NC0005088_Fish Tissue Monitoring_20190307

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
March 7th, 2019
David Barnhardt
Rogers Energy Complex
573 Duke Power Road
Mooresboro, NC 28114
NORTH CAROLINA
£nvirotnoentar Quality
Subject: Review of Duke Energy Carolinas, Rogers Energy Complex—Cliffside Steam Station
(NC0005088): Fish Tissue Monitoring Plan
Dear Mr. Barnhardt:
Thank you for your recent submittal of the Fish Tissue Monitoring Plan for this facility. Based on a review
of this plan, we offer the following comments:
1. As proposed, Station DN is approximately six (6) river miles downstream of the Cliffside Steam
Station. We acknowledge that this location has been approved by DEQ in the last few sampling
cycles. However, we request that Station DN be moved upstream to a more appropriate location,
preferably above the Sandy Run confluence (approximately 3.7 miles below the plant), to better
characterize the uptake of elements in fish muscle tissues downstream of the plant's outfall. We
believe that moving Station DN closer to the plant outfall would better align with the written
language in section A. (14) of the permit that requires annual "Fish Tissue Monitoring Near Ash
Pond Discharge". If relocating Station DN to an upstream location closer to the outfall is not
possible, please provide DEQ with justification for keeping it in its proposed location.
1) We suggest that DEC tries to obtain ten (10) individuals per species as NCDWR routinely
attempts during its fish tissue studies. Six (6) individuals would be the minimum to fulfill NPDES
requirements.
2) We also request any other supplementary metals data that DEC produces here (in addition to the
requirement of reporting As, Se, and Hg) for comparison to other studies of Broad River fish
tissues in the vicinity of the Cliffside Steam Station.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Cyndi Karoly
Chief, Water Sciences Section
Cc: Landon Davidson, Asheville Regional Office
Julie Grzyb, NCDWR Complex Permitting Unit
D North Carolina Department of Environmental Quality I Division of water Resources
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