ML23065A042
| ML23065A042 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/23/2023 |
| From: | Schmitt M Energy Northwest Environmental Services Laboratory |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML23065A042 (214) | |
Text
From: Schmitt, Marshall A. <maschmitt@energy-northwest.com>
Sent: Thursday, February 23, 2023 7:27 PM To: Ritchie Graves - NOAA Federal Cc: Briana Arlene; EndangeredSpecies Resource; Ramos, Mary Joy.;
Hildman, Cynthia M.; Pierson, Amanda M.
Subject:
[External_Sender] Energy Northwest Columbia Generating Station 2022 Biological Monitoring Report Attachments: GO2-23-027.pdf Mr. Graves, Please find attached the 2022 Biological Monitoring Report for Columbia Generating Station, submitted pursuant to Condition 2.9.4(4)(a) of the Endangered Species Act 7(a)(2) Biological Opinion and copied to the Nuclear Regulatory Commission (NRC).
This letter is being provided as an electronic transmittal only.
The Biological Monitoring Report contains a post-season report describing biological monitoring activities and a summary of any plant changes that affect effluent discharge.
It also contains a copy of all National Pollutant Discharge Elimination System (NPDES) submissions that were transmitted to EFSEC in the year. Please note that the Columbia Generating Station Annual 2022 Priority Pollutant Discharge Monitoring Report (DMR) has already been transmitted to the National Marine Fisheries Service (NMFS) and copied to NRC in an email dated December 1st 2022 and is not included in this submittal.
If you have any questions about this report, please contact me at (509) 372-5334 or maschmitt@energy-northwest.com Sincerely, Marshall Schmitt l Environmental Scientist Energy Northwest Environmental and Regulatory Programs 509-372-5334 l maschmitt@energy-northwest.com
Hearing Identifier: NRR_DRMA Email Number: 1970 Mail Envelope Properties (SA0PR09MB6969608D686BF3EFA90C036390A89)
Subject:
[External_Sender] Energy Northwest Columbia Generating Station 2022 Biological Monitoring Report Sent Date: 2/23/2023 7:27:28 PM Received Date: 2/23/2023 7:29:01 PM From: Schmitt, Marshall A.
Created By: maschmitt@energy-northwest.com Recipients:
"Briana Arlene" <briana.arlene@nrc.gov>
Tracking Status: None "EndangeredSpecies Resource" <EndangeredSpecies.Resource@nrc.gov>
Tracking Status: None "Ramos, Mary Joy." <mjoyramos@energy-northwest.com>
Tracking Status: None "Hildman, Cynthia M." <cmhildman@energy-northwest.com>
Tracking Status: None "Pierson, Amanda M." <ampierson@energy-northwest.com>
Tracking Status: None "Ritchie Graves - NOAA Federal" <ritchie.graves@noaa.gov>
Tracking Status: None Post Office: SA0PR09MB6969.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1303 2/23/2023 7:29:01 PM GO2-23-027.pdf 22160215 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Mary Joy C. Ramos Columbia Generating Station P.O. Box 968, MD PE03 Richland, WA 99352-0968 Ph. 509-377-8534 mjoyramos@energy-northwest.com February 23, 2023 GO2-23-027 DIC 404.1 Ritchie Graves Columbia Hydropower Branch National Marine Fisheries Service ELECTRONIC SUBMITTAL ONLY 1201 NE Lloyd Blvd, Suite 1100 Portland, OR 97232
Dear Mr. Graves:
Subject:
2022 BIOLOGICAL MONITORING REPORT
Reference:
Letter, GI2-17-061, March 10, 2017, from Barry A. Thorn (National Marine Fisheries Service) to Jeffery J. Rikhoff (Division of License Renewal, Office of Nuclear Regulation) Endangered Species Act Section 7(a)(2) Biological Opinion, and Magnusion-Stevens Fishery Conservation and Management Act Essential Fish Habitat Response for Renewing the Operating License for the Columbia Generating Station, Washington, Condition 2.9.4(4)(a).
Condition 2.9.4(4)(a) of the Endangered Species Act 7(a)(2) Biological Opinion requires Energy Northwest to submit an annual summary of biological monitoring data and reports submitted pursuant to National Pollutant Discharge Elimination System (NPDES) Permit WA002515-1. Attached is the 2022 Biological Monitoring Report, which consists of the Post Season Fish Collection Report, 2022 NPDES Permit Discharge Monitoring Reports (DMRs),
and Whole Effluent Toxicity (WET) Reports.
Respectfully, Signed By:
Ramos, Mary Joy. - DOMAIN1\mramos 2/23/2023 1:17 PM Final Approver Mary Joy C. Ramos Environmental and Regulatory Programs Manager
Enclosure:
2022 Post Season Fish Collection Report 2022 NPDES DMRs
2022 NPDES WET Reports cc: Briana.Grange@nrc.gov EndangeredSpecies.Resource@nrc.gov MR/sa INTERNAL DISTRIBUTION: FILE COPY Document Control APW Docket File PE20
Prepared by Energy Northwest Environmental Services, January 2023 Energy Northwest Columbia Generating Station 2022 Post Season Fish Collection Report The purpose of this report is to document fish collection activities on the part of Energy Northwest (ENW) during the 2022 calendar year and to verify that the activities were following the Endangered Species Act section 7(a)(2) Biological Opinion for the Columbia Generating Station (NMFS No: NWR/2011/05286) issued March 10, 2017. Also included is a discussion on changes in CGS operations during the 2022 calendar year that had the potential to affect CGS effluent discharges to the Columbia River.
Fish Collection Columbia Generating Station (CGS) is required to collect and analyze fish samples from locations near the CGS effluent discharge in the Columbia River and from a control location, typically the Snake River. The samples are analyzed for radioactive content with the purpose of determining what impact, if any, CGS operation may have on Columbia River fish. The requirements specify collection of one anadromous and two resident fish species from both locations. The fish collection activities are to be performed in accordance with the Endangered Species Act section 7(a)(2) Biological Opinion for the Columbia Generating Station.
Resident Species Collection Columbia River The two resident fish species collected from the Columbia River in 2022 were walleye and small mouth bass.
Energy Northwest (ENW) personnel collected one small mouth bass on 10/17/2022 from the shoreline near CGS and the Tower Make Up (TMU) pumphouse. GPS coordinates were recorded as 46° 28' 18.11"N, 119° 15' 54.2"W and water temperature was measured at 19.1 degrees Celsius. The fish was caught using hook and line techniques that targeted bass. On 10/15/2022, one Walleye was caught. GPS coordinates were recorded as 46° 27' 10.03"N, 119° 15' 48.97"W and water temperature was measured at 18.9 degrees Celsius. The fish were caught using hook and line techniques that targeted Walleye. Fishing techniques used to collect the resident species were in accordance with the Washington Department of Fish and Wildlife (WDFW) freshwater fishing rules for the resident species of interest.
Snake River The resident fish from the Snake River serve as controls and were obtained by local fisherman donation. The local fisherman collected two Walleye and one small mouth Bass on 11/12/2022 from GPS coordinates 46° 14' 14.72"N, 118° 58' 30.05"W, using hook and line techniques. The Snake River temperature was 18.3 degrees Celsius.
Anadromous Species Collection The anadromous species collected from the Snake and Columbia Rivers was Chinook Salmon. Authorization to obtain the fish from local hatcheries was provided by the State of Washington Department of Fish and Wildlife in a letter dated 8/11/2022.
Prepared by Energy Northwest Environmental Services, January 2023 One Chinook Salmon from Ringold Springs Hatchery was collected by hatchery personnel on 9/28/2022. The location is at Station-48, GPS coordinates 46°30'18.9"N 119°15'36.4"W and the water temperature was 20.3 degrees Celsius. A net was used to retrieve the Salmon by hatchery personnel.
A Chinook Salmon was provided by Snake River Lyons Ferry Hatchery on 10/11/2022, GPS coordinates 46° 35.848 N 118° 13.439 W and the water temperature was 19.0 degrees Celsius. The salmon was caught by net using hatchery personnel.
Fish Collection Summary Reasonable and prudent measures were utilized to minimize the impact of biological monitoring activities during 2022.
Fish collection was performed using hook and line techniques that targeted the species of interest; electroshock fishing was not performed. No capture or handling of Upper Columbia River (UCR) spring-run Chinook salmon occurred during the year. One Steelhead was caught using hook and line, but it escaped the hook and swam away prior to the fisherman being able to handle it. The Steelhead hook and escape was at GPS coordinates 46°28'0.88"N, 119°15'51.16"W and the river temperature was measured at 18.9 degrees Celsius Summary of Changes to CGS Aqueous Effluent Discharges During the 2022 calendar year, the National Pollutant Discharge Elimination System (NPDES) effluent monitoring as reported on the monthly discharge monitoring reports indicated that all parameters were within permit specifications with no issues or violations. Additionally, whole effluent toxicity testing performed on a quarterly basis showed no statistically significant difference in survival between the control and the acute critical effluent concentration (ACEC, 11% effluent). Continuous halogenation of circulating water with dehalogenation of the blowdown water was implemented on November 6, 2019. This process involves the discharge of additional dehalogenation chemicals as approved by an amendment to the CGS NPDES permit dated 3/19/2019. Implementation of this process has not resulted in any permit violations to date.
INTEROFFICE MEMO GO2-22-010 DIC: 1316.20 DATE: January 13, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station December 2021 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for December 2021.
The initial circulating water blowdown (CWBD) composite sample collected 12/3/21 for NPDES monitoring requirements exhibited higher than normal metals content due to unusual river sediment conditions. A second composite sample collected 12/15/21 had metal concentrations more in line with regular trends. Both sample results are provided.
Furthermore, December 2021 included a one-week maintenance outage (MO2) during which blowdown to the river remained in service. However tower makeup (TMU) flow was below the accuracy of the TMU flow meter. Therefore TMU influent flows for the period 12/6/21 - 12/11/21 are estimated based on CWBD and potable water usage.
All monthly averages for the monitoring parameters were within permit specifications for the month. The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact M Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, December 2021 JTL P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 1 of 91
Columbia Generating Station Page 2 of 2 January 13, 2022 December 2021 DMR DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB PE03 Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 K Byers PE12 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane T. LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 2 of 91
3 of 91 4 of 91 5 of 91 6 of 91 7 of 91 INTEROFFICE MEMO GO2-22-023 DIC: 1316.20 DATE: February 14, 2022 TO: Columbia Generating Station, (CGS)
FROM: Kris Byers, Environmental Scientist (PE12)
SUBJECT:
Columbia Generating Station January 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for January 2022.
All monitoring parameters were within permit specifications for the month. The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system.
If you have any questions concerning this information, please contact D Mehinagic at (509) 372-5768.
Attachment:
NPDES Discharge Monitoring Report, January 2022 KRB DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB PE03 Docket File PE20 D Mehinagic PE03 Columbia Files 964Y JT LePage 1025 K Byers PE12 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 8 of 91
Columbia Generating Station Page 2 of 2 February 14, 2022 January 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Jane T. LePage, Environmental Scientist, Environmental Services Reviewed by: Denis Mehinagic, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 9 of 91
10 of 91 11 of 91 12 of 91 13 of 91 14 of 91 INTEROFFICE MEMO GO2-22-040 DIC: 1316.20 DATE: March 10, 2022 TO: Columbia Generating Station (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station February 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for February 2022.
All monitoring parameters were within permit specifications for the month. During an electrical maintenance outage at the tower makeup (TMU) pump house, an alternate temperature monitor in the circulating water pump house was used. Additionally during this maintenance window, TMU flow was estimated based on bracketing days flows. The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system.
If you have any questions concerning this information, please contact D Mehinagic at (509) 372-5768.
Attachment:
NPDES Discharge Monitoring Report, February 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB PE03 Docket File PE20 D Mehinagic PE03 Columbia Files 964Y JT LePage 1025 K Byers PE12 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 15 of 91
Columbia Generating Station Page 2 of 2 March 10, 2022 February 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Denis Mehinagic, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Mary Ramos, Acting Manager, Environmental & Regulatory Programs 16 of 91
17 of 91 18 of 91 19 of 91 20 of 91 21 of 91 INTEROFFICE MEMO GO2-22-053 DIC: 1316.20 DATE: April 14, 2022 TO: Columbia Generating Station (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station March 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for March 2022. All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain method was used for sulfuric acid additions to the circulating water system to control the pH during the month. This method resulted in greater variation of the blowdown pH than is typical. The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system.
If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, March 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY MCR LB PE03 Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 K Byers PE12 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 22 of 91
Columbia Generating Station Page 2 of 2 April 14, 2022 March 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Mary Joy Ramos, Acting Manager, Environmental & Regulatory Programs 23 of 91
24 of 91 25 of 91 26 of 91 27 of 91 28 of 91 INTEROFFICE MEMO GO2-22-060 DIC: 1316.20 DATE: May 12, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station April 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for April 2022. All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from a temporary tanker truck was used for sulfuric acid additions to the circulating water system to control the pH during the month. This method resulted in greater variation of the blowdown pH than is typical. The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system.
If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, April 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY MCR LB PE03 Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 K Byers PE12 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 29 of 91
Columbia Generating Station Page 2 of 2 May 1 , 2022 April 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Mary Joy Ramos, Acting Manager, Environmental & Regulatory Programs 30 of 91
31 of 91 32 of 91 33 of 91 34 of 91 35 of 91 INTEROFFICE MEMO GO2-22-071 DIC: 1316.20 DATE: June 13, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station May 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for May 2022. All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method resulted in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, May 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY MCR LB PE03 Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 K Byers PE12 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 36 of 91
Columbia Generating Station Page 2 of 2 June 13, 2022 May 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Mary Joy Ramos, Acting Manager, Environmental & Regulatory Programs 37 of 91
38 of 91 39 of 91 40 of 91 41 of 91 42 of 91 INTEROFFICE MEMO GO2-22-081 DIC: 1316.20 DATE: July 13, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station June 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for June 2022. All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method resulted in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, June 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB PE03 Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 K Byers PE12 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 43 of 91
Columbia Generating Station Page 2 of 2 July 13, 2022 June 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 44 of 91
45 of 91 46 of 91 47 of 91 48 of 91 49 of 91 INTEROFFICE MEMO GO2-22-091 DIC: 1316.20 DATE: August 11, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station July 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for July 2022. All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method results in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, July 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB PE03 Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 K Byers 350 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 50 of 91
Columbia Generating Station Page 2 of 2 August 17, 2022 July 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 51 of 91
52 of 91 53 of 91 54 of 91 55 of 91 56 of 91 INTEROFFICE MEMO GO2-22-103 DIC: 1316.20 DATE: September 15, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station August 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for August 2022. All monitoring parameters were within permit specifications for the month. The temperature element for blowdown temperature compliance monitoring was out of service for calibration for approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on 8/1/22. Additionally, because of equipment issues, a gravity-drain from a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method results in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, August 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB PE03 Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 K Byers 350 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 57 of 91
Columbia Generating Station Page 2 of 2 September 15, 2022 August 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 58 of 91
59 of 91 60 of 91 61 of 91 62 of 91 63 of 91 INTEROFFICE MEMO GO2-22-114 DIC: 1316.20 DATE: October 13, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, (1025)
SUBJECT:
Columbia Generating Station September 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for September 2022. All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method results in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, September 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION:
M Schmitt (via email) Docket File PE20 J LePage (via email) Regulatory (via email)
K Byers (via email) Document Control (via APW)
P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 64 of 91
Columbia Generating Station Page 2 of 2 October 13, 2022 September 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Devon Van Alyne, Laboratory Services Manager Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 65 of 91
66 of 91 67 of 91 68 of 91 69 of 91 70 of 91 INTEROFFICE MEMO GO2-22-124 DIC: 1316.20 DATE: November 14, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station October 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for October 2022.
All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method results in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, October 2022 JTL DISTRIBUTION LIST:
INTERNAL DISTRIBUTION:
M Schmitt (via email) Docket File PE20 J LePage (via email) Regulatory (via email)
K Byers (via email) Document Control (via APW)
P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 71 of 91
Columbia Generating Station Page 2 of 2 November 14, 2022 October 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 72 of 91
73 of 91 74 of 91 75 of 91 76 of 91 77 of 91 INTEROFFICE MEMO GO2-22-128 DIC: 1316.20 DATE: December 15, 2022 TO: Columbia Generating Station, (CGS)
FROM: Kris Byers, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station November 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for November 2022.
All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from SAT-TK-2 and a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method results in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, November 2022 KRB DISTRIBUTION LIST:
INTERNAL DISTRIBUTION:
M Schmitt (via email) Docket File PE20 K Byers (via email) Regulatory (via email)
T Fitzpatric (via email) Document Control (via APW)
P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 78 of 91
Columbia Generating Station Page 2 of 2 December 15, 2022 November 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Timothy Fitzpatric, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Mary Joy C. Ramos, Manager, Environmental & Regulatory Programs 79 of 91
80 of 91 81 of 91 82 of 91 83 of 91 84 of 91 INTEROFFICE MEMO GO2-23-005 DIC: 1316.20 DATE: January 12, 2023 TO: Columbia Generating Station, (CGS)
FROM: Kris Byers, Environmental Scientist (1025)
SUBJECT:
Columbia Generating Station December 2022 NPDES Discharge Monitoring Report
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S3.A Please find attached the NPDES Discharge Monitoring Report (DMR) for December 2022.
All monitoring parameters were within permit specifications for the month. Because of equipment issues, a gravity-drain from SAT-TK-2 and a temporary tanker truck continues to be used for sulfuric acid additions to the circulating water system to control the pH. This method results in greater variation of the blowdown pH than is typical.
The report will be submitted electronically to the State of Washington Department of Ecology (Ecology) via Ecologys online reporting system. If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
Attachment:
NPDES Discharge Monitoring Report, December 2022 KRB DISTRIBUTION LIST:
INTERNAL DISTRIBUTION:
M Schmitt (via email) Docket File PE20 K Byers (via email) Regulatory (via email)
A Mowery (via email) Document Control (via APW)
P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 85 of 91
Columbia Generating Station Page 2 of 2 January 12, 2023 December 2022 DMR 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 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 fine and imprisonment for knowing violations.
Prepared by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Ashley Mowery, Environmental Technician, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Mary Joy C. Ramos, Manager, Environmental & Regulatory Programs 86 of 91
87 of 91 88 of 91 89 of 91 90 of 91 91 of 91 INTEROFFICE MEMO GO2-22-029 DIC: 409.3 DATE: February 16, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
COLUMBIA GENERATING STATION ACUTE TOXICITY BIOASSAY FOR THE 1ST QUARTER 2022
REFERENCE:
NPDES Permit No. WA 002515-1, Condition S13 Please find attached the acute toxicity bioassay report for Columbia Generating Station for the first quarter of 2022. The testing was conducted in accordance with condition S13 of Columbias National Pollutant Discharge Elimination System (NPDES) permit. The bioassay results are favorable with no acute toxicity detected in the test concentration representing the acute critical effluent concentration (ACEC; the ACEC equals 11% effluent). The results show 100% survival of the test species, Pimephales promelas, in the 100% effluent sample.
A copy of the report (*.pdf format) and supporting statistical analysis (*.mdb format) will be submitted electronically to the State of Washington Department of Ecology (Ecology) and the Energy Facility Site Evaluation Council (EFSEC) via Ecologys Water Quality Permitting Portal (WQWebPortal).
If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
JTL
Attachment:
Acute Toxicity Test Report P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 1 of 117
Columbia Generating Station Page 2 of 2 February 16, 2022 CGS Acute Toxicity Bioassay Report for the 1st Quarter 2022 DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane T. LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Denis Mehinagic, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad C. Barfuss, E&RP Manager 2 of 117
Water Quality Program Permit Submittal Electronic Certification Permittee: Energy Northwest Columbia Generating Station Permit Number: WA0025151 Site Address: T11N R28E S5 RICHLAND, WA 99352 Submittal Name: Acute toxicity compliance testing for acute toxicity Version: 1 Due Date: 4/30/2022 Comments: See attached for the PDF report and dataset.
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 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 fine and imprisonment for knowing violations.
Brad Barfuss 2/16/2022 2:54:24 PM Signature Date 3 of 117
AQUATIC TOXICOLOGY REPORT Project Name: ENERGY NORTHWEST Location: RICHLAND, WASHINGTON Prepared by: Eurofins Environment Testing Northwest, LLC (aka TestAmerica - ASL) 1100 NE Circle Boulevard, Suite 310 Corvallis, Oregon 97330 541-243-6137 Accredited in accordance with NELAP Oregon Environmental Laboratory Accreditation Program #OR100022 (NELAP)
State of Washington DOE Environmental Laboratory Accreditation Program, Lab ID C556 California State Environmental Laboratory Accreditation Program, Certificate No.: 1726 Report Date: February 9, 2022 Released by: Michelle Bennett Revision 1 Report Date: February 11, 2022 Released by: Michelle Bennett Lab I.D. No. B5276 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. If you have received this report in error, please notify the sender and destroy this report immediately. This report shall not be reproduced except in full, without prior express written approval by the laboratory.
Results relate only to the items tested and the sample(s) as received by the laboratory. The results included in this report have been reviewed for compliance and meet all requirements for accredited parameters. All data have been found to be compliant with laboratory protocol, with the exception of any items noted in this report. For questions, please contact the Project Manager (contact info on next page).
4 of 117 Page 1
CONTENTS Section Page INTRODUCTION .................................................................................................................. 3 OVERVIEW OF REGULATORY GUIDANCE ................................................................... 3
SUMMARY
OF TEST RESULTS ......................................................................................... 4 ACRONYM DEFINITIONS ...................................................................................... 5 SAMPLE INFORMATION ..................................................................................................... 5 METHODS AND MATERIALS ............................................................................................ 5 TEST METHODS ....................................................................................................... 5 DEVIATIONS FROM PROTOCOLS ........................................................................ 6 TEST DESIGN ........................................................................................................... 6 DILUTION WATER .................................................................................................. 6 SAMPLE COLLECTION AND STORAGE .............................................................. 7 SAMPLE PREPARATION ........................................................................................ 7 DATA ANALYSIS ..................................................................................................... 7 RESULTS AND DISCUSSION ............................................................................................. 8 REFERENCE TOXICANT TESTS ........................................................................... 9 APPENDIX A. RAW DATA SHEETS APPENDIX B. REFERENCE TOXICANT DATA SHEETS APPENDIX C. CHAIN OF CUSTODY LABORATORY CONTACT: Brett Muckey, Laboratory Director Brett.Muckey@eurofinset.com (541) 243-0980 5 of 117 Page 2
INTRODUCTION Eurofins Environment Testing Northwest, LLC Applied Sciences Laboratory (EETNW -
ASL) conducted toxicity testing on sample(s) from Energy Northwest, Richland, Washington.
Testing was initiated on: January 25, 2022 The test(s) were conducted using:
the fathead minnow (Pimephales promelas)
Note: A revised report is being issued February 11, 2022 to correct the Exhibit numbers.
OVERVIEW OF REGULATORY GUIDANCE The following provides an overview and excerpts of applicable permit specifics, regulatory guidance, and other relevant information. This is intended only as a helpful guide, from a laboratory perspective, for understanding test outcomes. The final responsibility for interpretation of results remains with the client and/or regulatory agency.
The following guidance is taken from EETNW-ASLs reading of the NPDES permit for Energy Northwests Columbia Generating Station in Richland, WA (permit #WA002515-1, effective Nov 1, 2014, expires Oct 31, 2019, modified Feb 8, 2016, and Mar. 19, 2019).
Acute toxicity:
Effluent Limit for Acute Toxicity:
o No acute toxicity detected in a test concentration representing the acute critical effluent concentration (ACEC).
o The ACEC equals 11% effluent.
Compliance with the Effluent Limit for Acute Toxicity:
o Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC.
o The Permittee must determine the statistical significance by conducting a hypothesis test at the 0.05 level of significance (i.e. alpha = 0.05) o If the difference in survival between the control and the ACEC is less than 10 percent, the Permittee must conduct the hypothesis test at the 0.01 level of significance.
o If the test results show a statistically significant difference in survival between the control and the ACEC, and EFSEC has not determined the test result to be anomalous under Section D, and the test is otherwise valid, the result is a violation of the effluent limit for acute toxicity.
Compliance Testing for Acute Toxicity:
o Conduct quarterly acute toxicity testing on the final effluent. (Jan-Mar, Apr-Jun, Jul-Sep, Oct-Dec) o using each of the species and protocols listed on a rotating basis.
6 of 117 Page 3
Response to Noncompliance With an Effluent Limit for Acute Toxicity:
o If a toxicity test determines a statistically significant difference in response between the ACEC and the control, the Permittee must begin additional compliance monitoring within one week of receiving the test results.
Sampling and Reporting Requirements:
o The permittee must collect grab samples must cool the samples to 0 - 6 degrees Celsius during collection and send them to the lab immediately upon completion.
o The lab must begin the toxicity testing no later than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after sampling was completed.
o The Permittee must chemically dechlorinate final effluent with sodium thiosulfate just prior to test initiation. Do not add more sodium thiosulfate than is necessary to neutralize the chlorine. Provide in the test report the calculations to determine the amount of sodium thiosulfate necessary The following is taken from the WDOE guidance (WQ-R-95-80, June 2016 revision):
To reduce WET limit violations (and anomalous concentration-response relationships) due to statistical significance that is a Type I error [false positive], we lower alpha when differences in test organism response are small.
Alpha will be lowered from 0.05 to 0.01 if a 10% difference in an acute test is significant
SUMMARY
OF TEST RESULTS Exhibit 1 provides a summary of the final test results.
EXHIBIT 1 Summary of Acute Test Results NOEC LOEC LC50 Was a statistically significant difference Species
(%) (%) (%) between control and ACEC shown?
P. promelas 100 > 100 > 100 No Note: acronyms are as defined below.
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
More detailed information is provided in the Results and Discussion section.
7 of 117 Page 4
ACRONYM DEFINITIONS (from EPA guidance):
NOEC = No Observed Effect Concentration: The highest test concentration that causes no observable adverse effects on the test organisms (i.e. no statistically significant reduction from the control).
LOEC = Low Observed Effect Concentration: The lowest test concentration that does cause an observable adverse effect on the test organisms (i.e. is statistically significant reduction from the control).
LC50 = Lethal Concentration (50%): A point estimate of the test concentration that would cause death in 50 percent of the test population.
SAMPLE INFORMATION Exhibit 2 provides a summary of the sample conditions as received.
EXHIBIT 2 Sample Conditions on Receipt Sample ID 220578-01 EETNW - ASL SDG B5276-01 Collection - Date and Time 01/24/2022 08:12 Receipt - Date and Time 01/25/2022 10:37 Temperature (oC) 1.1 Dissolved Oxygen (mg/L) 8.4 pH 7.8 Conductivity (S/cm) 1448 Total Residual Chlorine (mg/L) < 0.02 Ammonia (mg/L as NH3-N) < 0.10 Total Hardness (mg/L as CaCO3) 669 Total Alkalinity (mg/L as CaCO3) 117 METHODS AND MATERIALS TEST METHODS The acute test methods were performed according to: Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water (2002), EPA-821-R-02-012.
8 of 117 Page 5
Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
DEVIATIONS FROM PROTOCOLS Deviations from required procedures in the test methods:
None noted.
Deviations from recommended procedures in the test methods:
None noted.
TEST DESIGN The following summarizes the conditions used for both overall testing and the specifics for each test (observations and notations can be found on the datasheets in Appendix A):
Overall Test Design:
Acute test: 6.25, 11.0 [ACEC], 25.0, 50.0, and 100 percent sample + dilution water for the control.
Test Organism Conditions:
All organisms tested were fed and maintained during culturing, acclimation, and testing as prescribed by the EPA (2002).
The test organisms appeared vigorous and in good condition prior to testing.
P. promelas acute test (renewal):
Source: Aquatox Inc., Hot Springs, Arkansas Age: 1 to 14 days old, within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> age range Design: Four test vessels per concentration, Ten organisms per vessel Test Solution Renewal: Once @ 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (i.e. static-renewal test)
Monitoring:
o Daily: Survival, DO, pH, and temperature; all concentrations.
o Pre and Post Renewal solutions: DO and pH, all concentrations.
o Test Initiation, with each new sample use, and Termination:
Conductivity, all concentrations (WDOE)
Termination: 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
Endpoints: Survival (at termination)
DILUTION WATER The dilution water used was the standard culture water used by EETNW - ASL:
Reconstituted, moderately hard water (as per EPA protocol) with a total hardness of 75 to 105 mg/L as CaCO3 and an alkalinity of 50 to 75 mg/L as CaCO3.
9 of 117 Page 6
SAMPLE COLLECTION AND STORAGE Samples were collected by Energy Northwest personnel. The samples were accepted as scheduled by EETNW - ASL. Chain of Custody and Sample Receipt Records are provided in Appendix C.
The sample was received within the EPA recommended 0 to 6 oC range.
The sample was received within the WDOE required 0 to 6 oC range.
The sample was initially used for test initiation or test solution renewal within the EPA recommended maximum holding time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of sample collection.
All subsequent uses of the sample occurred within the EPA recommended maximum holding time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> past the time of initial use of that sample.
All subsequent uses of a sample occurred within the WDOE recommended maximum holding time of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> past the time of sample collection. (For renewals of a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> duration acute test)
Following receipt, the samples were stored in the dark at 0 to 6 C until test solutions were prepared and tested.
SAMPLE PREPARATION Samples used during these tests were:
Temperature adjusted prior to test initiation and each daily renewal.
As no Total Residual Chlorine was observed, dechlorination with sodium thiosulfate was not performed.
DATA ANALYSIS The statistical analyses performed for the acute tests were those outlined in Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water, Fifth Edition (2002), EPA-821-R-02-012, using CETIS.
The specific statistical analysis and CETIS version used for each endpoint evaluation is listed with the statistical outputs included with each test in Appendix A.
If any additional analysis methods were also used, an explanation of the rationale and reference to the source method is included with the presentation of those results below.
Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
10 of 117 Page 7
RESULTS AND DISCUSSION The raw data sheets for all tests are presented in Appendix A.
ACUTE BIOASSAYS Table 1 summarizes the survival data for the P. promelas acute test.
Table 1 Summary of Acute Results P. promelas Sample Percent Survival Concentration (at Test Termination)
(%)
Control 100 6.25 100 11.0 100 25.0 100 50.0 100 100 100 Statistical analysis in accordance with the EPA protocol and WDOE guidance results in:
NOEC = 100 %
LOEC > 100 %
LC50 > 100 %
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
No statistically significant difference between control and ACEC was shown.
Dissolved oxygen concentrations remained at 4.0 mg/L or greater throughout the test period.
Test temperatures remained in the range of 20+/-1 C.
The P. promelas acute test meets Test Acceptability Criteria (TAC) of a minimum 90 percent control survival. Unless referenced above, the tests proceeded without any noted deviations or interruptions that could have affected test results. The testing should be considered valid.
11 of 117 Page 8
REFERENCE TOXICANT TESTS Reference toxicant (reftox) testing is performed to document both initial and ongoing laboratory performance of the test method(s). While the health of the test organisms is primarily evaluated by the performance of the laboratory control, reftox test results also may be used to assess the health and sensitivity of the test organisms. Reftox test results within their respective cumulative summary (Cusum) chart limits are indicative of consistent laboratory performance and normal test organism sensitivity.
The results of the reftox tests indicate that the test organisms were within their respective cusum chart limits based on EPA guidelines. This demonstrates ongoing laboratory proficiency of the test methods and suggests normal test organism sensitivity in the associated client testing.
The P. promelas acute reftox test was conducted using sodium chloride. The data sheets for the reference toxicant tests are provided in Appendix B.
Table 2 summarizes the reference toxicant test results and Cusum chart limits.
Table 2 Acute Reference Toxicant Tests (g/L)
Species LC50 Cusum Chart Limits P. promelas 7.7 5.9 to 8.7 12 of 117 Page 9
APPENDIX A RAW DATA SHEETS 13 of 117 Page 10
117
<0.10 669 14 of 117 Page 11
15 of 117 Page 12
16 of 117 Page 13
17 of 117 Page 14
18 of 117 Page 15
CETIS Summary Report Report Date: 31 Jan-22 15:55 (p 1 of 1)
Test Code/ID: B527601ppa / 05-2527-0171 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Batch ID: 20-9203-2838 Test Type: Survival (96h) Analyst: Michelle Bennett Start Date: 25 Jan-22 15:11 Protocol: EPA/821/R-02-012 (2002) Diluent: Mod-Hard Synthetic Water Ending Date: 29 Jan-22 14:30 Species: Pimephales promelas Brine:
Test Length: 95h Taxon: Actinopterygii Source: Aquatox, AR Age: 1D Sample ID: 14-4487-7473 Code: B5276-01 Project:
Sample Date: 24 Jan-22 08:12 Material: Industrial Effluent Source: Energy Northwest (WA 0025151)
Receipt Date: 25 Jan-22 10:37 CAS (PC): Station:
Sample Age: 31h (1.1 °C) Client:
Multiple Comparison Summary Analysis ID Endpoint Comparison Method NOEL LOEL TOEL PMSD TU S 16-7906-0683 96h Survival Rate Steel Many-One Rank Sum Test 100 >100 --- 2.7% 1 1 Point Estimate Summary Analysis ID Endpoint Point Estimate Method Level % 95% LCL 95% UCL TU S 19-2150-2471 96h Survival Rate Linear Interpolation (ICPIN) EC50 >100 --- --- <1 1 Test Acceptability TAC Limits Analysis ID Endpoint Attribute Test Stat Lower Upper Overlap Decision 16-7906-0683 96h Survival Rate Control Resp 1 0.9 >> Yes Passes Criteria 19-2150-2471 96h Survival Rate Control Resp 1 0.9 >> Yes Passes Criteria 96h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Min Max Std Err Std Dev CV% %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
11 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
100 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
96h Survival Rate Detail MD5: 7C3CB5340F8C0CF602EDD7FB547CC89A Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 1.0000 1.0000 1.0000 1.0000 6.25 1.0000 1.0000 1.0000 1.0000 11 1.0000 1.0000 1.0000 1.0000 25 1.0000 1.0000 1.0000 1.0000 50 1.0000 1.0000 1.0000 1.0000 100 1.0000 1.0000 1.0000 1.0000 96h Survival Rate Binomials Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 9/9 10/10 10/10 10/10 6.25 10/10 10/10 10/10 11/11 11 10/10 10/10 10/10 10/10 25 10/10 10/10 10/10 10/10 50 10/10 10/10 10/10 10/10 100 10/10 10/10 10/10 10/10 19 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Page 16
CETIS Analytical Report Report Date: 31 Jan-22 15:55 (p 1 of 2)
Test Code/ID: B527601ppa / 05-2527-0171 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 16-7906-0683 Endpoint: 96h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 31 Jan-22 15:54 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 31 Jan-22 15:53 MD5 Hash: 7C3CB5340F8C0CF602EDD7FB547CC89 Editor ID: 000-042-882-4 Data Transform Alt Hyp NOEL LOEL TOEL TU MSDu PMSD Angular (Corrected) C>T 100 >100 --- 1 0.02695 2.70%
Steel Many-One Rank Sum Test Control vs Conc-% Test Stat Critical Ties DF P-Type P-Value Decision(:5%)
Dilution Water 6.25 18 10 1 6 CDF 0.8333 Non-Significant Effect 11 18 10 1 6 CDF 0.8333 Non-Significant Effect 25 18 10 1 6 CDF 0.8333 Non-Significant Effect 50 18 10 1 6 CDF 0.8333 Non-Significant Effect 100 18 10 1 6 CDF 0.8333 Non-Significant Effect ANOVA Table Source Sum Squares Mean Square DF F Stat P-Value Decision(:5%)
Between 3.259E-05 6.518E-06 5 1.198 0.3495 Non-Significant Effect Error 9.795E-05 5.442E-06 18 Total 0.0001305 23 ANOVA Assumptions Tests Attribute Test Test Stat Critical P-Value Decision(:1%)
Variance Bartlett Equality of Variance Test Indeterminate Distribution Shapiro-Wilk W Normality Test 0.7482 0.884 4.7E-05 Non-Normal Distribution 96h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
11 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
100 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
Angular (Corrected) Transformed Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 1.4100 1.4030 1.4170 1.4120 1.4030 1.4120 0.0022 0.31% 0.00%
6.25 4 1.4140 1.4080 1.4200 1.4120 1.4120 1.4190 0.0019 0.26% -0.29%
11 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% -0.15%
25 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% -0.15%
50 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% -0.15%
100 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% -0.15%
20 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Page 17
CETIS Analytical Report Report Date: 31 Jan-22 15:55 (p 2 of 2)
Test Code/ID: B527601ppa / 05-2527-0171 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 16-7906-0683 Endpoint: 96h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 31 Jan-22 15:54 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 31 Jan-22 15:53 MD5 Hash: 7C3CB5340F8C0CF602EDD7FB547CC89 Editor ID: 000-042-882-4 Graphics 1.0 0.006 0.005 0.9 0.004 0.8 0.003 96h Survival Rate 0.7 0.002 0.001 Centered 0.6 0.000 Corr. Angle 0.5
-0.001 0.4 -0.002 0.3 -0.003
-0.004 0.2
-0.005 0.1
-0.006 0.0 -0.007 0D 6.25 11 25 50 100 -2.0 -1.5 -1.0 -0.5 0.0 0.5 1.0 1.5 2.0 Conc-% Rankits 21 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Page 18
CETIS Analytical Report Report Date: 31 Jan-22 15:55 (p 1 of 1)
Test Code/ID: B527601ppa / 05-2527-0171 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 19-2150-2471 Endpoint: 96h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 31 Jan-22 15:54 Analysis: Linear Interpolation (ICPIN) Status Level: 1 Edit Date: 31 Jan-22 15:53 MD5 Hash: 7C3CB5340F8C0CF602EDD7FB547CC89 Editor ID: 000-042-882-4 Linear Interpolation Options X Transform Y Transform Seed Resamples Exp 95% CL Method Log(X+1) Linear 2033558 200 Yes Two-Point Interpolation Point Estimates Level % 95% LCL 95% UCL TU 95% LCL 95% UCL EC50 >100 --- --- <1 --- ---
96h Survival Rate Summary Calculated Variate(A/B) Isotonic Variate Conc-% Code Count Mean Median Min Max CV% %Effect A/B Mean %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 39/39 1.0000 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 41/41 1.0000 0.00%
11 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 1.0000 0.00%
25 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 1.0000 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 1.0000 0.00%
100 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 1.0000 0.00%
Graphics 1.0 0.9 0.8 0.7 96h Survival Rate 0.6 0.5 0.4 0.3 0.2 0.1 0.0 0 20 40 60 80 100 Conc-%
22 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Page 19
APPENDIX B REFERENCE TOXICANT DATA SHEETS 23 of 117 Page 20
24 of 117 Page 21
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APPENDIX C CHAIN OF CUSTODY 26 of 117 Page 23
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28 of 117 Page 25
INTEROFFICE MEMO GO2-22-064 DIC: 409.3 DATE: May 24, 2022 TO: Columbia Generating Station (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
COLUMBIA GENERATING STATION ACUTE TOXICITY BIOASSAY REPORT FOR THE 2ND QUARTER 2022
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S13 Please find attached the acute toxicity bioassay report for Columbia Generating Station for the second quarter of 2022. The testing was conducted in accordance with condition S13 of Columbias National Pollutant Discharge Elimination System (NPDES) permit. The bioassay results are favorable with no acute toxicity detected in the test concentration representing the acute critical effluent concentration (ACEC; the ACEC equals 11%
effluent). The results show 100% survival of the test species, Ceriodaphnia dubia, in the 100% effluent sample.
A copy of the report (*.pdf format) and supporting statistical analysis (*.mdb format) will be submitted electronically to the State of Washington Department of Ecology (Ecology) and the Energy Facility Site Evaluation Council (EFSEC) via Ecologys Water Quality Permitting Portal (WQWebPortal).
If you have any questions concerning this information, please contact MA Schmitt at (509) 372-5334.
JTL
Attachment:
Acute Toxicity Bioassay Report DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY MCR LB Docket File PE20 MA Schmitt PE03 Columbia Files 964Y JT LePage 1025 P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 29 of 117
Columbia Generating Station Page 2 of 2 May 24, 2022 CGS Acute Toxicity Bioassay Report for the 2nd Quarter 2022 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane T. LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Mary Joy Ramos, Acting Manager, Environmental & Regulatory Programs 30 of 117
Water Quality Program Permit Submittal Electronic Certification Permittee: Energy Northwest Columbia Generating Station Permit Number: WA0025151 Site Address: T11N R28E S5 RICHLAND, WA 99352 Submittal Name: Acute toxicity compliance testing for acute toxicity Version: 1 Due Date: 7/30/2022 Comments: Please see attached for the 2nd Quarter Acute Toxicity Lab Report (.pdf) and data
(.mdb).
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 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 fine and imprisonment for knowing violations.
Mary Ramos 5/24/2022 11:53:58 AM Signature Date 31 of 117
AQUATIC TOXICOLOGY REPORT Project Name: ENERGY NORTHWEST Location: RICHLAND, WASHINGTON Prepared by: Eurofins Environment Testing Northwest, LLC (aka TestAmerica - ASL) 1100 NE Circle Boulevard, Suite 310 Corvallis, Oregon 97330 541-243-6137 Accredited in accordance with NELAP Oregon Environmental Laboratory Accreditation Program #OR100022 (NELAP)
State of Washington DOE Environmental Laboratory Accreditation Program, Lab ID C556 California State Environmental Laboratory Accreditation Program, Certificate No.: 1726 Report Date: May 17, 2022 Released by: Michelle Bennett Revision 1 Report Date: May 19, 2022 Released by: Michelle Bennett Lab I.D. No. B5342 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. If you have received this report in error, please notify the sender and destroy this report immediately. This report shall not be reproduced except in full, without prior express written approval by the laboratory.
Results relate only to the items tested and the sample(s) as received by the laboratory. The results included in this report have been reviewed for compliance and meet all requirements for accredited parameters. All data have been found to be compliant with laboratory protocol, with the exception of any items noted in this report. For questions, please contact the Project Manager (contact info on next page).
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CONTENTS Section Page INTRODUCTION .................................................................................................................. 3 OVERVIEW OF REGULATORY GUIDANCE ................................................................... 3
SUMMARY
OF TEST RESULTS ......................................................................................... 4 ACRONYM DEFINITIONS ...................................................................................... 5 SAMPLE INFORMATION ..................................................................................................... 5 METHODS AND MATERIALS ............................................................................................ 6 TEST METHODS ....................................................................................................... 6 DEVIATIONS FROM PROTOCOLS ........................................................................ 6 TEST DESIGN ........................................................................................................... 6 DILUTION WATER .................................................................................................. 7 SAMPLE COLLECTION AND STORAGE .............................................................. 7 SAMPLE PREPARATION ........................................................................................ 7 DATA ANALYSIS ..................................................................................................... 7 RESULTS AND DISCUSSION ............................................................................................. 8 REFERENCE TOXICANT TESTS ........................................................................... 9 APPENDIX A. RAW DATA SHEETS APPENDIX B. REFERENCE TOXICANT DATA SHEETS APPENDIX C. CHAIN OF CUSTODY LABORATORY CONTACT: Brett Muckey, Laboratory Director Brett.Muckey@ET.eurofinsus.com (541) 243-0980 33 of 117 Page 2
INTRODUCTION Eurofins Environment Testing Northwest, LLC Applied Sciences Laboratory (EETNW -
ASL) conducted toxicity testing on sample(s) from Energy Northwest, Richland, Washington.
Testing was initiated on: April 26, 2022 The test(s) were conducted using:
the water flea (Ceriodaphnia dubia)
Note: A revised report has been issued May 19, 2022 to correct ET-C in the Sample Information section to EETNW-ASL.
OVERVIEW OF REGULATORY GUIDANCE The following provides an overview and excerpts of applicable permit specifics, regulatory guidance, and other relevant information. This is intended only as a helpful guide, from a laboratory perspective, for understanding test outcomes. The final responsibility for interpretation of results remains with the client and/or regulatory agency.
The following guidance is taken from EETNW-ASLs reading of the NPDES permit for Energy Northwests Columbia Generating Station in Richland, WA (permit #WA0025151, effective Nov 1, 2014, expires Oct 31, 2019, modified Feb 8, 2016, and Mar. 19, 2019).
Acute toxicity:
Effluent Limit for Acute Toxicity:
o No acute toxicity detected in a test concentration representing the acute critical effluent concentration (ACEC).
o The ACEC equals 11% effluent.
Compliance with the Effluent Limit for Acute Toxicity:
o Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC.
o The Permittee must determine the statistical significance by conducting a hypothesis test at the 0.05 level of significance (i.e. alpha = 0.05) o If the difference in survival between the control and the ACEC is less than 10 percent, the Permittee must conduct the hypothesis test at the 0.01 level of significance.
o If the test results show a statistically significant difference in survival between the control and the ACEC, and EFSEC has not determined the test result to be anomalous under Section D, and the test is otherwise valid, the result is a violation of the effluent limit for acute toxicity.
Compliance Testing for Acute Toxicity:
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o Conduct quarterly acute toxicity testing on the final effluent. (Jan-Mar, Apr-Jun, Jul-Sep, Oct-Dec) o using each of the species and protocols listed on a rotating basis.
Response to Noncompliance With an Effluent Limit for Acute Toxicity:
o If a toxicity test determines a statistically significant difference in response between the ACEC and the control, the Permittee must begin additional compliance monitoring within one week of receiving the test results.
Sampling and Reporting Requirements:
o The permittee must collect grab samples must cool the samples to 0 - 6 degrees Celsius during collection and send them to the lab immediately upon completion.
o The lab must begin the toxicity testing no later than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after sampling was completed.
o The Permittee must chemically dechlorinate final effluent with sodium thiosulfate just prior to test initiation. Do not add more sodium thiosulfate than is necessary to neutralize the chlorine. Provide in the test report the calculations to determine the amount of sodium thiosulfate necessary The following is taken from the WDOE guidance (WQ-R-95-80, June 2016 revision):
To reduce WET limit violations (and anomalous concentration-response relationships) due to statistical significance that is a Type I error [false positive], we lower alpha when differences in test organism response are small.
Alpha will be lowered from 0.05 to 0.01 if a 10% difference in an acute test is significant
SUMMARY
OF TEST RESULTS Exhibit 1 provides a summary of the final test results.
EXHIBIT 1 Summary of Acute Test Results NOEC LOEC LC50 Was a statistically significant difference Species
(%) (%) (%) between control and ACEC shown?
C. dubia 100 > 100 > 100 No Note: acronyms are as defined below.
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
More detailed information is provided in the Results and Discussion section.
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ACRONYM DEFINITIONS (from EPA guidance):
NOEC = No Observed Effect Concentration: The highest test concentration that causes no observable adverse effects on the test organisms (i.e. no statistically significant reduction from the control).
LOEC = Low Observed Effect Concentration: The lowest test concentration that does cause an observable adverse effect on the test organisms (i.e. is statistically significant reduction from the control).
LC50 = Lethal Concentration (50%): A point estimate of the test concentration that would cause death in 50 percent of the test population.
SAMPLE INFORMATION Exhibit 2 provides a summary of the sample conditions as received.
EXHIBIT 2 Sample Conditions on Receipt Sample ID 220834-01 EETNW - ASL SDG B5342-01 Collection - Date and Time 04/25/2022 09:23 Receipt - Date and Time 04/26/2022 10:03 Temperature (oC) 0.7 Dissolved Oxygen (mg/L) 7.2 pH 8.2 Conductivity (S/cm) 1316 Total Residual Chlorine (mg/L) 0.03*
Ammonia (mg/L as NH3-N) 0.11 Total Hardness (mg/L as CaCO3) 667 Total Alkalinity (mg/L as CaCO3) 94
- Note: Due to a laboratory error, the sample was not dechlorinated as required by the client permit. The test showed no toxicity, as such, it is EETNW-ASLs professional opinion that this deviation had no significant impact on the test results. WDOE was consulted on this deviation and found it to be acceptable. See email from WDOE in Appendix C.
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METHODS AND MATERIALS TEST METHODS The acute test methods were performed according to: Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water (2002), EPA-821-R-02-012.
Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
DEVIATIONS FROM PROTOCOLS Deviations from required procedures in the test methods:
The sample was not dechlorinated as required by the client permit. See further discussion in the Sample Information section. See WDOE acceptance of this deviation in Appendix C.
Deviations from recommended procedures in the test methods:
None noted.
TEST DESIGN The following summarizes the conditions used for both overall testing and the specifics for each test (observations and notations can be found on the datasheets in Appendix A):
Overall Test Design:
Acute test: 6.25, 11.0 [ACEC], 25.0, 50.0, and 100 percent sample + dilution water for the control.
Test Organism Conditions:
All organisms tested were fed and maintained during culturing, acclimation, and testing as prescribed by the EPA (2002).
The test organisms appeared vigorous and in good condition prior to testing.
C. dubia acute test: (WDOE)
Source: EETNW-ASL's in-house cultures Age: Less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> old Design: Four test vessels per concentration, five organisms per vessel Test Solution Renewal: None (i.e. static test)
Monitoring:
o Daily: Survival, DO, pH, and temperature; all concentrations.
o Test Initiation and Termination: Conductivity, all concentrations Termination: 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Endpoints: Survival (at termination).
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DILUTION WATER The dilution water used was the standard culture water used by EETNW - ASL:
Reconstituted, moderately hard water (as per EPA protocol) with a total hardness of 75 to 105 mg/L as CaCO3 and an alkalinity of 50 to 75 mg/L as CaCO3.
SAMPLE COLLECTION AND STORAGE Samples were collected by Energy Northwest personnel. The samples were accepted as scheduled by EETNW - ASL. Chain of Custody and Sample Receipt Records are provided in Appendix C.
The sample was received within the EPA recommended 0 to 6 oC range.
The sample was received within the WDOE required 0 to 6 oC range.
The sample was initially used for test initiation or test solution renewal within the EPA recommended maximum holding time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of sample collection.
All subsequent uses of the sample occurred within the EPA recommended maximum holding time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> past the time of initial use of that sample.
All subsequent uses of a sample occurred within the WDOE recommended maximum holding time of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> past the time of sample collection. (For renewals of a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> duration acute test)
Following receipt, the samples were stored in the dark at 0 to 6 C until test solutions were prepared and tested.
SAMPLE PREPARATION Samples used during these tests were:
Temperature adjusted prior to test initiation and each daily renewal.
Total Residual Chlorine was observed, however, due to a laboratory error, dechlorination with sodium thiosulfate was not performed. WDOE will accept the test with this deviation, see email is Appendix C.
DATA ANALYSIS The statistical analyses performed for the acute tests were those outlined in Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water, Fifth Edition (2002), EPA-821-R-02-012, using CETIS.
The specific statistical analysis and CETIS version used for each endpoint evaluation is listed with the statistical outputs included with each test in Appendix A.
If any additional analysis methods were also used, an explanation of the rationale and reference to the source method is included with the presentation of those results below.
Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
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RESULTS AND DISCUSSION The raw data sheets for all tests are presented in Appendix A.
ACUTE BIOASSAYS Table 1 summarizes the survival data for the C. dubia acute test.
Table 1 Summary of Acute Results C. dubia Sample Percent Survival Concentration (at Test Termination)
(%)
Control 100 6.25 100 11.0 100 25.0 100 50.0 100 100 100 Statistical analysis in accordance with the EPA protocol and WDOE guidance results in:
NOEC = 100 %
LOEC > 100 %
LC50 > 100 %
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
No statistically significant difference between control and ACEC was shown.
Dissolved oxygen concentrations remained at 4.0 mg/L or greater throughout the test period.
Test temperatures remained in the range of 20+/-1 C.
The C. dubia acute test meets Test Acceptability Criteria (TAC) of a minimum 90 percent control survival. Unless referenced above, the tests proceeded without any noted deviations or interruptions that could have affected test results. The testing should be considered valid.
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REFERENCE TOXICANT TESTS Reference toxicant (reftox) testing is performed to document both initial and ongoing laboratory performance of the test method(s). While the health of the test organisms is primarily evaluated by the performance of the laboratory control, reftox test results also may be used to assess the health and sensitivity of the test organisms. Reftox test results within their respective cumulative summary (Cusum) chart limits are indicative of consistent laboratory performance and normal test organism sensitivity.
The results of the reftox tests indicate that the test organisms were within their respective cusum chart limits based on EPA guidelines. This demonstrates ongoing laboratory proficiency of the test methods and suggests normal test organism sensitivity in the associated client testing.
The C. dubia reftox test was conducted using sodium chloride. The data sheets for the reference toxicant test are provided in Appendix B.
Table 2 summarizes the reference toxicant test results and Cusum chart limits.
Table 2 Acute Reference Toxicant Test with Sodium Chloride (g/L)
Species LC50 Control Chart C. dubia 2.37 1.61 to 3.00 40 of 117 Page 9
APPENDIX A RAW DATA SHEETS 41 of 117 Page 10
NA 0.11 667 94 Page 11 NA - Dechlorination was missed by analyst. See WDOE attached email.
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43 of 117 Page 12
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CETIS Summary Report Report Date: 12 May-22 15:59 (p 1 of 1)
Test Code/ID: B534201cda / 15-2338-9861 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Batch ID: 10-0066-3863 Test Type: Survival (48h) Analyst: Michelle Bennett Start Date: 26 Apr-22 13:23 Protocol: EPA/821/R-02-012 (2002) Diluent: Mod-Hard Synthetic Water Ending Date: 28 Apr-22 12:48 Species: Ceriodaphnia dubia Brine:
Test Length: 47h Taxon: Branchiopoda Source: In-House Culture Age: <24 Sample ID: 18-5403-1144 Code: B5342-01 Project:
Sample Date: 25 Apr-22 09:23 Material: Industrial Effluent Source: Energy Northwest (WA 0025151)
Receipt Date: 26 Apr-22 10:03 CAS (PC): Station:
Sample Age: 28h (0.7 °C) Client:
Multiple Comparison Summary Analysis ID Endpoint Comparison Method NOEL LOEL TOEL PMSD TU S 11-0387-8148 48h Survival Rate Steel Many-One Rank Sum Test 100 >100 --- --- 1 1 Point Estimate Summary Analysis ID Endpoint Point Estimate Method Level % 95% LCL 95% UCL TU S 04-8420-0413 48h Survival Rate Linear Interpolation (ICPIN) EC50 >100 --- --- <1 1 Test Acceptability TAC Limits Analysis ID Endpoint Attribute Test Stat Lower Upper Overlap Decision 04-8420-0413 48h Survival Rate Control Resp 1 0.9 >> Yes Passes Criteria 11-0387-8148 48h Survival Rate Control Resp 1 0.9 >> Yes Passes Criteria 48h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Min Max Std Err Std Dev CV% %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
11 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
100 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
48h Survival Rate Detail MD5: 7C3CB5340F8C0CF602EDD7FB547CC89A Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 1.0000 1.0000 1.0000 1.0000 6.25 1.0000 1.0000 1.0000 1.0000 11 1.0000 1.0000 1.0000 1.0000 25 1.0000 1.0000 1.0000 1.0000 50 1.0000 1.0000 1.0000 1.0000 100 1.0000 1.0000 1.0000 1.0000 48h Survival Rate Binomials Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 5/5 5/5 5/5 5/5 6.25 5/5 5/5 5/5 5/5 11 5/5 5/5 5/5 5/5 25 5/5 5/5 5/5 5/5 50 5/5 5/5 5/5 5/5 100 5/5 5/5 5/5 5/5 46 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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CETIS Analytical Report Report Date: 12 May-22 15:59 (p 1 of 2)
Test Code/ID: B534201cda / 15-2338-9861 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 11-0387-8148 Endpoint: 48h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 12 May-22 15:58 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 12 May-22 15:57 MD5 Hash: 7C3CB5340F8C0CF602EDD7FB547CC89 Editor ID: 000-042-882-4 Data Transform Alt Hyp NOEL LOEL TOEL TU Angular (Corrected) C>T 100 >100 --- 1 Steel Many-One Rank Sum Test Control vs Conc-% Test Stat Critical Ties DF P-Type P-Value Decision(:5%)
Dilution Water 6.25 18 10 1 6 CDF 0.8333 Non-Significant Effect 11 18 10 1 6 CDF 0.8333 Non-Significant Effect 25 18 10 1 6 CDF 0.8333 Non-Significant Effect 50 18 10 1 6 CDF 0.8333 Non-Significant Effect 100 18 10 1 6 CDF 0.8333 Non-Significant Effect ANOVA Table Source Sum Squares Mean Square DF F Stat P-Value Decision(:5%)
Between 0 0 5 Indeterminate Error 0 0 18 Total 0 23 ANOVA Assumptions Tests Attribute Test Test Stat Critical P-Value Decision(:1%)
Variance Bartlett Equality of Variance Test Indeterminate Distribution Shapiro-Wilk W Normality Test Indeterminate 48h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
11 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
100 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
Angular (Corrected) Transformed Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% 0.00%
6.25 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% 0.00%
11 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% 0.00%
25 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% 0.00%
50 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% 0.00%
100 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% 0.00%
47 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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CETIS Analytical Report R eport Date: 12 May-22 15:59 (p 2 of 2)
Test Code/ID: B534201cda / 15-2338-9861 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 11-0387-8148 Endpoint: 48h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 12 May-22 15:58 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 12 May-22 15:57 MD5 Hash: 7C3CB5340F8C0CF602EDD7FB547CC89 Editor ID: 000-042-882-4 Graphics 1.0 1.0 0.9 0.8 0.8 48h Survival Rate 0.7 0.6 C entered Corr. Angle 0.5 0.5 0.4 0.3 0.3 0.2 0.1 0.0 0 .0 0D 6.25 11 25 50 100 -2.0 -1.5 -1.0 - 0.5 0.0 0.5 1.0 1.5 2.0 Conc-% Rankits 48 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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CETIS Analytical Report Report Date: 12 May-22 15:59 (p 1 of 1)
Test Code/ID: B534201cda / 15-2338-9861 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 04-8420-0413 Endpoint: 48h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 12 May-22 15:58 Analysis: Linear Interpolation (ICPIN) Status Level: 1 Edit Date: 12 May-22 15:57 MD5 Hash: 7C3CB5340F8C0CF602EDD7FB547CC89 Editor ID: 000-042-882-4 Linear Interpolation Options X Transform Y Transform Seed Resamples Exp 95% CL Method Log(X+1) Linear 1192477 200 Yes Two-Point Interpolation Point Estimates Level % 95% LCL 95% UCL TU 95% LCL 95% UCL EC50 >100 --- --- <1 --- ---
48h Survival Rate Summary Calculated Variate(A/B) Isotonic Variate Conc-% Code Count Mean Median Min Max CV% %Effect A/B Mean %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 20/20 1.0000 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 20/20 1.0000 0.00%
11 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 20/20 1.0000 0.00%
25 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 20/20 1.0000 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 20/20 1.0000 0.00%
100 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 20/20 1.0000 0.00%
Graphics 1.0 0.9 0.8 0.7 48h Survival Rate 0.6 0.5 0.4 0.3 0.2 0.1 0.0 0 20 40 60 80 100 Conc-%
49 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Page 18
APPENDIX B REFERENCE TOXICANT DATA SHEETS 50 of 117 Page 19
51 of 117 Page 20
52 of 117 Page 21
APPENDIX C CHAIN OF CUSTODY 53 of 117 Page 22
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Bennett, Michelle From: Dudenhoeffer, Chris (ECY) <cdud461@ECY.WA.GOV>
Sent: Friday, May 13, 2022 10:59 AM To: Bennett, Michelle
Subject:
RE: Deviation Approval EXTERNAL EMAIL*
Im fine with this deviation. No toxicity was observed and as you pointed out it was not a high TRC reading.
Thank you for reaching out. Please make a note in the lab report.
- Cheers, Chris Chris Dudenhoeffer Lead for Aquatic Toxicity Assessments Water Quality Program l Dept of Ecology chris.dudenhoeffer@ecy.wa.gov 360.407.6445 (Desk) l 360.870.8409 (Cell)
From: Bennett, Michelle <michelle.bennett@et.eurofinsus.com>
Sent: Friday, May 13, 2022 8:00 AM To: Dudenhoeffer, Chris (ECY) <cdud461@ECY.WA.GOV>
Subject:
Deviation Approval THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the link Good morning Chris, We have a client that would like us to run a deviation by you for approval. The permit states that if chlorine is detected in the sample then we must dechlorinate. The analyst missed this step. The TRC reading was 0.03 mg/L (the reporting limit is 0.02 mg/L) in which we would have dechlorinated to have a reading of < 0.02 mg/L. No toxicity was shown and all of this will be noted in the report, but would this be acceptable to WDOE?
Thanks Michelle 1
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Michelle Bennett Project Manager/ QA Coordinator Eurofins Environment Testing Northwest - ASL (EETNW - ASL)
Phone (cell): 541-760-3031 COMMUNICATION ALERT: Change of e-mail addresses for all Eurofins Environment Testing businesses in the US effective April 4, 2022 Please update my e-mail address in your e-mail directory:
Michelle.Bennett@ET.EurofinsUS.com Email: Michelle.Bennett@ET.EurofinsUS.com Follow Us! Facebook l LinkedIn
- WARNING - EXTERNAL: This email originated from outside of Eurofins Environment Testing America. Do not click any links or open any attachments unless you trust the sender and know that the content is safe!
2 57 of 117 Page 26
INTEROFFICE MEMO GO2-22-101 DIC: 409.3 DATE: September 21, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
COLUMBIA GENERATING STATION ACUTE TOXICITY BIOASSAY FOR THE 3rd QUARTER 2022
REFERENCE:
NPDES Permit No. WA 002515-1, Condition S13 Please find attached the acute toxicity bioassay report for Columbia Generating Station for the third quarter of calendar year 2022. The testing was conducted in accordance with condition S13 of Columbias National Pollutant Discharge Elimination System (NPDES) permit. The bioassay results are favorable with no acute toxicity detected in the test concentration representing the acute critical effluent concentration (ACEC; the ACEC equals 11% effluent). In fact, the results show 97.5% survival of the test species, Pimephales promelas, in the 100% effluent sample.
A copy of the report (*.pdf format) and supporting statistical analysis (*.mdb format) will be submitted electronically to the State of Washington Department of Ecology (Ecology) and the Energy Facility Site Evaluation Council (EFSEC) via Ecologys Water Quality Permitting Portal (WQWebPortal).
If you have any questions concerning this information, please contact Marshall Schmitt at (509) 372-5334.
JTL
Attachment:
Acute Toxicity Test Report P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 58 of 117
Columbia Generating Station Page 2 of 2 September 22, 2022 CGS Acute Toxicity Bioassay Report for the 3rd Quarter 2022 DISTRIBUTION LIST:
INTERNAL DISTRIBUTION: FILE COPY BCB LB Docket File PE20 M Schmitt PE03 Columbia Files 964Y JT LePage 1025 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane T. LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad C. Barfuss, E&RP Manager 59 of 117
Water Quality Program Permit Submittal Electronic Certification Permittee: Energy Northwest Columbia Generating Station Permit Number: WA0025151 Site Address: T11N R28E S5 RICHLAND, WA 99352 Submittal Name: Acute toxicity compliance testing for acute toxicity Version: 1 Due Date: 10/30/2022 Comments: See attached for the 3Q2022 acute whole effluent toxicity lab report (.pdf) and data
(.mdb).
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 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 fine and imprisonment for knowing violations.
Brad Barfuss 9/21/2022 5:15:43 PM Signature Date 60 of 117
AQUATIC TOXICOLOGY REPORT Project Name: ENERGY NORTHWEST Location: RICHLAND, WASHINGTON Prepared by: Eurofins Environment Testing Northwest, LLC (aka TestAmerica - ASL) 1100 NE Circle Boulevard, Suite 310 Corvallis, Oregon 97330 541-243-6137 Accredited in accordance with NELAP Oregon Environmental Laboratory Accreditation Program #OR100022 (NELAP)
State of Washington DOE Environmental Laboratory Accreditation Program, Lab ID C556 California State Environmental Laboratory Accreditation Program, Certificate No.: 1726 Report Date: August 31, 2022 Released by: Michelle Bennett Revision 1 Report Date: September 1, 2022 Released by: Michelle Bennett Lab I.D. No. B5415 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. If you have received this report in error, please notify the sender and destroy this report immediately. This report shall not be reproduced except in full, without prior express written approval by the laboratory.
Results relate only to the items tested and the sample(s) as received by the laboratory. The results included in this report have been reviewed for compliance and meet all requirements for accredited parameters. All data have been found to be compliant with laboratory protocol, with the exception of any items noted in this report. For questions, please contact the Project Manager (contact info on next page).
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CONTENTS Section Page INTRODUCTION .................................................................................................................. 3 OVERVIEW OF REGULATORY GUIDANCE ................................................................... 3
SUMMARY
OF TEST RESULTS ......................................................................................... 4 ACRONYM DEFINITIONS ...................................................................................... 5 SAMPLE INFORMATION ..................................................................................................... 5 METHODS AND MATERIALS ............................................................................................ 5 TEST METHODS ....................................................................................................... 5 DEVIATIONS FROM PROTOCOLS ........................................................................ 6 TEST DESIGN ........................................................................................................... 6 DILUTION WATER .................................................................................................. 6 SAMPLE COLLECTION AND STORAGE .............................................................. 7 SAMPLE PREPARATION ........................................................................................ 7 DATA ANALYSIS ..................................................................................................... 7 RESULTS AND DISCUSSION ............................................................................................. 8 REFERENCE TOXICANT TESTS ........................................................................... 9 APPENDIX A. RAW DATA SHEETS APPENDIX B. REFERENCE TOXICANT DATA SHEETS APPENDIX C. CHAIN OF CUSTODY LABORATORY CONTACT: Brett Muckey, Laboratory Director Brett.Muckey@et.eurofinsus.com (541) 243-0980 62 of 117 Page 2
INTRODUCTION Eurofins Environment Testing Northwest, LLC Applied Sciences Laboratory (EETNW -
ASL) conducted toxicity testing on sample(s) from Energy Northwest, Richland, Washington.
Testing was initiated on: August 9, 2022 The test(s) were conducted using:
the fathead minnow (Pimephales promelas)
A revised report was issued September 1, 2022 to fix a formatting issue and to include a note on the missed temperature in the test.
OVERVIEW OF REGULATORY GUIDANCE The following provides an overview and excerpts of applicable permit specifics, regulatory guidance, and other relevant information. This is intended only as a helpful guide, from a laboratory perspective, for understanding test outcomes. The final responsibility for interpretation of results remains with the client and/or regulatory agency.
The following guidance is taken from EETNW-ASLs reading of the NPDES permit for Energy Northwests Columbia Generating Station in Richland, WA (permit #WA002515-1, effective Nov 1, 2014, expires Oct 31, 2019, modified Feb 8, 2016, and Mar. 19, 2019).
Acute toxicity:
Effluent Limit for Acute Toxicity:
o No acute toxicity detected in a test concentration representing the acute critical effluent concentration (ACEC).
o The ACEC equals 11% effluent.
Compliance with the Effluent Limit for Acute Toxicity:
o Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC.
o The Permittee must determine the statistical significance by conducting a hypothesis test at the 0.05 level of significance (i.e. alpha = 0.05) o If the difference in survival between the control and the ACEC is less than 10 percent, the Permittee must conduct the hypothesis test at the 0.01 level of significance.
o If the test results show a statistically significant difference in survival between the control and the ACEC, and EFSEC has not determined the test result to be anomalous under Section D, and the test is otherwise valid, the result is a violation of the effluent limit for acute toxicity.
Compliance Testing for Acute Toxicity:
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o Conduct quarterly acute toxicity testing on the final effluent. (Jan-Mar, Apr-Jun, Jul-Sep, Oct-Dec) o using each of the species and protocols listed on a rotating basis.
Response to Noncompliance With an Effluent Limit for Acute Toxicity:
o If a toxicity test determines a statistically significant difference in response between the ACEC and the control, the Permittee must begin additional compliance monitoring within one week of receiving the test results.
Sampling and Reporting Requirements:
o The permittee must collect grab samples must cool the samples to 0 - 6 degrees Celsius during collection and send them to the lab immediately upon completion.
o The lab must begin the toxicity testing no later than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after sampling was completed.
o The Permittee must chemically dechlorinate final effluent with sodium thiosulfate just prior to test initiation. Do not add more sodium thiosulfate than is necessary to neutralize the chlorine. Provide in the test report the calculations to determine the amount of sodium thiosulfate necessary The following is taken from the WDOE guidance (WQ-R-95-80, June 2016 revision):
To reduce WET limit violations (and anomalous concentration-response relationships) due to statistical significance that is a Type I error [false positive], we lower alpha when differences in test organism response are small.
Alpha will be lowered from 0.05 to 0.01 if a 10% difference in an acute test is significant
SUMMARY
OF TEST RESULTS Exhibit 1 provides a summary of the final test results.
EXHIBIT 1 Summary of Acute Test Results NOEC LOEC LC50 Was a statistically significant difference Species
(%) (%) (%) between control and ACEC shown?
P. promelas 100 > 100 > 100 No Note: acronyms are as defined below.
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
More detailed information is provided in the Results and Discussion section.
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ACRONYM DEFINITIONS (from EPA guidance):
NOEC = No Observed Effect Concentration: The highest test concentration that causes no observable adverse effects on the test organisms (i.e. no statistically significant reduction from the control).
LOEC = Low Observed Effect Concentration: The lowest test concentration that does cause an observable adverse effect on the test organisms (i.e. is statistically significant reduction from the control).
LC50 = Lethal Concentration (50%): A point estimate of the test concentration that would cause death in 50 percent of the test population.
SAMPLE INFORMATION Exhibit 2 provides a summary of the sample conditions as received.
EXHIBIT 2 Sample Conditions on Receipt Sample ID 230099-03 EETNW - ASL SDG B5415-01 Collection - Date and Time 08/08/2022 10:15 Receipt - Date and Time 08/09/2022 09:52 Temperature (oC) 0.8 Dissolved Oxygen (mg/L) 7.2 pH 7.5 Conductivity (S/cm) 739 Total Residual Chlorine (mg/L) < 0.02 Ammonia (mg/L as NH3-N) 0.11 Total Hardness (mg/L as CaCO3) 333 Total Alkalinity (mg/L as CaCO3) 106 METHODS AND MATERIALS TEST METHODS The acute test methods were performed according to: Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water (2002), EPA-821-R-02-012.
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Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
DEVIATIONS FROM PROTOCOLS Deviations from required procedures in the test methods:
Temperature readings were not taken at test termination in the P. promelas test as required by EPA and WDOE. See further discussion in the Acute Results section.
Deviations from recommended procedures in the test methods:
None noted.
TEST DESIGN The following summarizes the conditions used for both overall testing and the specifics for each test (observations and notations can be found on the datasheets in Appendix A):
Overall Test Design:
Acute test: 6.25, 11.0 [ACEC], 25.0, 50.0, and 100 percent sample + dilution water for the control.
Test Organism Conditions:
All organisms tested were fed and maintained during culturing, acclimation, and testing as prescribed by the EPA (2002).
The test organisms appeared vigorous and in good condition prior to testing.
P. promelas acute test (renewal):
Source: Aquatox Inc., Hot Springs, Arkansas Age: 1 to 14 days old, within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> age range Design: Four test vessels per concentration, Ten organisms per vessel Test Solution Renewal: Once @ 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (i.e. static-renewal test)
Monitoring:
o Daily: Survival, DO, pH, and temperature; all concentrations.
o Pre and Post Renewal solutions: DO and pH, all concentrations.
o Test Initiation, with each new sample use, and Termination:
Conductivity, all concentrations (WDOE)
Termination: 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
Endpoints: Survival (at termination)
DILUTION WATER The dilution water used was the standard culture water used by EETNW - ASL:
Reconstituted, moderately hard water (as per EPA protocol) with a total hardness of 75 to 105 mg/L as CaCO3 and an alkalinity of 50 to 75 mg/L as CaCO3.
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SAMPLE COLLECTION AND STORAGE Samples were collected by Energy Northwest personnel. The samples were accepted as scheduled by EETNW - ASL. Chain of Custody and Sample Receipt Records are provided in Appendix C.
The sample was received within the EPA recommended 0 to 6 oC range.
The sample was received within the WDOE required 0 to 6 oC range.
The sample was initially used for test initiation or test solution renewal within the EPA recommended maximum holding time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of sample collection.
All subsequent uses of the sample occurred within the EPA recommended maximum holding time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> past the time of initial use of that sample.
All subsequent uses of a sample occurred within the WDOE recommended maximum holding time of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> past the time of sample collection. (For renewals of a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> duration acute test)
Following receipt, the samples were stored in the dark at 0 to 6 C until test solutions were prepared and tested.
SAMPLE PREPARATION Samples used during these tests were:
Temperature adjusted prior to test initiation and each daily renewal.
As no Total Residual Chlorine was observed, dechlorination with sodium thiosulfate was not performed.
DATA ANALYSIS The statistical analyses performed for the acute tests were those outlined in Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water, Fifth Edition (2002), EPA-821-R-02-012, using CETIS.
The specific statistical analysis and CETIS version used for each endpoint evaluation is listed with the statistical outputs included with each test in Appendix A.
If any additional analysis methods were also used, an explanation of the rationale and reference to the source method is included with the presentation of those results below.
Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
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RESULTS AND DISCUSSION The raw data sheets for all tests are presented in Appendix A.
ACUTE BIOASSAYS Table 1 summarizes the survival data for the P. promelas acute test.
Table 1 Summary of Acute Results P. promelas Sample Percent Survival Concentration (at Test Termination)
(%)
Control 100 6.25 100 11.0 97.5 25.0 100 50.0 100 100 97.5 Statistical analysis in accordance with the EPA protocol and WDOE guidance results in:
NOEC = 100 %
LOEC > 100 %
LC50 > 100 %
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
No statistically significant difference between control and ACEC was shown.
The temperature was not recorded at test termination in the P. promelas test. EPA and WDOE manual states, Temperature and pH are measured at the end of each 24-h exposure period in at least one test chamber at each test concentration and in the control. Temperature should also be monitored continuously or observed and recorded daily for at least two locations in the environmental control system or the samples. The continuous monitoring of the water bath temperatures indicate the temperatures remained in the temperature range of 20 +/- 1 °C. As no toxicity was observed, it is EETNW - ASLs professional opinion that missing the required temperature measurements had no significant impact on test results.
Dissolved oxygen concentrations remained at 4.0 mg/L or greater throughout the test period.
Test temperatures remained in the range of 20+/-1 C.
The P. promelas acute test meets Test Acceptability Criteria (TAC) of a minimum 90 percent control survival. Unless referenced above, the tests proceeded without any noted deviations or interruptions that could have affected test results. The testing should be considered valid.
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REFERENCE TOXICANT TESTS Reference toxicant (reftox) testing is performed to document both initial and ongoing laboratory performance of the test method(s). While the health of the test organisms is primarily evaluated by the performance of the laboratory control, reftox test results also may be used to assess the health and sensitivity of the test organisms. Reftox test results within their respective cumulative summary (Cusum) chart limits are indicative of consistent laboratory performance and normal test organism sensitivity.
The results of the reftox tests indicate that the test organisms were within their respective cusum chart limits based on EPA guidelines. This demonstrates ongoing laboratory proficiency of the test methods and suggests normal test organism sensitivity in the associated client testing.
The P. promelas acute reftox test was conducted using sodium chloride. The data sheets for the reference toxicant tests are provided in Appendix B.
Table 2 summarizes the reference toxicant test results and Cusum chart limits.
Table 2 Acute Reference Toxicant Tests (g/L)
Species LC50 Cusum Chart Limits P. promelas 7.1 6.5 to 8.9 69 of 117 Page 9
APPENDIX A RAW DATA SHEETS 70 of 117 Page 10
106 333 0.11 71 of 117 Page 11
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CETIS Summary Report Report Date: 28 Aug-22 14:13 (p 1 of 1)
Test Code/ID: B541501ppa / 15-5985-5949 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Batch ID: 00-8996-6868 Test Type: Survival (96h) Analyst: Michelle Bennett Start Date: 09 Aug-22 14:20 Protocol: EPA/821/R-02-012 (2002) Diluent: Mod-Hard Synthetic Water Ending Date: 13 Aug-22 12:30 Species: Pimephales promelas Brine:
Test Length: 94h Taxon: Actinopterygii Source: Aquatox, AR Age: 8D Sample ID: 15-7653-9567 Code: B5415-01 Project:
Sample Date: 08 Aug-22 10:15 Material: Industrial Effluent Source: Energy Northwest (WA 0025151)
Receipt Date: 09 Aug-22 09:52 CAS (PC): Station:
Sample Age: 28h (0.8 °C) Client:
Multiple Comparison Summary Analysis ID Endpoint Comparison Method NOEL LOEL TOEL PMSD TU S 11-7738-8580 96h Survival Rate Steel Many-One Rank Sum Test 100 >100 --- 5.6% 1 1 Point Estimate Summary Analysis ID Endpoint Point Estimate Method Level % 95% LCL 95% UCL TU S 07-1453-9746 96h Survival Rate Linear Interpolation (ICPIN) EC50 >100 --- --- <1 1 Test Acceptability TAC Limits Analysis ID Endpoint Attribute Test Stat Lower Upper Overlap Decision 07-1453-9746 96h Survival Rate Control Resp 1 0.9 >> Yes Passes Criteria 11-7738-8580 96h Survival Rate Control Resp 1 0.9 >> Yes Passes Criteria 96h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Min Max Std Err Std Dev CV% %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
11 4 0.9750 0.8954 1.0550 0.9000 1.0000 0.0250 0.0500 5.13% 2.50%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- 0.00%
100 4 0.9750 0.8954 1.0550 0.9000 1.0000 0.0250 0.0500 5.13% 2.50%
96h Survival Rate Detail MD5: 5E2CBEDD783DBA21BCC854DC770C867 Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 1.0000 1.0000 1.0000 1.0000 6.25 1.0000 1.0000 1.0000 1.0000 11 0.9000 1.0000 1.0000 1.0000 25 1.0000 1.0000 1.0000 1.0000 50 1.0000 1.0000 1.0000 1.0000 100 1.0000 1.0000 1.0000 0.9000 96h Survival Rate Binomials Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 10/10 10/10 10/10 10/10 6.25 10/10 10/10 10/10 10/10 11 9/10 10/10 10/10 10/10 25 10/10 10/10 10/10 10/10 50 10/10 10/10 10/10 10/10 100 10/10 10/10 10/10 9/10 77 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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CETIS Analytical Report Report Date: 28 Aug-22 14:13 (p 1 of 2)
Test Code/ID: B541501ppa / 15-5985-5949 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 11-7738-8580 Endpoint: 96h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 28 Aug-22 14:12 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 28 Aug-22 14:11 MD5 Hash: 5E2CBEDD783DBA21BCC854DC770C867 Editor ID: 000-042-882-4 Data Transform Alt Hyp NOEL LOEL TOEL TU MSDu PMSD Angular (Corrected) C>T 100 >100 --- 1 0.05598 5.60%
Steel Many-One Rank Sum Test Control vs Conc-% Test Stat Critical Ties DF P-Type P-Value Decision(:5%)
Dilution Water 6.25 18 10 1 6 CDF 0.8333 Non-Significant Effect 11 16 10 1 6 CDF 0.6105 Non-Significant Effect 25 18 10 1 6 CDF 0.8333 Non-Significant Effect 50 18 10 1 6 CDF 0.8333 Non-Significant Effect 100 16 10 1 6 CDF 0.6105 Non-Significant Effect ANOVA Table Source Sum Squares Mean Square DF F Stat P-Value Decision(:5%)
Between 0.0088531 0.0017706 5 0.8 0.5640 Non-Significant Effect Error 0.039839 0.0022133 18 Total 0.0486921 23 ANOVA Assumptions Tests Attribute Test Test Stat Critical P-Value Decision(:1%)
Variance Bartlett Equality of Variance Test Indeterminate Distribution Shapiro-Wilk W Normality Test 0.6154 0.884 <1.0E-05 Non-Normal Distribution 96h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
11 4 0.9750 0.8954 1.0000 1.0000 0.9000 1.0000 0.0250 5.13% 2.50%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% 0.00%
100 4 0.9750 0.8954 1.0000 1.0000 0.9000 1.0000 0.0250 5.13% 2.50%
Angular (Corrected) Transformed Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% 0.00%
6.25 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% 0.00%
11 4 1.3710 1.2420 1.5010 1.4120 1.2490 1.4120 0.0407 5.94% 2.89%
25 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% 0.00%
50 4 1.4120 1.4120 1.4120 1.4120 1.4120 1.4120 0.0000 0.00% 0.00%
100 4 1.3710 1.2420 1.5010 1.4120 1.2490 1.4120 0.0407 5.94% 2.89%
78 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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CETIS Analytical Report Report Date: 28 Aug-22 14:13 (p 2 of 2)
Test Code/ID: B541501ppa / 15-5985-5949 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 11-7738-8580 Endpoint: 96h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 28 Aug-22 14:12 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 28 Aug-22 14:11 MD5 Hash: 5E2CBEDD783DBA21BCC854DC770C867 Editor ID: 000-042-882-4 Graphics 1.0 0.06 0.9 0.04 0.02 0.8 96h Survival Rate 0.00 0.7
-0.02 Centered 0.6
-0.04 Corr. Angle 0.5
-0.06 0.4
-0.08 0.3
-0.10 0.2
-0.12 0.1 -0.14 0.0 -0.16 0D 6.25 11 25 50 100 -2.0 -1.5 -1.0 -0.5 0.0 0.5 1.0 1.5 2.0 Conc-% Rankits 79 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Page 19
CETIS Analytical Report Report Date: 28 Aug-22 14:13 (p 1 of 1)
Test Code/ID: B541501ppa / 15-5985-5949 Fathead Minnow 96-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 07-1453-9746 Endpoint: 96h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 28 Aug-22 14:12 Analysis: Linear Interpolation (ICPIN) Status Level: 1 Edit Date: 28 Aug-22 14:11 MD5 Hash: 5E2CBEDD783DBA21BCC854DC770C867 Editor ID: 000-042-882-4 Linear Interpolation Options X Transform Y Transform Seed Resamples Exp 95% CL Method Log(X+1) Linear 702121 200 Yes Two-Point Interpolation Point Estimates Level % 95% LCL 95% UCL TU 95% LCL 95% UCL EC50 >100 --- --- <1 --- ---
96h Survival Rate Summary Calculated Variate(A/B) Isotonic Variate Conc-% Code Count Mean Median Min Max CV% %Effect A/B Mean %Effect 0 D 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 1.0000 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 1.0000 0.00%
11 4 0.9750 1.0000 0.9000 1.0000 5.13% 2.50% 39/40 0.9917 0.83%
25 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 0.9917 0.83%
50 4 1.0000 1.0000 1.0000 1.0000 0.00% 0.00% 40/40 0.9917 0.83%
100 4 0.9750 1.0000 0.9000 1.0000 5.13% 2.50% 39/40 0.9750 2.50%
Graphics 1.0 0.9 0.8 0.7 96h Survival Rate 0.6 0.5 0.4 0.3 0.2 0.1 0.0 0 20 40 60 80 100 Conc-%
80 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Page 20
APPENDIX B REFERENCE TOXICANT DATA SHEETS 81 of 117 Page 21
Page 22 7.1 82 of 117 6.5 8.9 Spearman-Karber
REFERENCE TOXICANT CUMLATIVE
SUMMARY
(CUSUM)
CHART 12 Pimephales promelas Acute Survival - LC50 Values Lethal Concentration - NaCl (g/l) 10 8
6 4
2 0
2096 2103 2111 2112 2115 2123 2127 2137 2141 2145 2148 2152 2157 2160 2166 2173 2176 2179 2186 2193 2194 2197 2202 2211 2212 2216 2222 2226 2226 2236 Organism ID#
LC50 Average Cusum Chart Limits EPA 75th Quartile EPA 25th Quartile Pimephales promelas - ACUTE (EPA Test Method 2000.0)
SODIUM CHLORIDE (g/L) From EPA 833-R-00-003:
Organism age: 1 to 14 days 10th Quartile CV (control limit ) = 0.08 Endpoint: 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Survival 25th Quartile CV (warning limit ) = 0.10 Stats Method: Probit, Spearman-Karber, Linear Interpolation 75th Quartile CV (warning limit ) = 0.19 Test Conditions: Recon MH, 20 oC 90th Quartile CV (control limit ) = 0.33 Intralab CV is compared to EPA Warning limits (25th and 75th CV's) and Control limits (10th and 90th CV's),
If lab CV is outside EPA Control limits, the EPA Control limits are used to set Cusum chart limits.
Event FHM Test Start Running Running Cusum Chart Limits Intralab LC50
- ID # Date Average SD AVG-2SD AVG+2SD CV 958 2186 10/21/2021 8.5 7.2 0.68 5.8 8.6 0.10 959 2193 11/23/2021 7.9 7.3 0.74 5.8 8.7 0.10 960 2194 12/7/2021 7.7 7.3 0.75 5.8 8.8 0.10 961 2197 1/4/2022 7.7 7.3 0.70 5.9 8.7 0.10 962 2202 2/8/2022 7.7 7.3 0.70 6.1 8.5 0.08 963 2211 3/22/2022 8.1 7.4 0.58 6.2 8.6 0.07 964 2212 4/5/2022 8.1 7.5 0.53 6.3 8.7 0.07 965 2216 5/4/2022 7.1 7.6 0.53 6.3 8.8 0.06 966 2222 6/14/2022 6.9 7.6 0.48 6.4 8.8 0.06 967 2226 7/6/2022 9.0 7.6 0.48 6.4 8.8 0.07 968 2226 7/12/2022 7.1 7.7 0.55 6.5 8.9 0.07 969 2236 8/23/2022 7.1 7.7 0.54 6.5 8.9 0.07 970 971 972 83 of 117 Page 23 FHM Acute, 8/28/2022 ASL912-0711
APPENDIX C CHAIN OF CUSTODY 84 of 117 Page 24
85 of 117 Page 25
X X
86 of 117 Page 26
87 of 117 Page 27
LePage, Jane T.
From: Bennett, Michelle <michelle.bennett@et.eurofinsus.com>
Sent: Friday, September 02, 2022 9:07 AM To: LePage, Jane T.
Subject:
FW: Deviation Question EXTERNAL: Think Before You Click!
Hi Jane, Please see WDOEs response below.
Thanks Michelle Michelle Bennett Project Manager/ QA Coordinator Eurofins Environment Testing Northwest - ASL (EETNW - ASL)
Phone (cell): 541-760-3031 COMMUNICATION ALERT: Change of e-mail addresses for all Eurofins Environment Testing businesses in the US effective April 4, 2022 Please update my e-mail address in your e-mail directory:
Michelle.Bennett@ET.EurofinsUS.com Email: Michelle.Bennett@ET.EurofinsUS.com Follow Us! Facebook l LinkedIn https://www.surveymonkey.com From: Dudenhoeffer, Chris (ECY) <cdud461@ECY.WA.GOV>
Sent: Friday, September 2, 2022 8:54 AM To: Bennett, Michelle <michelle.bennett@et.eurofinsus.com>
Subject:
RE: Deviation Question EXTERNAL EMAIL*
Hi Michelle, 1
88 of 117
Sorry I didnt realize I didnt click send yesterday. Yes the test is acceptable. Just report the water bath temperature for the test and note the deviation.
-Chris Chris Dudenhoeffer Lead for Aquatic Toxicity Assessments Water Quality Program l Dept of Ecology chris.dudenhoeffer@ecy.wa.gov 360.407.6445 (Desk) l 360.870.8409 (Cell)
From: Bennett, Michelle <michelle.bennett@et.eurofinsus.com>
Sent: Thursday, September 1, 2022 12:49 PM To: Dudenhoeffer, Chris (ECY) <cdud461@ECY.WA.GOV>
Cc: LePage, Jane T. <jtlepage@energy-northwest.com>
Subject:
Deviation Question Hi Chris, We have a client that would like your input on whether or not this test will be acceptable by WDOE. The analyst missed the temperatures at test termination. There was no observed toxicity, we included our temperature log that showed that the water bath was within temperature range, and made note of it in the final report. Would this be acceptable to WDOE?
Thanks Michelle Michelle Bennett Project Manager/ QA Coordinator Eurofins Environment Testing Northwest - ASL (EETNW - ASL)
Phone (cell): 541-760-3031 COMMUNICATION ALERT: Change of e-mail addresses for all Eurofins Environment Testing businesses in the US effective April 4, 2022 Please update my e-mail address in your e-mail directory:
Michelle.Bennett@ET.EurofinsUS.com Email: Michelle.Bennett@ET.EurofinsUS.com Follow Us! Facebook l LinkedIn https://www.surveymonkey.com 2
89 of 117
- WARNING - EXTERNAL: This email originated from outside of Eurofins Environment Testing America. Do not click any links or open any attachments unless you trust the sender and know that the content is safe!
3 90 of 117
INTEROFFICE MEMO GO2-22-125 DIC: 409.3 DATE: November 15, 2022 TO: Columbia Generating Station, (CGS)
FROM: Jane LePage, Environmental Scientist (1025)
SUBJECT:
COLUMBIA GENERATING STATION ACUTE TOXICITY BIOASSAY REPORT FOR THE 4th QUARTER 2022
REFERENCE:
NPDES Permit No. WA 002515-1 Condition S13 Please find attached the acute toxicity bioassay report for Columbia Generating Station for the fourth quarter of 2022. The testing was conducted in accordance with condition S13 of Columbias National Pollutant Discharge Elimination System (NPDES) permit. The bioassay results are favorable with no acute toxicity detected in the test concentration representing the acute critical effluent concentration (ACEC; the ACEC equals 11%
effluent). The results show 100% survival of the test species, Ceriodaphnia dubia, in the 100% effluent sample.
A copy of the report (*.pdf format) and supporting statistical analysis (*.mdb format) will be submitted electronically to the State of Washington Department of Ecology (Ecology) and the Energy Facility Site Evaluation Council (EFSEC) via Ecologys Water Quality Permitting Portal (WQWebPortal).
If you have any questions concerning this information, please contact MA Schmitt at (509) 372-5334.
JTL
Attachment:
Acute Toxicity Bioassay Report DISTRIBUTION LIST:
INTERNAL DISTRIBUTION:
M Schmitt (via email) Docket File PE20 J LePage (via email) Regulatory (via email)
K Byers (via email) Document Control (via APW)
P.O. Box 968 / Richland, WA 99352-0968 / (509) 372-5000 / www.energy-northwest.com 91 of 117
Columbia Generating Station Page 2 of 2 November 15, 2022 CGS Acute Toxicity Bioassay Report for the 4th Quarter 2022 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 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 fine and imprisonment for knowing violations.
Prepared by: Jane T. LePage, Environmental Scientist, Environmental Services Reviewed by: Kris Byers, Environmental Scientist, Environmental Services Reviewed by: Marshall Schmitt, Environmental Scientist, E&RP Reviewed by: Matthew Turner, Manager, Environmental Services Approved by: Brad Barfuss, Manager, Environmental & Regulatory Programs 92 of 117
Water Quality Program Permit Submittal Electronic Certification Permittee: Energy Northwest Columbia Generating Station Permit Number: WA0025151 Site Address: T11N R28E S5 RICHLAND, WA 99352 Submittal Name: Acute toxicity compliance testing for acute toxicity Version: 1 Due Date: 1/30/2023 Comments:
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 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 fine and imprisonment for knowing violations.
Brad Barfuss 11/15/2022 11:06:49 AM Signature Date 93 of 117
AQUATIC TOXICOLOGY REPORT Project Name: ENERGY NORTHWEST Location: RICHLAND, WASHINGTON Prepared by: Eurofins Environment Testing Northwest, LLC (aka TestAmerica - ASL) 1100 NE Circle Boulevard, Suite 310 Corvallis, Oregon 97330 541-243-6137 Accredited in accordance with NELAP Oregon Environmental Laboratory Accreditation Program #OR100022 (NELAP)
State of Washington DOE Environmental Laboratory Accreditation Program, Lab ID C556 California State Environmental Laboratory Accreditation Program, Certificate No.: 1726 Report Date: November 4, 2022 Released by: Michelle Bennett Lab I.D. No. B5488 This report is issued solely for the use of the person or company to whom it is addressed. Any use, copying or disclosure other than by the intended recipient is unauthorized. If you have received this report in error, please notify the sender and destroy this report immediately. This report shall not be reproduced except in full, without prior express written approval by the laboratory.
Results relate only to the items tested and the sample(s) as received by the laboratory. The results included in this report have been reviewed for compliance and meet all requirements for accredited parameters. All data have been found to be compliant with laboratory protocol, with the exception of any items noted in this report. For questions, please contact the Project Manager (contact info on next page).
94 of 117 Energy NW B5488.pdf Page 1 of 24
CONTENTS Section Page INTRODUCTION .................................................................................................................. 3 OVERVIEW OF REGULATORY GUIDANCE ................................................................... 3
SUMMARY
OF TEST RESULTS ......................................................................................... 4 ACRONYM DEFINITIONS ...................................................................................... 5 SAMPLE INFORMATION ..................................................................................................... 5 METHODS AND MATERIALS ............................................................................................ 6 TEST METHODS ....................................................................................................... 6 DEVIATIONS FROM PROTOCOLS ........................................................................ 6 TEST DESIGN ........................................................................................................... 6 DILUTION WATER .................................................................................................. 7 SAMPLE COLLECTION AND STORAGE .............................................................. 7 SAMPLE PREPARATION ........................................................................................ 7 DATA ANALYSIS ..................................................................................................... 7 RESULTS AND DISCUSSION ............................................................................................. 8 REFERENCE TOXICANT TESTS ........................................................................... 9 APPENDIX A. RAW DATA SHEETS APPENDIX B. REFERENCE TOXICANT DATA SHEETS APPENDIX C. CHAIN OF CUSTODY LABORATORY CONTACT: Brett Muckey, Business Unit Manager (BUMa)
Brett.Muckey@et.eurofinsus.com (541) 243-0980 95 of 117 Energy NW B5488.pdf Page 2 of 24
INTRODUCTION Eurofins Environment Testing Northwest, LLC Applied Sciences Laboratory (EETNW -
ASL) conducted toxicity testing on sample(s) from Energy Northwest, Richland, Washington.
Testing was initiated on: October 25, 2022 The test(s) were conducted using:
the water flea (Ceriodaphnia dubia)
OVERVIEW OF REGULATORY GUIDANCE The following provides an overview and excerpts of applicable permit specifics, regulatory guidance, and other relevant information. This is intended only as a helpful guide, from a laboratory perspective, for understanding test outcomes. The final responsibility for interpretation of results remains with the client and/or regulatory agency.
The following guidance is taken from EETNW-ASLs reading of the NPDES permit for Energy Northwests Columbia Generating Station in Richland, WA (permit #WA0025151, effective Nov 1, 2014, expires Oct 31, 2019, modified Feb 8, 2016, and Mar. 19, 2019).
Acute toxicity:
Effluent Limit for Acute Toxicity:
o No acute toxicity detected in a test concentration representing the acute critical effluent concentration (ACEC).
o The ACEC equals 11% effluent.
Compliance with the Effluent Limit for Acute Toxicity:
o Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC.
o The Permittee must determine the statistical significance by conducting a hypothesis test at the 0.05 level of significance (i.e. alpha = 0.05) o If the difference in survival between the control and the ACEC is less than 10 percent, the Permittee must conduct the hypothesis test at the 0.01 level of significance.
o If the test results show a statistically significant difference in survival between the control and the ACEC, and EFSEC has not determined the test result to be anomalous under Section D, and the test is otherwise valid, the result is a violation of the effluent limit for acute toxicity.
Compliance Testing for Acute Toxicity:
o Conduct quarterly acute toxicity testing on the final effluent. (Jan-Mar, Apr-Jun, Jul-Sep, Oct-Dec) o using each of the species and protocols listed on a rotating basis.
Response to Noncompliance With an Effluent Limit for Acute Toxicity:
96 of 117 Energy NW B5488.pdf Page 3 of 24
o If a toxicity test determines a statistically significant difference in response between the ACEC and the control, the Permittee must begin additional compliance monitoring within one week of receiving the test results.
Sampling and Reporting Requirements:
o The permittee must collect grab samples must cool the samples to 0 - 6 degrees Celsius during collection and send them to the lab immediately upon completion.
o The lab must begin the toxicity testing no later than 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after sampling was completed.
o The Permittee must chemically dechlorinate final effluent with sodium thiosulfate just prior to test initiation. Do not add more sodium thiosulfate than is necessary to neutralize the chlorine. Provide in the test report the calculations to determine the amount of sodium thiosulfate necessary The following is taken from the WDOE guidance (WQ-R-95-80, June 2016 revision):
To reduce WET limit violations (and anomalous concentration-response relationships) due to statistical significance that is a Type I error [false positive], we lower alpha when differences in test organism response are small.
Alpha will be lowered from 0.05 to 0.01 if a 10% difference in an acute test is significant
SUMMARY
OF TEST RESULTS Exhibit 1 provides a summary of the final test results.
EXHIBIT 1 Summary of Acute Test Results NOEC LOEC LC50 Was a statistically significant difference Species
(%) (%) (%) between control and ACEC shown?
C. dubia 100 > 100 > 100 No Note: acronyms are as defined below.
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
More detailed information is provided in the Results and Discussion section.
97 of 117 Energy NW B5488.pdf Page 4 of 24
ACRONYM DEFINITIONS (from EPA guidance):
NOEC = No Observed Effect Concentration: The highest test concentration that causes no observable adverse effects on the test organisms (i.e. no statistically significant reduction from the control).
LOEC = Low Observed Effect Concentration: The lowest test concentration that does cause an observable adverse effect on the test organisms (i.e. is statistically significant reduction from the control).
LC50 = Lethal Concentration (50%): A point estimate of the test concentration that would cause death in 50 percent of the test population.
SAMPLE INFORMATION Exhibit 2 provides a summary of the sample conditions as received.
EXHIBIT 2 Sample Conditions on Receipt Sample ID 23042501 EETNW - ASL SDG B5488-01 Collection - Date and Time 10/24/2022 09:40 Receipt - Date and Time 10/25/2022 10:30 Temperature (oC) 0.5 Dissolved Oxygen (mg/L) 7.4 pH 7.6 Conductivity (S/cm) 1030 Total Residual Chlorine (mg/L) < 0.02 Ammonia (mg/L as NH3-N) < 0.10 Total Hardness (mg/L as CaCO3) 475 Total Alkalinity (mg/L as CaCO3) 86 98 of 117 Energy NW B5488.pdf Page 5 of 24
METHODS AND MATERIALS TEST METHODS The acute test methods were performed according to: Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water (2002), EPA-821-R-02-012.
Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
DEVIATIONS FROM PROTOCOLS Deviations from required procedures in the test methods:
None noted.
Deviations from recommended procedures in the test methods:
None noted.
TEST DESIGN The following summarizes the conditions used for both overall testing and the specifics for each test (observations and notations can be found on the datasheets in Appendix A):
Overall Test Design:
Acute test: 6.25, 11.0 [ACEC], 25.0, 50.0, and 100 percent sample + dilution water for the control.
Test Organism Conditions:
All organisms tested were fed and maintained during culturing, acclimation, and testing as prescribed by the EPA (2002).
The test organisms appeared vigorous and in good condition prior to testing.
C. dubia acute test: (WDOE)
Source: EETNW-ASL's in-house cultures Age: Less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> old Design: Four test vessels per concentration, five organisms per vessel Test Solution Renewal: None (i.e. static test)
Monitoring:
o Daily: Survival, DO, pH, and temperature; all concentrations.
o Test Initiation and Termination: Conductivity, all concentrations Termination: 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Endpoints: Survival (at termination).
99 of 117 Energy NW B5488.pdf Page 6 of 24
DILUTION WATER The dilution water used was the standard culture water used by EETNW - ASL:
Reconstituted, moderately hard water (as per EPA protocol) with a total hardness of 75 to 105 mg/L as CaCO3 and an alkalinity of 50 to 75 mg/L as CaCO3.
SAMPLE COLLECTION AND STORAGE Samples were collected by Energy Northwest personnel. The samples were accepted as scheduled by EETNW - ASL. Chain of Custody and Sample Receipt Records are provided in Appendix C.
The sample was received within the EPA recommended 0 to 6 oC range.
The sample was received within the WDOE required 0 to 6 oC range.
The sample was initially used for test initiation or test solution renewal within the EPA recommended maximum holding time of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of sample collection.
All subsequent uses of the sample occurred within the EPA recommended maximum holding time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> past the time of initial use of that sample.
All subsequent uses of a sample occurred within the WDOE recommended maximum holding time of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> past the time of sample collection. (For renewals of a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> duration acute test)
Following receipt, the samples were stored in the dark at 0 to 6 C until test solutions were prepared and tested.
SAMPLE PREPARATION Samples used during these tests were:
Temperature adjusted prior to test initiation and each daily renewal.
As no Total Residual Chlorine was observed, dechlorination with sodium thiosulfate was not performed.
DATA ANALYSIS The statistical analyses performed for the acute tests were those outlined in Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, USEPA Office of Water, Fifth Edition (2002), EPA-821-R-02-012, using CETIS.
The specific statistical analysis and CETIS version used for each endpoint evaluation is listed with the statistical outputs included with each test in Appendix A.
If any additional analysis methods were also used, an explanation of the rationale and reference to the source method is included with the presentation of those results below.
Additional guidance was provided by:
Whole Effluent Toxicity Testing Guidance and Test Review Criteria, Washington State Department of Ecology (revised Jun 2016) Pub# WQ-R-95-80.
100 of 117 Energy NW B5488.pdf Page 7 of 24
RESULTS AND DISCUSSION The raw data sheets for all tests are presented in Appendix A.
ACUTE BIOASSAYS Table 1 summarizes the survival data for the C. dubia acute test.
Table 1 Summary of Acute Results C. dubia Sample Percent Survival Concentration (at Test Termination)
(%)
Control 95 6.25 100 11.0 100 25.0 100 50.0 100 100 100 Statistical analysis in accordance with the EPA protocol and WDOE guidance results in:
NOEC = 100 %
LOEC > 100 %
LC50 > 100 %
From the NPDES permit - Effluent Limit for Acute Toxicity: Compliance with the effluent limit for acute toxicity means the result of the testing show no statistically significant difference in survival between the control and the ACEC. [ACEC = 11%].
No statistically significant difference between control and ACEC was shown.
Dissolved oxygen concentrations remained at 4.0 mg/L or greater throughout the test period.
Test temperatures remained in the range of 20+/-1 C.
The C. dubia acute test meets Test Acceptability Criteria (TAC) of a minimum 90 percent control survival. Unless referenced above, the tests proceeded without any noted deviations or interruptions that could have affected test results. The testing should be considered valid.
101 of 117 Energy NW B5488.pdf Page 8 of 24
REFERENCE TOXICANT TESTS Reference toxicant (reftox) testing is performed to document both initial and ongoing laboratory performance of the test method(s). While the health of the test organisms is primarily evaluated by the performance of the laboratory control, reftox test results also may be used to assess the health and sensitivity of the test organisms. Reftox test results within their respective cumulative summary (Cusum) chart limits are indicative of consistent laboratory performance and normal test organism sensitivity.
The results of the reftox tests indicate that the test organisms were within their respective cusum chart limits based on EPA guidelines. This demonstrates ongoing laboratory proficiency of the test methods and suggests normal test organism sensitivity in the associated client testing.
The C. dubia reftox test was conducted using sodium chloride. The data sheets for the reference toxicant test are provided in Appendix B.
Table 2 summarizes the reference toxicant test results and Cusum chart limits.
Table 2 Acute Reference Toxicant Test with Sodium Chloride (g/L)
Species LC50 Control Chart C. dubia 2.21 1.83 to 2.98 102 of 117 Energy NW B5488.pdf Page 9 of 24
APPENDIX A RAW DATA SHEETS 103 of 117 Energy NW B5488.pdf Page 10 of 24
86
<0.10 475 104 of 117 Energy NW B5488.pdf Page 11 of 24
105 of 117 Energy NW B5488.pdf Page 12 of 24
106 of 117 Energy NW B5488.pdf Page 13 of 24
107 of 117 Energy NW B5488.pdf Page 14 of 24
CETIS Summary Report Report Date: 31 Oct-22 16:04 (p 1 of 1)
Test Code/ID: B548801cda / 06-5869-8977 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Batch ID: 08-5300-6934 Test Type: Survival (48h) Analyst: Michelle Bennett Start Date: 25 Oct-22 13:25 Protocol: EPA/821/R-02-012 (2002) Diluent: Mod-Hard Synthetic Water Ending Date: 27 Oct-22 12:21 Species: Ceriodaphnia dubia Brine:
Test Length: 47h Taxon: Branchiopoda Source: In-House Culture Age: <24 Sample ID: 18-1345-4859 Code: B5488-01 Project:
Sample Date: 24 Oct-22 09:40 Material: Industrial Effluent Source: Energy Northwest (WA 0025151)
Receipt Date: 25 Oct-22 10:30 CAS (PC): Station:
Sample Age: 28h (0.5 °C) Client:
Multiple Comparison Summary Analysis ID Endpoint Comparison Method NOEL LOEL TOEL PMSD TU S 15-2926-2410 48h Survival Rate Steel Many-One Rank Sum Test 100 >100 --- 8.34% 1 1 Point Estimate Summary Analysis ID Endpoint Point Estimate Method Level % 95% LCL 95% UCL TU S 04-1285-9764 48h Survival Rate Linear Interpolation (ICPIN) EC50 >100 --- --- <1 1 Test Acceptability TAC Limits Analysis ID Endpoint Attribute Test Stat Lower Upper Overlap Decision 04-1285-9764 48h Survival Rate Control Resp 0.95 0.9 >> Yes Passes Criteria 15-2926-2410 48h Survival Rate Control Resp 0.95 0.9 >> Yes Passes Criteria 48h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Min Max Std Err Std Dev CV% %Effect 0 D 4 0.9500 0.7909 1.1090 0.8000 1.0000 0.0500 0.1000 10.53% 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- -5.26%
11 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- -5.26%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- -5.26%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- -5.26%
100 4 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.0000 --- -5.26%
48h Survival Rate Detail MD5: 33690BFD37490A9C10D894817C0C6419 Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 1.0000 0.8000 1.0000 1.0000 6.25 1.0000 1.0000 1.0000 1.0000 11 1.0000 1.0000 1.0000 1.0000 25 1.0000 1.0000 1.0000 1.0000 50 1.0000 1.0000 1.0000 1.0000 100 1.0000 1.0000 1.0000 1.0000 48h Survival Rate Binomials Conc-% Code Rep 1 Rep 2 Rep 3 Rep 4 0 D 5/5 4/5 5/5 5/5 6.25 5/5 5/5 5/5 5/5 11 5/5 5/5 5/5 5/5 25 5/5 5/5 5/5 5/5 50 5/5 5/5 5/5 5/5 100 5/5 5/5 5/5 5/5 108 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
Energy NW B5488.pdf Page 15 of 24
CETIS Analytical Report Report Date: 31 Oct-22 16:04 (p 1 of 2)
Test Code/ID: B548801cda / 06-5869-8977 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 15-2926-2410 Endpoint: 48h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 31 Oct-22 16:03 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 31 Oct-22 16:02 MD5 Hash: 33690BFD37490A9C10D894817C0C6419 Editor ID: 000-042-882-4 Data Transform Alt Hyp NOEL LOEL TOEL TU MSDu PMSD Angular (Corrected) C>T 100 >100 --- 1 0.07927 8.34%
Steel Many-One Rank Sum Test Control vs Conc-% Test Stat Critical Ties DF P-Type P-Value Decision(:5%)
Dilution Water 6.25 20 10 1 6 CDF 0.9516 Non-Significant Effect 11 20 10 1 6 CDF 0.9516 Non-Significant Effect 25 20 10 1 6 CDF 0.9516 Non-Significant Effect 50 20 10 1 6 CDF 0.9516 Non-Significant Effect 100 20 10 1 6 CDF 0.9516 Non-Significant Effect ANOVA Table Source Sum Squares Mean Square DF F Stat P-Value Decision(:5%)
Between 0.0118141 0.0023628 5 1 0.4457 Non-Significant Effect Error 0.0425309 0.0023628 18 Total 0.0543451 23 ANOVA Assumptions Tests Attribute Test Test Stat Critical P-Value Decision(:1%)
Variance Bartlett Equality of Variance Test Indeterminate Distribution Shapiro-Wilk W Normality Test 0.4634 0.884 <1.0E-05 Non-Normal Distribution 48h Survival Rate Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 0.9500 0.7909 1.0000 1.0000 0.8000 1.0000 0.0500 10.53% 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% -5.26%
11 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% -5.26%
25 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% -5.26%
50 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% -5.26%
100 4 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 0.0000 0.00% -5.26%
Angular (Corrected) Transformed Summary Conc-% Code Count Mean 95% LCL 95% UCL Median Min Max Std Err CV% %Effect 0 D 4 1.2860 1.0960 1.4750 1.3450 1.1070 1.3450 0.0595 9.26% 0.00%
6.25 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% -4.63%
11 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% -4.63%
25 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% -4.63%
50 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% -4.63%
100 4 1.3450 1.3450 1.3460 1.3450 1.3450 1.3450 0.0000 0.00% -4.63%
109 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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CETIS Analytical Report Report Date: 31 Oct-22 16:04 (p 2 of 2)
Test Code/ID: B548801cda / 06-5869-8977 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 15-2926-2410 Endpoint: 48h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 31 Oct-22 16:03 Analysis: Nonparametric-Control vs Treatments Status Level: 1 Edit Date: 31 Oct-22 16:02 MD5 Hash: 33690BFD37490A9C10D894817C0C6419 Editor ID: 000-042-882-4 Graphics 1.0 0.10 0.9 0.05 0.8 48h Survival Rate 0.7 0.00 Centered 0.6 Corr. Angle 0.5 -0.05 0.4
-0.10 0.3 0.2
-0.15 0.1 0.0 -0.20 0D 6.25 11 25 50 100 -2.0 -1.5 -1.0 -0.5 0.0 0.5 1.0 1.5 2.0 Conc-% Rankits 110 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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CETIS Analytical Report Report Date: 31 Oct-22 16:04 (p 1 of 1)
Test Code/ID: B548801cda / 06-5869-8977 Ceriodaphnia 48-h Acute Survival Test Eurofins TestAmerica - Corvallis Analysis ID: 04-1285-9764 Endpoint: 48h Survival Rate CETIS Version: CETISv1.9.7 Analyzed: 31 Oct-22 16:03 Analysis: Linear Interpolation (ICPIN) Status Level: 1 Edit Date: 31 Oct-22 16:02 MD5 Hash: 33690BFD37490A9C10D894817C0C6419 Editor ID: 000-042-882-4 Linear Interpolation Options X Transform Y Transform Seed Resamples Exp 95% CL Method Log(X+1) Linear 81524 200 Yes Two-Point Interpolation Point Estimates Level % 95% LCL 95% UCL TU 95% LCL 95% UCL EC50 >100 --- --- <1 --- ---
48h Survival Rate Summary Calculated Variate(A/B) Isotonic Variate Conc-% Code Count Mean Median Min Max CV% %Effect A/B Mean %Effect 0 D 4 0.9500 1.0000 0.8000 1.0000 10.53% 0.00% 19/20 0.9917 0.00%
6.25 4 1.0000 1.0000 1.0000 1.0000 0.00% -5.26% 20/20 0.9917 0.00%
11 4 1.0000 1.0000 1.0000 1.0000 0.00% -5.26% 20/20 0.9917 0.00%
25 4 1.0000 1.0000 1.0000 1.0000 0.00% -5.26% 20/20 0.9917 0.00%
50 4 1.0000 1.0000 1.0000 1.0000 0.00% -5.26% 20/20 0.9917 0.00%
100 4 1.0000 1.0000 1.0000 1.0000 0.00% -5.26% 20/20 0.9917 0.00%
Graphics 1.0 0.9 0.8 0.7 48h Survival Rate 0.6 0.5 0.4 0.3 0.2 0.1 0.0 0 20 40 60 80 100 Conc-%
111 of 117 000-042-882-4 CETIS' v1.9.7.9 Analyst:________ QA:________
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APPENDIX B REFERENCE TOXICANT DATA SHEETS 112 of 117 Energy NW B5488.pdf Page 19 of 24
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APPENDIX C CHAIN OF CUSTODY 115 of 117 Energy NW B5488.pdf Page 22 of 24
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