that have evaluated nets and pumps have shown no clear pattern of one technology outperforming the other. The results from published and unpublished industry studies are equivocal with some examples suggesting that pumped samples outperform netted samples and vise -versa. Perhaps the greatest impediment to determining the collection efficiency of gear from existing data is the lack of standardized techniques for netting (e.g., net type, net shape, mesh sizes, mesh materials, methods of deployment, deployment location, and flow metering) or pumped samples (e.g., orifice size, orifice orientation, inlet velocity, impeller size, impeller shape, impeller material, mechanism for suction [vacuum, diaphragm, centrifugal], deployment location, and pumping capacity). These factors, along with site-specific hydraulics and life history characteristics of the early life stages of fish sampled, are likely to impact the performance of both collection systems. Further, short of a duplicative sampling with both sampling systems in tandem, it is unlikely that a study program could be developed that would provide the necessary data to develop a universal correction factor that could be used to quantitative adjust entrainment estimates. We acknowledge that no system for sampling ichthyoplankton densities is perfect given the patchy temporal and spatial distribution of fish eggs and larvae and inherent biases of all gear types. That said, the available data indicate that pumped samplers can be as efficient as nets. Because entrainment monitoring by pumped sampling is commonly used, widely accepted, and has practical advantages over using nets at the Duke Energy facilities, our recommendation is that no gear efficiency testing is necessary or warranted. Duke Energy 1 54 Entrainment Characterization Study Plan McGuire Nuclear Station References FN Aron, W. 1958. The Use of Large Capacity Portable Pump for Plankton Sampling, with Notes on Plankton Patchiness. Journal of Marine Research 16: 158-173. Bowles, R.R. and J.V. Merriner. 1978. Evaluation of ichthyoplankton sampling gear used in power plant entrainment studies. In L. Jensen (ed.). Fifth National Workshop on Entrainment and Impingement. Pp. 149-158. Cada, G.F. and J.M. Loar. 1982. Relative Effectiveness of Two Ichthyoplankton Sampling Techniques. Canadian Journal of Fisheries and Aquatic Sciences 39(6): 811-814. Elder, J.A., J.W. Icanberry, D.J. Smith, D.G. Henriet, and C.E. Steitz. 1979. Assessment of a Large Capacity Fish Pump for Sampling Ichthyoplankton for Power -plant Entrainment Studies. California Cooperative Oceanic Fisheries Investigation 20: 143-145 Ecological Analysts, Inc. (EA). 1978. Indian Point Generating Station Entrainment Survival and Related Studies 1977 Annual Report. Consolidated Edison Company of New York, Inc. _. 1979. Indian Point Generating Station Entrainment Survival and Related Studies: 1978 Annual Report. Consolidated Edison Company of New York, Inc. . 1981. Indian Point Generating Station Entrainment and Near Field River Studies: 1979 Annual Report. Consolidated Edison Company of New York, Inc.; Power Authority of the State of New York.. Electric Power Research Institute (EPRI). 2014. Entrainment Abundance Monitoring Technical Support Document: Updated for the New Clean Water Act §316(b) Rule. 3002001425. EPRI, Palo Alto, CA. 156 pp. Gale, W. R, and H. W. Mohr, Jr. 1978. Larval Fish Drift in a Large River with a Comparison of Sampling Methods. Transactions of the American Fisheries Society 107:46-55. Gibbons, S.G. and J. H. Fraser. 1937. The Centrifugal Pump and Suction Hose as a Method of Collecting Plankton Samples. Journal du Conseil / Conseil Permanent International pour I'Exploration de la Mer. 12: 155-170. Harris, R.P. L. Fortier, and R.K. Young. 1986. A Large -Volume Pump System for Studies of the Vertical Distribution of Fish Larvae Under Open Sea Conditions. Journal of the Marine Biological Association of the United Kingdom 66(4): 845-854. King, L.R., B.A. Smith, R.L. Kellogg, and E.S. Perry. 1981. Comparison of ichthyoplankton collected with a pump and stationary plankton net in a power plant discharge canal. In L. Jensen (ed.), Issues associated with Impact Assessment, Fifth National Workshop on Entrainment and Impingement. Pp. 267-276. Duke Energy 1 55 Entrainment Characterization Study Plan McGuire Nuclear Station FN Leithiser, R.M., K.F. Ehrlich, and A.B. Thum. 1979. Comparison of a High Volume Pump and Conventional Plankton Nets for Collecting Fish Larvae Entrained in Power Plant Cooling Systems. Journal of the Fisheries Research Board of Canada, 1979, 36(1): 81-84. Leonard, T.J. and G.E. Vaughn. 1985. A Comparison of Four Gear Types to Measure Entrainment of Larval Fish. Proceedings of the Annual Conference of the Southeast Association of Fish and Wildlife Agencies 39: 288-297. Normandeau Associates, Inc. (NAI). 1982. Gear comparability study for entrainment sampling of juvenile fish at the Indian Point Station, 1981. _. 1987. Indian Point Generating Station Entrainment Abundance Program 1985 Annual Report. Prepared for Consolidated Edison Company of New York, Inc. and New York Power Authority. Petering, R W and M.J. Van Den Avyle. 1988. Relative Efficiency of a Pump for Sampling Larval Gizzard and Threadfin Shad. Transactions of the American Fisheries Society 117: 78-83. Taggart, C.T. and W.C. Leggett. 1984. Efficiency of Large -Volume Plankton Pumps, and Evaluation of a Design Suitable for Deployment from Small Boats. Canadian Journal of Fisheries and Aquatic Sciences 41(10) 1428-1435.. Duke Energy 1 56