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HomeMy WebLinkAboutNCS000589_SW Fish Tissue Reporting Request Letter_20170713DUKE 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 (919)546-6647. 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 Kent.Tyndall@duke-energy.com; or • Mr. Reid Garrett, Lead Environmental Scientist at our North Carolina Regional Office, phone (919) 546-5434 or e-mail Reid.Garrett@duke-energy.com; 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