NC0005088_Monitoring (Information)_20190416

& DUKE Jim Wells
Vnt
le ENERGY® ProgramsEnvironmental
ntace Pcienes
EHS and Environmental Sciences
526 South Church Street
Mail Code EC13K
Charlotte,NC 28202
[phone]
james.wells @ d uke-energy.com
RECEtVED/DENR/DWR
April162019
APR 26 2019
Cyndi Karoly Water R a►ources
Permihing Section
NC Division of Water Resources
Water Science Section
1621 Mail Service Center
Raleigh, NC 27699-1621
Subject: Duke Energy Carolinas,LLC.
Rogers Energy Complex(Cliffside Steam Station)
NPDES#NC0005088—Rutherford & Cleveland Counties
Fish Tissue Monitoring Plan
Dear Ms. Karoly:
With reference to your letter on the subject plan, the attached Fish Tissue Monitoring Plan has
been revised to incorporate your comments as described below. Approval of this plan is
requested.
1. It was requested that the downstream monitoring location be located further upstream. River
access and employee safety were factors in determining the downstream monitoring location
(Station DN) due to the presence of numerous shoals during targeted sampling flows between the
station and the originally proposed downstream monitoring location. With additional effort and
a modified sampling approach, we have determined sampling 3.7 miles downstream of the
Rogers Energy Complex can be achieved. The attached updated study plan reflects the
downstream monitoring location 3.7 miles downstream of Rogers Energy Complex.
2. It was suggested that Duke Energy try to obtain ten individuals per species with six
individuals being a minimum requirement. Duke Energy will attempt to collect ten (10)
individuals per trophic guild species,recognizing six (6) individuals per species will meet the
requirements of the permit.
3. It was requested that any other supplementary metals data in addition to the permit specified
metals (As, Se and Hg)be reported for comparison purposes to other studies on the Broad River
fish tissues studies, in the vicinity,of Cliffside Steam Station. In addition to the permit-required
As, Se, and Hg, Duke Energy can provide Cu and Cd. Duke Energy uses an x-ray fluorescence
(XRF) instrument to analyze elements in fish tissue. The XRF instrument is calibrated for each

NC Division of Water Resources
Fish Tissue Monitoring Plan
April 16, 2019
element using standard certified reference materials. The standard reference materials for fish
tissue elemental analysis currently used by the Duke Laboratory are As, Cu, Cd, Hg, and Se.
Should you have questions or require additional information, please contact Robert Wylie at
9 Y
704 382-4669.
Sincerely,
Y
C1,Jimlls
Vesident
Eograms and Environmental Sciences
cc: Sergei Chernikov
Attachment:
Fish Tissue Monitoring Plan of the Broad River

Fish Tissue Monitoring of the Broad River
Study Plan
Rogers Energy Complex
NPDES No. NC0005088
(eN DUKE
IL, ENERGY
APRIL 2019

Table of Contents
Section Page
1.0 Introduction 2
2.0 Sampling Locations 2
3.0 Target Species for Tissue Monitoring 2
4.0 Field Sampling Methods 2
5.0 Tissue Analysis 3
6.0 Data Analysis and Reporting 3
7.0 References 3
Attachments
Attachment A - Fish Tissue Monitoring- Study Plan Summary and Map
1

1.0 Introduction
Duke Energy Carolinas (DEC) owns and operates the Rogers Energy Complex located on the Broad River
in Cleveland & Rutherford County, Mooresboro, North Carolina.The Rogers Energy Complex National
Pollutant Discharge Elimination System (NPDES) Permit (No. NC0005088, Section A.14.) requires DEC to
conduct trace elements monitoring in fish muscle tissue each calendar year, in accordance with a study
plan approved by the North Carolina Department of Environmental Quality(NCDEQ).This study plan
outlines the proposed methods for sampling, analyzing, and data reporting to fulfill these NPDES permit
monitoring requirements. DEC 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 Sampling Areas
Target fish will be collected from two locations on the Broad River(see attached map) for trace element
analysis of muscle tissue.The UP location will serve as a reference to monitor background trace element
concentrations in fish muscle tissue upstream of the Rogers Energy Complex ash basin discharge. All UP
samples will be collected on the Broad River upstream of the UP location depicted on the attached map
(approximately 1.5 miles, or greater, upstream of the current ash basin discharge). Exact collection
locations will be dependent upon river flow and access at the time of sampling. The DN location will
serve to monitor uptake of elements in fish muscle tissue downstream of the Rogers Energy Complex
ash basin discharge. All DN samples will be collected on the Broad River at the DN location depicted on
the attached map (approximately 3.7 miles, or less, downstream of the current ash basin discharge).
Exact collection locations will be dependent upon river flow and access at the time of sampling. The
sampling areas are similar to those previously approved for the Rogers Energy Complex by NCDEQ(Duke
Energy 2013).
3.0 Target Fish Species for Tissue Monitoring
The proposed target species are based on availability, recreational importance as a game or food fish,
and general trophic level. Duke Energy personnel will attempt to collect ten (six minimum) individuals of
insectivorous (e.g., sunfish) and piscivorous (e.g., black bass) species. 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(USEPA), 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 (USEPA 2000). Conformance with this guideline will depend
upon the fish/size class availability at a particular location.
4.0 Field Sampling Methods
Standard fishery sampling methods, including active and passive gear types, will be employed to collect
target species. Boat electrofishing (Procedure FSH-250.0, Rev. 5), trap nets (Procedure FSH-257.00, Rev.
2

3), or other standard fishery sampling gear types will be used as necessary to obtain the required
samples. If used, nets will be checked and captured fish removed daily during the sampling period.
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 placed in a labeled (sample date, sample location,
facility, etc.) bag on ice.This information will be recorded on field fisheries data sheets(generally
electronic). Each day the sealed bags of collected fish will be frozen in deep freezers. 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.
Supporting information will be collected during each trip including temperature, dissolved oxygen,
specific conductivity, and pH from the surface of each sampling location. Other environmental
conditions may be recorded during each sampling period such as weather conditions and lake level as
appropriate.
5.0 Tissue Analyses
All fish will be processed in the laboratory for metals analysis according to Procedure NR-00107 Rev. 4
Trace Element Monitoring Laboratory Procedure (approved SOP on file with NCDEQ). Sample custody
and tracking of samples will be performed using chain-of-custody forms during transport to or from the
laboratory. Quality of vendor laboratory data, if applicable, will be ensured through the use of National
Institute of Standards and Technology(NIST)tissue standards.The remaining processed sample will be
archived for two years if re-analysis is needed.
6.0 Data Analysis and Reporting
Arsenic, cadmium, copper, mercury, and selenium concentrations (converted to pg/g fresh weight)
determined from the fish tissue analyses will be reported. A report with the sampling methods, data
analysis, and conclusions will be prepared and submitted with the subsequent NPDES permit renewal
application as required by NPDES Permit No. NC0005088.
7.0 References
Duke Energy. 2013. Trace Elements Monitoring in Fish Tissue, Study Plan. Allen Steam Station NPDES No
NC0004979, Buck Steam Station NPDES No. NC0004774, Cape Fear Steam Station NPDES No.
NC0003433, Cliffside Steam Station NPDES No. NC0005088, Marshall Steam Station NPDES No.
NC0004987. Duke Energy Corporation. Charlotte, NC.
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.
3

Attachment A
Fish Tissue Monitoring - Study Plan Summary and Map
Rogers Energy Complex
PROGRAM FREQUENCY LOCATION
Trace Elements: Broad River near Rogers Energy Complex;
Fish (arsenic, cadmium, copper, mercury, selenium) Annual
UP, DN
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