NC0004979_Entrainment Characterization Study Plant_20160502

DUKEEnvironmental Services
ENERGY, Duke Energy
526 South Church Street
Charlotte, NC 28202
Mailing Address:
Mail Code EC13K!P.O. Box 1006
Charlotte, NC 28201-1006
May 31, 2016
REC E!V EDINCDEQIDWR
Mr. Tom Belnick, Supervisor JUN 0 2 2016
NPDES Complex Permitting Water Quality
NC DEQ/DWR/WQ Permitting Section Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Allen Steam Station
National Pollutant Discharge Elimination System - Permit No. NC0004979
316(b) Entrainment Characterization Study Plan (ECSP)
Dear Mr. Belnick:
Please find enclosed the final Entrainment Characterization Study Plan (ECSP) for Allen Steam
Station. The plan incorporates comments from the fisheries biologists peer reviewers, as well as
comments from the North Carolina Department of Environmental Quality (NCDEQ) received on
March 3, 2016. Responses to comments from NCDEQ are also enclosed.
If you have any questions or comments, please contact Nathan Craig at Nathan.Craig@duke-
energy.com/704-382-9622 or Randy Gantt at [e-mail] /704-829-2587.
Sincerely,
nAJjq-
P. Brent Dueitt
General Manager II
Allen Steam Station
Attachments:

Bc: Randy Gantt
Ross Hartfield
Nathan Craig
Linda Hickok
Tom Thompson
Matt McKinney
HDR, Inc. (Ty Ziegler)
UPS Tracking: 12)(67 601 42 9802 4805

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RECEIVEDiNCDEQIDVJR
JUN 0 2 2015
Water Quality
Permitting Section
Response to NCDEQ
Comments:
Entrainment Characterization Study
Plan — Allen Steam Station
Prepared for:
etioN EUKE
NERGY
Prepared by:
HDR Engineering, Inc.

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Entralmnent Ctractatation Study Plan ���
Response to NCDEO Comments-Men Steam Station
Contents
1 Introduction 1
2 Development of Entrainment Characterization Study Plans 1
3 Twice per Month Sampling fa Estimating Entrainment 3
3.1 Conclusion 5
References 6
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Response to NCDEQ Comments—Men Steam Station
1 Introduction
The U.S. Environmental Protection Agency's (EPA) rule implementing §316(b) of the Clean
Water Act(the rule)was published on August 15, 2014 in the Federal Register. The rule applies
to existing facilities with design intake flows (DIF)of more than 2 million gallons per day(MGI))
that withdraw from Waters of the United States, use at least 25 percent of that water exclusively
for cooling purposes, and have or require an NPDES permit. Existing facilities with an actual
intake flow x 125 MGD are required to provide an entrainment characterization study (at 40
CFR 122.21(rx9)) as part of its permit renewal application materials. Duke Energy facilities in
the Carolinas that meet the 125 MGD flow threshold are proposing a two-year entrainment
sampling program to gather the information necessary to fulfill the entrainment characterization
requirements. The goal of the proposed program is to estimate the seasonal and annual total
abundance of fish eggs and larvae that are drawn into the cooling water systems. Entrainment
sampling at each facility is proposed from March through October of 2016 and 2017.
2 Development of Entrainment Characterization
Study Plans
An Entrainment Characterization Study Plan (ECSP) was developed Allen Steam Station
(Allen). The ECSP describes the sampling design and site-specific approach being used at
Allen to sample for entrainment; the rationale for the selection of gear type, sampling location,
and other components of the sampling design; and a discussion on how the study fulfills the
requirements of the rule. While not required to undergo a peer-review, a draft of the ECSP was
sent to a subject matter expert in fisheries biology for an independent review. After addressing
comments and incorporating relevant changes, the final ECSP was sent to the Director for
comment. Comments were received from Bryn H. Tracy(Senior Environmental Specialist, North
Carolina Department of Environmental Quality [NCDEQ]) by email on March 3, 2016. We thank
Mr. Tracy for his comments and have provided responses in Table 2-1.
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Entrainment Characterization Study Plan
Response to NCDEQ Comments-Allen Steam Station
Table 2-1. Responses to Bryn H. Tracy (Sr. Environmental Specialist, North Carolina Department of Environmental Quality)
Comments on the Entrainment Characterization Study Plan for Allen Steam Station
Facility Comment Response and Resolution
The pumps at Allen are not equipped with variable speed pumps so each pump is on or
off.The difference between actual intake flow and design intake flow rates(as shown in
Table 2-1 of the ECSP)is determined by the number of pumps and units in operation
and the length of time they are operated.
Page 6,Table 2-1:a)Do the pumps operate variably or do they operate at
maximum design flow all the time? If they operate variably,how will you For entrainment,the underlying assumption used by EPA is that entrainable organisms
Allen account for this? For example,would you expect more or fewer organisms to are passive and move with the flow.Therefore,reduction in flow results in a
be entrained when the pumps are operating at the design flow rate vs.when commensurate reduction in entrainment.In your scenario,we would anticipate that a 50
they are operating at 50%of the design flow rate? percent reduction in flow would result in a 50 percent reduction in entrainment.
Entrainment data will be normalized by the volume of water sampled so that it will be
expressed as the number of organisms per volume of water.This convention will allow
for estimation of changes in entrainment rates based on the number of pumps and units
in operation.
Units are dispatched to meet system loads,at the lowest possible costs,and subject to
Allen b)This relates to your choice of using Units 2 and 3: are Units 2 and 3 always transmission and operational constraints.Units 2 and 3 were selected because they are
in use? Why not use Units 4 and 5 or Units 1 and 2? centrally located In the CWIS and are more frequently operated than some of the other
units.
Page 16,first and second paragraphs a)Please provide reason(s)as to why
you decided on bi-weekly sampling(or is it just twice a month?)vs.weekly
Allen sampling.I attended an NC AFS workshop in 2005 lead by Dr.Doug Dixon Please see Section 3-Twice per Month Sampling for Estimating Entrainment.
(EPRI)and I have in my notes that bi-weekly sampling is more biased than
more frequent sampling.
b)Please provide reason(s)as to why you decided on bi-weekly sampling(or
Allen is it just twice a month?)vs.weekly sampling.I attended an NC AFS workshop Please see Section 3-Twice per Month Sampling for Estimating Entrainment
in 2005 lead by Dr.Doug Dixon(EPRI)and I have in my notes that bi-weekly
sampling is more biased than more frequent sampling.
c)Given that the limited historical studies(page 11)showed very few Laboratory costs are charged on a per sample basis.Even samples with little debris and
organisms collected in the 1970s,it would seem that adding replication to your few eggs and larvae still need to be processed and subjected to QC procedures to
Allen study design would not substantially increase your laboratory time,unless the ensure all organisms have been removed for identification.Replication increases the
reservoirs productivity is far greater(more eutrophic)than it was 40 years ago number of samples and directly affects costs.
and you now encounter greater densities of ichthyoplankton.
Allen Page 17,Section 6.2,first paragraph,last sentence:Please provide citation(s) Please see Section 3-Twice per Month Sampling for Estimating Entrainment
justifying as to why twice per month sampling is sufficient.
You might as well add Alewife,Blueback Herring,Blue Catfish,Flathead We will add Alewife,Blueback Herring,Blue Catfish,Flathead Catfish,and Spotted Bass
Allen Catfish,and Spotted Bass to your appendix.They are all in Lake Norman and to Appendix A of the ECSP.
probably in Lake Wylie by now or will be soon.
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Entrainment Characterization Study Plan
Response to NCDEQ Comments—Allen Steam Station
3 Twice per Month Sampling for Estimating
Entrainment
Sampling interval — or the time between sampling events — is typically assigned to a regular
schedule(e.g., one month,two weeks, one week, etc.). In some cases, the interval may change
on a seasonal basis (EPRI 2014). In the Rile and its preamble, EPA provides no guidance on
the sampling interval associated with entrainment characterization studies required under
§122.21(rX9). The ECSPs reviewed by NCDEQ are based on twice per month 24-hour
sampling events where each sampling event contains four samples collected throughout the 24-
hour period, resulting in eight depth integrated entrainment samples per month. This sampling
frequency was selected based on careful consideration of study objectives, gear selection, and
historical 316(b) studies. This section provides additional clarification on sample frequency
selection based on NCDEQ comments.
The Electric Power Research Institute (EPRI), in its 2014 entrainment abundance monitoring
support document, took advantage of a large dataset from an intensive entrainment monitoring
program undertaken at the Indian Point Generation Station on the Hudson River, NY. These
data were collected over 5 years (1983-1987) continuously or near-continuously (24-hours per
day, 7-days per week). Using these data, different sampling frequency and intensity scenarios,
including monthly, twice per month, and weekly sampling frequency, were modeled for their
effect on entrainment abundance estimates.
A sampling frequency of one day in a twice per month interval produced a coefficient of variation
(CV—the ratio of the standard deviation to the mean)of annual entrainment estimates ranging
from 750 percent for taxa entrained at very low densities (0.001 per 100 m3) to roughly 50
percent at the highest densities (100 per 100 m3). The CV declined as the frequency of
sampling increased (Table 3-1). At densities between 0.1 and 1.0 per 100 m3 and greater, the
CV stabilized between 25-50 percent for weekly sampling and 50-75 percent for twice per
month sampling.
The Hudson River estuary is a dynamic and variable environment that is affected daily by tides,
salinity and temperature gradients, and freshwater and nutrient inputs. At locations such as this,
species compositions and their relative abundance can fluctuate rapidly. In addition, the
spawning season is more spread out than in freshwater (i.e., spawning can take place in any
month of the year). Comparatively, a southeastem Piedmont reservoir represents a more stable
ambient sourcewater system and the spawning season is discrete within the year. Based on
these factors, it is assumed that comparable levels of precision can be achieved with less
frequent sampling in southeastern Piedmont reservoirs than would be needed on the Hudson
River. Even Brunswick Steam Electric Plant (BSEP), which withdraws from an estuary, exhibits
similar estimates in entrainment based on monthly and twice per month sampling as described
below.
Organisms collected at very low densities will generally not contribute substantially to the
economic benefits valuation and as a result selection of fish protection technologies will not
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Entrainment Characterization Study Plan F•�'�
Response to NCDEQ Comments—Allen Steam Station
typically be driven by species rarely entrained'. Therefore, greater variability (CV) in estimates
for these rarely collected species should be acceptable for the Entrainment Characterization
Study and the analyses these data support. In addition, as shown in Table 3-1, there is
relatively little difference in the CV between the weekly and twice per month sampling
frequencies for the more abundant species which have a greater affect on the valuation of
economic benefits and the selection of fish protection technologies.
Table 3-1. Estimated Mean Coefficient of Variation of Annual Entrainment Estimates
Based on 100 Iterations of Different Sampling Scenarios (100 m3 per Sample) Applied to
Indian Point Entrainment Data from 1983-1987 (Modified from EPRI 2014)
Approximate Coefficient of
Sample Mean Variation (%)
Density Weekly Twice per Month
(No./100 m3) Sampling Sampling
425-750
0.01 125-50 350-150
0.1 50-75 50-150
1 25-50 50-75
10 25-50 50-75
100 25-50 50-75
We note EPRI (2014) did not provide entrainment estimates associated with the sample
frequencies modeled. Our assumption is the total estimated entrainment generally remains
consistent regardless of the frequency of sampling, but the CV around the estimate decreases
with increased sampling. This is consistent with observations at BSEP. Data from yearly
sampling at BSEP from 1979 to 2004 were used to demonstrate that estimates of entrainment
based on weekly sampling were similar to those based on a monthly sampling frequency (see
green and blue lines in Figure 3-12). Based on this data, and consultation with NCDEQ, Duke
Energy decreased the sampling frequency at BSEP from weekly to monthly.
1 A potential exception to this rule is when Federally-listed species may be involved in entrainment,
however, no Federally listed species are associated with potential for entrainment at these Duke Energy
facilities.
2 Baseline and Post-baseline refer to prior to and after the installation of entrainment reduction technology
and operation measures (fine-mesh panels and seasonal flow reduction) at BSEP, respectively. The
post-baseline data includes all sampling frequencies(i.e., weekly and monthly combined).
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Entrainment Characterization Study Plan
Response to NCDEQ Comments—Allen Steam Station
100
r...
• 80
a. 60
a 40
50th Percentile 80th Percentile
Nu. % Nu. %
• 20 -. Baseline 9.45 18.46
(�
Weekly 1.44 84.7 4.13 77.6
Monthly 2.38 74.9 5.06 72.6
Post-baseline 1.79 81.1 4.79 74.0
0
0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150
Number entrained (millions)
—Baseline Weekly —Monthly Post-baseline
Figure 3-1 Cumulative Distribution of Total Entrainment at Brunswick Steam Electric
Plant under Varying Sampling Frequency
3.1 Conclusion
In determining sampling frequency, twice per month sampling was selected to balance the level
of uncertainty and costs with rule requirements and considerations of how these data would be
used in the later §122.21(r) reports. Changing the sample frequency from twice per month to
weekly would double or more3 the program costs yet not materially improve the quality of the
larger technology evaluations required under the rule. For these reasons, the twice per month
sample frequency was proposed in the study plans and remains the recommendation after both
peer review and NCDEQ comments have been received.
3 Increasing sample frequency from twice per month to weekly will at least double the cost of the
entrainment characterization program. Given the scale of Duke Energy's fleet-wide entrainment
characterization effort, such an effort may require hiring of additional contractors and field/laboratory
staff raising the potential for even further cost escalation.
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Entrainment Characterization Study Plan inn
to NCDE0 Comments—Allen Steam Station
References
Donner, M.T. and R. Eckmann. 2011. Diel vertical migration of larval and early-juvenile burbot
optimises survival and growth in a deep, pre-alpine lake. Freshwater Biology 56: 916-925.
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.
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I Entrainment Characterization
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April 15, 2016
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-1 Allen Steam Station
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RECEIVEDINCDEOJD\VVR
JUN 0 2 2016
Water Q Section
Permitting
Entrainment Characterization
Study Plan
Prepared for:
UDNERUKE
�') ENERGY
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Prepared by:
' HDR Engineering, Inc.
' April 15, 2016
Allen Steam Station
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' Entrainment Characterization Study Plan rLpl
Allen Steam Station
' Contents
1 Introduction 1
1.1 Regulatory Background 1
1.2 Study Plan Objectives and Document Organization 3
I 2 Generating Station Description 3
2.1 Source Waterbody 3
2.2 Station and Cooling Water Intake Description 6
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2.2.1 Intake Structure 6
3 Historical Studies 11
4 Threatened and Endangered Species 11
5 Basis for Sampling Design 12
I 6 Entrainment Characterization Study Plan 17
6.1 Introduction 17
8.2 Sample Collection 17
6.2.1 Location 18
6.3 Sample Sorting and Processing 23
6.4 Data Management 24
6.5 Data Analysis 25
I 6.6 Field and Laboratory Audits 25
6.7 Laboratory Quality Control 26
6.8 Reporting 26
I6.9 Safety Policy 27
7 References 28
' APPENDIX A—Select Species Spawning and Early Life History Data 29
I Life History References 33
APPENDIX B—Response to Informal Review Comments 34
APPENDIX C—Comparison of Pumps and Nets for Sampling Ichthyoplankton 39
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Tables
Table 1-1. §316(b)Rule for Existing Facilities Submittal Requirements Summary 2
Table 2-1. Allen Steam Station Design Intake Flow Rate by Unit and Daily Average Water Withdrawal
from Lake Wylie, 2011-2014 8
' Table 5-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for Estimating
Ichthyoplankton Density in Cooling Water Intake Structures (some information adapted from EPRI 2014)
14
Table 5-2. Potential Disadvantages of Pumped Ichthyoplankton Sampling at Allen Steam Station 15
Table 5-3. Summary of Approach for Development of §122.21(rx9) Required Entrainment
Characterizations 16
' Table 6-1. Entrainment Sampling Details 18
Table B-1. Directed Charge Questions 34
' Table B-2. Peer Reviewer Responses to Directed Charge Questions 36
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 m3) 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
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Figures
Figure 2-1.Allen Steam Station Vicinity Map(Source: Duke Energy 2014) 5
Figure 2-2. Plan View of Allen Steam Station CWIS(Alden 2012) 7
' Figure 2-3. Section View of Allen Steam Station CWIS(Alden 2012) 8
Figure 2-4. Site Configuration of Allen Steam Station(Source:Alden 2012) 9
' Figure 2-5.Aerial View of South Fork portion of Lake Wylie(Image Modified from: ESRI) 10
Figure 4-1. Geographical Boundary of the IPAC Search 12
Figure 6-1. Plan View of the Allen Steam Station Cooling Water Intake Structure with Approximate
Sampling Locations(Unit 3, Screen a and Unit 2, Screen b)(Image Modified from:Alden 2012) 19
Figure 6-2. Section View of the Allen Steam Station Cooling Water Intake Structure with Approximate
Location of Sample Inlet—Sampler pipe (in red) not Shown to Scale (Image Modified from: Alden 2012)
20
' Figure 6-3. Aerial View Showing Approximate Locations of Sampling Gear (Image Modified from: Bing
Maps) 21
Figure 6-4. Example Entrainment Pump Sampling System Configuration 22
Figure 6-5. 7.5-Horsepower Electric Pump Used for Entrainment Sampling 23
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IAcronyms and Abbreviations
I ¶ degrees Fahrenheit
AIF actual intake flow
Alden Alden Research Laboratory, Inc.
' Allen Allen Steam Station
AOQL Average Outgoing Quality Limit
BTA Best Technology Available
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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
' El. elevation
ECSP Entrainment Characterization Study Plan
EPRI Electric Power Research Institute
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gpm gallons per minute
HDR HDR Engineering, Inc.
IPAC Information for Planning and Conservation (website)
' m3 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
NCDENR-DWQ North Carolina Department of Environment and Natural Resources,Division of Water Quality
' NCDEHNR
Normandeau North Carolina Department of Environment, Health, and Natural Resources
Normandeau Associates, Inc.
PVC Polyvinyl chloride
' QA Quality Assurance
QC Quality Control
SOP Standard Operating Procedures
IUSFWS U.S. Fish and Wildlife Services
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' 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 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 facilities with design intake flows (DIF) of more than 2
million gallons per day (MGD) that withdraw from Waters of the United States, use at least 25
percent of that water exclusively for cooling purposes, and have or require an NPDES permit.
The rule supersedes the Phase II rule, which regulated large electrical generating facilities until
it was remanded in 2007, and the remanded existing-facility portion of the previously
promulgated Phase Ill 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(rX2)-(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 s 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(rx9)-(13)). Existing facilities with AIF < 125 MGD
have fewer application submittals. For such facilities, the Director must still determine BTA for
entrainment on a site-specific basis and the applicant may supply information relevant to the
' Director's decision. Facilities are 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.
1 Duke Energy Carolinas, LLC's (Duke Energy) Allen Steam Station is subject to the existing
facility rule and, based on its current configuration and operation, is anticipated to be required to
' develop and submit each of the §122.21(rX2)-(13) submittal requirements with its next permit
renewal in accordance with the rule's technical and schedule requirements. Within the
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§122.21(rX2)-(13) requirements, (rX4), (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.
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IWhile 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
Irequirements and/or situations encountered during execution.
III
Table 1-1. §316(b) Rule for Existing Facilities Submittal Requirements Summary
Submittal Requirements Submittal Descriptions
at •122.21 r
(2) Source Water Physical Data Characterization of the source water body including intake area of influence.
(3) Cooling Water Intake Characterization of cooling water system;includes drawings and narrative;description of operation;
1 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
data;threatened and endangered species and designated critical habitat summary for action area;
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Characterization data
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 mortalityrequirement(chosen fromCompliance with
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(6) Impingement Mortality seven available options);provides detailed study plan for monitoring compliance,if required by
Standard selected compliance option;addresses entrapment where required.
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 capacityutilizations for the past five years;
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(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
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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
Entrainment facility and conditions at the site with documentation regarding the continued relevance of the data
9 Characterization document total entrainment and entrainment mortality;includes identifications to the lowest taxon
I • tudy j ssible;data must be representative of each intake;must document how the location of the intake
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.
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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
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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
I .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-1
pay;requires peer review.
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(12 Other Impacts Non-Water Quality Provides a discussion of non-water quality factors(air emissions and their health and environmentalp noise,safety,grid reliability,Environmental and
impacts,energypenalty,thermal discharge, consumptive water use,
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Assessment etc.)attributable to the entrainment technologies;requires peer review.
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I 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.
IMONew Units Identify the chosen compliance method for the new unit.
1 .2 Study Plan Objectives and Document Organization
IThe ECSP provided in this report was developed to support Allen's §316(b) compliance through
development of a site-specific ECSP with the following key objectives in mind:
I1. Collect data to support development of§122.21(rx9)which requires at least two years of
entrainment studies be conducted at the facility;
I2. Collect data to support development of §122.21(rX7) which allows for summaries of
relevant technology efficacy studies conducted at the facility; and
I 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
I §122.21(rx10)-(12) compliance evaluations.
While not a primary objective, the entrainment data gathered will help support development of
I §122.21(rX4)which requires a listing of species and life stages most susceptible to entrainment
at the facility.
I To meet these objectives, this document provides summaries of the station's configuration and
operations (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
I Endangered Species identified near the facility (Section 4), a sampling program design
justification based on this information (Section 5), the recommended study methods including
key parameters of gear, schedule, frequency, and quality control procedures (Section 6),
I references cited (Section 7), life history information on species likely to be entrained that
supports reducing sampling 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
IB), and a white paper on the use of pumped samplers in entrainment monitoring (Appendix C).
I 2 Generating Station Description
This section presents background information on the source waterbody(Lake Wylie)from which
Allen withdraws cooling water and the design and operation of the cooling water intake
Istructure.
I2.1 Source Waterbody
Lake Wylie was created in 1904 by damming the Catawba River near Fort Mill, South Carolina
' (Figure 2-1). The lake straddles the North Carolina — South Carolina border. The original dam
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' Entrainment Characterization Study Plan
Allen Steam Station
was rebuilt in 1924 and the lake's surface expanded to approximately 13,440 acres and 325
miles of shoreline. The lake has a mean depth of 23 feet and a usable storage capacity of
40,145 acre-feet at a full pond elevation of 569.4 feet. The hydraulic retention time is
approximately 39 days. Land use surrounding the lake is primarily residential, forested, and
agricultural lands.
In addition to supporting Wylie Hydroelectric Station, Lake Wylie supports Allen and Duke
Energy's Catawba Nuclear Station by providing cooling water and a dependable municipal
water supply for the cities of Belmont, North Carolina and Rock Hill, South Carolina. Lake Wylie
extends from the base of Mountain Island Dam downstream to Wylie Dam and is one of eleven
lakes on the Catawba River.
Historical water quality assessments characterized Lake Wylie as a mesotrophic to eutrophic
waterbody (Weiss and Kuenzler 1976; NCDEHNR 1994). Fluctuations in trophic classifications
' were attributed to temporal variations in meteorological conditions, closely linked to
hydroelectric generation and watershed inputs. Inflows from the relatively large basin have led
to spatial patterns of varying water quality within the reservoir.
1
1
Duke Energy 14

IEntrainment Characterization Study Plan I..)�
Allen Steam Station
Mountain Island Dam
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Figure 2-1. Allen Steam Station Vicinity Map (Source: Duke Energy 2014)
I
IDuke Energy 15

IEntrainment Characterization Study Plan F)�
Allen Steam Station r
1 2.2 Station and Cooling Water Intake Description
I Allen has five coal-fired units with a combined electric generating output of 1,145 megawatts
(MW). Units 1 and 2 are rated at 165 MW each and began operation in 1957. Units 3, 4, and 5
are rated at 265 MW, 280 MW, and 270 MW, respectively and began commercial operation in
1 1959, 1960, and 1961, respectively. Units 1-5 operate in a once-through cooling mode. The
design pumping capacity for the station is 861.1 MGD (Table 2-1).
I Table 2-1. Allen Steam Station Design Intake Flow Rate by Unit and Daily Average Water
Withdrawal from Lake Wylie, 2011-2014
I Design Flow Rate
(MGD) Average daily water withdrawal (MGD)from Lake Wylie
Unit
2011 2012 2013 2014
1 132.5
I2 132.5
3 198.7a
`
1 4 198.7 546.9
5 198.7
I
Facility 861.1
1 2.2.1 Intake Structure
Circulating water for all five units is withdrawn through a common CWIS located in a small
1 embayment along the west bank of Lake Wylie (Figures 2-2 and 2-4). The CWIS is
approximately 246.5 feet long and is divided into 15 screen bays, three per unit. Each screen
bay is 14 feet wide and equipped with a trash rack and traveling water screen.
The trash racks at the face of the screen bays prevent large debris from entering the CWIS and
damaging the traveling water screens. Each trash rack is approximately 14 feet wide. The steel
I
trash racks are made of 4 inch by 0.375 (i.e. 3/8) inch bars spaced 3 inches on-center, providing
2.6 inch clear openings. Cooling water for each intake passing through the trash racks then
water flows through an isolation gate prior to reaching the traveling screens. The isolation gates
1 for Units 1 and 2 are 6 feet by 8 feet, and the Units 3-5 gates are 8 feet by 8 feet.
Fifteen traveling water screens (three screens per unit) are located downstream of the isolation
I gates. Each screen is 10 feet wide and incorporates #12 gage wire mesh with 0.375 inch square
mesh openings (Figure 2-3). A high-pressure front wash spray system is used to remove
impinged fish and debris from the traveling water screens. The wash water flows into a single
1 trough that travels approximately 370 feet back to the lake. The discharge point is approximately
770 feet southeast (i.e., on the downstream) of the CWIS.
I
The circulating water pumps are located downstream of the traveling water screens. Cooling
water is drawn through the traveling water screens via ten cooling water pumps (i.e. two
circulating water pumps per unit). The four circulating water pumps serving Units 1 and 2 are
I
IDuke Energy I 6

' Entrainment Characterization Study Plan
Allen Steam Station
rated at 132.5 MGD (92,000 gallons per minute [gpm]) while the six circulating water pumps
serving Units 3, 4 and 5 are rated at 198.7 MGD (138,000 gpm)for a total combined flow of 861
' MGD (598,000 gpm) when all ten pumps are in operation. After passing through the
condensers, heated effluent is returned to the lake via the South Fork arm (west of the plant) of
the Catawba River(Figure 2-5).
' 24T-2-
50'UNIT 1-÷-49.8 UNIT -49'-8'UNIT 3- -48'UNIT 450'UNIT 5
j[ .11
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LL
0' 20' 40'
Figure 2-2. Plan View of Allen Steam Station CWIS (Alden 2012)
Duke Energy I 7

IEntrainment Characterization Study Plan F)1
Men Steam Station
I
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I
IFigure 2-3. Section View of Allen Steam Station CWIS (Alden 2012)
I
I
1
1
Duke Energy 18

INIII MN N 1 IIIIIII M = = M - i♦ IIIIIII - M E INIIII M - M
Entrainment Characterization Study Plan FN
Allen Steam Station
\IltkItt ..... ....- 1\0'1, 4 , . 4 ,., , - '
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Figure 2-4. Site Configuration of Allen Steam Station (Source: Alden 2012)
Duke Energy 19

IINI M lid lid N M 111111 ININ N I I 1 I N N INNI I I N
Entrainment Characterization Study Plan FINL
Allen Steam Station r
411, t , ,; '*41 Or' 4 iii,
• w.. I
aa ., Allen CWIS
R, . wc. 4 Discharge Canal ,,
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Figure 2-5. Aerial View of South Fork portion of Lake Wylie (Image Modified from: ESRI)
Duke Energy i 10

' Entrainment Characterization Study Plan
Men Steam Station
3 Historical Studies
' Duke Energy conducted extensive entrainment and ichthyoplankton sampling at Allen in the
1970s. The first entrainment study was conducted from September 1973 to July 1974. During
this study, samples were collected at the intake and discharge 1 meter below the surface using
a filter-pump system and 153 micron (pm) mesh netting. Sample volumes averaged 200 cubic
meter (m3) per sample. No fish eggs or larvae were collected in the intake or discharge during
' the 1973-1974 study. However, lake sampling at five locations indicated that larvae were
present from 27 March to 2 July in 1974. Lake samples were dominated by shad (Dorosoma
spp.), sunfish (Lepomis spp.), Yellow Perch (Perca flavescens), and unidentified larval fish.
Common Carp (Cyprinus carpio), buffalo (lctiobus sp.), redhorse (Moxostoma spp.), White Bass
(Morone chrysops), Largemouth Bass (Micropterus salmoides), crappie (Pomoxis spp.), and
Johnny Darter(Etheostoma nigrum)were also collected.
' Follow-up studies were conducted from 16 May 1975 through 24 August 1976. In this study,
samples were collected from a 2-inch diameter gate valve located upstream of the water box on
' Unit 5's main condenser. Water flowed into a 794-pm plankton net suspended in a 55-gallon
drum. Flow rates were determined by measuring the time required to fill the drum. Sample
volume was calculated using flow rate and sample time to the nearest minute. In 1975, duplicate
' one-hour samples were collected during the day and night once per week. Average sample
volume was 17 m3. In 1976, 24-hour samples were collected three times each week. Sample
' volumes averaged 450 m3.
During 1975, 144 eggs and 18 larval fish were collected. Shad and White Catfish (Ameiurus
catus) were the only species of larval fish collected. Eggs and/or larvae were present from 16
' May to 22 August, which is essentially the entire period during which samples were collected.
During 1976, 1,430 eggs and 288 larval fish were collected. Catch was dominated by shad,
' Yellow Perch, and catfish (lctalurus spp.). Based on time of year and size, all eggs were
identified as shad. Fish eggs and/or larvae were present in entrainment samples from 20 March
to 2 August.
4 Threatened and Endangered Species
There are no State or Federal rare, threatened or endangered species or critical habitat
designations near Allen. The U.S. Fish and Wildlife's map-based search tool (IPAC) was
consulted to generate a resource report and determine the potential presence of Federally-listed
' species within Lake Wylie and the surrounding land (Figure 4-1; USFWS 2015). The only
aquatic species identified was the endangered Carolina Healsplitter (Lasmigona decorate).
However, the Carolina Healsplitter is usually found in mud, muddysand, or muddy gravel
' substrates along stable, well-shaded stream banks (USFWS 1996). The habitat near Allen's
intake is not suitable to Carolina Healsplitter and it is not anticipated to reside anywhere near
' the Allen CWIS.
Duke Energy 111

UEntrainment Characterization Study Plan �L
Allen Steam Station r
I . ',fancy
L''w . Dallas \.. -\
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r • Mo .
bessemerCttY Holy,Pw 'lECK.I..
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IFigure 4-1. Geographical Boundary of the IPAC Search
1 5 Basis for Sampling Design
p J J
I
HDR Engineering, Inc. (HDR) and Normandeau Associates, Inc. (Normandeau) participated in
a site visit to Allen on April 23, 2015 to evaluate potential entrainment sampling methods and
locations that would be practicable based on best professional judgment and previous
I
entrainment sampling. During the site visit, it was determined that pumped samples from within
the CWIS would best represent entrainment rates at Allen. Sampling at the intake with a
Ipumped-sampler eliminates the potential damage to or loss of organisms that can occur if
organisms pass through the cooling water system and are sampled at the discharge. In addition,
properly designed and operated pumped systems have shown collection efficiency of 95
I
percent or greater for fish eggs and larvae with little or no organism damage (EPRI 2014).
Two primary methods that have been historically used to estimate ichthyoplankton entrainment
I
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 and collect
organisms. Alternatively, pumps can be used to convey water from the intake structure to a fine-
I mesh net onshore. Onshore nets are suspended in a buffering tank to minimize damage and
extrusion of eggs and larvae.
I
I
Duke Energy 112

Entrainment Characterization Study Plan
Allen Steam 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
' Allen. 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. 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 Allen.
1
t
Duke Energy 113

' Entrainment Characterization Study Plan
Allen Steam Station
' Table 5-1. Advantages and Disadvantag4ne information adapted from EPRI 2014)
Gear Type vantages
' Hoop Nets Deployed in the Intake - Large volurrrfined space of intake structures—precludes the use
samples),ston nets, or Tucker trawls).
- If net frame modifications to intake structures (e.g., frame-
' deploymel
-No potentialers.
less temporal variability as compared to pumped
structure offer a small spatial sample. Multiple nets
cost of additional samples to be processed in the
rid (commonly used during ichthyoplankton
' majority of intakes.
e. life stage (e.g., late larvae and early juvenile).
ial for avoidance, but would require a larger
' to opening diameter in properly sized nets'.
nples (no buffering tank).
' ys and associated safety concerns.
Pumped Samplers in the Intake - 100 msame life stage(e.g., late larvae and early juvenile).
variability i
age to organisms during sampling.
t - Limited mod
the samoity, because pump inlets are generally smaller than
- In-line flow n
' - Some poterr
damage or
' - Fixed pipe a
- Less potenti
- Lower poter
-Allows techr>I
use of 330
required di
1
1
'A general rule of thumb,as described in EPRI 2014,states that tl to mouth opening diameter ratio of three or more.
1
Duke Energy 114

' Entrainment Characterization Study Plan F)�
Allen Steam Station
' While all sampling techniques are biased to some degree, the design of the Allen intake is ideal
for pumped entrainment sampling. Potential disadvantages to pumped entrainment sampling at
intake structures (compared to sampling at the discharge) have been studied by EPRI (2014).
An explanation of how these potential disadvantages are minimized at Allen is provided in Table
5-2. Despite some potential disadvantages, pumped samples collected at the intake structure
' remain a better option than sampling at the discharge 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 intake structure 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.
' Table 5-2. Potential Disadvantages of Pumped Ichthyoplankton Sampling at Allen Steam
Station
t Potential Disadvantage Sampling at Allen
(as described in EPRI 2014)
Non-random vertical distribution may Sampler at Allen will collect from the midway point of a relatively
require depth-stratified sampling small intake opening. (see Section 6)
' Low water velocities at some CWIS
my increase likelihood of active gear Intake velocities below the curtain wall at Allen are likely greater than
avoidance for more motile larval and 1.0 fps reducing the potential for avoidance to occur.
' juvenile stages
Potential uncertainty as to whether Only the late larvae and early juvenile fish might escape entrainment
' organisms were destined to be
entrained below the curtain wall where velocities are likely greater than 1.0 fps.
The recommended approach for Allen is to pump water from between the trash racks and the
traveling screens to an entrainment sampling tank. The sampling system will utilize a fixed pipe
with a single orifice located near mid-point between the bottom of the curtain wall (— El. 552.02)
and the bottom of the intake structure (— El. 545.5) at —. El. 549. The vertical fixed pipe will be
secured to the stop log I-beams using riser clamps on the pipe. The riser clamps will have I-
beam clamps welded to them for fastening to the I-beams. Two identical pipes will be installed
' at Units 2 & 3 to allow flexibility in sampling (i.e., if one unit is not in operation on any given
sampling trip, samples can be taken from the other unit). These locations are near the horizontal
' mid-point of the CWIS and will sample the units that have the highest capacity factors; resulting
in samples that are representative of plant operation. Both sampling pipes will be equipped with
quick-connect couplings to allow either pipe to be sampled from a single pump. The quick-
connect couplings will also allow above deck piping to be removed between sampling events to
facilitate on-deck access between sampling events.
2 Elevations in this document refer to Mean Sea Level
1
Duke Energy 115

IEntrainment Characterization Study Plan F)
Allen
Allen Steam Station r
IEntrainment 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
I Wylie based on spawning characteristics of the species most likely to be entrained (see
Appendix A). To account for potential shifts in spawning time periods, the sampling program will
be run adaptively in response to entrainment densities. For example, if the densities of
I 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
Ithe 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.
I
Each sampling collection event will be conducted over a 24-hour period with sample sets
collected in four, 6-hour intervals. This sampling frequency will provide fish taxa, density
Idistribution, and seasonal/diel variation in data collected over the two year period.
Factors important to meeting §122.21(r)(9) requirements, along with a basis for how these
Irequirements will be addressed at Allen, are summarized in Table 5-3.
Table 5-3. Summary of Approach for Development of§122.21(r)(9) Required Entrainment
ICharacterizations
122.21(r)(9)Requirement Basis for Meeting the Requirement
I 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.
I 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
I
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)
IEvaluation of Year 1 and Year 2 data to determine species and life
Variation related to spawning, stage period of occurrence for spawning and feeding variation;
feeding and water column Sampling from an area well mixed and representative of water
I migrations entrained will account for depth variability by species and life stage
for water column migrations.
The resolution of taxonomic and life stage designations will be
I
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.
IData must be representative of each Sampling in Units 2 &3 are expected to be representative of the total
intake CW IS.
I A curtain wall in the intake extends to about 6.5 feet above the
How the location of the intake in the bottom of the intake structure.A sample collected at the midpoint of
water body is accounted for this opening will be well mixed and representative of the intake
location within the waterbody.
I
IDuke Energy 116

IEntrainment Characterization Study Plan L)�
Allen Steam Station
122.21(r)(9) Requirement Basis for Meeting the Requirement
Document flow associated with the Facility will monitor flows for period of sampling for use in the final
Idata 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.
IData must be appropriate for a Data will be expressed as taxon and life stage specific densities
which can be multiplied by flow to support quantification of
quantitative survey entrainment.
I
ll 6 Entrainment Characterization Study Plan
6.1 Introduction
IThis section of the ECSP provides methods, materials, and procedures for entrainment sample
collection and processing. A site-specific Standard Operating Procedure (SOP) will also be
Ideveloped and serve as a companion document to this ECSP. The SOP will lay out detailed
field sampling procedures, laboratory procedures, data quality assurance and quality control
I (QA/QC), and database management. This will ensure field sampling and laboratory methods
are adhered to and provide a base level of consistency with other plants in Duke Energy's fleet
where entrainment sampling is required.
I 6.2 Sample Collection
I Entrainment sampling will be conducted twice per month between March 1 and October 31, in
2016 and 2017. This frequency should be sufficient to capture the annual, seasonal, and diel
variability in entrainment with acceptable confidence levels (inferred from EPRI 2014). This
I period corresponds to when fish eggs and larvae are likely present in Lake Wylie based on
spawning characteristics of the species with the potential to be entrained and historic sampling
described in Section 3 (see Appendix A). To account for potential shifts in spawning time
I periods, the entrainment sampling program will be modified, if necessary, 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
Ithe 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). These adjustments, if necessary, will provide
I
the greatest potential to collect representative samples throughout the entrainment season.
Coordination with station operations will be necessary to ensure pumps are scheduled to
I operate for the duration of the sampling period in order to obtain representative density
measurements. This 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
Ifacilities.
During each 24-hour sampling event, the Unit 2 or Unit 3 intake bay will be sampled (depending
I
upon which unit is in operation) within the following discrete 6-hour time intervals: 2100-0300
IDuke Energy 117

Entrainment Characterization Study Plan
Allen Steam Station
(night), 0300-0900 (morning), 0900-1500 (day) and 1500-2100 hours (evening). During each 24-
hour sampling event, 2-hour samples will be taken within each of the above 6-hour sampling
windows 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.
A total of 64 samples will be collected during each year over the entrainment season for a
' program total of 128 for the two years of study (Table 6-1). This sampling frequency will provide
fish taxa, density distribution, and seasonal variation in data collection over the two year period.
Table 6-1. Entrainment Sampling Details
Details
Units to be Sampled Unit 2 or Unit 3
Thirty-two(32)sampling events total(16 sampling events per year);
Sampling Events(Days) 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-hr period
(4 collections/24-hr period)
' Targeted Organisms Fish eggs, larvae,and juveniles
Depths Sample collected from the midpoint between the bottom of the intake
' structure and the bottom of the curtain wall (—El. 549).
Sample Duration Approximate 2-hour samples collected within each 6-hour sampling
interval.
' Number of Samples per Sampling
Event(Day) Four samples per sampling 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 from either the northern-most pump bay of Unit 2 or
southern-most pump bay of Unit 3, which are immediately adjacent to one another. If both
' pumps are operational on a given sampling date, the Unit 3 pump will be selected preferentially,
because it is more centrally located within the CWIS. The pipe sampler will be situated near the
middle of selected intake opening, which should reduce the risk of turbulence and any
hydrodynamic proceeses. Sampling near the middle of the intake opening will still allow for
secure attachment of the sampling pipe. Samples will be collected between the trash racks and
' the traveling screens at -El. 549, which represents the near midpoint between the bottom of the
curtain wall and bottom of the intake structure. (See Figures 6-1 and 6-2). The sampling pipe
will be oriented with the opening forward facing and sized to allow the pump to reach the target
' pumping rate.
The electric pump and buffering tank will be located on the CWIS deck south of Unit 2 with PVC
' or flexhose piping running on the concrete deck of the intake structure to the sampling locations
for Units 2 and 3 (Figure 6-3). Changes or variations in the sampling location over the duration
of the 2-year study will require Duke Energy notification and approval.
Duke Energy 118

EN N NM 11111 11111 EN — NM H MN r MI MI N — — 1 1 NM
Entrainment Characterization Study Plan �1�
Allen Steam Station J
` C
24T.r
I: 50'UNIT 1--41++-49W UNIT 2--e÷+-4w-r UNIT 3-s.f's 411'UNIT 4--+ --60r UNIT S
i
1 !J I. �
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,IDES rig - -- .1 tii •
;i - - r i . g
_ ,,
I k, E E E
Sampling Location i Sampling Location
d 0. 20' 40'
6111W.11111
Figure 6-1. Plan View of the Allen Steam Station Cooling Water Intake Structure with Approximate Sampling Locations (Unit
3, Screen a and Unit 2, Screen b) (Image Modified from: Alden 2012)
Duke Energy 1 19

IEntrainment Characterization Study Plan EN
Allen Steam Station
I
I
R
2
'
/ b
/ (7
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ISampling Point
I 1 . (-El. 549)
1L..552.a
I II
�----
El_
` 547
'5'
of Flow
IDirection
I ELS
S ' '
�� \�1
EL 542.0'
Ia 5. 10'
I
IFigure 6-2. Section View of the Allen Steam Station Cooling Water Intake Structure with
Approximate Location of Sample Inlet— Sampler pipe (in red) not Shown to Scale (Image
I
Modified from: Alden 2012)
I
I
I
Duke Energy 120

IEntrainment Characterization Study Plan EN
Steam Station
~fir`;•.�Y m s ` '- .
j, Electric Pump Flex-hose or :rte
; , - and Tank Piping
1 - -•--• -'" — Location Connecting -
!_10„,.--4'4: —; i Pump to In i'
` M
water Sampler „`
r
,, Sampling ,--- �. .�
Location
�. Sampling M
. - Location
I Overflow Water
Discharge _ �r Flex-hose or
�..-.. Piping %_� ,.
Connecting
1 Pump to In-
water Sampler ,
IFigure 6-3. Aerial View Showing Approximate Locations of Sampling Gear (Image
Modified from: Bing Maps)
I 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
Idiscretely 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
Iwater-filled tank to reduce velocity and turbulence and prevent extrusion of larvae through the
mesh. A larger mesh (e.g., 505 pm) may be used if net clogging precludes sampling with 330-
pm mesh. An example ichthyoplankton sampler is shown on Figure 6-4. The proposed electric
'
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 6-5). Pump specifications are
Iprovided below:
• Capacity: 240 gpm;
I • Range: 5 gpm — 380 gpm
• 7.5 horsepower
• Inlet diameter: 3 inches
I • 230/460 volts
• 18/9 amps
• 3 Phase
I • Length: 36 inches
• Self Priming
I
• Suction Lift: approximately 25 feet
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IEntrainment Characterization Study Plan ���
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I • Impeller: Urethane coated steel
• Weight: 230 lbs
1 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
I 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
I collection cup will be carefully rinsed into sample jars with preprinted labels and preserved in 5-
10 percent formalin solution containing Rose Bengal stain.
I 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.
I
I JOINT MUST SWIVEL
APPROX.90" r 1
(POSSIBLY MORE)
SAMPLE FLOW RATE-240 gpm
I ,c77..--•,----=:-.--- ---- ,
-- ---- , 3"0 ADAPTER SOCKET
I
WOODEN CRADLES(typ.2) i [ ) 3'0 OVERFLOW DRAIN
ISTAINLESS STEEL BANDS(typ.2) 330p ICHTHYO-NET
...9.:,�, /
IINLINE ,,. /
FLOW TOTALIZING 3"0 PVC VALVE
METER
(PVC SADDLE MOUNT) ` / 3"0 PVC
Iv
330p ` ( 110 gal t�� .4—'---(PASSIVE DISCHARGE)
COO END- III
-1. POLYETHYLENE, L
J BUCKET IM TANK „ . _– , j
SAMPLER
FLOW IN — _
/// //17;3// l////
/-
3"0 PVC NIPPLEpvc
/ / / /, / % ISCHARG£THROUGH NET)
3'0 RADIAL FLEX HOSE 3"0 QUICK-CONNECT 3'0 PVC VALVE
INOT TO SCALE
Figure 6-4. Example Entrainment Pump Sampling System Configuration
I
I
I
I
IDuke Energy 122

IEntrainment Characterization Study Plan F)?
Allen Steam Station
I
1i
1 ,. f
v
-1
• ^ .;/..
a .
/
I pum
•,,o
I
.11 - i
I
Figure 6-5. 7.5-Horsepower Electric Pump Used for Entrainment Sampling
I6.3 Sample Sorting and Processing
I Upon arrival in the laboratory, all ichthyoplankton samples will be logged on an lchthyoplankton
Sample Control Sheet/Sorting Form. Because Lake Wylie is a freshwater reservoir, we do not
anticipate shellfish larvae, as defined as commercially important crustaceans or bivalves, will be
Ipresent 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
I size opening of less than or equal to 330 pm 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
I (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
Iappropriate 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
I
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-
Iviable will be stored in separate vials.
Fish eggs, larvae, and juveniles will be identified using a dissecting scope equipped with a
I
polarizing lens. Identifications will be made to the lowest practical taxonomic level using current
I
Duke Energy 1 23

' Entrainment Characterization Study Plan
Allen Steam Station
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 http://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 finfold absorption.
lchthyoplankton 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.
' • 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., ImageToolTA° Software).
Organism identification will be cross-checked using the QC procedure described below.
1 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 percent (>_ 99 percent 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.
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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),Xk ,
will be calculated as:
1 "
)37 = n ixm
nh
where:
' nh = the number of samples in the hth stratum
xh, is the i'" observation in the hth stratum.
' 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 h1h month
will calculated using the equation provided above. The total number entrained (E) during the
sampled months will then then calculated as:
H
E= EVASell
n=t
' where:
' 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
' Duke Energy 125

Entrainment Characterization Study Plan L1�
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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 initiation of sampling, two trained QA staff members (one each from HDR and entrainment
sampling contractor) will each conduct separate independent QA audits 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 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 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.
1 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% (a90% accuracy). Identification
checks will be 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). Detailed methods for quality control will be provided in the SOP developed by the
entrainment contractor. 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 updates will outline the status of the on-going sampling and
laboratory processing. At the end of the first year of study, preliminary results of testing will be
provided to Duke Energy, which 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
' Duke Energy I 26

' Entrainment Characterization Study Plan )1
Allen Steam Station r
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.
1
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1
1
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7 References
' Alden Research Laboratory, Inc. (Alden). 2012. Generating Station Assessment Draft 316(b)
Rule Compliance Options, Allen Steam Station. Prepared for Duke Energy and the Electric
Power Research Institute.
' 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. Assessment of Balanced and Indigenous Populations in Lake Wylie near
Allen Steam Station. Duke Energy, Environmental Services. Huntersville, NC.
EPRI (Electric Power Research Institute). 2014. Entrainment Abundance Monitoring Technical
Support Document. Updated for the New Clean Water Act §316(b) Rule. 3002001425.
EPRI, Palo Alto, CA.
' 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, USA.
' North Carolina Department of Environmental and Natural Resources, Division of Water Quality
(NCDENR-DWQ). 2010. Catawba River Basin Plan: Basin Overview. Raleigh, NC,
' September 9, 2010.
North Carolina Department of Environment, Health, and Natural Resources (NCDEHNR). 1994.
' Basinwide assessment report support document, Catawba River basin. NCDEHNR, Water
Quality Section, Raleigh, NC.
' Simon, T.P. and R. Wallus. 2004. Reproductive Biology and Early Life History of Fishes in the
Ohio River Drainage, Volume 3: lctaluridae—Catfish and Madtoms. CRC Press. 204 pp.
' U.S. Fish and Wildlife Service (USFWS). 2015. Information for Planning and Conservation
(IPaC) Report for Allen Steam Station (Lake Wylie). Generated November 05, 2015.
' . 1996. Recovery Plan for Carolina Healsplitter (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.
' Weiss, CM and EJ Kuenzler. 1976. The trophic state of North Carolina Lakes. University of
North Carolina, Water Resources Research Institute. July 1976. Chapel Hill, NC.
1
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IIIII N i 1 — — M M I MI — M M MO l— — OM INN INS
Entrainment Characterization Study Plan L1�
Allen Steam Station rJ
APPENDIX A - Select Species Spawning and Early Life History Data
Sampling for entrainment year-round at Allen is expected to be a poor allocation of resources, since few if any eggs or larvae are
likely to be present in Lake Wylie 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 in any meaningful way and thus do not warrant the additional sampling costs necessary to
extend the sampling season.
NCDENR
Young-of-
Spawning Spawning Habitat/ Egg Fecundity the-Year Cut- Larvae
Species Period Nest Structure Characteristics Rates off Lenghts Size References
Family Centratchidae
Bluegill Spring and Early Shallow waters with Adhesive Up to 60,000 <50 mm YS 4-6 mm 2, 3
(Lepomis Summer sand and gravels. eggs
macrochirus) Average PYS 7-14
Water Nests are saucer- diameter: 1.0-1.4 mm
Temperatures 70- shaped depressions mm
75°F in sand or gravel.
Black Crappie Spring Shallow calm Demersal and 3,000 to <75 mm YS 2-4 mm 1, 2, 3
(Pomoxis waters near adhesive 188,000 eggs
nigromaculatus) vegetation or cover. PYS 3-18
Average mm
Depression in sand diameter: 0.93
or gravel mm
Green Sunfish Spring and Early Shallow waters with Demersal and Up to 50,000 <50 mm YS 3-6 mm 2, 3, 4
(Lepomis Summer sand and gravels. adhesive eggs
cyanellus) Nests are saucer- PYS 7-11
Water shaped depressions Average mm
Temperatures 60- in sand or gravel. diameter:
80°F 1.O to 1.4 mm
Duke Energy 129

n MI 1 MI all all OM OM MI I MS OM EN N NM = 1 N M
Entrainment Characterization Study Plan ��
Allen Steam Station r
NCDENR
Young-of-
Spawning Spawning Habitat/ Egg Fecundity the-Year Cut- Larvae
Species Period Nest Structure Characteristics Rates off Lenghts Size References
Largemouth Bass Early Spring Shallow water on Demersal and 5,000 to <100 mm YS 3-8 mm 2, 3,4
(Micropterus bottoms composed adhesive 43,000 eggs
salmoides) Water of sand, gravel, or PYS 6-16
Temperatures 60- pebbles near cover. Average mm
75°F Nests are circular diameter:
and clear of organic 1.4 to 1.8 mm
debris and silt.
Redbreast Spring and Early Shallow water on Demersal and Up to 14,000 <50 mm PYS 7-11 2, 3, 4
Sunfish Summer bottoms composed adhesive eggs mm
(Lepomis auritus) of sand, gravel, or
Water pebbles near cover. Average
Temperatures 65- Nests are saucer- diameter:
75°F shaped depressions 1.8 to 2.1 mm
in sand or silt.
Redear Sunfish Spring Shallow water on Adhesive 2,000 to <50 mm YS <5 mm 2, 3, 5
(Lepomis firm substrates often 10,000 eggs
microlophus) Water in locations exposed PYS 5-15
Temperatures 68- to the sun. Nests Average mm
70°F are depressions in diameter:
sand to soft mud in 1.3 to 1.6 mm
areas containing
aquatic plants.
Family Clupeidae
Gizzard Shad Spring and Early Shallow water. Demersal and Up to 50,000 <100 mm 2, 3
(Dorosoma Summer adhesive eggs
cepedianum) Eggs broadcast in
open water.
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Entrainment Characterization Study Plan FIN
Steam Station
NCDENR
Young-of-
Spawning Spawning Habitat/ Egg Fecundity the-Year Cut- Larvae
Species Period Nest Structure Characteristics Rates off Lenghts Size References
Threadfin Shad Spring and Early Eggs broadcast Demersal and 2,000 to <100 mm YS 3-7 mm_ 2, 3, 4
(Dorosoma Summer over plants or loose semi-adhesive 24,000 eggs
petenense) sediments. PYS"6-20,
Water Average mm
Temperatures 60- diameter: 0.75 to
80°F 1.2 mm
Family Cyprinidae
Golden Spring through Eggs are scattered Adhesive 10,000 to <75 mm YS 3-6 mm 2, 3, 6
Shiner Late Summer over filamentous 20,000 eggs
(Notemigonus algae or rooted Average PYS 5-11
crysoleucas) Water aquatic plants and diameter: 1.0 mm mm
Temperatures sometimes over
>70°F nest of largemouth
bass.
Common Carp Spring and Early Eggs scattered in Demersal and 36,000 to <150 mm YS 3-8 mm 1, 3, 4, 8
(Cyprinus carpio) Summer shallow waters with adhesive 2,000,000
aquatic vegetation, eggs PYS 8-21
dilt
Water mud bottoms, and Average . mm
Temperatures 60- over debris; open diameter: 1.5 to
80 °F waters 2.1 mm
Whitefin Shiner Spring and Early Shallow waters with Demersal and 10,000 to <50 mm 2, 4
(Cyprinella Summer typically with adhesive 20,000 eggs
galactura) filamentous algae or
Water root aquatic plants. Average
Temperatures Eggs are deposited diameter: 1.6 mm
>68°F beneath bark, in
crevices of rock, or
on the undersides of
logs, rock, or other
structures.
Family Morodidae
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NCDENR
Young-of-
Spawning Spawning Habitat/ Egg Fecundity the-Year Cut- Larvae
Species Period Nest Structure Characteristics Rates off Lenghts Size References
White Bass Spring Shallow waters on Eggs are Adhesive 60,000 to 75-126 1,4,6
(Morone stream or reservoir deposited over 900,000 eggs mm
Chrysops) bottoms sands and gravel. Average
Water diameter:
Temperatures 0.8-0.9 mm
>60 (°F)
Family Percidae
Yellow Perch Late Winter or Shallow waters with Demersal and 23,000 eggs <80 mm YS 8-20 1, 3, 8
(Perca Early Spring moderate adhesive mm
flavescens) vegetation; Eggs
deposited over PYS 8-21
submerged plants, mm
logs, gravel, and
rocks; eggs laid in
log "ropes."
Family lctaluridae
White Catfish Early Summer Shallow waters Demersal and 10,000 to <50 mm 1
(Ameiurus catus) typically filamentous adhesive 20,000 eggs
Water algae or rooted
Temperatures aquatic plants; Eggs
65-75 °F are deposited Average diameter
beneath bark, in 1.6 mm
crevices of rock, or
on the undersides of
logs, rock, or other
structures
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' Entrainment Charaderization Study Plan
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1
' Life History References
1) Rohde, F.C., R.G. Amdt, D.L. Lindquist, and J.F. Pamell. 1994. Freshwater fishes of the
' Carolinas, Virginia, Maryland, & Delaware. The University of North Carolina Press.
Chapel Hill, NC
' 2) //www.flmnh.ufl.edu/fish/gallery/Descript/BlackCrappie/BlackCrappie.html
3) 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.
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) Carlander, K.D. 1977. Handbook of freshwater fishery biology. Vol. 2. The Iowa
State University Press, Ames, IA. 431 pp.
6) Ross, S. T. 2001. The Inland Fishes of Mississippi. University Press of Mississippi,
' Jackson.
7) Wang, J.C.S and R.J. Kemehan. 1979. Fishes of the Delaware Estuaries. A guide to the
early life histories, Towson, MD. pp. 410. ISSN 0-931842-02-6.
8) Animal Diversity Web. http://animaldiversity.org/
9) Lazur A.M. and F.A. Chapman. 1996. Golden shiner Culture: A reference profile.
Department of Fisheries and Aquatic Sciences, Florida Cooperative Extension Service,
Institute of Food and Agricultural Sciences. University of Florida.
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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
t 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
Question Entrainment Characterization Study Response Comments(if any)
' Number Plan
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 clearly? 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)?
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' Entrainment Characterization Study Plan
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Question Entrainment Characterization Study Response Comments(if any)
Number Plan
' 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 stud > Yes/.
plan that might prevent you or others
8) (e.g., Regulators) from understandin
what is being proposed for sampling? I
so,what needs to be added or clarified?'
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.
Below are the site-specific responses to comments received on the Allen ECSP.
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. Entrainment Characterization Study Plan
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ITable B-2. Peer Reviewer Responses to Directed Charge Questions
Category Charge No. Comment Response and Resolution
I3 f Given the design of this CWIS a single orifice for the in-water sampler,at the depth proposed, is adequate to obtain a No response required.
representative sample.
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Regarding the location(s)of sample collection I agree that samples from the pump bays of Units 2 and 3 should be To the extent possible the entrainment sampling pipe will be placed in an area of the intake that is
representative for this CWIS. From the information provided it appears that the sampler orifice will be situated near the ' well mixed and typical of hydraulic conditions within the intake.That is,away from structures that
middle of the intake opening,well away from the walls or other physical structure of the bays.This should minimize the.: ,could be causing vortices(highly turbulent areas)or in eddies or other areas of stalled flows.At
risk that flow at the collection point might not be representative of flow across the mouth of the intake in general due to _ some facilities we may be limited by where we can access the intake(e.g.,a facility with an existing
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eddies,turbulence or other hydrodynamic processes. If there is any question about this,a few strategically located access grate on the deck would be used preferentially to cutting through the concrete decking). In
"' measurements with a current meter may be sufficient to confirm it. many cases,best professional judgment can be used. If velocity measurements are warranted they
will be undertaken.
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Note:midway between the bottom of the curtain wall(-El. 552.01)and 1 the bottom of the intake structure(-El.545.5)
1 1 is at El. 548.75, so closer to 549 than 548;so better to say at-549,or at least indicate sampling will occur near the ECSP was changed to indicate both-549 and near the midpoint
midpoint.
The proposed sampling period and frequency are appropriate to encompass the periods when fish eggs and larvae are
I likely to be present,and to provide information on seasonal patterns of entrainment(but see concerns regarding the No response required. Concerns addressed below in Question 3.
need for sample replication in response to question 3).
1.111111111 The historical data indicate that white catfish larvae were collected in entrainment samples in 1975-1976, but no life
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2 history information on them is provided in Appendix 1.You might want to consider adding that,to document that the Additional species were added to Appendix A
proposed sampling period would encompass their spawning period.
_, It isn't clear why life history information is provided for some species and not others. Detailed life history information of
I the type provided is reasonable for the primary entrainment candidates,but at least limited,key information ought to
provided on the other species present in the reservoir.Consider providing a complete species list in table form that This is an excellent idea.This was added to this and other ECSPS See tablular format of Appendix
gives the spawning period for each species,the kind of eggs and larvae they have(e.g.,adhesive eggs, pelagic larva A
and other key relevant information,along with the source reference(s),to provide some evidence that the sampling
I " period is sufficient for all of them.That would be more valuable than extensive narratives on each species that include
""' information that isn't particularly relevant.
Pump sampling has been used in a variety of settings to sample zooplankton and fish early life history stages.However,
I 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
4 3 samples could be collected with another method,at a time when densities are relatively high),that would go a long way Please see white paper on use of pumped samplers and a comparison of their performance to nets
toward addressing any concerns about if,or how much,this method underestimates actual entrainment. If such (Appendix C).
I 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.
I pow , - - - • •- ,• - Allen,where sampling will happen at only one depth the bottom of the sampling pipe will be a 3-
inch diameter elbow with the open end facing into the incoming current.
it would be difficult to simulate the flow field conditions from a power plant in a laboratory setting.
I Presumably one would want to test at the approach velocities similar to levels in the field.This
What size will the orifice be,and what will the flow velocity be at the opening(not the normal flow through the intake,bwould require a test flume with flow control to achieve the desired test velocities.Since one would
the flow into the orifice)? Both could affect capture efficiency,given escape behaviors and rheotaxis exhibited by larval. be removing organisms and water while sampling,one would have to develop a method to replace
fish.If this is a concern,it might help to have the sampler intake end in a flange that widens out from the orifice. If the removed organisms and water. If you use a recirculating flume,so only the volume of water
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necessary,test runs could be done in the lab,sampling larvae of a known density out of a tank. 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
I ant to test different species,life stages and/or organism sizes,then several tests would be
•.At
required.What at first glance appears to be a simple test,is actually quite complicated.
t,---11,..--- —MIMI If a 330-pm mesh net works without clogging,that would be ideal;but if problems occur then use of a-500 pm mesh
1 311.1111111 net would be acceptable for egg and larval fish collections.That mesh size is often used in larval fish collections. We agree.
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111 Entrainment Characterization Study Plan
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ICategory Charge No. Comment Response and Resolution
The lab and field SOP and audit plans are generally sound.However,an Average Outgoing Quality Limit(AOQL)of 1%
I (?99%accuracy)strikes me as rather liberal for data entry. It seems to me that an error rate of one error per 100 Typically the average outgoing quality(AOQ)is better than the AOQL. Both this and the AOQL for
entries is too high. How does it compare to the observed error rate on similar work(I expect actual accuracy is typically larval identification are industry standard for entrainment sampling.
better than that)? If it is feasible to commit to a lower error rate that would be preferred.
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The sampling plans implemented under our proposed QC procedures have a specified average
Likewise, an AOQL of 10 percent for organism identification seems pretty high to me(I expect the error rate will be outgoing quality limit(AOQL)of 10 percent,which represents the maximum fraction of all items
lower than that for experienced personnel). I recognize that identifying fish eggs and larvae is tricky, so I fully expect (e.g.,measurements,taxonomic identifications or counts)that could be defective as a worst case.A
some individuals to end up in broader categories(e.g., unidentified shiners or unidentified larvae)- I don't consider that
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4 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
an identification error. But I would expect organisms identifiable to a given taxonomic level to be correctly classified AOQL. Items are inspected using a QC procedure derived from MIL-STD(military-standard)1235B
more than 90%of the time.Again,what is the observed error rate on similar analyses? Maybe my expectations are too (single and multiple level continuous sampling procedures and tables for inspection by attributes)to
high. the 10 percent AOQL .Both this and the AOQL for data entry are industry standard for entrainment
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sampling.
The data security and chain-of-custody plan is good,but one can never be too careful.Data remain vulnerable to loss
1 4 during the period when they exist only on one hardcopy datasheet,particularly while still in the field.You might consider This is a good idea.We added words that a digital image of the datasheet will be taken in the field
111 taking a picture of each datasheet when completed,to have an electronic backup until the datasheet can be scanned or prior to the datasheets leaving the site.
entered into a computer.
1 4 Given that regulatory compliance is sometimes the subject of litigation, I think that retaining samples for only three years ECSP was revised to indicate samples will be held until Duke Energy authorizes their disposal.
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is not sufficient. My sense is that something on the order of seven years would be a better safeguard.
3 5 Adequate information is provided to document that the specific pump to be used are of the type that will not cause No response required.
organism damage as noted in EPRI(2005).
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3 6 Proposed preservation methods will fix organisms in a manner that will maintain their morphological integrity for No response required.
identification purposes.
The proposal indicates that"To the extent practicable, long-dead,moribund,and/or non-viable eggs will be identified
I >using appropriate and well-defined techniques developed in the SOP and categorized in the database accordingly.
When estimates of entrainment are generated,moribund,dead,and non-viable individuals will not be included." The ;Agreed.We will look at the data inclusive and exclusive of our two categories and both will be
discrimination of dead,moribund or non-viable eggs from live eggs is a critical step because it directly affects ;preserved for future inspection.At present there are few reliable methods that are not time
entrainment estimates. Differences between live and dead individuals are often fairly obvious in fresh samples, but can ,consumptive or expensive to implement.Here we are thinking of excluding only the most obvious
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<be markedly reduced after preservation. Because any error in this process will bias entrainment estimates downward I f ]categories of organism.For example,we might require eggs be whole,show signs of fertilization,
'expect this step would receive heightened scrutiny.Therefore the methodology should be fully explained,and be pretty i and not be covered with fungus.
iron-clad. Even if it is, I certainly recommend retaining both groups of eggs in separate vials,and be prepared to provide
entrainment estimates based on both groups combined as a conservative measure of entrainment if necessary.
IIIThe 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.
IWe interpret the Rule as requiring sufficient sampling to collect data over the range of conditions
The Rule requires"sufficient data to characterize annual, seasonal, and diel variations in entrainment, including but not that are likely to occur and to prevent bias through selective sampling. For example, you could not
limited to variations related to climate and weather differences, spawning, feeding, and water column migration." The Propose to sample only during the day, because you would miss any density differences due to diel
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proposed sampling plan calls for collecting a single, large sample in each sampling period. I believe that this collection variability. You could not propose to sample only on sunny days, because you would miss any
Ian willprovide data representative of the entrainment at the intakes, but determiningif apparentpatterns or density differences due to weather. You could not propose to sample only from near the bottom of
P P the intake, because you would miss any density differences due to vertical stratification in the water
differences are real (as the requirements seem to call for) requires some measure of variability in the estimates. That column.
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4 6 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. We believe that the way in which these data will be used do not justify extensive replication.
Additional replication is necessary in order to determine if any of these factors affect entrainment. For example, one Relationships between weather, climate, spawning, and feeding (as a few examples) and
could not separate weather effects from temporal differences in this sampling design. If it is necessary to be able to entrainment rates are not going to change the determination of best technology available for
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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. 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.
11 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.
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' Category Charge No. Comment Response and Resolution
That said, I think this issue could be addressed with a modicum of additional effort.The simplest approach would be to We disagree that splitting each 2-hour sample into smaller sub-samples requires only a small
' r
4 6 divide each 2-hour sample into at least three, preferably four, samples collected immediately one after the other. The additional effort. While it is true that the extra effort in the field will be minimal (extra net wash-
collection cup (or entire net) could be swapped out after a sample and processed while the next sample is being downs, extra datasheets to fill out), the effort (and associated labor costs) in the laboratory will
collected. This replication would allow straightforward statistical analysis to determine if these factors (or their increase proportionally. So splitting the 2-hour samples into four sub-samples will quadruple the lab
interaction)affect entrainment. costs.
' Replication is important for density estimates, but it would not be necessary to have morphometric measurements on a
3 6 full compliment of individuals from each replicate; one pooled sample for each six-hour period would suffice.A total of Agreed.
up to 10 individuals of each taxon could be drawn at random from all the individuals collected in all replicates combined g
' within one six-hour sampling period.
3 With minor modifications as noted in responses to other questions, this study design should provide a sound basis to No response necessary
support the required benefits analysis.
'
1 8 Section 2.2.1 Intake Structure would benefit from some further detail. It is unclear whether there is one isolation gate
per unit, or one per intake bay. Inclusion of a figure with the features in this section noted, like figure 6.1,would help(on We modified the figure and figure numbering.
a related note, it is curious that there are Figures 2.1 and 2.3 but no Figure 2.2).
' 1 8 A table number is missing on p. 14,line 35 of the Allen ECSP document(Table 6.2 I think). We corrected figure and table numbering and checked all captions
1 8 In Table 6.2, second row,either indicate 64 sampling events, or 32 sample events per year. We modified accordingly
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1 Allen Entrainment
Steam StationCharacterization Study Plan 0
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APPENDIX C - Comparison of Pumps and Nets for
' Sampling Ichthyoplankton
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1 Allen Steam Stationcterizatlon Study Plan Hn
iComparison of Pumps and Nets for Sampling lchthyoplankton
Prepared by:
1 -)1
440 S. Church Street, Suite 900
1 Charlotte, NC 28202-2075
February 19, 2016
1 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 Entrainment
1 Characterization Study Plans (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
meeting', there was a concern among the biological reviewers that the proposed pumped
1 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
1 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
1 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
1 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
1 eggs and larvae.
Each method has advantages and disadvantages and a comparison of the two methods are
1 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.
1
1 Duke Energy I 40

Entrainment Characterization Study Plan ���
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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
York4, Pennsylvania, New Hampshire5, 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 §316(b) Rule.
Table C-1. Advantages and Disadvantages of Hoop Nets and Pumped Samplers for
Estimating lchthyoplankton Density in Cooling Water Intake Structures (some
information adapted from EPRI 2014)
Gear Type Advantages Disadvantages
Hoop Nets - Large volumes are sampled quickly(less - Can be difficult to deploy and retrieve in the
111
Deployed in the manpower required for the same number of confined space of intake structures—
Intake pumped samples). precludes the use of some net types(e.g.,
- If net frames are not used,then there is standard bongo, neuston nets,or Tucker
trawls).
limited to no modifications to the intake
required for deployment. -Depending on deployment method,may
No potential for mechanical damage require modifications to intake structures
- (e.g.,frame-mounted nets in frame guides).
associated with pump passage.
- Less precise flow metering than pumped
samplers.
-Large volumes are sampled quickly-
I capturing less temporal variability in a single
sample as compared to pumped samples.
- Relatively small nets needed to fit in the
' 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.
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4 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.
s The states of New Hampshire and Massachusetts do not have delegated authority to issue NPDES permits and are administered
by EPA Region 1.
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Gear Type Advantages Disadvantages
- 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.
' - 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 nets6.
- Greater potential for extrusion than pumped
samples(no buffering tank).
- Boat deployed nets are subject to weather
delays and associated safety concems.
- May be restricted to relatively deep areas that
are free of floating debris,submerged
snags,and other obstructions
Pumped -Sample durations are typically longer - Some active avoidance possible by larger
Samplers in the increasing the potential to capture temporal motile life stages(e.g.,late larvae and early
Intake variability in ichthyoplankton densities not juvenile).
observed in net samples. - Improperly designed samplers can lead to
- Limited modifications to intake or discharge damage to organisms during sampling.
structures are required to install—usually
just anchoring points for the sample pipe. - Samples a smaller portion of the spatial
variability, because pump inlets are
- In-line flow metering offers greater precision generally smaller than net openings.
in measuring the volumes of flow sampled.
-Some potential for mechanical damage.
However,correctly designed systems can
offer<5%damage or destruction of eggs
and larvae.
- Fixed pipe allows precise control over water
depth and orientation to intake flows.
-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-urn nets
1 increases potential for net occlusion and
frequent net change outs may be required
during certain times of the year).
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9 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.
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' Allen Steam Staattioona��don Study Plan ImN
Literature Review
Methods
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
1 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 (1992) 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)
1 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 and Gizzard Shad) 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 samples were not statistically significant.
'By comparison,the pumps proposed for use for entrainment sampling at Duke Energy facilities have a target capacity of 240 gpm
with a range from 5 to 380 gpm depending upon head.
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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 (1992) 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
(1992) 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-pm 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.
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' 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,e 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 nets9,
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.
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Sampler efficiency was only presented for surface sampler in Gale and Mohr 1978.
9 The WP2 Net is a vertical plankton net with messenger operated closing mechanism based on the design of the UNESCO Working
Party 2.
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' King, L. R., B. A. Smith, R. L. Kellogg and E. S. Perry. 1981. Comparison of
lchthyoplankton 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 3.0/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; Van Den Avyle, MJ. 1988. Relative Efficiency of a Pump for Sampling
1
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, Georgia10 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-pm mesh net
suspend over the side of a boat. A cylindrical metal sieve with 8 mm (5/16 inch) holes was
1 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
1 pumping specifications. Triplicate samples (75 m3) were collected with a towed net that was
0.25-m2 (2.7 feet2)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
1 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
0A 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.
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Station
to Cada and Loar(1982), the inlet to the pumped sampler was screened and moved through the
water. The screening could alter 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-pm 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
1 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).
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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 (MNS) 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
1 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-pm 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-pm 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
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' entrainment. The Tucker trawl had 710-pm 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
1 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
1 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
1 statistically no different than measuring ichthyoplankton density at the condenser tap and better
than a streamed net.
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Table C-2. Total Number (N) and Mean Densities (MD) (mean number of shad/ 1,000 m3) of
All Shad Collected with Comparison Gear and Shad <28 mm Total Length Collected with
I
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)
Net Screen Pump Tap Upper Trawl Lower Trawl
I Date © MD N MD N MD © MD ' 1 N MD N MD
Jun 6 0 0.0 2 a
1° 5 56.4 164 195.3 27 27.9
1 Jun 7 0 11 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 ,I 7.0 11 43.0 80 196.9 25 346.1 511 666.1 86 76.4
IJun 10 0 11 5.0 10 32.1 36 82.4 4 82.0 279 406.5 134 85.7
Total illa
0.0 46 161 56 2,203 512
Ave. 29 92 65 38 206 317
Sample
I Volume
(ms)
I a-Unable to calculate volume
-Number not considered valid due to malfunctioning equipment
`-Density not calculated on invalid data
ITaggart, 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
IFisheries and Aquatic Sciences 41(10) 1428-1435.
Taggart and Leggett (1984) identified and evaluated five major studies that compared the
I 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.
I 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
I 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
I
of accurate flow measurement used in many of these studies. Despite these challenges, no
systematic biases were detected.
I 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
fished. Three sets of comparisons were made. In 1981 an 80-pm net was towed immediately
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Allen Steaam Characterization Study Plan
' below the surface 2 m (6.6 feet) behind the pump intake. In 1982 and 1983 a 153-pm 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), 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.
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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)
Pump
Tow or current
Suction speed Volume sampled
Type and Tow net and (mis) (ms)
mesh size Row Diameter Velocity mesh size
Reference (µm) (m3/min) (m) (mis) (pm) Pump Net 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 sites surface"(marine)
Partner and Rohde Tandem propeller, 8.6 0.20 4.60 0.5-m-dia.std., Local current 86' 44' 1 1 I paired stationary
1977 500 nitex 500 Sex 0.4 sanpies 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-rec., Local current 7 stationary sets of 4 pump
1978 centrifugal, 400 x 800 niter "modaae–strong" — — and 8 net replicates
400 x 800 niter (0.24)° (0.92)° at surface and bottom
(riverine)
I.eithiser et al. Fish transfer, 2.1 0.15 1.92 (a)l-m-dia.cyl.cone, Local current (a)62 121 (a)10 stationary pairs at
1979 335 niter 335 obex (a)0.26 0.5-1.5 m depth
(riverine)
(b)as in(a)and (b)0.30 (b)64 414 (b)as in(a)above
0.5-m dia.std., 64 105
363 Sex
Cada and Loar Open impeller 1.10 0.076 4.04 0.5-m-dia. "Slowly" 1.2-1.9 17 85-100 3 sets of 3 replicates not
1982 243 nimx (0.021)° (1.1)° Hensen net, paired in time at
243 nitex 0-0.5 m depth(rivedne)
'Estimated from data provided in paper referenced.
°Measured at intake,which differs in size from suction hose.
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' Results
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 (Dorosoma petenense) and Gizzard Shad (Dorosoma
' cepedianum) 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 s 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
'I 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 I 53

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' deployment conditions at power plants in the U.S. routinely since the 1970s. This method has
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.
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' References
' 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.
Ecological Analysts, Inc. (EA). 1978. Indian Point Generating Station Entrainment Survival and
Related Studies 1977 Annual Report. Consolidated Edison Company of New York, Inc.
' EA. 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.
Elder, J.A., J.W. Icanbery, D.J. Smith, D.G. Henriet, and C.E. Steitz. 1979. Assessment of a
Large Capacity Fish Pump for Sampling lchthyoplankton for Power-plant Entrainment
Studies. California Cooperative Oceanic Fisheries Investigation 20: 143-145
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
l'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. Joumal 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.
' 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.
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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.
NAI. 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; Van Den Avyle, MJ. 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.
Waite, S.W. and S.M. O'Grady. 1980. Description of a new submersible filter-pump apparatus
for sampling plankton. Hydrobiologia 74(2): 187-191.
' Welch, P.S. 1948. Limnological Methods. McGraw-Hill Co., New York. 318 pp.
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