Notes from Follow-Up Correspondence with FirstEnergy Regarding Data Submittal

This summary documents EPA’s follow-up correspondence with FirstEnergy regarding the data that 

FirstEnergy submitted to EPA on February 20, 2014 (DCN SE04679) in response to EPA’s January 17, 

2014 data request to FirstEnergy (DCN SE04660). 

On March 5, 2014, EPA provided FirstEnergy with a list of five questions related to the Hatfield’s Ferry 

data that had been submitted. FirstEnergy provided responses to those questions on March 10, 2014. 

The following is a list of FirstEnergy’s correspondence with EPA (with associated DCNs):

 Email to Phillip Flanders (DCN SE04316A2); and

 FirstEnergy responses to EPA questions (DCN SE04316A3). 

On March 25, 2014, EPA provided FirstEnergy with a list of three additional questions related to the 

Hatfield’s Ferry data (DCN SE04316A4). FirstEnergy provided responses to these questions on March 26, 

2014. The email from FirstEnergy to EPA with responses to the questions is included in the record as 

DCN SE04316A5.

EPA and ERG participated in a call with FirstEnergy on April 10, 2014 to discuss additional EPA questions 

on the Hatfield’s Ferry data and information FirstEnergy provided in follow-up responses. 

The following people participated in the call:

EPA Personnel FirstEnergy Personnel ERG Personnel

Ron Jordan Joe Lapcevic TJ Finseth

Phillip Flanders Bill Cannon

Cuc Schroeder

The following questions were discussed during the call, with FirstEnergy’s responses described after 

each question. The questions were not provided to FirstEnergy prior to the call.

1. Why is there an approximately 1 year gap in the data between 11/29/2011 and 11/6/2012? Did 

FirstEnergy's Beta Lab begin analyzing samples on 11/6/2011, 12/1/2011, or 11/6/2012?

FirstEnergy Response: FirstEnergy stated that there should be data for that time period. FirstEnergy 

stated that November 29, 2011 is the last of samples that were analyzed by the Allegheny Lab, and that 

there should be data from FirstEnergy’s Beta Lab starting shortly after that time period. FirstEnergy 

stated that the data must have been transferred to the spreadsheet incorrectly. 

Action Item: FirstEnergy stated that they would pull the data and provide it to EPA.

2. Is the change in MDL for arsenic meant to be after 11/6/2012 when the reporting begins again? 
FirstEnergy Response: FirstEnergy stated that the change in MDL is related to the change in the 

laboratories. Therefore, the change in MDL occurs after the last Allegheny laboratory arsenic result 

from November 29, 2011. FirstEnergy stated that arsenic MDL may change a couple times because the 

FirstEnergy Beta lab started analyzing samples using 200.8. However, FirstEnergy was uncertain 

whether there are any 200.8 results from the FirstEnergy Beta lab that are provided in the output.

Action Item: FirstEnergy will determine when the FirstEnergy Beta lab started using 200.8 and will let 

EPA know if any of the arsenic results are from 200.8 analysis and, if so, what the associated MDL and RL 

for those samples. 

3. Is the MDL that is mentioned for arsenic for the Allegheny Chemical Lab the same as the lab's 

reporting limit? If so, we would treat data points reported as "0" as "ND 2ppb" non-detect with a 

quantitation limit of 2 ppb (for example).

FirstEnergy Response: FirstEnergy stated that they reported everything to the MDL, so they don’t think 

the Allegheny lab ever generated a quantitation limit for its 200.7 arsenic analyses. FirstEnergy stated 

that because they don’t have a quantitation limit, they can’t speak to whether the values close to the 

MDL are truly present at the values reported or whether they are estimated values.

4. Please confirm the following table of what we believe the MDL, RL, and laboratory are for each 

column of data. There are two RLs that we are missing.

Column Letter (Analyte) MDL RL Lab Name

D (Arsenic - Before 11/30/2011) 0.002 mg/L Allegheny’s Chemical Lab

D (Arsenic - After 12/1/2011) 0.006 mg/L 0.03 mg/L FirstEnergy’s Beta Lab

E (Trace mercury) 0.010 ug/L 0.03 ug/L Geochemical Labs

F (Mercury – EPA Method 245.7) 0.010 ug/L 0.03 ug/L Geochemical Labs

H (Mercury – EPA Method 245.1) 0.00006 mg/L 0.0002 mg/L FirstEnergy’s Beta Lab

I (Arsenic – EPA Method 200.8) 0.000035 mg/L

FirstEnergy Response: As described in response to Question 3, FirstEnergy does not believe that the 

Allegheny lab generated a quantitation limit for the 200.7 arsenic analyses. For Column I, which is 200.8 

TestAmerica arsenic analyses, FirstEnergy stated that they would have to check with TestAmerica.

Action Item: FirstEnergy will check the TestAmerica laboratory reports to determine whether the 35 ppt 

MDL is correct and also find the associated quantitation limit.
5. Did the laboratory used for mercury analyses change (as was done for arsenic) or did Geochemical 

Lab do all mercury analyses?

FirstEnergy Response: FirstEnergy stated that Geochemical Labs was always used for the mercury 

analyses.

6. Please confirm the startup/commissioning date for the treatment system at Hatfield’s Ferry --

According to our site visit notes, “In June 2009, Hatfield’s Ferry began sending wastewater to the 

FGD wastewater treatment system. The wastewater treatment system first discharged on June 30, 

2009.” Please note however, that the FGD did not start up all at once. According to the Hatfield’s 

Ferry SER, “The Unit 1 FGD system was installed in June 2009, and the Unit 2 and Unit 3 FGD systems 

were both installed in October 2009.”

FirstEnergy Response: FirstEnergy stated that information is correct, but they do not know what the 

estimated commissioning time was for the treatment system, in terms of when the operators seemed to 

have the system under control and operating properly. FirstEnergy stated that they did have issues for 

some time related to plugging in the sand filters and building the floc in the clarifiers when both 

clarifiers were operating. FirstEnergy noted that while they were having some of these issues, it didn’t 

seem to show up in the effluent results. FirstEnergy also noted that the plant ultimately altered the 

operation of the treatment system to only operate one of the two clarifiers at a time, which helped build 

the floc and resulted in better settling.

Action Item: FirstEnergy will talk with one of the engineers that worked with the system to get an 

estimate of when the system started operating properly. Additionally, FirstEnergy will check when the 

performance testing was conducted by Siemens, which should identify when Siemens was comfortable 

that the system was operating properly. 

7. We notice that all data is more variable after 11/6/12. This is particularly striking for arsenic, but 

also apparent for mercury. What do you believe to be the cause for this? For example, there is a

significant change in the concentrations and numbers of nondetects for arsenic reported after 

11/6/2012. The data provided from before 11/29/2011 seems to contain no nondetects and is 

consistently below 0.022 ppm. We also noticed this happens to correspond to the change in 

laboratories. Was there some other change in plant operations going on between 11/6/2012 and 

decommissioning that might explain the pattern in the data?

FirstEnergy Response: FirstEnergy stated that they do not have any explanation for the increase in 

arsenic concentrations corresponding to the change in laboratories. They do not know if there were 

specific changes in the plant operations that would have cause the increase or if it simply because a 

different laboratory is analyzing the samples.
8. For mercury, there are several other observations that are unusual. What would be the reason for 

the following occurrences:

 Before 11/6/12

o 3 observations substantially above 1,000 ppt (1/5/10, 1/12/10, 1/19/10). These 

observations are order of magnitude higher than the preceding and following 

weeks.

o 1 observation at 752 ppt (3/29/11). The preceding week is at 488 ppt, but all 

other preceding and following weeks are hundreds of ppt lower.

o Observations at 519 & 488 ppt

 After 11/6/12

o 4 results above 1,000 ppt

o 1 result at 909 ppt

FirstEnergy Response: FirstEnergy stated that they do not know what is causing the large spikes in the 

mercury concentrations. Because the results are not three orders of magnitude off, it doesn’t seem to 

be a units issue; however, FirstEnergy stated that it could be a data entry error (i.e., someone converted 

the units and tied in the wrong number. 

Action Item: FirstEnergy will look at the laboratory reports to confirm that the data were entered 

correctly. FirstEnergy will also pull the data they have for additional analytes to determine if they tend 

to see increases in other pollutants at the times when there are increases in the mercury 

concentrations. FirstEnergy stated that they would provide these additional data to EPA.

On May 2, 2014, FirstEnergy sent an email to Phillip Flanders with responses to the follow-up action 

items from the call on April 10, 2014. The following is a list of FirstEnergy’s correspondence with EPA 

(with associated DCNs):

 Email to Phillip Flanders, including responses to action items (DCN SE04316A6);

 Hatfield’s Ferry Outfall 306 arsenic and mercury data from June 2009 through December 2013 

(DCN SE04316A7);

 Hatfield’s Ferry Outfall 306 data for multiple pollutants from July 2009 through November 2011 

(DCN SE04316A8); and

 Hatfield’s Ferry Outfall 306 DMR for June 2009 (DCN SE04316A9).

On May 13, 2014, FirstEnergy sent another email to Phillip Flanders with an additional spreadsheet of 

analytical data from Hatfield’s Ferry Outfall 306. The following is a description of the information 

provided, as well as the associated DCNs for the information:

 Email to Phillip Flanders (DCN SE04316A10); and

 Hatfield’s Ferry Outfall 306 data for multiple pollutants from December 2011 through April 2014 

(DCN SE04316A11).

On May 29, 2014, Ron Jordan sent an email to FirstEnergy (DCN SE04316A12) to try and set up a call to 

discuss three additional questions regarding the additional data that FirstEnergy provided in the May 2 
and May 13 deliveries. FirstEnergy responded to the email on June 2, 2014 with responses to a few of 

the questions prior to the follow-up call (DCN SE04316A13). EPA, ERG, and Westat participated in a call 

with FirstEnergy on June 2, 2014 to discuss EPA’s remaining questions from the May 29, 2014 follow-up. 

The following people participated in the call:

EPA Personnel FirstEnergy Personnel ERG Personnel Westat Personnel

Ron Jordan Joe Lapcevic TJ Finseth Yan Zhuang

Phillip Flanders Dan-Tam Nguyen

Cuc Schroeder

The following questions were discussed during the call, with FirstEnergy’s responses described after 

each question. 

1. Comparing the data you provided on 5/2/2014 and 5/13/2014, we observed apparent data entry 

errors. Please specify which values for mercury Chem Precip Effluent are correct.

Date

5/2/2014 dataset

(Hg, ng/L)

5/13/2014 dataset

(Hg, ng/L)

12/20/2011 122 12.2

1/3/2012 424 42.4

2/2/2012 144 14.4

2/21/2012 170 17

FirstEnergy Response: FirstEnergy reviewed the original raw data download and determined that the 

values from the 5/13/2014 spreadsheet are correct (i.e., 12.2, 42.4, 14.4, and 17 ng/L). FirstEnergy 

noted that the original download file had data in both ng/L and ug/L and they assume there was an error 

with the conversion for the first data set.

EPA then asked whether FirstEnergy had checked all the data or whether they had checked just the four 

data points identified in the table above. How confident is FirstEnergy that there aren’t other errors in 

the datasets?

Action Item: FirstEnergy stated that they would check the mercury data for all the associated dates to 

confirm there are no other transcription errors.

2. What is the cause for elevated mercury concentrations for Chem Precip Effluent on the following 

dates?

a. 2/28/2012 (1,520 ng/L)

b. 3/13/2012 (1,160 ng/L)

c. 3/20/2012 (1,710 ng/L)

d. 3/27/2012 (1,320 ng/L)
e. 4/3/2012 (3,400 ng/L)

f. 6/5/2012 (830 ng/L)

FirstEnergy Response: FirstEnergy stated that they checked the data and did not find any transcription 

errors; therefore, they believe the values are correct. FirstEnergy noted that they occasionally had issues 

with the sand filters, but they didn’t see any correlation between the elevated mercury results and 

increased TSS in these samples. FirstEnergy also noted that the wastewater treatment operators were 

changing frequently during those time periods because of training, and that could have led to multiple 

operators making various changes that may have impacted the performance of the system. However, 

FirstEnergy noted that the arsenic concentrations were not elevated during this time period. Therefore, 

FirstEnergy stated that they don’t have a good explanation for the increased mercury concentrations 

that occurred during this time period.

3. We noticed dates for Method 245.1 (mercury) data and Method 200.8 (arsenic) data changed 

between your original spreadsheet provided 2/20/2014 and the updated spreadsheets provided 

5/2/2014 and 5/13/2014. Specifically, the 2/20/2014 spreadsheet shows the 245.1 and 200.8 data 

on 12/18/12, 1/4/13, and 1/8/13; the 5/2/2014 spreadsheet shows these data on 11/29/12, 

12/19/12, and 12/21/12. Which dates are correct?

FirstEnergy Response: FirstEnergy noted that the correct dates are 11/29/2012; 12/19/2012; and 

12/21/2012. 

4. What are the target parameters (analytes & concentrations) for the FGD wastewater treatment 

effluent? 

FirstEnergy Response: FirstEnergy stated that the plant did not have any specific targets for metals. 

FirstEnergy noted that the limits in the plant’s NPDES permit were set based on the design report that 

was prepared by Siemens. The estimated effluent concentrations included in the design report were 

based on a certain coal quality. FirstEnergy stated that the FGD wastewater treatment system was 

operated based on maintaining the pH, floc in the clarifier, and TSS out of the sand filter.

5. How would the plant operators have responded to the high effluent mercury results noted in 

Question 2?

FirstEnergy Response: FirstEnergy stated that because the analytical results are not available in real 

time, it is unlikely that the operators made any changes to the system after getting those mercury 

results. 
6. What is represented by the “0” (zero) results in the data spreadsheets. For example, the mercury 

result for 11/24/2009 is reported as 0.

FirstEnergy Response: FirstEnergy noted that the 0 (zero) results were entered into the spreadsheet 

when the result was less than the MDL. Per West Virginia regulations, FirstEnergy was required to 

report values down to the MDL. The MDL for the Geochemical Labs mercury results using 245.7 was 10 

ng/L and the RL was 30 ng/L. FirstEnergy noted that some of the results in the spreadsheet are likely Jvalues (i.e., results between the MDL and the RL). For example, the mercury result on 11/17/2009 of 

24.1 ng/L should be considered a J-value.

7. EPA noted a couple discrepancies between some mercury results provided by FirstEnergy and 

results provided in UWAG’s comments. The following table identifies the discrepancies.

Date

FirstEnergy Mercury Result

(ng/L)

UWAG Mercury Results

(ng/L)

5/25/2010 4.38 <10

6/1/2010 7.95 <10

FirstEnergy Response: FirstEnergy noted that the results included in the FirstEnergy spreadsheet are less 

than the laboratory MDL. When inputting the results into its LIMS system, FirstEnergy would simply 

enter whatever value was provided by the laboratory and be confident that the system would convert 

any values below the MDL into “<10” when reporting to the state. When FirstEnergy pulled the data, 

they pulled the values that were entered into the system, not what was reported to the state. UWAG 

probably noticed that these results were below the MDL and reported it as such.

8. What is the procedure (i.e. total recoverable metals or dissolved metals) for all of the analytes 

provided in the “Hatfield 306Data 11-29-2011_to_04-28-2014jpl.xlsx” and “HatfieldIMP306Data7-1-

2009to11-30-2011RawEdited.xlsx” spreadsheets?

FirstEnergy Response: FirstEnergy stated that all analytical results are total recoverable metals except 

where explicitly noted that it is dissolved. FirstEnergy noted that “FeD” and “NiD” represent dissolved 

iron and dissolved nickel, respectively. FirstEnergy doesn’t think there is any other dissolved metals 

data in the spreadsheet.

9. What are the MDLs and RLs for all analytes (except arsenic and mercury) provided in the “Hatfield 

306Data 11-29-2011_to_04-28-2014jpl.xlsx” and “HatfieldIMP306Data7-1-2009to11-30-

2011RawEdited.xlsx” spreadsheets?
FirstEnergy Response: FirstEnergy stated that they will provide EPA with the MDL and RLs for each 

analyte included in those spreadsheets.

Action Item: FirstEnergy stated that they would check the mercury data for all the associated dates to 

confirm there are no other transcription errors.

On June 11, 2014, EPA sent a follow-up email to FirstEnergy requesting responses to the action items 

from the June 2, 2014 call (DCN SE04316A14). FirstEnergy sent a response to one of the action items 

later that day on June 11, 2014 related to the MDLs and RLs for the other analytes. The following is a list 

of FirstEnergy’s correspondence with EPA (with associated DCNs):

 Email to Ron Jordan (DCN SE04316A15); and

 MDLs and RLs for Hatfield’s Ferry Outfall 306 data for multiple pollutants from December 2011 

through April 2014 (DCN SE04316A16).

On June 16, 2014, FirstEnergy sent a response to the final action item from the June 2, 2014 call related 

to the comparison of analytical mercury results and potential transcription errors. The following is a 

description of the information provided, as well as the associated DCNs for the information:

 Email to Ron Jordan (DCN SE04316A17); and

 Mercury data comparison (DCN SE04316A18).