NC0039586_Schedule of Compliance (Outfall 006)_20170911

('DUKE
ENERGY
Serial: HNP -17-071
Paul V. Fisk
Plant Manager
Harris Nuclear Plant
5413 Shearon Harris Rd
New Hill, NC 27562-9300
Mr. Jay Zimmerman, DirectorRE
CE 'E01NMENWR
NC DEQ Division of Water Resources SEPi
512 N. Salisbury Street Y Z01�'
Raleigh, NC 27604 v-;kar Quality
Permitting Section
Subject: Duke Energy Progress, LLC — Shearon Harris Nuclear Power Plant (HNP)
NPDES Permit No. NC0039586
Part I (A)(9) — Schedule of Compliance (Outfall 006)
Wake County
Dear Mr. Zimmerman:
On August 29, 2016, NC DEQ DWR issued NPDES Permit NC0039586 with an effective date of
September 1, 2016. Contained within this permit were new effluent limit requirements for
copper and zinc for Outfall 006 (Combined Outfall for Internal Outfalls 001-005) serving HNP.
Part I (A)(9) of the permit requires Duke Energy Progress, LLC (Duke Energy), submit to the
Division of Water Resources a Corrective Action Plan which summarizes the actions to be taken
to achieve the total copper and total zinc limits at Outfall 006 and a schedule of actions to be
taken to implement the plan. The purpose of this letter is to provide the Corrective Action Plan
in accordance with requirements of NPDES Permit No. NC0039586.
Duke Energy respectfully requests a meeting with appropriate staff of the Division of Water
Resources to review and discuss our findings thus far and the enclosed Corrective Action
Plan.
If you have any questions regarding this matter or wish to discuss in further detail, please do not
hesitate to contact Mr. Bob Wilson, HNP Site Environmental Professional, at [phone].
l certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the Information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely,
Paul V. Fisk

NC DEQ Division of Water Resources
Serial HNP -17-071
Page 2 of 2
Enclosure — NPDES Permit No NC0039586 Submittal of Corrective Action Plan
cc Mr Danny Smith, NC DEQ DWR Raleigh Regional Office
Ms Teresa Rodriguez, NC DEQ DWR Complex Permitting Branch
Mr Bob Wilson, HNP Site Environmental Professional
Mr Don Safnt, P E, Carolinas Permitting & Compliance

NC DEQ Division of Water Resources
Serial HNP -17-071
Enclosure
Harris Nuclear Plant
NPDES Permit No NCO039586
Submittal of Corrective Action
Plan (30 pages including cover)

Final Technical Memorandum
-WV-01`108814....9
d ' •:'�6TING�: V
17
Prepared for
Duke Energy Progress, LLC
Shearin Harris Nuclear Plant
NPDES Permit No. NCO039586
August 2017
chzmlo
CH21VI HILL North Carolina, Inc.
3120 Highwoods Blvd. Suite 214
Raleigh, NC 27604

TECHNICAL MEMORANDUM
Corrective Action Plan for Copper and Zinc for Harris
Nuclear Plant NPDES Permit
PREPARED FOR
Duke Energy
COPYTO
Bob Wilson/ Shearon Harris Nuclear Plant (HNP)
Don Safrit/Duke Energy
PREPARED BY
CH21VI HILL North Carolina, Inc (CH2M)
DATE
August 18, 2017
PROJECT NUMBER
680115
REVISION NO
Version 3
Executive Summary
The 2016 National Pollutant Discharge Elimination System (NPDES) permit for the Shearon Harris
Nuclear Plant (HNP) included effluent limits for copper and zinc for Outfall 006 and a compliance
schedule requiring development of a Corrective Action Plan (CAP) by September 1, 2017 (Year 1 of the
permit) Characterization of the Outfall 006 discharge indicates that using a hardness value higher than
the default of 25 mg/L used to derive current permit limits is appropriate for evaluating the applicable
water quality criteria for metals, with recent sampling data showing an average hardness of
43 6 milligrams per liter (mg/L) Characterization of zinc levels in the effluent indicates that the change
in anticorrosion agents was successful in reducing zinc levels, and no further action is needed to
demonstrate compliance with the zinc effluent limit Characterization of copper levels indicates that
copper compliance will continue to be problematic and that further efforts to either manage water
chemistry or justify alternative effluent limits are necessary.
HNP will continue to evaluate water chemistry management efforts that can be used to potentially
reduce copper Alternatives for further adjustment of effluent limits were evaluated, and HNP is
recommending that water effect ratio (WER) testing be conducted to determine levels of copper that
are actually toxic in Outfall 006 effluent This WER testing, along with continued water chemistry
management, are the primary activities proposed in the CAP for Year 2
Purpose
The purpose of this Corrective Action Plan (CAP) is to present to the North Carolina Division of Water
Resources (DWR) the actions that will be taken by Duke Energy's Shearon Harris Nuclear Plant (HNP) to
achieve compliance with effluent limitations for copper and zinc for discharge through Outfall 006, as
included in National Pollutant Discharge Elimination System (NPDES) Permit NC0039586, effective
September 1, 2016 The requirement for this CAP is included in Part A. (9) of the NPDES Permit
Background
HNP has an NPDES permit issued by the DWR within the North Carolina Department of Environmental
Quality (DEQ) based on requirements in North Carolina General Statutes 143-215 1 and a memorandum
of agreement with the U S Environmental Protection Agency (EPA) to assure permit requirements are
consistent with federal requirements under the Clean Water Act (CWA). The NPDES Permit authorizes
PRO802171202CLT CH2M HILL NORTH CAROLINA, INC

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
discharges from seven outfalls with designations from 001 through 007. Outfalls 001 to 005 are internal
outfalls, which then combine as Outfall 006, which then discharges into to the receiving water, Harris
Reservoir Outfall 007 is a discharge to Harris Reservoir from a wastewater facility serving the Harris
Energy & Environmental Center
The DEQ Environmental Management Commission (EMC) adopted changes to water quality standards
for metals that became effective in January 2015, and were approved by EPA Region 4 in April 2016
Changes included hardness -based equations to calculate applicable criteria for dissolved metals, and
equations for acute and chronic toxic effects to aquatic life The EMC -adopted rules also retained the
Action Level concept for copper and zinc, which allowed higher levels of these metals as long as a
discharge was meeting effluent toxicity requirements EPA disapproved this part of the water quality
standards although it is still in the NC administrative code.
In reviewing the permit application for the HNP discharges, including data for 3 years prior to the
application, DWR determined that there was a reasonable potential to exceed the adopted criteria for
copper and zinc based on the monitored levels of metals in the combined discharge from Outfall 006
The equations used to calculate the applicable dissolved copper and zinc criteria are as follows
• Copper, Acute = WER*(0 960 eA[0 9422[ln Hardness] -1 700]]
• Copper, Chronic = WER*(0 960 eAf0 8545(ln Hardness] -1.702}]
• Zinc, Acute = WER*(0 978 e^{0.8473[ln Hardness1+0.884}]
• Zinc, Chronic = WER*(0 985 eAfO.8473[ln Hardness]+0.88411
Note WER is the Water Effect Ratio, which is equal to 1 unless a different value is determined by testing
DWR used a hardness value of 25 milligrams per liter (mg/L) expressed as calcium carbonate (CaCO3) to
calculate applicable effluent limits because, at the time, there was a lack of historical data on hardness
available for Outfall 006 discharges They also calculated the limits for total recoverable copper and total
recoverable zinc using an assumption of 100 percent effluent (that is, no allowance for consideration of
dilution in Harris Reservoir) and default EPA chemical translators for determining total recoverable
metals concentrations based on dissolved criteria. Table 1 shows the effluent limitations page from the
NPDES Permit for Outfall 006
The 2016 permit included a schedule of compliance for the effluent limits for copper and zinc, as
specified in Part A. (9). The schedule includes the following milestones:
1 Within 1 year from the effective day of the permit, the permittee will submit to DWR a CAP
summarizing the actions to be taken to achieve compliance with the total copper and total zinc
limits at Outfall 006 and a schedule of activities to implement the plan The CAP may include mixing
zone studies and site-specific studies Methods for conducting site-specific studies must be
approved by DWR
2 Within 2 years from the effective date of the permit, submit a report to DWR summarizing actions
taken in accordance with the CAP.
3 Within 3 years from the effective date of the permit, submit a report to DWR summarizing actions
taken in accordance with the CAP
4. Within 4 years from the effective date of the permit, submit a report to DWR summarizing actions
taken in accordance with the CAP
5. Achieve compliance with total copper and total zinc limits by September 30, 2021.
CH2M HILL NORTH CAROLINA, INC PR0802171202CLT

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
Table 1 Effluent Limitations and Monitoring Requirements (Outfall 006)
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge
treated wastewater from outfall 006, combined outfalls 001 through 005 Such discharges shall be limited and
monitored by the Permittee as specified below
Effluent Limitations
Effluent Characteristics
Monthly Weekly
Average I Average
Monitoring Requirements
Daily Measurement Sample TypeI Sample
equency
Maximum FrLocation'
Flow (MGD) Weekly Estimate Effluent
Hydrazine
60 0 µg/I Weekly
Grab
Effluent
Temperature
(April 1— October 31) 4 (°C)
Weekly
Grab
Effluent
Temperature
(November 1— March 31) (°C)
Weekly
Grab
Effluent
Acute Toxicity
Quarterly
Composite
Effluent
pH
6 to 9 S U Weekly
Grab
Effluent
Total Copper?
7 9 µg/I 10 5 Vg/I Monthly
Composite
Effluent
Total Zinc?
126 jig/[ 126 µg/I Monthly
Composite
Effluent
NH3 as N (mg/I)
Monthly
Composite Effluent
Total Suspended Solids (mg/1)
Monthly
Composite6 Effluent
Total Nitrogen (mg/1)
Monthly
Composite Effluent
Total Phosphorus (mg/1)
Monthly
Composlte6 Effluent
Notes
1 Effluent after combination of all waste streams from outfalls 001 through 005 and prior to discharge into Harris Reservoir
2 The volume of wastewater discharged from the facility shall be monitored If continuous flow monitoring is not feasible,
flow may be estimated
3 The hydrazine limit of 60 µg/L shall apply at all times except during the periods following wet lay-up of equipment during
an extended outage when a hydrazine limit of 2 0 mg/L shall apply for a total period of no more than 48 hours Alternately,
the permittee may elect to meet these limits at outfall 004, in which case sampling for hydrazine at Outfall 006 is not
required
4 The discharge shall not result in the violation of the temperature or chlorine water quality standards outside of a mixing
zone of 200 acres around the point of discharge The facility is located in the Lower Piedmont area of the state, the
applicable state water quality temperature standard is 32 °C (89 6 °F) and the total residual chlorine standard is 17 pg/I
The temperature within the mixing zone shall not (1) prevent free passage of fish around or cause fish mortality within the
mixing zone, (2) result in offensive conditions, (3) produce undesirable aquatic life or result in a dominance of nuisance
species outside of the zone, or (4) endanger the public health or welfare Temperature and total residual chlorine data
collected according to the Monitoring Plan for Harris Reservoir should be summarized in the Annual Environmental
Monitoring Report for Harris Reservoir
5 Acute toxicity (Pimephales) P/F at 90% February, May, August, and November, See Special Condition A (8)
6 A composite sample consisting of 24 or more grab samples of equal volumes taken at equal intervals over a 24 hour
period
7 The limits shall become effective September 30, 2021 See Special Condition A (9) Schedule of Compliance for Hardness
Dependent Metals
8 By December 21, 2016, begin submitting Discharge Monitoring Reports electronically using INC DWR's eDMR application
system See Special Condition A (19)
There shall be no discharge of floating solids or visible foam in other than trace amounts
PRO802171202CLT CH2M HILL NORTH CAROLINA, INC 3

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
The first-year requirements of this schedule allowed for the development of this CAP The first step of
this process was to further characterize the effluent to better define potential compliance Issues. The
following section summarizes effluent characterization studies conducted since the permit was Issued
and effective September 1, 2016 It Is Important to clarify that beginning about January 1, 2016, the HNP
began using a different anticorrosion agent for Its cooling water systems, and this agent does not
Include zinc The effluent characterization reflects this operational change
Effluent Characterization
Duke Energy created a plan to perform additional studies to Justify alternative limits on copper and zinc
as Is consistent with the language in the NPDES Permit A staged approach, summarized In Table 2, Is
being used to evaluate the options suitable to Justify permit modifications The hardness
characterization and intensive sampling tasks have been completed, the results are summarized in this
section
Table 2 Summary of Staged Year 1 Approach for Permit Modification Studies
Task Duration Note
(months)
Hardness characterization 4 Hardness alone may Justify higher limits
Intensive sampling 3 Permit requires monthly sampling, weekly samples
(hardness, zinc, copper) collected April to June 2017
Data evaluation 2 Determine if sampling alone Justifies higher limits
CAP development for additional studies 2 If necessary, to include in Year 1 report to DWR
The objective of the first two tasks Is to better characterize the effluent from Outfall 006 with respect to
copper, zinc, and hardness By collecting high-quality data for these parameters, less stringent permit
limits may be justified Hardness characterization Is especially Important because no monitoring data of
the effluent hardness were available for development of the 2016 NPDES Permit limits, therefore, the
minimum, default hardness (25 mg/L as CaCO3) was used for the Reasonable Potential Analysis (RPA)
conducted by DWR to support the NPDES Permit renewal process. If effluent hardness Is found to be
greater than 25 mg/L, less stringent limits are justified.
Initial Hardness Characterization
The Initial hardness characterization was conducted by HNP staff Hardness was sampled dally at raw
water and weekly at cooling tower makeup and circulation water locations Circulation water,
represented as Outfall 001 In the Permit, which discharges to Outfall 006, was found to have an average
calcium hardness of 412 mg/L as CaCO3 Given the calcium hardness of Outfall 001, total hardness for
this stream Is expected to be In the range of 50 to 200 mg/L as CaCO3 (which assumes calcium hardness
contributes 20 to 80 percent of total hardness) The contribution of Outfall 001 to the total flow from
Outfall 006 ranges from 20 to 60 percent, thus, it Is likely that effluent hardness from Outfall 006
exceeds the 25 mg/L as CaCO3 default used during the RPA for this NPDES Permit renewal Therefore, it
was determined that a more intensive sampling campaign that focused on hardness and the permitted
hardness -dependent metals was warranted
Sampling Plan
A sampling plan was developed and is detailed in this section to sufficiently characterize the conditions
at HNP Outfall 006 The results of this characterization were used to guide the decisions and
recommendations summarized in a later section of this CAP
CH2M HILL NORTH CAROLINA, INC PR0802171202CLT

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
Protocol
Samples were collected by HNP staff with the composite sampler (Isco 3710FR) at Outfall 006 also used
for NPDES monitoring Although EPA Method 1669• Sampling Ambient Water for Trace Metals (EPA,
1996) suggests using a grab -sampling technique, there is no location at Outfall 006 that is conducive to
collecting a true grab sample. Outfall 006 effluent samples were collected per Duke Energy's Procedure
CRC -591. Operation of Isco Samplers (Attachment 1) To minimize contamination of the composite
sampling equipment, disposable 2 -gallon sample bags (Isco ProPak) were used to line composite sample
bottles These bags are clean and made of EPA -approved low-density polyethylene (LDPE) plastic that
won't contaminate or enrich samples. Samples were collected in bottles containing preservative (nitric
acid [HNO3]) which were obtained from the lab performing the analyses
For quality assurance (QA) and quality control (QC) purposes, a schedule of blank (both field and
equipment) and duplicate samples and was developed to provide reliability In results; these procedures
were developed by modifying the recommendations from EPA Method 1669 (EPA, 1996) to fit the
conditions of this study Per the method, equipment blanks for the composite sampler were collected
prior to sample collection, and at least one field blank per every 10 samples was collected Equipment
blanks were collected in the same manner as true samples by pumping distilled water through the
composite sampler tubing into a clean sample collection bag, and then transferring to a sample bottle
for analysis Field blanks were collected immediately prior to sample collection using identical collection
procedures and distilled water
To maintain precision of the field sampling and analytical procedures, at least one field duplicate sample
was collected for every 10 samples that were collected at a given site. Duplicates were collected by
splitting a sample of adequate volume into two sample bottles for separate analysis.
Analyses
Analyses of copper, zinc, and hardness were performed by certified labs (ENCO Laboratories in Cary,
North Carolina [NC], and Duke Energy Central Laboratory in Huntersville, NC) using EPA Method 200 7:
Determination of Metals and Trace Elements in Water and Wastes by Inductively Coupled Plasma Atomic
Emission Spectrometry (EPA, 1994a) (Method 200 7). Hardness was determined by calculation using
calcium and magnesium concentrations determined by Method 200.7
Schedule
Sampling was conducted weekly from April to June, 2017 by HNP staff Duplicate and blank samples
were collected according to the schedule shown in Table 3 Samples were collected at Outfall 006 for
each day listed in the schedule. The total number of samples collected was 13 true samples, 2 field
blanks, 2 equipment blanks, and 5 duplicates The count of QA/QC samples exceeded the requirement
of 1 per 10 samples per location established by EPA Method 1669 (EPA, 1996)
Upon completion of the weekly sampling plan at the end of June, a modified schedule was developed
for ongoing sampling. Sampling frequency was reduced to every other week starting in July; three
duplicate samples and two of each type of blank will be collected through the end of September
Table 3 Schedule of Duplicate and Blank Samples for QA/QC
Outfall 006
Date
Duplicate Field Blank Equipment Blank
4 -Apr -17
11 -Apr -17
18 -Apr -17 V
25 -Apr -17 V V
PRO802171202CLT CH2M HILL NORTH CAROLINA, INC

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
Table 3. Schedule of Duplicate and Blank Samples forQA/QC
Outfall 006
Date
Duplicate Field Blank Equipment Blank
2 -May -17
9 -May -17 V
16 -May -17
23 -May -17 V
30 -May -17
6 -Jun -17
13 -Jun -17 V V
20 -Jun -17 V
27 -Jun -17
Sample Count 5 2 2
Sampling Results
The average effluent hardness at Outfall 006 was 43 6 mg/L during the 3 months of weekly sampling, as
shown on Figure 1 Results were consistently within the range of 35-50 mg/L, except for one value
(58 mg/L) for one duplicate sample on June 13, 2017. The average hardness value was used to calculate
potential adjusted limits for copper and zinc, as described previously and as shown on Figure 2 and
Figure 3
O 006 Effluent 006 Ave (43 6 mg/L)
70
60
50 8 O
40 O ® O
30
L
= 20
10
0 - - — -
4/I/2pZ, 4/I6v1:10 S/1/HOZ, Sj16V?O Sj31/?o7, 6jjsV'O10 6/30/'107, ;/Is
Figure 1 Results of Weekly Hardness Samples (April through June)
Total zinc concentrations In the effluent from Outfall 006 are consistently less than the current limit of
126 micrograms per liter (jig/Q, with average and maximum concentrations of 20 5 and 48 7 µg/L,
respectively Zinc was not detected exceeding the reporting limit for one sample on April 4, 2017, this
value was represented as the reporting limit (10 µg/L) on Figure 2 and was used for calculating the
average value Using the average effluent hardness at Outfall 006, chronic and acute toxicity limits were
calculated to be 201 and 203 µg/L, respectively Given the low level of zinc in the effluent, no further
action is needed to demonstrate compliance with the 2016 NPDES Permit for zinc, as written.
6 CH21M HILL NORTH CAROLINA, INC PR0802171202CLT

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
O 006 Effluent — — — Monthly Ave Daily Max ......••• Lim, Chr (43 6 mg/L) ----- Lim, Ac (43 6 mg/L)
250
200 . - - - ......................................................................................................d........---
J
150 ;
U 100
N
50 Q
0
4/1/hoz j 4/zs/?01,;,
?o1 j s/I/2 01;'s/16�?Oj> s/�1/�07 j s�Is/?a1 j si30 j-,01.> `/Is/ -,o„>
Figure 2 Zinc Concentrations during 3 Months of Weekly Sampling
Monthly average and daily maximum limit (126 pg/L) from current permit are shown, chronic and acute toxicity
limits (201 and 203 pg/L, respectively) calculated using the average effluent hardness values are also shown
Total copper was detected exceeding the reporting limit of 5 pg/L in all effluent samples collected during
the intensive sampling period The results range from 7 4 ltg/L on April 18 to 38 1 µg/L on June 13, 2017,
the duplicate sample collected June 13 had a concentration of 30 7 µg/L, resulting in a daily average
concentration of 34 4 pg/L Considering the current NPDES Permit limits, the effluent copper
concentration exceeded the monthly average limit in 14 of 17 and the daily maximum limit in 11 of 17
samples and duplicates collected during the 3 months of weekly sampling.
Chronic and acute toxicity limits of 12 7 and 17 7 µg/L, respectively, were calculated for copper using the
average effluent hardness of 43 6 mg/L. Given these calculated limits, the effluent copper concentration
exceeded the acute limit in 5 of 17 and the chronic limit in 9 of 17 samples duplicates collected during
weekly sampling Therefore, more studies are required for HNP to demonstrate compliance with the
NPDES Permit for total copper
O 006 Effluent - - - Monthly Ave Daily Max ......••• Lim, Chr (43 6 mg/L) ----- Lim, Ac (43 6 mg/L)
45 ,
40
35
30
25 O O O•
20
----------------------------
Q----------------------�----------
0- ..
•
15 �i Q• Q'
v
............................................ • ...... •...................................................
10 .-• ----------------------------
--O.--Q-------
5
0 - - -
41-71” 4116'.
4/16 ?01> S/1/?ox> s/I6�?01> S/31/?oZ> 611S 61
6/�0/`�01> >/IS/?o7>
Figure 3 Copper Concentrations during 3 Months of Weekly Sampling
Monthly average and daily maximum limits (7 9 and 10 5 pg/L) from current permit are shown, chronic and acute
toxicity limits (12 7 and 17 7µg/L) calculated using the average effluent hardness values are also shown
PR0802171202CLT CI -12M HILL NORTH CAROLINA, INC 7

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
Quality Assurance and Control Results
Duplicates, field blanks, and equipment blanks for the composite sampler at Outfall 006 were collected
to confirm the reliability of the results collected during the intensive sampling period Five duplicate
samples for copper, zinc, and hardness were collected during this time period Duplicate samples were
compared based on the relative percent difference (RPD), calculated as follows and shown in Table 4•
Relative percent difference (RPD) = nl—n2 X100%
(n1+nz)/2
Two field blanks were collected, no copper or zinc
was detected in either sample Hardness was
detected at a low level (0 046 mg/L) in the field
blank collected on June 20, 2017 Three equipment
blanks were collected at the composite sampler, zinc
was not detected in any of the samples Copper was
detected in one equipment blank collected on
Table 4 Relative Percent Difference Results for
Duplicate Samples
Parameter
Average RPD
N
RPD Range
N
Copper
12
2-22
Zinc
23
08-40
Hardness
6
2-22
May 9, 2017, however, the concentration detected
(1 68 µg/L) was less than the reporting limit used for effluent sample analyses Hardness was detected in
all of the equipment blanks at levels of 0 390, 0 169, and 0 198 mg/L, this is likely the result of scale that
has accumulated in the composite sampler tubing
Although detections in blanks and RPD between duplicates up to 40 percent are not ideal, none of the
QA/QC sample results indicate that the results are unreliable Given the low average RPD of the
hardness data, and despite the high RPD, zinc concentrations are still well less than permit limits and at
relatively low detections in blank samples, the conclusions drawn from these data are not in question. A
tabular summary of all sampling data can be found in Attachment 2.
Effluent Characterization Conclusions
Results from the intensive sampling campaign show that effluent hardness from Outfall 006 is higher
than the default 25 mg/L used in the reasonable potential analysis to determine the copper and zinc
limits in the current permit Therefore, modification to the limits is justified given this effluent hardness
data
Regardless of whether compliance is based on the current 2016 permit or modified based on the higher
hardness value, HNP is in compliance with total zinc limits under current operation However, the Plant
is not able to achieve compliance with copper limits in the current permit or if the limits are modified
based on effluent hardness Further investigation, therefore, is required to demonstrate compliance
Plan for Further Evaluation
The results of the effluent characterization indicate that the HNP can achieve the effluent limits for zinc
for Outfall 006 as included in the current NPDES Permit (Table 1) In addition, hardness data collected
for Outfall 006 should increase these limits However, the results indicate that further studies are
required for the facility to consistently demonstrate compliance with the effluent limits for copper
The following sections describe potential and selected actions that will be taken as part of the CAP to
meet the milestones identified in the NPDES Permit.
Continued In -facility Water Chemistry Management Investigation
One of the reasons that compliance with the zinc effluent limits is no longer an issue is because of the
use of an alternative anticorrosion agent that does not include zinc. Use of this alternative agent began
in January 2017, and zinc levels have been dramatically reduced since that time.
CH2M HILL NORTH CAROLINA, INC PR0802171202CLT

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
Copper was not an Initial focus of the water chemistry management efforts The recent effluent
characterization efforts have established effluent hardness conditions and showed that copper levels
periodically exceed the current limits, so potential limits were established based on the new hardness
Information The copper levels still periodically exceed the potential limits HNP does not believe copper
Is being added from any water treatment additives. Concentration of the Intake water by cooling tower
cycling has been Identified as a contributor to elevated levels Corrosion of plant components that
contain copper is a potential Issue HNP will work with chemical suppliers to evaluate the potential
sources of copper and determine whether copper levels can be reduced through further management of
water chemistry
Options for Further Permit Limits Modifications
Several regulatory options are available to potentially modify the water quality -based effluent limit In
the NPDES Permit These Include using a mixing zone analysis to justify more dilution for permit
calculations, using the biotic ligand model (BLM) (EPA, 2007) to justify alternative receiving water
criteria for dissolved copper, and conducting necessary bioassay tests to support development of a
water effect ratio (WER) for copper Each of these Is discussed In this section
Mixing Zone Analysis
The current permit limitations were developed assuming no dilution for the discharge from Outfall 006
While Harris Reservoir has a significant volume to provide dilution, no specific mixing zone studies or
modeling has been conducted It is Duke Energy's experience that no dilution credit has been given for
cooling water or combined discharges in other lake discharge situations in North and South Carolina
Justification for dilution in effluent limits development would likely require a dilution model and,
potentially, a broader water quality modeling evaluation to consider the build-up of copper in the lake
Since this type of evaluation has not been undertaken previously in North Carolina, this approach is not
recommended as an initial alternative to provide some regulatory relief However, use of a mixing zone
analysis, as outlined in Chapter 5 of EPA's Water Quahty Standards Handbook (EPA, 1994b) may be
pursued during Year 3 or 4 of the compliance schedule, if necessary
Biotic Ligand Model
The BLM for copper was published In draft form by EPA in 2003 and finalized in 2007 (EPA, 2007) While
the ambient criteria that is the basis for the North Carolina hardness -based equation for copper (15A
North Carolina Administrative Code [NCAC] 2b 0211 (11)(d)) was first published in 1984, the 2007
criteria document Is also referenced in the rule.
The BLM could support development of site-specific criteria applicable to Harris Reservoir. However, the
HNP Outfall 006 effluent limits are calculated without consideration of dilution In Harris Reservoir
Therefore, it seems like the an effluent specific approach like the WER (discussed below) Is more
appropriate
Water Effect Ratio
A WER Is a procedure to account for the difference in toxicity of a metal In laboratory water versus the
toxicity In water "at the site" (EPA, 1994c) The guidance specifically uses the term "site" because the
water used to compare toxicity (to laboratory water) varies, depending on the discharge situation There
is an effect due to the same Influences of pH, dissolved organic matter (DOM), and minerals that EPA
has considered in the BLM, but they are measured through a series of toxicity tests. In the case of the
HNP Outfall 006, the site water would be the effluent, since permit limits have been calculated based on
the hardness -based equations without any consideration of dilution
The NC water quality standards rules reference development of a WER based on the Water Quahty
Standards Handbook Second Edition (EPA, 1994b) and subsequent amendments The Handbook
PR0802171202CLT CH2M HILL NORTH CAROLINA, INC

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
references an Interim guidance document for determining WER values for metals (EPA, 1994c) EPA also
developed a streamlined WER approach specifically for copper, which would seem to be suitable for
relatively simple permitting situations (criteria applied with no consideration of dilution), as Is the case
for the HNP (EPA, 2001)
Selection of Water Effect Ratio and Schedule for Implementation
The HNP Is proposing to conduct WER testing for copper at Outfall 006 as part of the Year 2 activities
associated with this CAP Duke Energy has familiarity with using WER to calculate limits for copper for
discharges from facilities In South Carolina, where water quality -based limits are also calculated
assuming little or no dilution of the combined discharge.
HNP Is recommending that WER testing Is the next step in evaluating alternative permit limits for
copper, and Is proposing the activities described In the following paragraphs be undertaken
Protocol Development
Following acceptance of this CAP by DWR, SNHP will submit a protocol for WER testing within 60 days It
Is anticipated that the protocol will be based on the Interim Guidance (EPA, 1994c)
Sampling and Testing Schedules
The 3 -month characterization Information for copper shows that copper levels appeared to Increase
from April through June, as water and air temperature (and cooling requirements) Increased For this
reason, It is anticipated that a sampling event will be targeted for this transition period, with one or two
more for the summer However, copper Is continuing to be monitored at an increased frequency (twice
per month), and all data will be considered when recommending a sampling schedule as part of the WER
protocol
Final Water Effect Ratio Report
A final report will be prepared summarizing the entire process of developing a WER for Outfall 006,
including all field and laboratory back-up materials It is anticipated that this report will be submitted
approximately 90 days after the final sampling event
Year 2 Activities Report
As required by Part A. (9) of the NPDES Permit, all actions taken based on this CAP will be reported on by
September 1, 2018 This report will summarize activities, conclusions, and any adjustments to the CAP
based on the Year 2 activities.
10 CH2M HILL NORTH CAROLINA, INC PRO802171202CLT

CORRECTIVE ACTION PLAN FOR COPPER AND ZINC FOR HARRIS NUCLEAR PLANT NPDES PERMIT
References
HydroQual, Inc. 2007 Biotic Ligand Model— Windows Interface. Version 2.2.3
U.S. Environmental Protection Agency (EPA) 1985 Ambient Water Quality Criteria for Copper -1984
Washington, DC- Office of Water Regulations and Standards, Criteria and Standards Division
US Environmental Protection Agency (EPA) 1994a. Method 200.7— Determination of Metals and Trace
Elements in Water and Wastes by Inductively Coupled Plasma -Atomic Emission Spectrometry Cincinnati,
OH: Environmental Monitoring Systems Laboratory, Office of Research and Development
U.S Environmental Protection Agency (EPA) 1994b Water Quality Standards Handbook- Second Edition
Washington, DC Office of Water, Office of Science and Technology Accessed July 2017
http://water.epa gov/scitech/swguidance/standards/handbook
U.S Environmental Protection Agency (EPA) 1994c. Interim Guidance on Determination and Use of
Water -Effect Ratios for Metals. Washington, DC- Office of Water, Office of Science and Technology.
U S Environmental Protection Agency (EPA) 1996 Method 1669 —Sampling Ambient Water for Trace
Metals at EPA Water Quality Criteria Levels Washington, DC- Office of Water, Engineering and Analysis
Division
U.S Environmental Protection Agency (EPA) 2001 Streamlined Water -Effect Ratio Procedure for
Discharges of Copper Washington, DC Office of Water, Office of Science and Technology
U S Environmental Protection Agency (EPA). 2007 Ambient Water Quality Criteria for Copper -2007
Revision Washington, DC Office of Water, Office of Science and Technology
U.S. Environmental Protection Agency (EPA) 2016a Water Quality Standards Academy: Biotic Ligand
Model and Copper Criteria Washington, DC: Office of Science and Technology
U S Environmental Protection Agency (EPA) 2016b. Draft Technical Support Document- Recommended
Estimates for Missing Water Quality Parameters for Application in EPA's Biotic Ligand Model
Washington, DC: Office of Water.
PR0802171202CLT CH2M HILL NORTH CAROLINA, INC 11

Attachment 1
Procedure CRC 591 Operation of Isco Samplers

HARRIS NUCLEAR PLANT
PLANT OPERATING MANUAL
VOLUME 5
PART 3
PROCEDURE TYPE- Chemistry and Radiochemistry
NUMBER. CRC -591
TITLE: Operation of the ISCO Samplers
I
INFORMATION
USE
CRC -591 I Rev 14 1 Page 1 of 13

Table of Contents
Section
Page
10
PURPOSE . ...... .......
..3
20
REFERENCES . ......
3
30
DEFINITIONS AND ABBREVIATIONS
3
4.0
RESPONSIBILITIES...
3
5.0
GENERAL ...... ..........
3
6.0
PREREQUISITES .....
3
70
PRECAUTIONS AND LIMITATIONS
4
80
REAGENTS AND APPARATUS .............. . ..................... ..
4
90
ACCEPTANCE CRITERIA
4
100
PROCEDURE STEPS
5
101 Composite Sample Collection from Cooling Tower Blowdown
..5
102 Composite Sampler Setup for Combined Outfall
6
103 Composite Sample Collection from Combined Outfall
6
104 Grab Sample Collection from Combined Outfall
8
105 Sample Collection from Sewage Treatment Plant .......................
8
106 Preventive Maintenance.
8
10.7 Sampler Operability Check
9
110
DIAGRAMS /ATTACHMENTS /CALCULATIONS
9
11 1
Diagrams. ................ ............... ............ ...
9
112
Attachments
..9
113
Calculations
9
Attachment 1- ISCO SAMPLER LOCATIONS ...........
10
Attachment 2- ISCO OPERABILITY CHECK
11
Attachment 3- ISCO MAINTENANCE LOG..... . ...........12
Revision Summary..... ... . .. ...
13
CRC -591 I Rev 14 1 Page 2 of 13

1.0 PURPOSE
This procedure provides guidance on the use and maintenance of ISCO composite
liquid samplers located outside the Protected Area. Specificsample requirements,
such as for the ODCM and NPDES, are not covered by this procedure, but rather in
their respective procedures.
2.0 REFERENCES
1. ISCO Model 3710 Portable Samplers Installation and Operation Guide,
Teledyne ISCO, Inc.
2 ISCO Model 3710FR/3730 Fiberglass Refrigerated Sampler Instruction
Manual, Teledyne ISCO, Inc
3. ISCO Model 4700 Refrigerated Sampler Installation and Operation Guide,
Teledyne ISCO, Inc.
4. ISCO Model 5800 Refrigerated Sampler Installation and Operation Guide,
Teledyne ISCO, Inc.
5 Off -Site Dose Calculation Manual (ODCM)
6 CRC -290, Radiological Sample Compositing System
7. EMP -001, NPDES Permit Monitoring
8. EMP -009, Operation of the AX -Max Sewage Treatment System
9 EMP -010, Sanitary Sewage Treatment Plant Operating Procedure
10 VM-UHH, ISCO Mfg. Co. Inc. Equipment
3.0 DEFINITIONS AND ABBREVIATIONS
31 Definitions
N/A
32 Abbreviations
a. NPDES — National Pollutant Discharge Elimination System
b ODCM — Off Site Dose Calculation Manual
C PPE— Personnel Protective Equipment
4.0 RESPONSIBILITIES
W10
5.0 GENERAL
The ISCO samplers are automatic samplers used to obtain composite liquid
samples from continuous liquid waste release streams. Attachment 1 lists the ISCO
samplers in use. The ISCO samplers use a peristaltic pump to force incremental
sample volumes (aliquots) into a sample container at pre-programmed frequencies
and rates. Some models are refrigerated.
6.0 PREREQUISITES
N/A
CRC -591 Rev. 14 Page 3 of 13

7.0 PRECAUTIONS AND LIMITATIONS
1. The suction line from the sampler to the sample point is sloped downhill to
minimize clogging and sample line freeze-up
2 Sampler settings will provide adequate sample volume so that all required
analyses can be performed without exceeding the sample container capacity
and allow for margin of error in the volume of individual sample capture.
3 Cooling Tower composite samples are acidified and handled with the
appropriate PPE
4. The Combined Outfall toxicity sample must be maintained 0°C - 6°C during
shipment Any toxicity sample failing to meet temperature requirements
upon receipt at the off-site laboratory is discarded and the effluent must be
resampled
5. The Combined Outfall toxicity sample must be used within 72 hours after
collection.
6 Refrigerated temperature for NPDES and Toxicity samples are maintained
between 1°C and 4°C during sampling.
8.0 REAGENTS AND APPARATUS
1 1:1 Nitric Acid (HNO3) - Mix equal volumes of demineralized water and
reagent grade nitric acid (65%), Cat ID 72856859
9.0 ACCEPTANCE CRITERIA
1 The ISCO Operability Check Acceptance Criteria is +/- 25%.
CRC -591 I Rev 14 1 Pa e 4 of 13

10.0 PROCEDURE STEPS
NOTE: Attachment 1 lists the samplers in use and provides some general information.
This procedure assumes that the sampler is set up and operational. If initial set
up information is needed, refer to the vendor manual. Information on sampler
settings may be available near the sampler or included in the appropriate
binder.
10.1 Composite Sample Collection from Cooling Tower Blowdown
NOTE: Steps 1 and 2 may be performed in any order, but should be completed
expeditiously at the Cooling Tower
1. RECORD the Cooling Tower Blowdown integrator readings
2. STOP the composite sampler to prevent automatic operation during the
sample collection
3. REMOVE the sample container, AND MIX thoroughly.
NOTE: Typically, a one liter sample volume is collected for Cooling Tower Blowdown.
4 COLLECT enough volume of sample to perform desired analysis.
5. DISCARD the remainder of sample from the sample container
6 VERIFY pH of sample is <2 with pH paper.
NOTE: Steps 7 and 8 may be performed in any order
7 REPLACE the sampler container.
NOTE: The amount of acid added in the next step will vary based on composite
sampler settings and will be determined by experience Typically, 50 mis of 1:1
nitric acid is added.
8 ADD 1.1 nitric acid such that sample pH will be <2 while collecting sample.
9. START the composite sampler.
CRC -591 I Rev. 14 1 Pa e 5 of 13

10.2 Composite Sampler Setup for Combined Outfall
NOTE: Typically, an approximately 400 ml aliquot is collected once per hour for a
24 -hr period
NOTE: For NPDES sampling, a plastic liner is used in the collection container. The
plastic liner cannot be used for toxicity sampling otherwise the collection
temperature will not be met. A separate container will be utilized for toxicity
sampling
1. TURN ON the composite sampler.
2. IF necessary to collect an aliquot each hour for a 24 -hr period, THEN
PROGRAM the composite sampler.
3 FLUSH the composite sampler pump and tubing by manually collecting a
sample aliquot.
4 DISCARD the collected aliquot from the sample container
5. IF necessary to ensure sample is maintained 0°C - 4°C during sampling,
THEN ADJUST composite sampler thermostat.
6 START the composite sampler
10.3 Composite Sample Collection from Combined Outfall
1. VERIFY all 24 samples have been collected.
2. STOP the composite sampler.
3. RECORD ISCO refrigerator temperature on appropriate log.
4 REMOVE the sample container AND MIX thoroughly.
5. COLLECT enough volume of sample to perform analyses per EMP -001 AND
CRC -001.
6 IF collecting a toxicity sample, THEN perform the following.
a. RINSE sample container with sample three (3) times
b. FILL sample container completely with no airspace.
c. MEASURE composite sample temperature
d LABEL the toxicity sample.
e SEAL the toxicity sample
f PLACE the toxicity sample in an insulated container.
g. COVER the toxicity sample with ice to maintain sample temperature
0°C - 6°C during shipment
7 DISCARD the remainder of sample from sample container
8. RINSE AND REPLACE the sampler container.
9. TURNOFF the composite sampler.
CRC -591 I Rev. 14 1 Pa e6 of 13

10.3 Composite Sample Collection from Combined Outfall (continued)
NOTE: The Combined Outfall toxicity sample must be used within 72 hours after
collection. The Combined Outfall toxicity sample should be shipped to the off-
site lab on the same day as collected by overnight delivery. The off-site lab
should be notified of the Combined Outfall toxicity sample gamma scan and
tritium results
10 IF shipping sample to off-site lab, THEN,
a COMPLETE all applicable forms.
b. SHIP the sample.
CRC -591 I Rev 14 1 Page 7 of 13

10.4 Grab Sample Collection from Combined Outfall
1. OPERATE the composite sampler in manual mode.
2. COLLECT enough volume of sample to perform analyses per EMP -001 AND
CRC -001
10.5 Sample Collection from Sewage Treatment Plant
1. IF sampling STP 2 (Extended Aeration), THEN GO TO
EMP -010, Section 10.3.
2. IF sampling STP 3 (AX -Max), THEN GO TO EMP -009, Section 10 3.
10.6 Preventive Maintenance
II NOTE: Refer to the vendor manual for additional maintenance details. II
1 DOCUMENT maintenance performed on Attachment 3.
Preventive Maintenance Task
Recommended
Frequency
Battery check (CTBD only)
Weekly
Check and/or replace desiccant cartridge
Monthly
Check and/or replace pump tube
Monthly
Delivered Volume Check
Monthly
Operability Check
Quarterly
Check suction tubing and strainer assembly
Quarterly
Clean condenser cod area and clean/replace
As needed
refrigerator filter
Defrost refrigerator
As needed
CRC -591 I Rev. 14 1 Page 8 of 13

10.7 Sampler Operability Check
A cursory and visual check of the sampler should be performed each time the
sampler is used to ensure that the sampler is functioning normally If any
malfunction or discrepancy is suspected, verification of proper sampler operation
should be done An acceptable method of operability check is to correlate the total
volume of sample collected with: the effluent flow, the expected total sample
volume, the volume of each sample capture, and number of samples collected If
the actual total volume is within 25% of the expected volume, it is acceptable. If not,
further investigation should be conducted to identify and correct the problem. The
sampler operability check should be performed as necessary and at least quarterly
for the samplers in use, and documented on Attachments 2 and 3.
11.0 DIAGRAMS/ATTACHMENTS/CALCULATIONS
11.1 Diagrams
N/A
11.2 Attachments
Attachment 1 - ISCO SAMPLER LOCATIONS
Attachment 2 - ISCO OPERABILITY CHECK
Attachment 3 - ISCO MAINTENANCE LOG
11.3 Calculations
N/A
CRC -591 I Rev. 14 1 Pa e 9 of 13

ATTACHMENT 1
Page 1 of 1
ISCO SAMPLER LOCATIONS
Sample Point
Combined Outfall
(Required by NPDES)
STP 2 (Extended Aeration)
Sewage Treatment Plant
(Required by NPDES)
STP 3 (AX -Max)
Sewage Treatment Plant
(Required by NPDES)
CT Blowdown Weir
(Required by ODCM)
Model
3710FR
4700
5800
3710
Two samplers are in
service, one as a backup.
Located in a shed about
A sample is pulled from
350 ft SSW of ESW
one and the other is
Screening Structure, the
discarded. Located near
sampler suction line is
the CTBD, the sampler
routed to the combined
Located at the STP The
suction line is positioned at
discharge line. Powered
sampler receives a signal
Located in the AX -Max
the blowdown weir. In the
Description
from PP -1-4A10121-20
from the ISCO Model 4210
Control Building. Sample is
railcar chlorination shed
which is located in the
Flow Recorder. Sample is
cooled between 1 ° and 4° C.
(east of NSW), LP -618-10
Aux. Intake Structure. Set
cooled between 1 ° and 4° C.
provides power to the
to Time mode and pulls
outlets for the samplers
samples hourly for 24
The samplers receive a
hours. Sample is cooled
signal from the respective
between 1' and 4°C
ISCO Model 4210 Flow
Recorder.
NOTE: The model numbers are provided for information only. If the refrigerated unit is not available or functioning, ice may be used
for sample cooling Sample volumes may be adjusted as necessary.
NOTE: The Cooling Tower ISCO Model 4210 Flow Recorder emits a pulse for every 100,000 gallons of flow.
CRC -591 I Rev. 14 1 Page 10 of 13

ISCO OPERABILITY CHECK
LOCATION -
ATTACHMENT 2
Page 1 of 1
ACTUALm, X100%=
EXPECTED„,
RESULTS- PASS/FAIL
ACCEPTANCE CRITERIA +/- 25%
INITIALS
NO OF
NO. OF
VOLUME OF
VOLUME OF
DATE
ALIQUOTS
ALIQUOTS
SAMPLE
SAMPLE
COLLECTED
EXPECTED
COLLECTED
EXPECTED
ACTUALm, X100%=
EXPECTED„,
RESULTS- PASS/FAIL
ACCEPTANCE CRITERIA +/- 25%
INITIALS
ACTUAL,,,, X 100% _
EXPECTED,,,, ACCEPTANCE CRITERIA +/- 25%
RESULTS PASS/FAIL INITIALS
NO OF
NO. OF
VOLUME OF
VOLUME OF
DATE
ALIQUOTS
ALIQUOTS
SAMPLE
SAMPLE
COLLECTED
EXPECTED
COLLECTED
EXPECTED
ACTUAL,,,, X 100% _
EXPECTED,,,, ACCEPTANCE CRITERIA +/- 25%
RESULTS PASS/FAIL INITIALS
ACTUALm„s X100%=
EXPECTED,,,s
RESULTS PASS/FAIL
ACCEPTANCE CRITERIA +/- 25%
W "1 011613
CRC -591 I Rev 14 1 Page 11 of 13
NO OF
NO OF
VOLUME OF
VOLUME OF
DATE
ALIQUOTS
ALIQUOTS
SAMPLE
SAMPLE
COLLECTED
EXPECTED
COLLECTED
EXPECTED
ACTUALm„s X100%=
EXPECTED,,,s
RESULTS PASS/FAIL
ACCEPTANCE CRITERIA +/- 25%
W "1 011613
CRC -591 I Rev 14 1 Page 11 of 13

ISCO MAINTENANCE LOG
LOCATION -
ATTACHMENT 3
Page 1 of 1
BATTERY
CHECK
(CTBD ONLY)
WEEKLY
CHECK
DESICCANT
MONTHLY
CHECK
PUMP
TUBING
MONTHLY
DELIVERED
VOLUME
CHECK
MONTHLY
OPERABILITY
CHECK
QUARTERLY
CHECK SUCTION
TUBING &
STRAINER
QUARTERLY
CLEAN CONDENSER
COIL AND
CLEAN/REPLACE
REFRIGERATOR FILTER
DEFROST
REFRIGERATOR
TECNICIAN TO INITIAL AND DATE WHEN COMPLETED
COMMENTS
CRC -591 I Rev. 14 1 Page 12 of 13

Revision Summary
PRP 7ngRAR
Section
Change
All
Updated footer to Rev 14.
Added/updated the following references:
2. ISCO Model 3710FR/3730 Fiberglass Refrigerated Sampler Instruction
20
Manual, Teledyne ISCO, Inc.
4. ISCO Model 5800 Refrigerated Sampler Installation and Operation
Guide, Teledyne ISCO, Inc.
8 EMP -009, Operation of the AX -Max Sewage Treatment System
Revised first line in 7.0.4 to- The Combined Outfall toxicity sample must
be maintained 0°C - 6°C during shipment
7.0
Added 7 0 6. Refrigerated temperature for NPDES and Toxicity samples
are maintained between 1 °C and 4°C during sampling.
102
Step 10.2.5: Revised temperature range to 0°C - 4°C.
Added new Step 10.3.3: RECORD ISCO refrigerator temperature on
103
appropriate log.
Revised/added the following steps:
1. IF sampling STP 2 (Extended Aeration), THEN GO TO EMP -010,
10.5
Section 10 3
2. IF sampling STP 3 (AX -Max), THEN GO TO EMP -009, Section 10.3.
Attachment 1
1 Updated table to reflect current ISCO sampler models in service.
CRC -591 I Rev. 14 1 Page 13 of 13

Attachment 2
Results of Intensive Sompling Compoign

Location
Date Time
Constituent
Value
Unit
Duplicate? Rel. % Diff.
006 - NPDES Effluent
4/4/2017 8.20
Copper - Total
8.91
ug/L
006 - NPDES Effluent
4/11/2017 9 50
Copper - Total
841
ug/L
006 - NPDES Effluent
4/11/2017 9:50
Copper - Total
761
ug/L
Yes 10%
006 - NPDES Effluent
4/18/2017 9 05
Copper - Total
74
ug/L
006 - NPDES Effluent
4/18/2017 9.05
Copper - Total
7.54
ug/L
Yes 2%
006 - NPDES Effluent
4/25/2017 8 30
Copper - Total
101
ug/L
006 - NPDES Effluent
4/25/2017 8.30
Copper - Total
107
ug/L
Yes 6%
006 - NPDES Effluent
5/9/2017 9 25
Copper - Total
144
ug/L
006 - NPDES Effluent
5/16/2017 8 15
Copper - Total
146
ug/L
006 - NPDES Effluent
5/23/2017 8 48
Copper - Total
164
ug/L
006 - NPDES Effluent
5/23/2017 8 48
Copper - Total
136
ug/L
Yes 19%
006 - NPDES Effluent
5/30/2017 1111
Copper - Total
123
ug/L
006 - NPDES Effluent
6/6/2017 14 06
Copper - Total
229
ug/L
006 - NPDES Effluent
6/13/2017 14 42
Copper - Total
307
ug/L
006 - NPDES Effluent
6/13/2017 14 42
Copper - Total
381
ug/L
Yes 22%
006 - NPDES Effluent
6/20/2017 1130
Copper - Total
22
ug/L
006 - NPDES Effluent
6/27/2017 10 39
Copper - Total
182
ug/L
006 - NPDES Effluent
7/5/2017 8 10
Copper - Total
144
ug/L
006 - NPDES Effluent
7/11/2017 0.00
Copper - Total
24
ug/L
006 - NPDES Effluent Blank
4/25/2017 8 30
Copper - Total
< 1
ug/L
006 - NPDES Effluent Blank
5/9/2017 9 25
Copper - Total
< 1
ug/L
006 - NPDES Effluent Blank
6/20/2017 1130
Copper - Total
< 5
ug/L
006 - NPDES Effluent Eq Blank
5/9/2017 9 25
Copper - Total
168
ug/L
006 - NPDES Effluent Eq Blank
6/13/2017 14 30
Copper - Total
< 5
ug/L
006 - NPDES Effluent Eq Blank
7/11/2017 0 00
Copper - Total
< 1
ug/L
006 - NPDES Effluent
4/4/2017 8 20
Hardness
38
mg/L
006 - NPDES Effluent
4/11/2017 9.50
Hardness
41
mg/L
006 - NPDES Effluent
4/11/2017 9 50
Hardness
40
mg/L
Yes 2%
006 - NPDES Effluent
4/18/2017 9.05
Hardness
46
mg/L
006 - NPDES Effluent
4/18/2017 9 05
Hardness
47
mg/L
Yes 2%
006 - NPDES Effluent
4/25/2017 8 30
Hardness
41
mg/L
006 - NPDES Effluent
4/25/2017 8 30
Hardness
42
mg/L
Yes 2%
006 - NPDES Effluent
5/9/2017 9.25
Hardness
41
mg/L
006 - NPDES Effluent
5/16/2017 8.15
Hardness
41
mg/L
006 - NPDES Effluent
5/23/2017 8 48
Hardness
40
mg/L
006 - NPDES Effluent
5/23/2017 8 48
Hardness
39
mg/L
Yes 3%
006 - NPDES Effluent
5/30/2017 11:11
Hardness
45
mg/L
006 - NPDES Effluent
6/6/2017 14 06
Hardness
487
mg/L
006 - NPDES Effluent
6/13/2017 14.42
Hardness
462
mg/L
006 - NPDES Effluent
6/13/2017 14 42
Hardness
578
mg/L
Yes 22%
006 - NPDES Effluent
6/20/201711.30
Hardness
447
mg/L
006 - NPDES Effluent
6/27/2017 10 39
Hardness
439
mg/L
006 - NPDES Effluent
7/5/2017 8 10
Hardness
409
mg/L
006 - NPDES Effluent
7/11/2017 0.00
Hardness
476
mg/L
006 - NPDES Effluent Blank
4/25/2017 8.30
Hardness
< 0
mg/L
006 - NPDES Effluent Blank
5/9/2017 9 25
Hardness
<0 14
mg/L
006 - NPDES Effluent Blank
6/20/2017 11.30
Hardness
0 046
mg/L
006 - NPDES Effluent Eq Blank
5/9/2017 9 25
Hardness
039
mg/L
006 - NPDES Effluent Eq Blank
6/13/201714.30
Hardness
0.169
mg/L
006 - NPDES Effluent Eq Blank
7/11/2017 0 00
Hardness
0 198
mg/L

Location
Date Time
Constituent
Value
Unit
Duplicate? Rel. % Diff.
006 - NPDES Effluent
4/4/2017 8:20
Zinc - Total
< 10
ug/L
006 - NPDES Effluent
4/11/2017 9 50
Zinc - Total
243
ug/L
006 - NPDES Effluent
4/11/2017 9.50
Zinc - Total
21
ug/L
Yes 15%
006 - NPDES Effluent
4/18/2017 9 05
Zinc - Total
129
ug/L
006 - NPDES Effluent
4/18/2017 9:05
Zinc - Total
12.8
ug/L
Yes 08%
006 - NPDES Effluent
4/25/2017 8 30
Zinc - Total
168
ug/L
006 - NPDES Effluent
4/25/2017 8 30
Zinc - Total
211
ug/L
Yes 23%
006 - NPDES Effluent
5/3/2017 9 44
Zinc - Total
192
µg/L
006 - NPDES Effluent
5/9/2017 9.25
Zinc - Total
252
ug/L
006 - NPDES Effluent
5/16/2017 8 15
Zinc - Total
222
ug/L
006 - NPDES Effluent
5/23/2017 8 48
Zinc - Total
26.2
ug/L
006 - NPDES Effluent
5/23/2017 8 48
Zinc - Total
175
ug/L
Yes 40%
006 - NPDES Effluent
5/30/2017 11:11
Zinc - Total
119
ug/L
006 - NPDES Effluent
6/6/201714 06
Zinc - Total
16
ug/L
006 - NPDES Effluent
6/13/2017 14 42
Zinc - Total
326
ug/L
006 - NPDES Effluent
6/13/2017 14.42
Zinc - Total
487
ug/L
Yes 40%
006 - NPDES Effluent
6/20/201711:30
Zinc - Total
22
ug/L
006 - NPDES Effluent
6/27/2017 10 39
Zinc - Total
139
ug/L
006 - NPDES Effluent
7/5/2017 8.10
Zinc - Total
954
ug/L
006 - NPDES Effluent
7/11/2017 0 00
Zinc - Total
269
ug/L
006 - NPDES Effluent Blank
4/25/2017 8.30
Zinc - Total
< 10
ug/L
006 - NPDES Effluent Blank
5/9/2017 9 25
Zinc - Total
< 10
ug/L
006 - NPDES Effluent Blank
6/20/2017 11 30
Zinc - Total
< 5
ug/L
006 - NPDES Effluent Eq Blank
5/9/2017 9 25
Zinc - Total
< 10
ug/L
006 - NPDES Effluent Eq Blank
6/13/201714.30
Zinc -Total
< 5
ug/L
006 - NPDES Effluent Eq Blank
7/11/2017 0 00
Zinc - Total
< 5
ug/L