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

30 May 2012

EPA Contract No. 68-C-02-095

Work Assignment 9-29
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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 wastewater samples were sent to EPA-contracted 

laboratories for analysis. This report describes the samples collected and the laboratory analyses 

performed, and presents the analytical results for the wastewater samples.

The plants selected for this sampling 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’ Pleasant 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, LLC’s Dickerson Generating Station,

o Appendix F: RRI Energy’s Keystone Generating Station,

o Appendix G: Allegheny Energy’s Hatfield’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 (untreated and treated 

wastewater from a FGD vapor-compression evaporation system),

o Appendix I: Tampa Electric Company’s Polk Station (wastewater from the 

gasification process),

o Appendix J: Wabash Valley Power Association’s Wabash River Station

(wastewater from the gasification process), and

o Appendix K: Appalachian Power Company’s Mountaineer Plant (wastewater 

from a pilot-scale carbon capture system).

The seven plants included in EPA’s onsite sampling program were required to collect 

four sets of samples over a four or five month 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 additional 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 collected, based on system knowledge acquired during 

site visits to the plants or discussions with plant technical staff. Each of the appendices include a 

process flow diagram depicting the 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 the analytical method used for each analyte. The samples 
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were collected using clean sampling techniques (i.e., EPA Method 1669) to limit potential 

contamination from the sampling activities.

Table 1. Analytical Methods

Parameter Method Number

Classicals

Biochemical oxygen demand (BOD5) 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 which 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 the 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 included 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 the sample collection activities to confirm that the 

samples were collected following the instructions 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 samples to EPA-contracted laboratories, the 

plants were also required to provide engineering data regarding the plants operation (e.g., power 

generation, wastewater flow rates, unit configurations) during the sampling period. Additionally, 

the individual responsible for directing or supervising the sample collection and the engineering 

data preparation of the sampling program was required to certify that the samples were collected 

appropriately and the engineering data are accurate 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 included in Section 4 for each of the appendices.
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As shown in Table 1, the samples collected as part of the CWA 308 monitoring program 

were analyzed for classical analytes and total metals. The total mercury samples were analyzed 

by Frontier Global Sciences (Frontier). The mercury samples were subjected to a room 

temperature bromine monochloride digestion prior to analysis using a method-compliant bubbler 

system.

For the total mercury samples collected from sample points representing the effluent from 

wastewater treatment systems, the plants collected four individual grab samples that were 

composited by Frontier and analyzed as one sample. Frontier composited these samples by 

combining the entire sample bottle for each of the four individual grab samples prior to digestion 

and analysis; however, if one or more of the grab samples were received with limited volume, 

equal volumes from each individual grab sample were combined for the composite analysis.

The total metals by EPA Method 200.7 were analyzed by TestAmerica Laboratories –

Denver (TestAmerica). The total metals samples were preserved to a pH <2 at least 24 hours 

prior to being subjected to a heated nitric acid digestion according to SW846 Method 3010A. 

The total metals by EPA Method 200.8 were also analyzed by TestAmerica. The total 

metals samples were preserved to a pH <2 at least 24 hours prior to being subjected to a closed 

vessel, heated nitric acid and hydrochloric acid digestion according to EPA Method 1638.

The classical analytes were analyzed by TestAmerica and were digested, prepared, and 

analyzed according to the methods specified in Table 1.

The analytical data are included in Section 5 for each of the appendices. 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 concentrations among the various sampling locations; and

• Analytical results for each individual sample point.

Please note that although the Dickerson Generating Station collected four sets of samples, 

as required, EPA only analyzed three sets of samples because of resource constraints.

ERG chemists conducted quality control reviews of the analytical data and created data 

review narratives to describe problems encountered during the analyses 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 appendix contains all narratives associated with the 

samples from that plant.