20070812 Ver 2_Discharge Sampling Narrows Dam_20080620

ALC 'A
June 20, 2008
HAND-DELIVERY
Cyndi Karoly, Supervisor
Division of Water Quality
N.C. Department of Environment & Natural Resources
401 Oversight/Express Review Permitting Unit
2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604
Dear Ms. Karoly:
Alcoa Power Generating Inc.
Yadkin Division
PO Box 576
Badin, North Carolina 28009-0576
Tel: [phone]
Fax: [phone]
www.alcoa.com/yadkin
Enclosed please find five copies each of (1) a plan for sampling the discharge from
the Narrows dam and (2) a plan for sampling lake sediment in transects from the
Alcoa Badin Works facility to the Narrows dam. The plans have been prepared in
satisfaction of the Request for More Information dated May 23, 2008. Per your
request, by copy of this letter we are also providing copies of the plans to Alan
Johnson of the DWQ Mooresville Regional Office and we are providing courtesy
copies to John Dorney.
Please feel free to contact me at [phone] if you have any questions
regarding these plans. We trust that upon receipt of this requested information, the
APGI application for 401 Certification will be considered complete.
Sincerely yours,
Gene Ellis
Licensing & Property Manager
cc: Alan Johnson, MRO, w/enc
John Dorney, w/enc
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JUN 2 0 {008
DENR - WATER QU I -r
WETLANDS AND STORMWA R B€"C;H
Prepared for:
Alcoa Power Generating Inc., Yadkin Division
Badin, North Carolina
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Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in
the Narrows Tailrace
ENSR Corporation
June 2008
ENSR
Prepared for:
Alcoa Power Generating Inc., Yadkin Division
Badin, North Carolina
Yadkin Project (Project No. 2197)
Sampling Plan for Priority Pollutants in
the Narrows Tailrace

Prepared By

Reviewed By
ENSR Corporation
June 2008
ENSR
ENSR
Contents
1.0 Introduction and background .............................................................................................................. 1-1
2.0 Location of sampling ............................................................................................................................. 2-1
3.0 Timing of sampling ................................................................................................................................ 3-1
4.0 Sampling methods ................................................................................................................................. 4-1
5.0 Analytical methods ................................................................................................................................ 5-1
6.0 Data analysis, reporting and contingency sampling ........................................................................ 6-1
7.0 References ..............................................................................................................................................7-1
List of Appendices
Appendix A Figures and tables
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
June 2008
ENSR
List of Tables
Table 1. Parameters to be measured in this study and analytic methods proposed .........................................7
List of Figures
Figure 1. Narrows (Badin Lake) and Falls Reservoir sampling stations (adapted from Normandeau 2005) ...3
Figure 2. Narrows tailrace sampling station (continuous monitor is at station F1) and transects used to
evaluate tailrace mixing to confirm monitor placement (adapted from Normandeau 2005) ...............4
Figure 3. Temperature and dissolved oxygen profiles in Narrows Reservoir near the dam from 1999 to 2003 (y
axis scale of 100 to 160 meters is equivalent to 328 to 525 feet) (adapted from Normandeau 2005).
............................................................................................................................................................... 5
Figure 4. Narrows water level, 1999 - 2004 (y axis scale of 150 to 160 meters is equivalent to 492 to 525 feet)
(adapted from Normandeau 2005) .......................................................................................................6
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
June 2008
ENSR
1.0 Introduction and background
Alcoa Power Generating Inc. (APGI) is currently licensed by the Federal Energy Regulatory Commission to
operate four hydroelectric developments (Yadkin Project - FERC No. 2197 NC) on the Yadkin River in central
North Carolina, and has an application for new license pending before FERC. The original license was issued
for a period that ended April 30, 2008, and FERC has issued on a year-to-year basis an annual license to
APGI under the terms and conditions of the prior license until the new license is issued. A prerequisite of the
new license is the receipt of water quality certification from the State of North Carolina under Section 401 of
the Clean Water Act.
As part of the relicensing process, APGI sought comment from agencies, municipalities, organizations and the
public on concerns related to the water quality at the Project. The principal concerns are the current status of
water quality in the reservoirs and tailwaters and the effects of hydroelectric facility operations on water quality.
APGI voluntarily initiated water quality monitoring in the reservoirs and tailwaters in 1999 to establish baseline
water quality conditions and assess the current status of water quality. Baseline studies are summarized in
Normandeau (2005). In May 2007, APGI filed an application for Section 401 Water Quality Certification. At the
request of the NC Division of Water Quality (NCDWQ), APGI's 401 application was withdrawn and re-filed on
May 8, 2008.
By letter dated May 23, 2008, the NCDWQ has requested additional information to be included in the pending
application for water quality certification under Section 401 of the Clean Water Act. This work plan responds to
Item 1 of the letter from Cyndi Karoly of the NCDWQ to Mark Gross of APGI dated May 23, 2008. This item
states that:
• APGI must provide a written plan for sampling the discharge from the Narrows (Badin Lake) dam for
pollutants to include heavy metals and organic pollutants including volatile organic compounds, acid
extractable compounds, base-neutral compounds, and PCBs using a priority pollutant scan analyzed
in accordance with 40 CFR Part 136. This analysis must be conducted by a DWQ-certified laboratory.
APGI recognizes that there is variability in water quality conditions in the tailrace in response to changes in
flow, generation, spill and lake level and has attempted to take this into account in the development if this plan.
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
1-1 June 2008
ENSR
2.0 Location of sampling
APGI proposes to sample water quality in the tailrace of Narrows dam at the historic water quality sampling
station F-1 (N 350 25'05.637", W 801 05'28.767") as referenced in Normandeau (2005). This station has
been sampled frequently for nutrients and continuously for dissolved oxygen and temperature during
stratification periods over the past 9 years. These historic data will be helpful in interpretation of the testing
data to be generated by this plan. A series of surveys conducted by Normandeau (2005) confirmed that the
Narrows tailrace is well mixed and that water quality at sampling station F-1 is representative of conditions in
the Narrows tailrace. Station F-1 is depicted in Figures 1 and 2.
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
2-1 June 2008
ENSR
3.0 Timing of sampling
Narrows Reservoir, as the deepest impoundment in the Yadkin Project, is the only one that consistently
thermally stratifies. Associated with this thermal stratification is anoxia in the deeper portions of the
impoundment including the hypolimnion (deep cold layer), metalimnion (transitional layer) and the lower
portion of the epilimnion (warmer surface layer). Any contaminants in the sediments being studied under this
plan (particularly metals) are more likely to be mobilized under anoxic conditions. The samples will be
collected to reflect those anoxic conditions under which it is most likely that sediment contamination might be
migrating. The proposed tailrace sampling period has been chosen to coincide with a period of strong thermal
stratification and resulting anoxia in Narrows Reservoir. This period generally encompasses June through
early October with the strongest stratification and anoxia generally occurring from July through September
(Figure 3). Many of the substances which are the focus of this investigation are found in littoral zone
sediments in the vicinity of the Badin Works on Narrows Reservoir. Migration of these contaminants via
surface water from this zone may be maximized during low water when exposed sediments are eroded by
surface water runoff and deeper sediments are disrupted by wave action from wind driven waves and wakes
from boat traffic. Historic water levels on Narrows Reservoir are presented in Figure 4. Although water levels
do not fluctuate greatly in Narrows Reservoir, historically water levels have been at or near their lowest in from
July through mid-September. Because this period encompasses both the occurrence of low water and
reservoir anoxia, July through mid-September will be the target period for the sampling. Furthermore, flows
through the Yadkin Project are typically at a minimum during the July through mid-September period,
minimizing any potential dilution of substances and maximizing concentrations in the Narrows tailrace.
Most of the water that passes through the Narrows dam during the July to September period passes through
the turbines during generation. Sampling will be timed to occur during a period of generation from at least 1
unit at Narrows. Sampling will not start until at least 2 hours after the commencement of generation to allow
the tailrace to come to equilibrium, such that samples taken from Station F-1 will be representative of the
quality of water discharged. This time period was demonstrated to be appropriate during air injection testing at
Narrows in 2001 and 2004 (Normandeau 2005).
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
3-1 June 2008
ENSR
4.0 Sampling methods
A single sampling event will be scheduled to occur in July-August, 2008. For this sampling event the
discharge from Narrows dam/powerhouse will be sampled by collecting surface water samples at Station F-1.
Station F-1 is a historic water quality sampling station located just downstream of the Narrows powerhouse.
This station is in the tailrace and well mixed so samples will be collected from the surface. Samples collected
will include a field blank and replicate water samples for analysis of all water quality parameters. U.S. EPA's
field procedure for Clean Hands (CH)/Dirty Hands (DH) surface water sampling techniques (EPA Method 1669
Section 8.2.8) will be used as a general guideline for surface water sample collection. This method will allow
low levels of metals to be detected without atmospheric or sampling environment contamination. Sample
laboratory analyses and methods are listed in Table 1.
The sample containers will be pre-labeled by the sampling task manager. The labels with the sample
identification number will be attached directly to the sample containers, or to the inner bag for the low level
metals analysis. Each low level metals sample container will be double bagged to maintain the cleanliness and
integrity of the container. Per U.S. EPA methods, the CH sampler will come into contact only with the inner bag
and the sample container. The DH sampler will complete the remainder of the activities.
Once the sample container is removed from the inner bag, the container will be submerged, capped, directly
into the water. While under water, the sample cap will be removed, the bottle will fill with water, and the sample
cap replace prior to removing from the water column. Care will be taken to collect the sample upstream of the
outboard motor on the boat.
Sample containers containing preservative will not be submerged directly. Rather, a clean non-preserved
amber glass container will be submerged using the techniques described above, and the surface water will be
transferred to the preserved sample container. A sample label listing sample identification number, sample
date and time, analysis, preservative, and sampler names will be included inside the outer bag.
Field notebooks and sample collection forms will be used to record pertinent data while sampling. All samples
will be stored on ice (at 4°C), packed in coolers, and shipped under chain of custody for laboratory analyses to
a North Carolina laboratory certified for the parameters to be analyzed.
Field replicates will be collected in separate containers. A field blank will be collected by filling a non-
preserved amber container with reagent-grade deionized water.
Field parameters will be collected at the surface following collection of the surface water sample. Water depth,
dissolved oxygen (DO), temperature, conductivity, turbidity, and pH will be measured with a YSI 600 XL, or
equivalent. Field parameters will be measured by submerging the instrument probe directly in the surface
water, and recording the measurements after stabilization.
A profile of dissolved oxygen, temperature, pH and specific conductance will be recorded from Narrows
Reservoir at station N-4 (Figure 1) on the day of the tailrace survey to confirm that the impoundment conditions
represent a period of stratification and anoxia. Visual observations including weather will also be recorded in
the field logbook. The field instrument will be pre- and post calibrated for quality assurance purposes.
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
4-1 June 2008
ENSR
5.0 Analytical methods
Parameters to be collected along with methods of analysis are presented in Table 1. Laboratory analysis will
be conducted by a NCDWQ certified laboratory, following their approved protocols.
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
5-1 June 2008
ESR
6.0 Data analysis, reporting and contingency sampling
Data collected as a part of this sampling plan will be compiled in a data report. Concentrations will be
'presented along with method detection limits and North Carolina standards for Class C and WS surface
waters. Field data and weather, dam operations and water level observations will also be reported. Quality
control information will be reported along with explanations of any anomalies in the field or laboratory program.
Should concentrations of priority pollutants in the Narrows tailrace collected as a part of this program be
detected in concentrations in excess of North Carolina Class C or WS standards, the following steps will be
considered after consultation with NCDWQ. First, a confirmatory sampling round will be conducted with the
procedures described above and under similar environmental conditions (Narrows Reservoir stratified with
anoxia). During this sampling round, samples will be collected in the Narrows tailrace (station F-1), in the
epilimnion and hypolimnion of Narrows Reservoir (station N-4), in the littoral zone in the embayment adjacent
to the Badin Works and in the tailrace of the Tuckertown dam at the upper end of Narrows Reservoir (station
N-1).
Should the results of the first confirmatory round of sampling indicate that there may be an export of priority
pollutants through the Narrows dam, after consultation with NCDWQ, additional sampling will occur to
determine if this export occurs under other conditions of flow, water level and reservoir stratification.
Specifically, sampling will occur during two other target periods; after fall turnover in Narrows Reservoir and
during high spring flows. Should this sampling be required, it will encompass stations F-1, N-1, N-4 and a
station near the Badin plant as suggested for the confirmatory sampling. Field profiles and flow records will be
consulted prior to sampling to insure that the target conditions are present. Depending on results of the initial
sampling rounds, samples collected during confirmatory and follow up sampling rounds (if required) may only
include a subset of analytes from the original list. Reduction of the analyte list will only occur after consultation
with and approval of the NCDWQ.
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
6-1 June 2008
ENSR
7.0 References
Normandeau Associates. 2005. Yadkin Project, FERC No. 2197 NC, Yadkin Water Quality Monitoring Report,
Final Study Report. Prepared for ALCOA Power Generating Inc., Yadkin Division.
RETEC. 2007. Characterization of the Toxicity and Bioavailability of Polycyclic Aromatic Hydrocarbons in
Aquatic Sediments from Narrows Reservoir. Prepared for Aluminum Corporation of America, Alcoa Center,
Pa.
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
7-1 June 2008
ESR
Appendix A
Figures and Tables
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
June 2008
ENSR
Figure 1. Narrows (Narrows Reservoir) and Falls Reservoir sampling stations (adapted from
Normandeau 2005)
Rox•an (County Randolph Co.
X - - -- '- --1--
Montgomery Connty
i
?l
;^ ItW
i / j
'Fuckertoa•n
Dam `
MA JW
? Manly County _ N2 • N3
Nanmvs
? i Resenrolr
I i
t ? l
Dam
?1?-Falls Dam
F2 i
3
f3
Water Quality Sampling Stations
--- County Boundary in Falls and Narrows Reservoirs
Yadkin Project
• Sampling Locations (2 of 2) _
Hydrog-phy N
-, s September2002 °' Figure 2
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
June 2008
ENSR
Figure 2. Narrows tailrace sampling station (continuous monitor is at station F1) and transects used to
evaluate tailrace mixing to confirm monitor placement (adapted from Normandeau 2005).
June 2008
ENSR
Figure 3. Temperature and dissolved oxygen profiles in Narrows Reservoir near the dam from 1999 to
2003 (y axis scale of 100 to 160 meters is equivalent to 328 to 525 feet) (adapted from
Normandeau 2005).
E
C
O
N
W
Dissolved Oxygen (mg/L) at Station N4
160
155
150
145
140
135
130
125
120
115
110
105
100
i
M rn m ai M 0 0 0 0 0
0 rn o 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Z 3- -J ~ z d' J ~ Z W J 0 Z J 0 Z ?' J ~ Z
Q Q 7 O 7 Q - O a Q 7 Q Q Q Q ' O Q
Month
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
June 2008
ENSR
Figure 4. Narrows water level, 1999 - 2004 (y axis scale of 150 to 160 meters is equivalent to 492 to 525
feet) (adapted from Normandeau 2005).
NARROWS
160
159
158
157
75 156
Z
O
Q 155
J 154
W
153
152
151
150
FULL POND
Jan I Feb l Mar l Apr IMay l Jun Jul IAug ISep I Oct INov IDec I
YEAR: 1999 2000 2001
2002 2003 - 2004
AVERAGE
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
June 2008
ENSR
Table 1. Parameters to be measured in this study and analytic methods proposed.
Parameter Method Number
Heavy metals EPA 1631
Volatile Organic Compounds (VOC) EPA 624
Acid-extractable compounds EPA 625
Base-neutral compounds EPA 625
PCB's EPA 6-8
Yadkin Project (FERC No. 2197)
Sampling Plan for Priority Pollutants in the Narrows Tailrace
June 2008