# Power Plant Monitoring Data Collected Under Clean Water Act Section 308 Authority (“CWA 308 Monitoring Data”) Sampling Episodes 6565 - 6575

Prepared for:



## U.S. Environmental Protection Agency
Engineering and Analysis Division Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared by:



### Eastern Research Group, Inc. 14555 Avion Parkway Suite 200 Chantilly, VA 20151

27 March 2012

EPA Contract No. 68-C-02-095 Work Assignment 9-291 As part of EPA’s sampling program for the steam electric effluent guidelines rulemaking, EPA required eleven steam electric power plants to collect wastewater samples for use in determining the pollutant characteristics of the wastewaters and the performance of the associated wastewater treatment systems. The wa stewater samples were sent to EPA-contracted laboratories for analysis. This report describes th e samples collected and the laboratory analyses performed, and presents the analytical results for the wastewater samples.

The plants selected for this samp ling program included the following:

 Samples of FGD wastewater from the seven plants that were included in EPA’s onsite field sampling program:

o Appendix A: Duke Energy Carolina’s Belews Creek Steam Station,

o Appendix B: We Energies’ Plea sant Prairie Power Plant,

o Appendix C: Duke Energy’s Miami Fort Station,

o Appendix D: Duke Energy Carolina’s Allen Steam Station,

o Appendix E: Mirant Mid-Atlantic, LL C’s Dickerson Generating Station,

o Appendix F: RRI Energy’s Keys tone Generating Station,

o Appendix G: Allegheny Energy’s Ha tfield’s Ferry Power Station,

 Samples from four plants not included in EPA’s onsite field sampling program:

o Appendix H: Kansas City Power & Light’s Iatan Station (unt reated and treated wastewater from a FGD vapor-com pression evaporation system),

o Appendix I: Tampa Electric Company’s Polk Station (wastewater from the gasification process),

o Appendix J: Wabash Valley Power A ssociation’s Wabash River Station (wastewater from the gasification process), and

o Appendix K: Appalachian Power Compa ny’s Mountaineer Plant (wastewater from a pilot-scale carbon capture system).

The seven plants included in EPA’s onsite sa mpling program were required to collect four sets of samples over a four or five mont h period, with no samples collected within four weeks of each other. The samples were to be collected from the same sample location as the samples collected by EPA during the onsite field sampling program, unless an alternative sample location was approved by EPA. The four additio nal plants included in this CWA 308 monitoring program were required to collect four consecutive days of samples, similar to the approach used during EPA’s onsite sampling program. For each of these four additional plants, EPA specified the location where samples were to be coll ected, based on system knowledge acquired during site visits to the plants or disc ussions with plant technical staff. Each of the appendices include a process flow diagram depicting th e wastewater sampling locations.

The analytes included in the CWA 308 monitoring program were identical to the EPA onsite sampling program, except that dissolved metals, dissolved mercury, and dissolved hexavalent chromium were not sampled/analyzed. Table 1 presents the analytes included in the CWA 308 monitoring program and th e analytical method used for each analyte. The samples2 were collected using clean sampling techni ques (i.e., EPA Method 1669) to limit potential contamination from the sampling activities.

Table 1. Analytical Methods

Parameter Method Number
Classicals Biochemical oxygen demand (BOD 5 ) SM 5210 B Chemical oxygen demand (COD) EPA 410.4 Total suspended solids (TSS) SM 2540 D Total dissolved solids (TDS) SM 2540 C

Sulfate EPA 300.0

Chloride EPA 300.0 Ammonia as nitrogen EPA 350.1

Nitrate/nitrate as nitrogen EPA 353.2 Total Kjeldahl nitrogen (TKN) EPA 351.2 Total phosphorus EPA 365.1 Total cyanide SM 4500 CN E

Total Metals Mercury EPA 1631E Antimony, arsenic, cadmium, chromium, copper, lead, manganese, nickel, selenium, silver, thallium, and vanadium EPA 200.8 with collision cell

Aluminum, barium, beryllium, boron, calcium, cobalt, iron, magnesium, molybdenum, sodium, tin, titanium, and zinc EPA 200.7

A letter describing the requirements of the CWA 308 monitoring program and instructions for the sample collection activities were sent to each of the 11 plants in July or August, 2010. Each letter specified dates for wh ich the samples should be collected; however, many of the specific dates were revised after the letters were distributed to provide the plants with enough time to prepare for th e sampling and also to adjust for outages and other operational concerns to ensure that the samples collected were representative of normal operations. The letter distributed to each plant is incl uded in Section 1 for each of the appendices.

For each of the 11 plants, except Dickerson and Mountaineer, EPA or its contractor, ERG, conducted an on-site audit of one set of th e sample collection activi ties to confirm that the samples were collected following the instructi ons provided by EPA. A memorandum describing the findings/observations from the on-site audits is included in Section 2 for each of the appendices.

In addition to collecting and shipping the sa mples to EPA-contracted laboratories, the plants were also required to provide engineering da ta regarding the plan ts operation (e.g., power generation, wastewater flow rates, unit configur ations) during the sampling period. Additionally, the individual responsible for directing or supe rvising the sample collect ion and the engineering data preparation of the sampling program was requi red to certify that the samples were collected appropriately and the engineering data are accu rate and complete. A copy of the signed
certification statement is included in Section 3 for each of the appendices and the engineering data associated with each plant are include d in Section 4 for each of the appendices.3 The analytical data are included in Section 5 for each of the appendice s. The analytical data are presented in tables that provide the following information:

 Analytical results for each set of samples collected at a sampling location, including a calculated 4-set average;

 Summary of the 4-set average concentrati ons among the various sampling locations; and

 Analytical results for each individual sample point.

Please note that although the Dickerson Generati ng Station collected four sets of samples, as required, EPA only analyzed three sets of samples.

ERG chemists conducted quality control reviews of the analytical data and created data review narratives to describe pr oblems encountered during the an alyses and the quality of the data submitted by the laboratories. The data review narratives are included in Section 6 for each of the appendices. Note that because multiple plants were analyzed in the same analytical batches, the same narrative may apply to multiple plants and therefore, may be included in multiple appendices. This ensures that each appendi x contains all narratives associated with the samples from that plant.