NCS000572_SW Fish Tissue Reporting Request Letter_20170713

DUKE
O ENERGY®
PROGRES`'
July 13, 2017
Ms. Bethany Georgoulias
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, N.C. 27699-1612
Environmental Services
Duke Energy Progress, LLC
410 S. Wilmington Street
Raleigh, NC 27601
Subject: Clarification of NPDES Stormwater Fish Tissue Monitoring Reporting Requirements
Dear Ms. Georgoulias,
As follow up to our joint meeting on April 18, 2017 and your email on June 8, 2017, Duke
Energy requests clarification of the stormwater NPDES permit requirement for reporting of fish
tissue monitoring data.
Duke Energy has a number of NPDES wastewater permits with fish tissue monitoring and
reporting requirements. Typically the wastewater permits for generating sites require sampling
once per year, while permits for retired sites require sampling once during the permit term.
The reporting requirements in the wastewater permits also vary; in some cases the permits
require yearly reporting (in the year following sample collection) while others require that data
be reported with the permit renewal package. Duke Energy performs the sampling in
accordance with a plan reviewed and approved by the Division. The approved plan for the
Sutton Energy Complex is attached to this letter for your reference.
The wastewater permit provides for a time delay, between the fish sample collection and the
data reporting requirement, in consideration of the time required to collect, process, and
analyze fish tissue. For sample collection, Duke Energy staff makes multiple trips throughout
the calendar year to obtain fish species of the appropriate size and diversity to meet the plan
requirements. Fish collected during each sampling trip are frozen and stored until the end of
the calendar year. Fish tissue processing, sample analysis, and QA/QC take place the year
following sample collection and require several months to complete. Duke Energy then
prepares reports to present and trend the data which are tailored to the specific requirements
of the NPDES wastewater permits.
Reflective of the fish tissue sample collection and analysis process which has been approved by
DEQ in the sampling plans and reflected in the NPDES wastewater permit requirements, Duke

Duke Energy Request for Clarification of NPDES Stormwater Fish Tissue Monitoring Requirements
Page 2 of 2
Energy requests that DEMLR provide clarification for the fish tissue reporting requirements in
the NPDES individual stormwater permit. Duke Energy requests the clarification indicate that
fish tissue monitoring data be provided to the DEMLR concurrent with submittal to the NC
Division of Water Resources (DWR). Where stormwater and wastewater permit expiration
dates are not aligned, Duke Energy proposes that the clarification indicate that data available at
the time of stormwater permit renewal be submitted with the renewal application and that
subsequent data submitted to DWR with the wastewater permit renewal application be
provided to DEMLR at the same time.
Thank you for your consideration of Duke's request. If you have any questions or need
additional information, please don't hesitate to contact Toya Ogallo at letoya.ogallo@duke-
energy.com or [phone].
Sincerely,
E. Shannon Langley
EHS-CCP Permitting and Compliance

WaterResources
ENVIRONMENTAL QUALITY
September 8th, 2016
® HNWE DD
0,a 1 Q 7016
Duke Energy Progress, Inc.
L. V. Sutton Energy Complex
Mr. Jesse Huntley
L.V. Sutton Energy Complex
601 Sutton Steam Plant Road
Wilmington, NC 28401
PAT MCCRORY
Goeenror
DONALD R. VAN DER VAART
Secretan.
S. JAY ZIMMERMAN
Subject: Review of Duke Energy Progress, Sutton Energy Complex (NC0001422) Proposed
NPDES Fish Tissue and Ambient Sampling Plan.
Dear Mr. Huntley:
Director
Jeff DeBerardinis from the Water Sciences Section (WSS) staff has reviewed the aforementioned fish
tissue and ambient sampling plan. From this review, we concur with your ambient monitoring proposal. In
terms of the fish tissue sampling methods, and as is the case in other NPDES Permits, we would suggest
the following general sampling regime: Three (3) river stations: 1) Upstream Station (clearly outside of
plant influence), 2) Outfall Station, and 3) Downstream Station location. In addition, we would suggest
one (1) lake station where target species can be obtained. Aside from these issues, we concur with the
remaining portion of your fish tissue sampling proposal.
We fully understand the difficulty and effort required to obtain fish from this segment of the Cape Fear
River, and we are willing to accept the appropriate surrogate species when necessary. However, if this
does become necessary, we would need clarification on what species are being used as surrogates.
Lastly, we apologize for the delay in this review. We never physically received the letter here at the Water
Sciences Section and were only made aware of this letter in an email (dated 912116) from Toya Ogallo to
Cyndi Karoly where this letter was an attachment.
In any event, if you have any questions, please do not hesitate to contact me or my staff.
Sincerely,
v
Cyndi Karoly
Chief, Water Sciences Section
Ce'. Jim Gregson, Wilmington Regional Office
Tom Belnick, Surface Water Protection Section
Ken Rudo, North Carolina Department of Health and Human Services
Mina Shehee, North Carolina Department of Health and Human Services
State of North Carolina I Environmental Quality, Water Resources
Water Sciences SediOn
1621 Mail Service Center
Raleigh NC 27699-1621
919-743-8400

4*DUKE
ENERGY,
PROGRESS
April 22, 2016
CerfiMiod MNxii * 7012 1640 0000 46%9 808f (2 copies)
Ms. Cyndi Karoly, Chief Water Sciences Section
North Carolina Department of Environmental Quality
Division of Water Resources
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Subject: Duke Energy Progress, LLC., Sutton Energy Complex (NC0001422)
Proposed NPDES Fish Tissue and Ambient Sampling Plan
Dear Ms. Karoly:
L. V. Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
m 910.341.4750
f: 910.341.4790
Enclosed is Duke Energy Progress LLC's (Duke Energy's) NPDES Sampling Plan. This plan has been
prepared and is being submitted in accordance with condition A(17) and A22) of NPDES permit
NCO001422 for the L.V. Sutton Energy Complex.
Duke Energy appreciates your review of this study proposal. As required by the permit, upon approval by
the Division, the study plan will become an enforceable part of the NPDES permit.
If there are any questions, please contact either:
• Mr. R. Glenn Rivenbark, NPDES ORC for the L. V. Sutton Energy Complex; phone (910) 341-
4774, e-mail Roland. Rivenbark@ duke-energy.com;
• Mr. Kent Tyndall, Environmental Professional for the L. V. Sutton Energy Complex; phone (910)
341-4775 or e-mail [e-mail]; or
• Mr. Reid Garrett, Lead Environmental Scientist at our North Carolina Regional Office, phone
[phone] or e-mail [e-mail];
I 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. l am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.
Sincerely,
JAWL, E [" II
Jesse E. Huntley, II
Station Manager Station Manager
C: Cerfired Mai! # 7012 if4c MW 4619 80TB (r copy)
Sergei Chernikov
NCDEQ NPDES Complex Permitting Unit
1617 Mail Service Center
Raleigh, NC 27699-1617

NPDES Water Quality and Fish Tissue Monitoring Plan
March 2016
Sutton Energy Complex
NPDES No. NC0001422
DUKE
ENERGY-

1.0 Introduction
Duke Energy Progress, LLC (DEP) owns and operates the L.V. Sutton Energy Complex (Sutton Plant)
located near Wilmington, North Carolina. The National Pollutant Discharge Elimination System
(NPDES) permit for the Sutton Plant requires DEP to conduct trace elements monitoring in fish muscle
tissue once per year, in accordance with a study plan approved by the North Carolina Division of
Environmental Quality (NCDEQ). This study plan outlines the proposed methods for sampling,
analyzing, and data reporting to fulfill the NPDES permit requirement for fish tissue and ambient metals
monitoring. DEP recognizes that the specifics of this plan may need to be modified to reflect information
gained during implementation. Any such modifications shall be subject to NCDEQ approval.
2.0 Fish Tissue Monitoring Plan Near Outfalls 001, 002 and 004
Fish muscle tissue will be collected from locations on the Cape Fear River and in Sutton Lake.
2.1 Target Species
The proposed target species will be selected based on prior sampling experience, likely availability,
importance as fish food, predatory nature of certain species, and general trophic level. Species may
include Micropterus spp. (top predator), and Lepomis spp. (intermediate predator), however other similar
species may be retained if the primary target species are unavailable.
Specimens retained for analysis will be individuals considered of sufficient size for human consumption.
As recommended by the US Environmental Protection Agency (EPA), an attempt will be made to ensure
that the size of the smallest individual sampled will not be less than 75% of the total length of the largest
fish within each species group (US EPA 2000). Conformance with this guideline will depend upon the
availability of size class at a particular sampling station.
2.2 Field Sampling Methods
The following active and passive sampling methods may be employed to efficiently collect target species:
boat electrofisher (pulsed DC current), hoop nets, gill nets, and trotlines. Standard sampling methods will
be used for each gear type as outlined in the American Fisheries Techniques Manual (Zale, Parrish, and
Sutton 2012).
Fish retained for trace elements analysis will be identified to species, measured for total length to the
nearest millimeter, weighed to the nearest gram, and immediately placed in a labeled (date, transect,
station, etc.) zip -lock bag on ice until they can be frozen. Only fresh fish that show no signs of
deterioration will be retained for analysis. Fish that have visible, open wounds that could allow
contamination will not be retained.
2.3 Laboratory Processing and Elements Analysis
All fish will be processed in the laboratory for arsenic, selenium and mercury analysis. Sample custody
and tracking of samples will be performed using chain -of -custody forms during transport to or from the
laboratory. The remaining sample will be archived and kept by DEP for up to two years in the event that
re -analysis is needed.
2.4 Data Analysis and Reporting
A report with the sampling methods and data analysis will be prepared and submitted upon the
subsequent NPDES permit renewal application as required by the current NPDES permit NC0001422.
2

3.0 Instream Monitoring in Cape Fear River and Sutton Lake
In accordance with the NPDES permit, DEP will collect ambient samples at three locations: two in the
Cape Fear River (an upstream sample at CFUP and a downstream sample at CFDN) and one on Sutton
Lake at approximately location 8B. The locations have been selected to meet the NPDES permit
requirement: 1000 ft upstream and downstream from outfall 001 and 1000 ft from outfall 004. The
locations are noted in Figure 1. The samples will be collected twice per year and will include total
arsenic, total selenium, total mercury (method 1631), total chromium, total lead, total cadmium, total
copper and total zinc. The monitoring results will be submitted with the NPDES renewal application.
Currently, DEP is an active member of the Lower Cape Fear River Program. As described by the NPDES
permit, the instream monitoring requirements are provisionally waived in light of DEP's participation in
the program. Monitoring requirements will be reinstated if DEP ends its participation with the
Monitoring Coalition.
7.0 References
CP&L. 1998. Selenium monitoring of fish in the Cape Fear River, New Hanover County, North Carolina,
Study Plan. New Hill, North Carolina.
United States Environmental Protection Agency (US EPA). 2000. Guidance for assessing chemical
contaminant data for use in fish advisories, vol. 1. Fish sampling and analysis, third edition. EPA 823-B-
00-007. US EPA, Office of Water. Washington, DC.
Zale, AV, DL Parrish, and TM Sutton, editors. 2012. Fisheries techniques, third edition. American
Fisheries Society. Bethesda, MD.
3

Sutton Lake and Cape Fear River Ambient Sampling Locations
N 0 1,000 2,000 4,000 Feet
0 250 500 1,000 Meters
Public r'r
iy Makeup Boat
LL Pump Ramp
9)
eo
i}
Outfal 1004
[)Ike $B
New
Ash Pond a
a4e
Outfall 002 Cid
Ash Pond
Intake Discharge
Indian Creek Canal / Canal
k
CFUP Sutton Steam Plant Rd
Cooling Pond
Discharge
(Outfall 001)
CFON
Cartwheel
Sutton Steam Electric Plant Branch
4