Attachment 1

Monfalcone FGD Wastewater Treatment Process Flow DiagramsAttachment 2

Monfalcone Sampling InstructionsInstructions for Sample Collection, Packaging, and Ship ment
A2A Monfalcone Plant

This document provides instructions for collecting, packaging, and shipping samples from the A2A Monfalcone power plant to lab oratories in the United States for analysis. If you have any questions regarding these instructions, please contact TJ Finseth at (703)

633

- 1698 (office), (703) 969

- 3316 (cell), or thomas.finseth@erg.com.

Equipment Needed

Most of the supplies needed for the sampling were provided in the three coolers that were shipped to the plant; however, the following are additional items that will be needed :

**•** Sulfuric acid ;

**•** Garbage bags (at least six bags) ; and

**•** Ice.

Sampling Points

As we discussed during the sit e visit, there are three sampling points from which we need you to collect samples.

**•** FGD Influent (SP

- 1) : This sample should be collected from the sample tap that is

located on the feed line to the first reaction tank

.

**•** Distillate from B rine C oncentrator ( SP

- 2 ) : This sampl e should be collected from the sample tap of the distillate generated from the brine concentrator that is transferred to the plate heater.

**•** Condensate from Crystallizer (SP

- 3 ) : This sampl e should be collected from the sample tap of the condensate from the crystallizer. From the site visit, it was determined that the condensate would represent both the condensate from the air cooler as well as the condensate from the forced circulation heat exchanger.

Sample Bottles and Preservatio n

The t able below identifies the sample bottles that are needed for collect ing samples at each of the sampling points . The table also identifies the on

- site preservation that is required for the samples. As you can see from the table, there are seven bo ttles that need to be filled at each of the sampling points. Additionally, each of the two Group II sample bottles will need to be preserved with sulfuric acid to a pH of 2. Within the supplies sent to the plant, there are pH strips and pipettes that can be used to transfer the sulfuric acid into the sample bottles and test the pH of the samples. Finally, the Group I and Group II sample bottles will need to be placed on ice and cooled to <6 **°** C prior to shipping the samples to the laboratory.The total me tals and total mercury sample bottles have been specially

- cleaned and

double

- bagged in a clean laboratory to help prevent contamination. The outer bag is considered “dirty,” while the inner bag and the sample bottle are considered “clean.” The Group I an d Group II sample bottles have not been specially

- cleaned because there are fewer contamination concerns with these samples.

Table 2. Summary of Sample Container and Planned Preservation

Parameter Sample Container

and Volume On

- Site Preservation

Group I One 1

- L HDPE

bottle a ≤6 **°** C

Group II Two 1

- L HDPE

bottle s b H 2 SO 4

T otal metals (EPA Method 200.8 with collision cell) to pH <2, ≤6 **°** C

One 5 0 0

- mL HDPE

bottle None (acid preserve at laboratory)

T otal metals (EPA Method 200.7) One 5 0 0

- mL HDPE

bottle None (acid preserve at laborat ory)

T otal mercury Two 250

- mL glass

bottles None (acid preserve at laboratory)

(a) Group I includes TSS, TDS, sulfate, and chloride. (b) Group II includes ammonia as nitrogen, COD, nitrate/nitrite as nitrogen, TKN, and total phospho rus. NOTE: The number of sample bottles refers to the number of sample bottles needed for each sampling point

.

Sample Labeling

The 1

- L plastic bottles that are used for the Group I and Group II sample bottles are already pre

- labeled and are ready for sa mple collection. The total metals and total mercury sample bottles are not pre

- labeled. Therefore, you will need to label these sample bottles. The attached file titled, “Monfalcone_Sampling_Labels.PDF” contains the sample labels needed for all three sa mpling points. For the total metals and total mercury sample bottles, you will need to print the labels (preferable onto white shipping labels with adhesive backing) and put the label onto the outer bag of the sample bottle. If regular paper is used, ple ase tape the label to the outer bag. Each of the total metals and total mercury sample bottles has an inner and outer bag, the label can be attached to the outer bag of the sample bottle. To ensure that the sample label does not become separated from the bottle, the double

- bagged sample bottle should be placed in an additional storage bag (provided in the orange box included in the shipment to the plant).

Sample Collection

For the collection of the samples at each sampling point, you will need two sam pling personnel, a “clean hands” sampler and a “dirty hands” sampler. The “dirty hands” sampler will get all the supplies ready, open and close the sample tap valve, and hand the

bottles to the “clean hands” sampler. The “dirty hands” sampler should only handle the outer bag of the bottles and should NOT touch the inner bag or the bottle itself. The“clean hands” sampler does not touch anything other than the inner bag and the sample bottle and fills the sample bottle.

The following steps should be use d for the sample collection at each of the three sampling points.

Grab Sample Colle c tion

1. Arrive at the sampling point location and organize supplies and bottles for the sample collection.

2. “ Clean hands ” and “ dirty hands ” put on Tyvek® suits, masks, and powder

free gloves.

3. “ Dirty hands ” opens the valve to the sample tap and purges the tap for at
least two minutes . Note: the tap should be kept flowing until all samples are collected; therefore, a bucket can be placed under the tap, if desired.

4. “ Dirty hand s ” opens the outer bag for the total mercury sample bottle and pulls the outer bag down slightly

. “ Clean hands ” pulls the sample bottle and inner bag out of the outer bag

. “ Clean hands ” opens the inner bag and pulls it down slightly , opens the lid of the sample bottle and fills the total mercury sample bottle. “ Clean hands ” caps the sample bottle as quickly as possible and then closes the inner bag

. 5. “Dirty hands” holds the outer bag open so “clean hands” can place the sample bottle and inner bag into the outer bag. “ Dirty hands ” closes the outer bag.

6. The samplers repeat this procedure for the collection of the total metals samples (both EPA 200.8 with collision cell and EPA 200.7).

7. The samplers then collect the Group I and Group II samples by filling t he the bottles directly from the tap. NOTE: the “clean hands/dirty hands” sampling techniques do not need to be following for the collection of the Group I and Group II samples

. 8. The samplers then preserve the Group II samples using sulfuric acid to bring the pH to 2 S.U.

9. The samplers then place the Group I and Group II samples on ice to cool

them to <6 **°** C

.

Sample Packing and Shipment

The following steps should be used when packing and shipping the samples to the

laboratories.

1. Make sure that each sample bottle has a label, and that the label correctly specifies the sample point.

2. Tighten the lid on each filled sample bottle, being careful not to overtighten the lid. NOTE: the total mercury and total metals samples

should not be removed from the inner/out er bags when checking the lids.

3. Prior to packaging, p lace each sample bottle requiring ≤6 ° C preservation (Group I and Group II samples) into an ice chest with wet ice to cool.4. When each sample requiring ≤6 ° C preservation has reached the desired

temperatu re, wipe the sample bottle dry with paper towels (or rag) and place in a plastic storage bag.

5. W rap each glass

6. Place each total metals plastic sample bottle in a plastic storage bag. sample bottle (mercury samples) with two layers of “bubble wrap”. The bubble wrap must fit snugly and completely cover the sample bottle. Enclose e ach “bubble

- wrapped” mercury sample in a plastic storage bag. Note: do not remove the inner and outer bags prior to bubble wrapping the samples.

7. Place two garbage bags inside each oth er in each of the coolers used to ship samples to the laboratories (the large cooler will be used for Group I and Group II sample shipment and one small cooler will be used for the mercury sample shipment and the other small cooler will be used for the

met als sample shipment)

. 8. Place the Group I and Group II samples in the garbage bags in the coolers with proper end up, close the interior garbage bag by tying.

9. Prepare ice bags by scooping ice into a Ziploc freezer bag and then placing the ice bag into a sec ond Ziploc freezer bag. Approximately 12 bags of ice (half full) will be needed for the shipment.

10. Add the ice bags to the cooler (between the interior and exterior garbage bags) to keep samples cold during shipment. Arrange sealed plastic freezer bags fi lled with wet ice on the sides and on top of the sample bottles. Place

t he ice inside the second garbage bag. Place as much ice as possible in the cooler to ensure the samples stay cold.

11. Close the second garbage bag by tying.

12. Place the metals samples in t he garbage bags in a different cooler with proper end up, close the interior garbage bag by tying. Close the second garbage bag by tying. NOTE: the metals samples are not required to be

cooled.

13. Fill in any free space around the bottles in the metal s cool er with additional cushioning material. Sufficient packing material should be used so that the sample containers will not shift during shipment.

14. Finish f ill ing out and print a traffic report form for the classicals and metals samples (provided electronica lly by ERG). Seal the last two pag es of the traffic report forms in a plastic envelope secured to the inside of the top of the cooler. NOTE: the top page of the traffic report must be sent to ERG at the following address:

Eastern Research Group

14555 Avion Parkway, Suite 200 Chantilly, VA 20151

Attn: TJ Finseth (703) 633

- 1698

15. Close the cooler(s).16. Place a completed laboratory address label on the lid of the cooler(s). The classicals and metals samples should be shipped to TestAmerica as

follows:

TestAmerica

4955 Yarrow Street Arvada, CO 80002 Attn: Elizabeth Eichelberger (303) 736

- 0138

17. Make several wraps with strapping tape around the cooler perpendicular to the seal to ensure that the lid will remain closed if the latch is accidentally

relea sed or damaged.

18. Place the mercury samples in the garbage bags in a separate cooler with proper end up, close the interior garbage bag by tying,.

19. Do not add ice to the mercury cooler; simply close the second garbage bag by tying.

20. Fill in any free space ar ound the bottles with additional cushioning material. Sufficient packing material should be used so that the sample containers will not shift during shipment.

21. Fill out and print a traffic report form for the mercury samples (provided electronically by ER G). Seal the last two pages of the traffic report form in a plastic envelope secured to the inside of the top of the cooler. NOTE: the top page of the traffic report must be sent to ERG at the same address provided in step 14.

22. Close the cooler.

23. Place a c ompleted laboratory address label on the lid of the cooler. The mercury samples should be shipped to Frontier as follows:

Frontier GeoSciences

414 Pontius Ave. North Seattle, WA 98109

Attn: Patrick Garcia

- Strickland (206) 957

- 1428

24. Make several wrap s with strapping tape around the cooler perpendicular to the seal to ensure that the lid will remain closed if the latch is accidentally released or damaged.

25. For each of the three coolers, attach a FedEx cooler tag (large white tag) to

the handle of the co olers. Then place a FedEx international pouch on the cooler tag by removing the adhesive backing and placing on the tag.

26. Print out the necessary paperwork for FedEx to prepare the shipment for pick up or drop off. ERG will prepare the three FedEx shipmen ts on

- line using our account number. After the shipments are prepared, labels will

be converted to PDF and will be e

- mailed to Javier for printing. You will need to print four copies of the labels that are provided. F old themtogether, with the bar code facing outward, and place them in the International pouch.

27. Update and print the invoices needed for the shipment to the laboratories (provided electronically by ERG). You will need to print four copies of the invoices and sign and date each copy (or prin t one, sign and date and make three additional copies). Fold the invoices together and place them in the International pouch.

28. After the coolers have been dropped off (or picked up), please contact TJ Finseth at (703) 633

- 1698, to notify him that the sampl es have been shipped to the laboratories.

Traffic Reports

ERG is providing electronic copies of the traffic reports (e.g., chain of custody forms) needed for the Monfalcone shipments . The samplers will need to update s ome information, such as the date and sample collection times and the FedEx airbill number,

which must be entered after the sample collection and therefore, will not be included in

the forms provided by ERG.

After the traffic report is completed, you must print the four pages in the file . The last two pages in the file must be placed in the cooler for shipment to the laboratories and the first page must be sent to ERG. You can keep the second page of the traffic report.

FedEx Paperwork

ERG will prepare the paperwork for the FedEx shipp ing and will email the in formation to Javier on Thursday morning. You will need to print four copies of the FedEx labels, each on different sheets of paper, and place them into the FedEx International shipping pouch with the barcode facing outward so it can be scanned by FedEx.

Invoices

ERG is providing electronic copies of the invoices that will be associated with each of the three shipments. The samplers will need to update some information, such as FedEx airbill number, prior to printing the forms. Additionally, you will ne ed to provide the Tax Payer ID Number for HPD on the invoice form to prevent customs delays

. You will need to print four copies of the Invoices and sign and date each copy. The invoices can then be folded together and put in the FedEx International shipp ing pouch along with the

FedEx labels.