NC0001422_Demonstration Plant of Study_20171117

DUKE
ENERGY®
PROGRESS
November 17, 2017
r
L V Sutton Energy Complex
801 Sutton Steam Plant Rd
Wilmington, NC 28401
o 910 341 4750
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NOV 21 2017
Certified Mail # 7013 3020 0001 4984 1838 (2 copies)
North Carolina Division of Water Resources Water Quality
Water Sciences Section Permitting Section
1621 Mail Service Center
Raleigh, NC 27699-1621
Subject: Proposed L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
Dear Ms Cyndi Karoly,
In accordance with Part I, Condition A. (20.) of our National Pollutant Discharge Elimination
System (NPDES) Permit No. NC0001422, enclosed is the Draft 316(a) Demonstration Plan of
Study (study plan) for review and comment. This study plan was developed for Duke Energy
Progress, LLC, L. V. Sutton Energy Complex following several meetings earlier this year with
the North Carolina Department of Environmental Quality (NCDEQ) to discuss potential 316(a)
demonstrations at several company facilities in North Carolina, including a meeting on July 14,
2017, specifically regarding Sutton Lake.
A number of points of agreement came from these meetings and were incorporated in the
Sutton Lake study plan. These points include:
• Acceptable use of the DEP 316(a) Demonstration Decision Matrix approach for
addressing study components
• Addressing phytoplankton, zooplankton, benthic macroinvertebrates (excluding
mussels), and periphyton by narrative as these components are considered to be of
Low Potential Impact based on the USEPA 1977 316(a) guidance document and the
experience of NCDEQ and DEP staff biologists
• Use of data from DEP's established Sutton Lake environmental monitoring program
from 2013 to present and recent 316(b) sampling data as relevant to the 316(a)
demonstration
• Sutton Lake being unconventional in the application of 316(a) due to its transitional
location between freshwater and marine ecosystems and the influence of makeup
water pumping from the Cape Fear River, with both aspects influencing the aquatic
community
• Lack of a suitable waterbody identified with similar limnological/environmental
characteristics to Sutton Lake to use as a reference for comparison
• The use of Representative Important Species in the assessment as indicators of a
Balanced Indigenous Community
• Use of continuous temperature monitors rather than modeling for the Sutton Lake
thermal analysis

Ms Cyndi Karoly
Proposed Initial 316(a) Demonstration Plan of Study
November 17, 2017
Page 2
DEP plans to implement the two-year demonstration during 2018 upon receiving final approval
of the study plan from NCDEQ. Please keep in mind the NPDES permit requires the following
milestones as a component of the 316(a) compliance schedule (section A(2)) of the permit)::
• DEQ will perform the Plan review and provide comments to Duke within 30 days of the
plan receipt;
• Duke will meeting with DEQ January 29, 2018 to provide responses the DEQ/EPA
comments and discuss the Study Plan;
• Duke will submit the Final Plan to DEQ and EPA by February 28, 2018; and
• Duke will conduct 2 years of monitoring after obtainin and approval of the Study Plan.
If there are any questions, please contact either:
• Mr. Reid Garrett, Lead Environmental Scientist at our North Carolina Regional Office,
phone [phone], e-mail Reid. [e-mail]; or
• Mr. Kent Tyndall, Environmental Professional for the L. V. Sutton Energy Complex;
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 I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations
Si
n Talbott
on Manager
CC: Certified Mail #'7013 3020 0001 49.84 1852 (1 copy)
Sergei Chernikov
North Carolina Division of Water Resources
WQ Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Certified Marl # 7013 3020 00014984 1869 (1 copy)
Karrie-Jo Shell
US EPA REGION 4
61 Forsyth Street, S.W.
Mail Code: 9T25
Atlanta, GA 30303-8960

Plan of Study for Conducting an Initial Section 316(a) Demonstration:
L. V. Sutton Energy Complex, November 2017
Submitted by:
Duke Energy Progress, LLC.
801 Sutton Stearn Plant Rd
Wilmington, NC

L.V. Sutton Energy Complex
Table of Contents
316(a) Demonstration Plan of Study
Page
EXECUIVE SUMMARY .....................................................................................................
1.0
INTRODUCTION............................................................................................................
1
1.1 Regulatory Basis......................................................................................................
1
1.2 Objectives..................................................................................................................
2
2.0
STUDY BACKGROUND..................................................................................................
3
3.0
STUDY PLAN...............................................................................................................
4
3.1 Sutton Lake Description......................................................................................
4
3.2 Sutton Lake Map and Sampling Locations..............................................................
4
3.3 Sutton Lake 316(a) Demonstration Decision Matrix ...............................................
4
3.4 Limnology, Thermal Analysis, Migration Barriers ................................................
5
3.5 Habitat Formers.........................................................................................................
5
3.6 Plankton, Periphyton, and Benthic Macroinvertebrates..........................................
5
3.6.1 Plankton, Periphyton, and Benthic Macroinvertebrates ...............................
5
3.6.2 Mussel Community Survey...........................................................................
5
3.7 Fish Community Assessment...................................................................................
6
3.8 Other Vertebrate Wildlife..........................................................................................
7
3.9 Threatened and Endangered Species.........................................................................
8
4.0
STUDY INITIATION AND DURATION.........................................................................
8
5.0
DATA MANAGEMENT, ANALYSIS, AND REPORTING ..........................................
8
6.0
REFERENCES.....................................................................................................................9
7.0
FIGURES and TABLES.....................................................................................................10

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
EXECUTIVE SUMMARY
As required by the Sutton NPDES permit NC0001422, effective October 1, 2017, Duke Energy
Progress, LLC. has prepared a plan of study to conduct an initial demonstration under Section 316(a) of
the Clean Water Act to support the issuance of an alternative temperature limitation for Outfall 008
based on the protection of a balanced, indigenous community in and on Sutton Lake. The demonstration
is to be completed during a 2 -year period as specified in the NPDES permit and the completed report
will be submitted with the subsequent permit renewal application.
The Plan of Study provides the regulatory basis for issuing an alternative temperature limitation, a
description of the site and the waterbody, the geographic location, environmental conditions that make
the system unique, the study components of the fieldwork, and the final report. Fieldwork will
commence upon final approval of the Plan of Study.

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of
Study
1.0 INTRODUCTION
Duke Energy Progress's (DEP) L. V. Sutton Electric Plant (hereafter Sutton Plant) is located
approximately five miles northwest of Wilmington, NC The plant operated as a three -unit 575
megawatt (MW) coal- fired facility from 1972 to 2013. In November 2013, a newly constructed 625 -
MW combined -cycle natural gas-fired power plant began operations. The new Sutton Plant National
Pollutant Discharge Elimination System (NPDES) permit NC0001422 for this facility requires that a
316(a) demonstration and temperature analysis be completed within term of a compliance schedule in
the permit and a final report to be submitted within the term of the permit.
1.1 Re u�yBasis
On October 1, 2017, the Sutton Plant renewal NPDES permit was issued requiring a section 316(a)
demonstration and temperature analysis to be conducted in accordance with the "specifications
outlined in 40 CFR 125 Subpart H and the EPA's Draft 316(a) Guidance Manual, dated 1977, and the
Region 4 letter to NCDENR, dated June 3, 2010". North Carolina protects freshwater against thermal
effects primarily under 15A NCAC 02B .0208(b) and 15A NCAC 02B .0211(18). However, under
the regulatory authority of 40 CFR 125.73 - Criteria and standards for the determination of alternative
effluent limitations under section 316(a) and 15A NCAC 02B .0208(b), alternative effluent limitations
may be granted based on the demonstration.
40 CFR 125.73 holds that:
"(a) Thermal discharge effluent limitations or standards established in permits may be less
stringent than those required by applicable standards and limitations if the discharger
demonstrates to the satisfaction of the director that such effluent limitations are more stringent
than necessary to assure the protection and propagation of a balanced, indigenous community
of shellfish, fish and wildlife (BIC) in and on the body of water into which the discharge is
made. This demonstration must show that the alternative effluent limitation desired by the
discharger, considering the cumulative impact of its thermal discharge together with all other
significant impacts on the species affected, will assure the protection and propagation of a
balanced indigenous community of shellfish, fish and wildlife in and on the body of water into
which the discharge is to be made.
(b) In determining whether or not the protection and propagation of the affected species will be
assured, the Director may consider any information contained or referenced in any applicable
thermal water quality criteria and thermal water quality information published by the
Administrator under section 304(a) of the Act, or any other information he deems relevant.
(c) (1) Existing dischargers may base their demonstration upon the absence of prior
appreciable harm in lieu of predictive studies. Any such demonstrations shall show:
1

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
(i) That no appreciable harm has resulted from the normal component of the discharge (taking
into account the interaction of such thermal component with other pollutants and the additive
effect of other thermal sources to a balanced, indigenous community of shellfish, fish and
wildlife in and on the body of water into which the discharge has been made; or
(ii) That despite the occurrence of such previous harm, the desired alternative effluent
limitations (or appropriate modifications thereof) will nevertheless assure the protection and
propagation of a balanced, indigenous community of shellfish, fish and wildlife in and on the
body of water into which the discharge is made.
(2) In determining whether or not prior appreciable harm has occurred, the Director shall
consider the length of time in which the applicant has been discharging and the nature of the
discharge"
and
15A NCAC 02B .0208(b) holds that:
"(b) Temperature: the Commission may establish a water quality standard for temperature for
specific water bodies other than the standards specified in Rules .0211 and .0220 of this
Section, upon a case-by-case determination that thermal discharges to these waters, that serve
or may serve as a source or receptor of industrial cooling water provide for the maintenance of
the designated best use throughout a reasonable portion of the water body. Such revisions of
the temperature standard must be consistent with the provisions of Section 316(a) of the
Federal Water Pollution Control Act as amended. A listing of existing thermal revisions shall
be maintained and made available to the public by the Division.
History Note: Authority G.S 143-214.1; 143-215.3(a)(1);
Eff. February 1, 1976;"
Two options for granting an alternative thermal limitation or standard are possible in North Carolina.
For a facility (generally a new facility) without an operating history with a thermal discharge, the
pathway to being granted an alternative thermal limitation would be based on predictive methods
including scientific literature surveys, laboratory studies, and/or modeling. Existing facilities with an
operating history and that have been discharging heated effluent to waterbody do not need to use such
predictive methods. These dischargers may conduct section 316(a) demonstrations based upon
"absence of prior appreciable harm" and the existence of a Balanced Indigenous Community (BIC)
within the receiving waters. It is the intention of Duke Energy Progress to seek an alternative effluent
thermal limitation for Outfall 008 for the Sutton Plant.
1.2 Objectives
The purpose of this Plan of Study is to provide information and data that will support a "thermal
variance/mixing zone for Sutton Lake/Cape Fear River" as outlined in Part I.A.(20) of NC0001422
and Section 316(a) of the Clean Water Act. The study results will be used to demonstrate that Sutton
Lake supports a BIC when the Sutton Plant is operating and discharges heated effluent. BICs are
2

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
those communities that:
1) are not dominated by pollution tolerant species,
2) are self-sustaining through successful reproduction and recruitment,
3) have adequate food items,
4) have diversity and representative trophic levels within expectations.
The information collected during this study will be evaluated against these four primary criteria,
which are defined in 40 CFR 125.71. Sutton Lake is a unique system that is subject to both freshwater
(from Cape Fear River flows) and marine (tidal intrusion) conditions that change through time,
therefore Representative Important Species (RIS) will be part of the assessment, as agreed to by the
North Carolina Department of Environmental Quality (NCDEQ), the North Carolina Wildlife
Resources Commission, and DEP. The RIS will be used to indicate that a self-sustaining BIC exists
within Sutton Lake.
2.0 STUDY BACKGROUND
Sutton Lake (lake) was permitted as an offstream as a wastewater cooling pond and therefore not
subject to water quality standards for over 40 years. Since construction, the lake has been open to the
public for fishing and the North Carolina Wildlife Resources Commission has managed the fishery by
agreement under an easement. The purpose of the lake was to provide condenser -cooling water for
operation of the Sutton Plant. The plant was coal-fired from 1972 to 2013. The original design of the
lake was for a thermal cooling capacity of 575 MW. Upon the shutdown of coal-fired operations,
natural gas-fired operations commenced in November of 2013. The new replacement plant consists of
two dual -fuel Siemens combustion turbines plus two Vogt triple -pressure reheat heat recovery steam
generators. The new steam generators heat rejection potential for the new plant is approximately 265
MWs thermal, which is less than half of the original design capacity. Heated effluent from the plant
enters Sutton Lake from an effluent channel creating a counterclockwise flow from the effluent
channel to the intake allowing the water to cool before being used again.
On November 5, 2014, the NCDEQ declared Sutton Lake to be Waters of the State and thus it became
subject to compliance with water quality standards, including thermal. With the issuance of the new
NPDES permit, the plant is required to demonstrate that a BIC would be protected according to
section 316(a) as described above (see 1.1 Regulatory Basis).
The aquatic community in Sutton Lake is well understood because of the DEP's long-term
environmental monitoring program, which has focused primarily on limnology and fisheries. These
discretionary studies have documented that the water chemistry and aquatic community within Sutton
Lake are significantly and frequently affected by tidal waters being pumped into the lake. Also,
occasional drought conditions have caused elevated chloride concentrations and conductivity levels.
While the fishery is dominated by freshwater fish, a number of resident marine/estuarine species are
present in the system and their numbers tend to fluctuate with salinity.
3

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
As for the fieldwork, data management, and analysis conducted during this 316(a) demonstration, to
the extent possible, these activities will be carried out using Standard Operating Procedures under
Duke Energy's Certified Biological Laboratory (#006 and #008). Some activities conducted may not
be a part of a laboratory certification program as it does not exist within North Carolina for such work.
The natural resources surveys for wildlife are an example of work not carried out under a laboratory
certification. However, this work will be conducted under the oversight and direction of Certified
Wildlife Biologists on the Duke Energy staff.
3.0 STUDY PLAN
The following describes the various aspects and study components of the proposed Sutton Lake
316(a) Demonstration. The sampling programs, frequencies, and locations for the 2018-2019 study
period are shown in Table 1.
3.1 Sutton Lake Description
Sutton Lake is a 445 -ha (4.4-krn) cooling pond constructed during 1972. The lake consists of a 3.8 -
km central bisecting main dike and six wing dikes to maximize circulation of water and cooling
efficiency. The cooling pond has a volume of 8.64 x 106 m3; a mean depth of 1.9 in; normal
elevations of 2.9-m to 3.1-m NGVD (National Geodetic Vertical Datum). The land surrounding the
approximately 22 -km shoreline is either undeveloped and primarily forested or cleared with ongoing
earth -moving activity.
3.2 Sutton Lake Map and Sampling Locations
Corresponding to the bays created by the wing dikes are eight sampling areas designated for the
routine Sutton Lake environmental monitoring program (Figure 1). These same area designations will
be retained for the 316(a) study areas and sampling.
3.3 Sutton Lake 316(a) Demonstration Decision Matrix
Duke Energy evaluated Sutton Lake and its aquatic community and constructed a Sutton Lake 316(a)
Demonstration Decision Matrix to help guide how each study component would be addressed during
the demonstration as well as in the final report (Table 2). Several components were determined to be
best addressed by a narrative assessment using scientific literature and previous 316(a) guidance
documents. Other components will be addressed by field surveys, observations, sample collections,
and data analysis. This Decision Matrix and the proposed study approaches were discussed with
representatives of NCDEQ during the development of this plan of study.
4

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
3.4 Limnology, Thermal Analysis, and Migration Barriers
As limnology (in situ monitoring and water chemistry) is part of the ongoing Sutton Lake monitoring
program, data and results may be utilized as needed to augment the Sutton Lake 316(a)
Demonstration. A listing of variables from the program is found in Tables 3 and 4. To describe the
cooling rate of the thermal effluent as it circulates from the effluent channel through the lake to the
intake canal, a series of in situ continuous temperature monitors will be installed at representative
locations (installed approximately centrally in each area and at mid -water column) in each sampling
area and one each near the plant discharge and intake. These devices will be installed to collect water
temperature data at these locations during the summer months when there would be the greatest
chance of temperatures above the thermal standard (32°C). To assess the possibility of migratory
barriers related to the thermal discharge, the temperature monitoring data will also be used along with
bathymetric data and shoreline topographic information to assess the potential for thermal barriers
(avoidance areas based on species thermal tolerances) to form.
3.5 Habitat Formers
A qualitative one-time habitat former (primarily aquatic vegetation) survey will be performed during
the growing season of the first year of the study. Geographic Information System (GIS) techniques
will be employed to characterize habitat formers in Sutton Lake. Habitat former species presence,
spatial distribution, and relative abundance will be documented. Similarly, this information will be
used to assess spatial distribution, relative abundance, biomass, and diversity considerations of the
BIC.
3.6 Plankton, Penphyton, and Benthic Macroinvertebrates
Narrative assessments for plankton, periphyton, and benthic macroinvertebrates will be made and
considered within the framework of the overall BIC of Sutton Lake.
3.6.1 Plankton, Periphyton, and Benthic Macroinvertebrates
Following discussions with NCDEQ and the application 316(a) Demonstration Decision Matrix, the
phytoplankton, zooplankton, periphyton, and benthic macroinvertebrate (excluding mussels)
components will be evaluated as part of the Sutton Lake BIC in narrative form. A scientific literature
survey will be conducted to assess these components in combination with previous guidance regarding
their contribution integral to the existence of a BIC. An overview of the validity of this approach can
be found in the most recent 316(a) review by Coutant (2013).
3.6.2 Mussel Community Survey
Based upon habitat surveys and recording substrate habitat type, a timed/distance mussel surveys will
be performed once during the first year of the demonstration under Duke Energy procedure (FSH -
867.0) in Areas B,D, F, and H of Sutton Lake (Figure 1). A copy of the procedure can be found in the
Duke Energy SOP on file with NCDEQ. A goal will be to complete at least one timed survey within
5

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
each of the designated areas for a minimum time of 4.0 person -hours or at least a distance of 200
meters. Catch -Per -Unit -Effort (CPUE), survey techniques (depending upon habitats, may include the
use of bathyscopes, snorkeling, unaided visual searches, and tactile searches), specimen
identifications, individual length measurements, habitat descriptions (dominant and subdominant
substrate), and survey site locations (using GPS) will be recorded for each survey site. Survey result
summary maps will be provided through the use of ArcGIS.
3.7 Fish Communitv Assessment
Fish community assessments will be performed during the two-year study to evaluate whether fish
communities in Sutton Lake meet expectations for species composition, exhibit good fish health, are
not dominated by pollution tolerant species, reproduce and recruit well, and are in balance with
respect to predator and prey species despite the presence of a thermal discharge to the lake.
Standard fisheries sampling methods, including boat electrofishing (Procedure NR00080) (Zale et al.
2012) will be conducted four times (seasonal) annually at four locations during daylight hours from
the Sutton Lake at Areas B, D, F, and H (Figure I and Table 1). The sampling programs and
frequency are found in Table 1. At each area, two stations with a least 300 -to -500 meter distances
(depending on the size of the sampling area) will be sampled using a Smith -Root equipped,
Wisconsin -design electrofishing boat with pulsed DC current. Time will be recorded for Catch per
Unit Effort (CPUE) metrics calculations at each station. Station locations in each area will be at
shoreline portions of the lake that ensure no overlapping interactions occur between stations such as
recapture of released fish. During the summer sampling periods (August or September), additional
fishery methods will be employed based on the preliminary fieldwork to establish the most effective
geartypes and locations for their use. These other methods and geartypes assessed for use include flat
seines, hoop nets, and gill nets.
Fish will be identified, total length measured to nearest millimeter, weighed to nearest gram, and
qualitatively examined for presence of external parasites, disease, and anomalies/deformities. Adult
fish will also be checked for spawning condition and qualitatively noted based on whether eggs or
milt can be readily stripped from the fish with pressure on the abdominal and urogenital pore region.
Small fish not readily identifiable in the field will be preserved and returned to the laboratory for
identification. Water quality data (i.e., temperature, dissolved oxygen, pH, and conductivity) will be
collected to evaluate environmental conditions during each fishery sampling trip.
Because of the shifting nature of the aquatic community based on changing environmental conditions,
DEP proposed a list of indigenous Representative Important Species (RIS) for the Sutton Lake 316(a)
Demonstration. These RIS species included American Eel, Bluegill, Gizzard Shad, Largemouth Bass,
Redbreast Sunfish, Redear Sunfish, and Warmouth. The NCWRC recommended adding Flathead
Catfish as the apex predator of the system which was agreed upon by all the stakeholders.
To assess the RIS Flathead Catfish, a special targeted sampling will be conducted once annually
during the two study years. The work involves electrofishing with multiple boat electrofishers and

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
"chase" boats. The approach is based on low level amperage (typically 1.0-2 0 amps) and volts
(typically 500 volts DC) using 15 pulses per seconds (Quinn 1988; Heyer et al 1994, Rachels and
Ashley 2002; Bodine 2013). Netted fish are then processed normally as with routine boat
electrofishing protocol.
A variety of standard fishery data metrics including total number, total biomass, CPUE, Relative
Weight (WR), percent by species, percent pollution -tolerant species, percent intolerant species, and
Proportional Size Distribution (for balanced populations), and others will be tabulated and reported to
relate to potential thermal impacts. All raw fisheries data will be available to stakeholders upon
request.
3.8 Other Vertebrate Wildlife
As part of an overall natural resources survey and observations, Duke Energy will conduct
observations regarding "other vertebrate wildlife" (wildlife) that are associated with aquatic habitats
and/or rely on the waters for foraging, reproduction, and other life functions (e.g., waterfowl, bald
eagles, aquatic mammals, amphibians).
According to the USEPA 1977 316(a) technical guidance document, most sites in the United States
will likely be considered ones of LPI for other vertebrate wildlife simply because thermal discharge
plumes should not generally impact large or unique populations of wildlife (e.g., waterfowl
concentrations, eagle wintering areas). Exceptions to sites classified as LPI would be those few sites
where the discharge might affect protected, RIS, or threatened and endangered wildlife The RIS are
those that are representative in terms of their biological needs of a balanced, indigenous community of
wildlife in the body of water into which the thermal discharge is made.
The 316(a) wildlife observations will be conducted at sampling sites, similar in general location, to
those being conducted for the fisheries study component (Braun 2005; Heyer et. al., 1994; Wilson
et.al., 1996). Additional areas may be added on a case-by-case basis to augment the overall survey.
The observations will also be conducted in the same time period (i.e., month, season) as the fisheries
fieldwork. The observations will also be augmented by literature reviews of pertinent information
[e.g., United States Fish and Wildlife Service (USFWS) listed species county list, USFWS
Information for Planning and Construction database, facility -specific reports) which will enable Duke
Energy to prepare rationale regarding why the site should be considered one of low potential impact or
an exception to that. Observations will be conducted for aquatic wildlife species or species that use
the Sutton aquatic system during activities such as foraging for fish or other life function activities.
During this 316(a) assessment, Duke Energy will not be documenting wildlife species that do not fit
the criteria mentioned above (e.g., white-tailed deer, most songbirds, and wild turkeys).
As at other 316(a) assessment sites, Duke Energy will be aware of and document any potential
federally listed or protected species that may inhabit or potentially use the area near the Sutton Plant
(e.g., wood stork, American alligator, and bald eagle). Information regarding the protected and
7

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
federally listed species will be obtained via the New Hanover County, NC county -wide list (USFWS
2014).
3.9 Threatened and Endangered Species
As mentioned above, included in the natural resources survey and observations is an assessment of
presence/absence of threatened and endangered species at the Sutton site including Sutton Lake and
nearby surrounding lands In addition, scientific literature, federal and state surveys and listings, and
Natural Heritage Program database element occurrences will be reviewed or queried Also,
consultations will be made with the NCWRC and the North Carolina Division of Marine Fisheries.
4.0 STUDY INITIATION AND DURATION
The Sutton 316(a) Demonstration will officially begin in 2018 after the final Plan of Study approval
has been received by DEP. The duration of the sampling and information gathering will follow the
Sutton NPDES permit language as it appears.
5.0 DATA MANAGEMENT, ANALYSIS, AND REPORTING
Where applicable, data generated by Duke Energy for the Sutton 316(a) Demonstration purposes,
including water quality, water chemistry, and fisheries, will be digitally uploaded to Duke Energy's
EQuIS database for retrieval and analyses. All data will undergo internal QA/QC protocols to ensure
accuracy of the stored data. When used, GPS data will be presented as decimal degree coordinates.
GIS will be utilized when appropriate along with compatible programs for two-dimensional graphic
display for presentation or reporting purposes. Standard statistical analyses (e.g., t-test, ANOVA,
means separation techniques, regression, K -S testing, etc.) will be used to assess temporal/spatial
differences by variable or differences by species or groups. The alpha = 0.05 level will be used to test
these type differences. Also, simple raw data, means, standard deviation, and range data may be
reported.
0

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
6.0 REFERENCES
APHA. 2012. Standard Methods for the examination of Water and Wastewater. 22th Edition.
American Public Health Association, Washington, DC.
Rachels, R. T., K. W. Ashley. 2002. Comparison of 3 Electrofishing Gear Types Used to Capture
Catfish.
Braun, C.E., editor. 2005. Techniques for Wildlife Investigations and Management. Sixth edition
The Wildlife Society, Bethesda, Maryland, USA.
CP&L 1994. L.V. Sutton Steam Electric Plant 1993 annual environmental monitoring report.
Carolina Power & Light Company, New Hill, NC.
Coutant, C. C. 2013. Considerations and requirements for biological determinations related to thermal
discharges. Special report NO. 13-02, National Council for Air and Stream Improvement.
August 2013.
Heyer, W.R, Maureen Donnelly, Roy McDiarmid, Lee -Ann Hayek, and Mercedes Foster, editors.
1994. Measuring and Monitoring Biological Diversity. Standards Methods for Amphibians.
Smithsonian Institution Press. Washington and London.
Bodine, K. A., D. E. Shoup, J. Olive, Z. L. Ford, R. Krogman and T. J. Stubbs. 2013. Catfish
sampling techniques: where we are now and where we should go. Fisheries Vol. 38 , Issue 12.
Quinn, S. P. 1988. Effectiveness of an electrofishing system foi collecting flathead catfish.
Proceedings of the Annual Conference Southeastern Association of Fish and Wildlife
Agencies, 40(1986). 85-91.
USEPA. 1977. Interagency 316(a) technical guidance manual and guide for thermal effects sections
of nuclear facilities environmental impact statements. Washington, DC: United States
Environmental Protection Agency.
USFWS. 2014. Endangered Species, Threatened Species, Federal Species of Concern, and Candidate
Species. New Hanover County, North Carolina. Raleigh Ecological Field Office. NC
Wilson, Don, F. Russell Cole, James Nichols, Rasanayagam Rudran, and Mercedes Foster, editors.
1996. Measuring and Monitoring Biological Diversity. Standards Methods for Mammals.
Smithsonian Institution Press. Washington and London.
Zale, A.V., D.L. Parrish, and T.M. Sutton, editors. 2012. Fisheries techniques, third edition American
Fisheries Society. Bethesda, MD.
9

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
7.0 FIGURES and TABLES
iA
I Indian Creek
0 1,000 2,000 4,000 Feet
PieaF L � I � T I
0 250 500 1,000 Meters
New
Ash Pond
B1 Outfall 008old
\ Ash Pond
Area B Area A
Intake
B3 Canal
Cooling Pond
Discharge
(Outfall 001)
11--�
Cartwheel
Branch
Sutton Steam Electric Plant
Figure 1. Sutton Plant site and Sutton Lake sampling locations.
10
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a'tie
ya�`o
Discharge
/ Canal
Sutton Iant Rd
�
Pcea�
D1
Area G
m
L
Q
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D3
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I
- H1 Ramp
LL
CL a
H3
�j
v
Area H
Q
�
g
Q
Dike
New
Ash Pond
B1 Outfall 008old
\ Ash Pond
Area B Area A
Intake
B3 Canal
Cooling Pond
Discharge
(Outfall 001)
11--�
Cartwheel
Branch
Sutton Steam Electric Plant
Figure 1. Sutton Plant site and Sutton Lake sampling locations.
10
�a
a'tie
ya�`o
Discharge
/ Canal
Sutton Iant Rd

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
Table 1. L.V. Sutton Energy Complex 316(a) Demonstration Study Plan, 2018-2019
PROGRAM FREQUENCY LOCATION
Water quality
Water chemistry
Habitat survey, including
habitat formers
Mussel survey
Natural Resources Survey,
including other vertebrate
wildlife
Fisheries
Electrofishing
Special Flathead Catfish
Study
Netting/seining
Alternate calendar months
(January, March, May, July,
September, November)
Alternate calendar months
(January, March, May, July,
September, November)
Once during summer months
Station H-1 (surface to bottom at
1-m intervals),
Station H-1
Whole lake
Once during summer months, Areas B, D, F, H
Once during summer months, Areas B, D, F, H
Once every three calendar
months (March, June,
September, December
Once annually during summer
months
Once annually during summer
months
Stations B-1, B-3, D-1, D-3, F-1,
F-3, H-1, H-3
.E
Areas, A,C, G
Thermal Analysis Once annually during summer Areas A, B, C, D, E, F, G, H
months
11

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
Table 2. Sutton Lake 316(a) Demonstration Study Plan Matrix
12
1, a study
Nfastcr Rationale
rate
ncedvd7 Scope
(relevant,
absence of
Inon•
literature
impact be
of'thr SIM N:
internal/rvtcr
prior
thermal
demonstrated
nal; elata?
appreciahle
and/or
using
harm
thermal
reference
I:1P_�Hr?
with data)
lake or
--:,
lake with
literature?
available
Phytoplankton
Dated
Yes (Fish as
None
Yes
No
No
Narrative
evidence of
appropriate
APAH)
Zooplankton
Dated
Yes (Fish as
None
Yes
No
No
Narrative
evidence of
appropriate
APAH)
Habitat formers
Dated
NA
None
Yes
No
Yes (survey
Survey
appropriate
TBD)
Shellfish/Macroinvertebrates
Dated
Yes
None
Yes
Yes
No (Mussel
Narrative
Appropriate
survey needed-
macroinvertebrate;
see WE
Mussel survey
Fish
Yes
Yes
None
Yes
No
Yes
Study
app ro riate
Other vertebrate wildlife
No
Ye,
None
Yes
Yes No (Continue Observations
a ro riate
observations)
(Area H) to the Intake (Area A)
Temperature analysis
lilillillillilim
Simple tempe data loggers deployed from near the discharge
Migration barriers, thermal
traps, exclusion zones
Lake confiradon/Bath me /Lake Temperature Analysis
Threatened and endangered
species
Surve /Observations/Uterature survey
12

L.V. Sutton Energy Complex Initial 316(a) Demonstration Plan of Study
Table 3. Sutton Lake Water Quality Monitoring Variables
Temperature Specific Conductance
pH Secchi disk transparency
Dissolved oxygen
Table 4. Sutton Lake Water Chemistry Monitoring Variables
TOTAL ALKALINITY
TOTAL HARDNESS
IONS
Chloride
Sulfate
NUTRIENTS
Total phosphorus
Total nitrogen
Nitrate-Nitnte
Ammonia
TOTAL DISSOLVED SOLIDS
TURBIDITY
TRACE ELEMENTS
(TOTAL)
Lower reporting limits in
parentheses
Calcium Total organic carbon Arsenic (0.5 gg/L)
Magnesium Copper (0.5 µg/L)
Sodium Mercury0 5
( ng/L)
Selenium (0.5 µg/L)
13