Appendix E

Mirant Mid-Atlantic, LLC’s Dickerson Generating Station
Section 1 

CWA 308 Monitoring Letter and Instructions 



Enclosure 1 

Instructions for Sample Collection, Packaging, and Shipment

EPA Sampling Program

The samples you will be collecting are very important. The samples will be used by the 

U.S. Environmental Protection Agency (EPA) for revising the effluent limitations 

guidelines and standards for the Steam Electric Power Generating Industry. 

These instructions are being provided to Miran Mid-Atlantic, LLC’s Dickerson 

Generating Station to aid in collecting, packaging, and shipping samples for this sampling 

program. 

The plant must collect grab samples for all analytes at the influent to the FGD wastewater 

treatment sampling point and 24-hour composite samples for all analytes except mercury 

and cyanide at the influent to the SBR and effluent from the SBR sampling points. At the 

influent to the SBR and effluent from the SBR, the plant must collect cyanide as a single 

grab sample and mercury must be collected as four individual grab samples over the 24-

hour period (i.e., a grab sample collected every six hours). 

Samples will be collected once a month for four months. The samples should be 

collected and shipped to the laboratories according to the schedule provided in the cover 

letter of this request. If the plant has any questions regarding the timeline or the steps 

provided, please contact Mr. Ronald Jordan at (202) 566-1003 or jordan.ronald@epa.gov. 

Equipment Needed

The plant will need to obtain the following equipment to collect, pack, and ship the 

samples to the laboratories: 

• Sample bottles, composite containers, and tubing sets (specially-cleaned 

according to EPA Method 1669); 

• Automatic compositor; 

• Powder-free gloves; 

• Tyvek® coveralls or suitable alternative; 

• Dust masks (for use while collecting mercury samples) 

• Labels (for sample bottles and shipping samples to laboratories); 

• Preservation supplies (see the “Sample Bottles and Preservation” Section); 

• Coolers; 

• Garbage bags; 

• Packing material; 

• Strapping tape; and 

• Traffic Report (will be provided by ERG). 
Sampling Points

The plant must collect samples once per month for four months, based on the schedule 

specified in the letter. Samples are to be collected from each of the three sampling points 

included in the EPA’s sampling episode. Figure 1 identifies each of the sampling points 

for this sampling program. The following is a description of the three sampling points: 

• FGD wastewater treatment influent (FGD scrubber purge) (SP-1): This 

sampling point shall represent the FGD purge stream (e.g., hydroclone overflow) 

transferred to the FGD wastewater treatment system prior to any commingling 

with other wastewaters or treatment system recycle streams. This sample should 

be collected from the sample tap located on the drain of the pump that transfers 

the FGD wastewater from the purge tank to the equalization tank. 

• FGD influent to SBR system (SP-2): This sampling point shall represent the 

effluent from the chemical precipitation system and the influent to the biological 

treatment system (prior to nutrient addition). This sampling point should be 

collected from the sample tap located at the heat exchanger tank pump discharge, 

which is downstream of the hydrochloric acid addition, but upstream of the heat 

exchanger and SBR influent equalization tank. 

• FGD effluent from SBR system (SP-3): This sampling point shall represent the 

effluent from the biological treatment system, prior to mixing with dilution water 

or other streams. This sampling point should be collected from the sample tap 

that is located on the wastewater piping downstream of the tertiary continuous 

backwash gravity filters. 

Analytes

The analytes included in this sampling program include all analytes from EPA’s sampling 

program, except for the dissolved metals analyses (which includes hexavalent 

chromium). Table 1 contains the listing of all the analytes included in the monitoring 

program, as well as the analytical methods that will be used to analyze the samples. 
Table 1. Analytes and Analytical Methods Included in the Monitoring Program 

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

Total mercury EPA 1631E 

Antimony, arsenic, cadmium, chromium, copper, lead, nickel, 

selenium, silver, thallium, vanadium, and zinc 

EPA 200.8 with collision 

cell 

Aluminum, barium, beryllium, boron, calcium, cobalt, iron, 

magnesium, manganese, molybdenum, sodium, tin, and titanium 

EPA 200.7 

 
Figure 1. Dickerson FGD Wastewater Treatment System Monitoring Program Sampling Points
Sample Bottles and Preservation

Table 2 identifies the sample bottles that are needed for collecting samples. The table 

also identifies the on-site preservation that is required for the samples. Please note that 

the number of sample bottles listed in Table 2 refers to the number of bottles that will 

need to be collected from each sampling point for each of the four sets of samples. For 

the Group II samples, the plant can either preserve the samples with sulfuric acid after 

sample collection, or the plant can order pre-preserved sample bottles. 

For the total cyanide samples, the plant should test the wastewater from the sampling 

points with lead acetate paper (turns black in the presence of sulfide) and potassium 

iodide starch paper (turns blue/violet in the presence of chlorine). If sulfide is present, 

the plant will need to dilute the sample with blank water until the sulfide is not detected 

by the lead acetate paper. If chlorine is present, then the plant will need to add sodium 

arsenite until the chlorine is not detected by the potassium iodide starch paper. After any 

dilution and/or sodium arsenite is added to the sample, the plant will need to preserve the 

sample with sodium hydroxide until the sample reaches a pH of 10 S.U. Please see 

ASTM Method D 7365-09a for more details on the preservation requirements for total 

cyanide. 

Table 2. Summary of Sample Container and Planned Preservation 

Parameter 

Sample Container 

and Volume On-Site Preservation 

BOD5 One 1-L HDPE 

bottle 

≤6°C 

Group I a One 1-L HDPE 

bottle 

≤6°C 

Group II b Two 1-L HDPE 

bottles 

H2SO4 to pH <2, ≤6°C 

Total cyanide One 1-L HDPE 

bottle 

Dilution until sulfide is not detected, 

NaAsO2 until total chlorine is not 

present, NaOH to pH >10, ≤6°C 

Total metals (EPA Method 200.8 with 

collision cell) 

One 500-mL HDPE 

bottle 

None 

(acid preserve at laboratory) 

Total metals (EPA Method 200.7) One 500-mL HDPE 

bottle 

None 

(acid preserve at laboratory) 

Total mercury: 

Laboratory composite grab samples at 

influent to SBR and effluent from SBR 

Four 125-mL glass 

bottles 

Influent samples and field blank samples 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 phosphorus. 

NOTE: The number of sample bottles refers to the number of sample bottles needed for each sampling point for each of

the four sets of samples. 
Sample Labeling

Label each bottle prior to collecting the sample so it can be identified by the laboratory. 

Each self-adhesive label must be completed in indelible ink and must contain the 

following information: 

• Sample number (see Table 3); 

• Sampling episode number (see Table 3); 

• Sampling point/description (see Table 3); 

• Date of sample collection; 

• Analysis to be performed; 

• Sample bottle type; and 

• Required on-site preservation. 

If any of the information is incorrect, the plant must revise the label using indelible ink. 

Once applied to the sample container, the plant must cover the labels with clear tape to 

prevent tampering, abrasion, smearing, or loss during transit. For metal and mercury 

samples, do not place labels directly on the sample bottles because of the potential for 

contamination. Instead, place the label on the outer plastic bag of the sample bottle. To 

ensure that the sample label does not become separated from the bottle, the doublebagged sample bottle should be placed in an additional Ziploc bag after collection. 

Table 3 provides the sampling point descriptions, sample numbers, and sampling episode 

number for the plant for this monitoring program. The information in the table should be 

provided on the sample bottle labels for the appropriate bottles. The “analysis to be 

performed” should be shown on the label as the following, depending on the specific 

analysis: 

• BOD; 

• Group I; 

• Group II; 

• Total Cyanide; 

• Total Metals – 200.8 w/ CC; 

• Total Metals – 200.7; 

• Total Mercury (for influent and field blank samples); 

• Total Mercury – Grab 1 (for influent to SBR and effluent from SBR 

laboratory composite samples. The bottles should be labeled as Grab 1, 

Grab 2, Grab 3, and Grab 4 for the four respective collection times). 

The “sample bottle type” should be shown on the label the same as the “Sample 

Container and Volume” column in Table 2, except that the quantity should not be 

included. For example, for total mercury, the “sample bottle type” should be “250-mL 

glass bottle.” The “required on-site preservation” should be shown on the label the same 

as the “On-Site Preservation” column in Table 2, except that “(acid preserve at 

laboratory)” does not need to be included for the total metals and total mercury sample 

bottles. 
Table 3. Sampling Point Descriptions and Sample Numbers for Monitoring 

Program 

 

Sampling Point Description Sample Number Sampling Episode Number 

FGD Wastewater Treatment Influent – Set 1 72191 6569 

FGD Wastewater Treatment Influent – Set 2 72192 6569 

FGD Wastewater Treatment Influent – Set 3 72193 6569 

FGD Wastewater Treatment Influent – Set 4 72194 6569 

Influent to SBR System - Set 1 72195 6569 

Influent to SBR System - Set 2 72196 6569 

Influent to SBR System - Set 3 72197 6569 

Influent to SBR System - Set 4 72198 6569 

Effluent from SBR System - Set 1 72199 6569 

Effluent from SBR System - Set 2 72200 6569 

Effluent from SBR System - Set 3 72201 6569 

Effluent from SBR System - Set 4 72202 6569 

FGD Wastewater Treatment Influent Field Blank 72203 6569 

Influent to SBR System Field Blank - Set 1 72204 6569 

Influent to SBR System Field Blank - Set 2 72205 6569 

Influent to SBR System Field Blank - Set 3 72206 6569 

Influent to SBR System Field Blank - Set 4 72207 6569 

Effluent from SBR System Field Blank - Set 1 72208 6569 

Effluent from SBR System Field Blank - Set 2 72209 6569 

Effluent from SBR System Field Blank - Set 3 72210 6569 

Effluent from SBR System Field Blank - Set 4 72211 6569 

QC Samples

The plant is required to collect field blank samples as part of the sampling program. The 

field blank samples should be collected at the frequency specified in Table 4. 

Table 4. Field Blank Collection Frequency 

Sampling Point Total Mercury 

Total Metals (200.8 

and 200.7) Classicals1 

FGD Wastewater 

Treatment Influent 

Collected during one 

of the four sets 

Collected during one 

of the four sets 

No field blanks 

required 

Influent to SBR System Collected during all 

four sets 

Collected during all 

four sets 

No field blanks 

required 

Effluent from SBR 

System 

Collected during all 

four sets 

Collected during all 

four sets 

No field blanks 

required 

1

 Classicals includes the analyses for BOD, Group I, Group II, and total cyanide. 
The laboratory will perform MS/MSD analyses on the total metals and total mercury 

analyses; however, no additional sample volume is required. 

Sample Collection

The plant must use clean sampling techniques when collecting the total metals and total 

mercury samples; therefore, the sampling team should follow the clean hands/dirty hands 

sampling techniques outlined in EPA Method 1669. Additionally, the plant must try to 

avoid significant contamination during sample collection, especially from sources such as 

airborne particles, dirt, and corrosion particulates from piping, railing, etc. 

The plant must collect grab samples for all analytes at the influent to the FGD wastewater 

treatment system. The plant must collect 24-hour composite samples for all analytes 

except cyanide and mercury at the influent to the SBR and effluent from the SBR 

sampling points. The 24-hour composites must be set up to collect equal sample aliquots 

every hour over the 24-hour period. For mercury at the influent to the SBR and effluent 

from the SBR sampling points, the plant must collect four individual grab samples over 

the 24-hour period (i.e., one mercury grab collected every six hours). For cyanide at the 

influent to the SBR and effluent from the SBR sampling points, the plant must collect a 

single grab sample after the one of the mercury grab samples. 

If the plant collects the samples from the same taps that will be used for the collection of 

samples during the EPA sampling episode, the plant can follow the instructions included 

in the sampling plan drafted for the EPA sampling episode to collect the field blank 

samples, set up the composite containers, and perform the composite pump-off procedures 

for the influent to the SBR and effluent from the SBR sampling points. The following 

instructions can be used to collect the grab samples at the influent to the FGD wastewater 

treatment system sampling point and for the mercury and cyanide grab samples at the 

influent to the SBR and effluent from the SBR sampling points: (NOTE: If a sample tap 

or valve is not available to collect these samples or if the influent to the SBR and effluent 

from the SBR sampling points have intermittent flows which may interfere with the 

automatic composite collection, please contact TJ Finseth, (703) 633-1698 to discuss 

possible alternatives.) 

1. Arrive at the sampling point location and prepare 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 gets a clear plastic bag and opens it slightly (touching only the 

outer part of the bag) so that clean hands can place hands in the bag and 

open the bag completely. 

4. Clean hands then uses the plastic bag to shroud the sample tap (note that 

there should be no flow through the sample tap at this time). Clean hands 

will need to puncture a small hole in the bag using the tap and dirty hands 

can cable tie the bag to the tap to prevent it from falling during sample 

collection. 
5. Dirty hands opens the outer bags of the field blank water and total mercury 

and total metals field blank sample bottles. Clean hands opens the inner 

bag of the field blank water and unscrews the lid. Clean hands then opens 

the inner bag of the total mercury and total metals field blank sample 

bottles. Clean hands pours the blank water into the field blank sample 

bottles under the shrouding, caps the bottles, and closes the inner bags. 

Clean hands then places the total mercury and total metals bottles in the 

outer bags and dirty hands closes the outer bag. 

6. Dirty hands then opens the valve to the sample tap and purges the tap for at 

least two minutes, then keeps the valve open until all samples have been 

collected. 

7. Dirty hands opens the outer bag for the total mercury sample bottle. Clean 

hands takes the sample bottle and inner bag and holds them under the 

shroud. Clean hands then opens the inner bag, opens the lid of the bottle 

and fills the total mercury sample bottle. Clean hands caps the sample 

bottle, closes the inner bag, and places the sample bottle in the outer bag. 

Dirty hands closes the outer bag. The samplers repeat this procedure for 

the collection of the total metals samples (both EPA 200.8 with collision 

cell and EPA 200.7), unless the plant is collecting the metals samples as 

composite samples. 

8. The samplers then collect the BOD, Group I, Group II, and total cyanide 

samples. NOTE: the samplers can collect these samples using the same 

technique as the mercury and metals samples, or they can remove the 

plastic bag shrouding and collect directly from the tap. 

9. The Group II and total cyanide samples must be preserved prior to 

shipment to the laboratories. Use the information provided in the “Sample 

Bottle and Preservation” section of these instruction for the preservation 

steps. Additionally, the BOD, Group I, Group II, and total cyanide samples 

should be placed on ice immediately after sample collection/preservation. 

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. If bottle threads are dirty to where the lid is impeded 

from closing, clean the threads on the bottle being careful to not introduce 

contamination into the sample. Clean the sample bottle with a cloth rag or 

paper towel. 

3. Prior to packaging, place each sample bottle requiring ≤6°C preservation 

into an ice chest with wet ice to cool. 

4. When each sample requiring ≤6°C preservation has reached the desired 

temperature, wrap each glass sample bottle with two layers of “bubble 
wrap” (or place bottle in two “bubble bags”). The bubble wrap must fit 

snugly and completely cover the sample bottle. Enclose each “bubblewrapped” container and plastic container in an individual sealable plastic 

freezer bag. 

5. Place two garbage bags inside each other in each of the coolers used to 

ship samples to the laboratories. 

6. Place the classicals samples in the garbage bags in the coolers with proper 

end up, close the interior garbage bag by tying, or with a twist-tie. 

7. Add ice to the cooler to keep samples cold during shipment. Arrange blue 

ice or sealed plastic freezer bags filled with wet ice on top of the sample 

bottles (if samples require ≤6°C preservation). If using wet ice, place the 

ice inside two one-gallon sealable freezer bags. Put at least 4 × 1⁄2 gallons 

of ice (4 × 2.5 pounds of ice) in each large cooler and 2 × 1⁄2 gallons of ice 

(2 × 2.5 pounds of ice) in each small cooler. Use more ice when ambient 

temperatures are very high. Place the ice inside the second garbage bag. 

8. Close the second garbage bag by tying, or with a twist-tie. 

9. Place the metals samples in the garbage bags in a different cooler with 

proper end up, close the interior garbage bag by tying or with a twist-tie. 

Close the second garbage bag by tying, or with a twist-tie. NOTE: the 

metals samples are not required to be cooled; however, because the metals 

and classicals are being analyzed by the same laboratory, the metals can 

be shipped with the classicals, but the metals samples would need to be 

chilled prior to packing them in the cooler with the classicals and ice 

would need to be added to the cooler between the interior and outer 

garbage bags to keep the samples cold. 

10. Fill in any free space around the bottles in the metals and classicals 

coolers with additional cushioning material. Sufficient packing material 

should be used so that the sample containers will not shift during 

shipment. 

11. Fill out and print a traffic report form for the classicals and metals samples 

(provided electronically by ERG). Seal the last two pages of the traffic 

report form(s) in a plastic envelope secured to the inside of the top of the 

cooler(s). 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 

12. Close the cooler(s). 

13. 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) 736-0100 

14. 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 

released or damaged. 

15. Place the mercury samples in the garbage bags in a separate cooler with 

proper end up, close the interior garbage bag by tying, or with a twist-tie. 

16. Do not add ice to the mercury cooler, simply close the second garbage bag 

by tying, or with a twist-tie. 

17. Fill in any free space around the bottles with additional cushioning 

material. Sufficient packing material should be used so that the sample 

containers will not shift during shipment. 

18. Fill out and print a traffic report form for the mercury samples (provided 

electronically by ERG). 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 11: 

19. Close the cooler. 

20. Place a completed 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 

21. 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 

released or damaged. 

22. Fill out the necessary paperwork for FedEx or UPS to prepare the 

shipment for pick up or drop off. NOTE: the samples must be shipped 

priority overnight to arrive at the laboratories the following morning. Ship 

the coolers to the laboratories. 

23. After the coolers have been dropped off (or picked up), please contact TJ 

Finseth at (703) 633-1698, to notify him that the samples have been 

shipped to the laboratories. 

Traffic Reports

An example traffic report will be provided to the plant by ERG for the first sample 

collection event. The plant will need to make changes to the traffic report electronically 
for the other three sample collection events. Some information, such as the date and 

sample collection times must be entered by the plant after the sample collection and 

therefore, will not be included in the example provided by ERG. 

After the traffic report is completed by the plant, the plant 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. The plant can keep the second page 

of the traffic report. 

Engineering Data

The plant must provide engineering data regarding the operation of the plant and FGD 

systems during the sample collection period. Additionally, the plant must make some 

field measurements when samples are collected, including pH, temperature, and visual 

observations, and provide the data to EPA after the sample collection period. The 

engineering data and field measurement data requirements are in an Excel® spreadsheet 

titled “Monitoring Program Engineering Data Tables,” which will be provided by ERG. 

The tables are also included at the end of this enclosure. The plant must complete the 

engineering data sheets and field measurement sheets in the Excel® file and e-mail the 

completed forms to TJ Finseth at thomas.finseth@erg.com. 

Certification Statement 

The individual responsible for directing and supervising the sample collection and the 

engineering data preparation must sign the certification statement (provided in Enclosure 

4) and submit it upon the completion of the sampling program. The signed certification 

statement should be scanned and e-mailed to TJ Finseth at thomas.finseth@erg.com, at 

the same time the engineering data is submitted. 
Complete the following tables for each sampling point

Plant Name

Sample 

Collection 

Number

Date of Sample 

Collection

Sample Collection 

Time Temperature (°C)

pH

(S.U.)

Set 1Set 2Set 3Set 4

Plant Name

Sample 

Collection 

Number

Influent Samples 

Collected as 

Grabs

(Yes or No)

Mercury and Cyanide 

Samples Collected as 

Grabs

(Yes or No)

Bioreactor Influent 

and Bioreactor 

Effluent Samples 

Collected as 24-Hour 

Composites

(Yes or No)

Tyvek Suits 

used

(Yes or No)

Dust Masks 

Used for 

Mercury 

(Yes or No)

Clean Hands/Dirty 

Hands Sampling 

Techniques Used

(Yes or No)

Description of Sample 

Collection Technique (if 

different than 

instructions)

Description of Abnormal 

Conditions in FGD System 

or FGD Wastewater 

Treatment System that May 

Impact Concentrations

Set 1Set 2Set 3Set 4
Complete the following tables based on the plant operating characteristics during each set of samples collected

Units Operating 

During Sampling 

Day

Units Off-line 

Entire 

Sampling Day

SCRs/SNCRs 

Operating on 

Units

Set 1Set 2Set 3Set 4

Flow Rate (gpm) Duration

Set 1Set 2Set 3Set 4

Lime Usage 

(tons)

Ferric Chloride 

Usage 

(Liters/day)

Organosulfide Usage 

(Liters/day)

Polymer Usage 

(Liters/day)

Acid Usage 

(Liters/day)

Chemical 

Precipitation 

System Effluent 

Flow Rate (gpd)

Dilution Water 

Addition Prior 

to Biological 

Treatment 

System

(gpd)

Biological 

Treatment 

System Effluent 

Flow Rate (gpd)

Set 1Set 2Set 3Set 4

Percent Hydroclone 

Overflow Recycled 

Back to Scrubber Plant Name

Sample 

Collection 

Number

Date of Sample 

Collection

Scrubber Slurry Blowdown Flow 

Rate Scrubber Slurry 

Percent Solids

Plant Operation During Sample Collection

FGD Wastewater Treatment Operation During Sample Collection

Plant Name

Date of Sample 

Collection

Sample 

Collection 

Number

Scrubber Purge 

Flow Rate During 

Influent Sample 

Collection

(gpm)

Plant Name

Date of Sample 

Collection

Sample 

Collection 

Number

Plant Operation During Sample Collection
Unit 1 Unit 2 Unit 3

Daily Power Generation (MW-hrs)

Plant Name Date

Provide the daily power generation for each scrubbed unit starting two weeks prior to the first 

set of samples through the last set of samples
Chemical 

Precipitation 

Effluent

Dilution Water 

Addition Prior to 

Biological 

Treatment 

System

Biological Treatment 

Plant Name Date System Effluent

FGD Wastewater Treatment System Flow Rates

(gpd)

Provide the average flow rate in the FGD wastewater treatment system for each stream included in the 

table starting two weeks prior to the first set of samples through the last set of samples
Enclosure 2 

Authority

This request for information is made under authority provided by Section 308 of the Federal 

Water Pollution Control Act, as amended, 33 USC 1318. Section 308 provides that, "Whenever 

required to carry out the objective of this Act, including but not limited to . . . developing or 

assisting in the development of any effluent limitation . . . pretreatment standard, or standard of 

performance under this Act," the Administrator shall require the owner or operator of any point 

source to "establish and maintain such records, . . make such reports, . . install, use, and maintain 

such monitoring equipment . . . sample such effluent . . . and provide such other information as 

he may reasonably require." 

Confidentiality

A business ("you") may not withhold information from EPA on the grounds that it is 

confidential. You may, however, if you desire, assert a business confidentiality claim covering 

part or all of the information that you furnish to EPA. 

EPA regulations concerning confidential business information are contained in 40 CFR Part 2, 

Subpart B. The manner of asserting such a claim is specified in 40 CFR 2.203(b). Information 

covered by such a claim will be disclosed by EPA only to the extent, and by means of the 

procedures, set forth in Subpart B. 

If you wish to claim as confidential any of the information covered by the enclosed request, you 

must do so at the time you submit the information to EPA. If no such claim accompanies the 

information when EPA receives it, EPA may make the information available to the public 

without further notice to you. 

EPA will notify you in the event that a request is made for release of information that you have 

claimed to be confidential or EPA otherwise decides to make a determination as to whether or 

not such information is entitled to confidential treatment. At that time, EPA will request that you 

substantiate any claim you have made that information is confidential. Therefore, we encourage 

you to consult 40 CFR Part 2, and to claim as confidential only those items that you truly believe 

satisfy the criteria for confidentiality. 

Note that effluent data are not eligible for confidential treatment (see 40 CFR 2.302). 
Enclosure 3

Notice of Intent to Transfer Confidential Information to Selected EPA Contractors

EPA intends to grant access to confidential information collected under the sampling program to 

selected EPA contractors. 

In accordance with 40 CFR Sections 2.301(h)(2-3), 2.302(h)(2-3), and 2.305(h)(2-3), EPA may 

allow those contractors identified below access to all data (including data claimed to be 

confidential) collected as part of the follow-on sampling program. Transfer of this information 

to these contractors is necessary in order for the contractors to assist EPA in performing 

technical, statistical, and environmental analyses to support the development of effluent 

limitations guidelines and standards for the Steam Electric Power Generating industry. 

The contractors and subcontractors that will be providing support to EPA during the 

development of these regulations are listed below: 

EPA Office 

Receiving 

Support 

Contractor Name EPA Contract 

No. Type of Support 

Eastern Research Group, Inc. 68-C-02-095 Engineering analysis 

Office of Water/ 

Office of 

Science & 

Technology/ 

Engineering & 

Analysis 

Division 

Westat EP-C-10-023 Statistical analysis 

EPA has determined that it is necessary to transfer the information described above to the 

designated contractors and subcontractors in order that they may carry out the work required by 

their contracts. The contracts contain all provisions necessary to implement the confidentiality 

regulations (see 40 CFR 2.301(h)(2), 2.302(h)(2), and 2.305(h)(2)). 

In accordance with these confidentiality regulations, you are entitled to provide comments to 

EPA regarding this notice of contemplated disclosure. Any such comments must be received by 

EPA in writing within 10 days of your receipt of this notice. Please send such comments to: 

Ronald Jordan 

USEPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Ave., N.W. 

Mail Code: 4303T 

Washington, DC 20460 

jordan.ronald@epa.gov 
Enclosure 4 

Certification Statement 

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

data preparation for the sampling program must read and sign the Certification Statement listed 

below. The certifying official must be a responsible corporate official or his/her authorized 

representative. 

Certification Statement 

I certify under penalty of law that the samples collected for the sampling program were collected 

under my direction or supervision, that qualified personnel collected the samples following the 

procedures described in the instructions (including the use of clean hands/dirty hands sampling 

techniques described in EPA Method 1669), that qualified personnel gathered the engineering 

data required, and that the sampling and engineering data provided are complete and reflect 

normal operations for this plant. The engineering data submitted are, to the best of my 

knowledge and belief, accurate and complete. In those cases where we did not possess direct 

measurement, we provided best estimates. We have to the best of our ability indicated what we 

believe to be company confidential business information as defined under 40 CFR Part 2, 

Subpart B. We understand that we may be required at a later time to justify our claim in detail 

with respect to each item claimed confidential. I am aware that there are significant penalties 

for submitting false information, including the possibility of fines and imprisonment as explained 

in Section 308 of the Clean Water Act.

 

Signature of Certifying Official Date 

( ) 

Printed Name of Certifying Official Telephone Number of Certifying Official 

Title of Certifying Official 

Company Name 

 
Section 2

On-Site Audit Memorandum
An on-site audit was not performed at the Dickerson Generating Station.
Section 3

Signed Certification Statement

Section 4

Engineering Data
Table E4-1. Field Measurements for Sample Collection at the Influent to FGD Wastewater Treatment System

Episode Number 

Sample Collection 

Number 

Date of Sample 

Collection 

Sample Collection 

Time 

Temperature 

(°C) 

6569 Set 1 - Grab 1 9/29/2010 0945 35 6569 Set 2 - Grab 1 12/8/2010 1034 29 6569 Set 3 - Grab 1 1/12/2011 0806 36 6569 Set 4 - Grab 1 2/9/2011 0904 33 
Table E4-2. Field Measurements for Sample Collection at the Influent to the SBR System, Dickerso

Episode Number 

Sample Collection 

Number 

Date of Sample 

Collection 

Sample Collection 

Time 

Temperature 

(°C) 

6569 Set 1 - Grab 1 9/28/2010 1355 35.0 6569 Set 1 - Grab 2 9/28/2010 1955 33.0 6569 Set 1 - Grab 3 9/29/2010 0155 31.9 6569 Set 1 - Grab 4 9/29/2010 0753 31.1 6569 Set 2 - Grab 1 12/7/2010 1205 14 6569 Set 2 - Grab 2 12/7/2010 1803 14 6569 Set 2 - Grab 3 12/8/2010 0007 14 6569 Set 2 - Grab 4 12/8/2010 0638 13 6569 Set 3 - Grab 1 1/11/2011 1111 22 6569 Set 3 - Grab 2 1/11/2011 1713 23 6569 Set 3 - Grab 3 1/11/2011 2310 16 6569 Set 3 - Grab 4 1/12/2011 0512 19 6569 Set 4 - Grab 1 2/8/2011 1031 21 6569 Set 4 - Grab 2 2/8/2011 1629 25 6569 Set 4 - Grab 3 2/8/2011 2230 22 6569 Set 4 - Grab 4 2/9/2011 0432 23 
Table E4-3. Field Measurements for Sample Collection at the Effluent from the SBR System, Dicker

Episode Number 

Sample Collection 

Number 

Date of Sample 

Collection 

Sample Collection 

Time 

Temperature 

(°C) 

6569 Set 1 - Grab 1 9/28/2010 1325 28.7 6569 Set 1 - Grab 2 9/28/2010 1925 29.6 6569 Set 1 - Grab 3 9/29/2010 0125 27.4 6569 Set 1 - Grab 4 9/29/2010 0733 27.2 6569 Set 2 - Grab 1 12/7/2010 1120 10 6569 Set 2 - Grab 2 12/7/2010 1713 16 6569 Set 2 - Grab 3 12/7/2010 2308 17 6569 Set 2 - Grab 4 12/8/2010 0510 16 6569 Set 3 - Grab 1 1/11/2011 0951 23 6569 Set 3 - Grab 2 1/11/2011 1552 24 6569 Set 3 - Grab 3 1/11/2011 2158 22 6569 Set 3 - Grab 4 1/12/2011 0358 17 6569 Set 4 - Grab 1 2/8/2011 0911 26 6569 Set 4 - Grab 2 2/8/2011 1505 26 6569 Set 4 - Grab 3 2/8/2011 2115 22 6569 Set 4 - Grab 4 2/9/2011 0309 22 

NR – Not reported. 
Table E4-4. Sample Collection Procedures Used during the Sampling Episode 

Episode 

Number 

Sample 

Collection 

Number 

Influent 

Samples 

Collected as 

Grabs 

(Yes or No) 

Mercury 

and Cyanide 

Samples 

Collected as 

Grabs 

(Yes or No) 

SBR Influent and 

SBR Effluent 

Samples Collected 

as 24-Hour 

Composites 

(Yes or No) 

Clean 

Hands/Dirty 

Hands Sampling 

Techniques Used

(Yes or No)* 

Description of 

Sample 

Collection 

Technique (if 

different than 

instructions) 

6569 Set 1 Yes Yes Yes Yes None 6569 Set 2 Yes Yes Yes Yes None 6569 Set 3 Yes Yes Yes Yes Note 1 6569 Set 4 Yes Yes Yes Yes None 

* Includes the use of tyveks suits during all sampling events and dust masks during the collection of mercury samples. Note 1: The compositor effluent tube for the effluent from the SBR system froze during sample collection causing the sample tap to bloApproximately one hour lapsed from the schedule before sampling resumed.
Table E4-5. Generating Unit Operation at Time of Sampling, Dickerson 

Episode Number 

Sample Collection 

Number 

Date of Sample 

Collection 

Plant Operation During Sample Colle

Units Operating 

During Sampling 

Day 

Units Off-line Entire 

Sampling Day 

6569 Set 1 9/28/10 - 9/29/10 Units 1,2,3 None 6569 Set 2 12/7/10 - 12/8/10 Units 1,2,3 None 6569 Set 3 1/11/11 - 1/12/11 Units 2,3 Unit 1 6569 Set 4 2/8/11 - 2/9/11 Units 1,2,3 None 
Table E4-6. FGD Scrubber Slurry Information at Time of Sampling, Dickerson 

Episode 

Number 

Sample 

Collection 

Number 

Date of Sample 

Collection 

Plant Operation During Sample Collection 

Scrubber Slurry Blowdown 

Flow Rate 

Scrubber 

Slurry 

Percent 

Solids 

(%) 

Percen

Hydrocl

Overflow Re

Back to Scr

(%) 

Flow Rate 

(gpm) 

Duration 

(Hours) 

6569 Set 1 9/28/2010 889 8.00 19.94 2.30 6569 Set 1 9/29/2010 721 4.58 19.90 5.04 6569 Set 2 12/7/2010 650 3.87 19.98 6.63 6569 Set 2 12/8/2010 572 6.40 19.93 4.55 6569 Set 3 1/11/2011 788 6.95 20.09 3.04 6569 Set 3 1/12/2011 744 5.82 19.70 3.85 6569 Set 4 2/8/2011 816 7.10 18.63 2.88 6569 Set 4 2/9/2011 452 3.30 19.15 1.24 
Table E4-7. FGD Wastewater Treatment System Operation Information, Dickerson 

Episode 

Number 

Sample 

Collection 

Number 

Date of Sample 

Collection 

FGD Wastewater Treatment Operation During Sample Colle

Lime Usage 

(tons) 

Ferric Chloride 

Usage 

(Liters/day) 

Organosulfide 

Usage 

(Liters/day) 

Polymer Usage 

(Liters/day) 

6569 Set 1 09/28/2010 3.05 27.25 NOT USED 2.61 6569 Set 1 09/29/2010 2.9 28.16 NOT USED 3.14 6569 Set 2 12/07/2010 2.3 19.98 54.5 4.24 6569 Set 2 12/08/2010 2.9 27.25 54.5 5.22 6569 Set 3 01/11/2011 5.8 27.25 49.96 5.22 6569 Set 3 01/12/2011 3.85 27.25 54.5 3.86 6569 Set 4 02/08/2011 5.3 27.25 31.79 4.81 6569 Set 4 02/09/2011 4.73 27.25 36.34 4.54 
Table E4-8. Daily Power Generation During Sampling Period, Dickerson 

Episode Number Date 

Daily Power Generation 

(MW-hrs) 

Unit 1 Unit 2 Unit 3 

6569 9/14/2010 2,686 2,196 2,590 

6569 9/15/2010 2,592 1,999 2,599 

6569 9/16/2010 3,020 2,875 3,155 

6569 9/17/2010 3,110 2,883 3,143 

6569 9/18/2010 2,100 229 2,139 

6569 9/19/2010 2,403 2,727 2,199 

6569 9/20/2010 2,831 2,843 2,327 

6569 9/21/2010 2,287 2,351 2,131 

6569 9/22/2010 3,079 3,179 3,007 

6569 9/23/2010 3,381 3,195 3,493 

6569 9/24/2010 3,465 3,507 3,483 

6569 9/25/2010 3,597 3,669 3,677 

6569 9/26/2010 2,683 2,781 2,387 

6569 9/27/2010 3,484 3,426 3,737 

6569 9/28/2010 3,313 2,984 3,463 

6569 9/29/2010 2,830 2,524 2,706 

6569 9/30/2010 3,397 3,394 1,203 

6569 10/1/2010 3,305 3,368 1,465 

6569 10/2/2010 1,901 1,897 1,902 

6569 10/3/2010 1,927 1,920 1,949 

6569 10/4/2010 1,959 1,963 1,951 

6569 10/5/2010 2,020 1,985 2,067 

6569 10/6/2010 1,898 110 1,880 

6569 10/7/2010 169 0 57 

6569 10/8/2010 0 0 0 

6569 10/9/2010 0 0 0 

6569 10/10/2010 0 0 0 

6569 10/11/2010 0 0 0 

6569 10/12/2010 0 0 0 

6569 10/13/2010 0 0 0 

6569 10/14/2010 0 0 0 

6569 10/15/2010 0 0 0 

6569 10/16/2010 0 0 0 

6569 10/17/2010 0 0 0 

6569 10/18/2010 0 0 0 

6569 10/19/2010 0 0 0 

6569 10/20/2010 0 0 0 

6569 10/21/2010 0 0 0 

6569 10/22/2010 0 0 0 

6569 10/23/2010 0 0 0 

6569 10/24/2010 0 0 0 
Table E4-8. Daily Power Generation During Sampling Period, Dickerson 

Episode Number Date 

Daily Power Generation 

(MW-hrs) 

Unit 1 Unit 2 Unit 3 

6569 10/25/2010 0 0 0 

6569 10/26/2010 0 1,678 793 

6569 10/27/2010 0 3,160 2,413 

6569 10/28/2010 0 2,433 2,339 

6569 10/29/2010 0 100 117 

6569 10/30/2010 0 0 0 

6569 10/31/2010 0 0 0 

6569 11/1/2010 865 746 865 

6569 11/2/2010 2,400 2,641 2,400 

6569 11/3/2010 2,199 2,271 2,199 

6569 11/4/2010 2,274 2,261 2,274 

6569 11/5/2010 103 2,141 103 

6569 11/6/2010 0 2,558 0 

6569 11/7/2010 0 2,075 0 

6569 11/8/2010 0 2,145 0 

6569 11/9/2010 0 2,048 0 

6569 11/10/2010 0 1,908 0 

6569 11/11/2010 0 2,159 0 

6569 11/12/2010 0 2,186 0 

6569 11/13/2010 0 1,940 0 

6569 11/14/2010 0 2,011 0 

6569 11/15/2010 0 2,022 0 

6569 11/16/2010 0 2,378 0 

6569 11/17/2010 0 2,492 0 

6569 11/18/2010 0 2,319 0 

6569 11/19/2010 500 1,903 500 

6569 11/20/2010 0 1,836 0 

6569 11/21/2010 0 28 0 

6569 11/22/2010 0 0 0 

6569 11/23/2010 0 0 0 

6569 11/24/2010 0 0 0 

6569 11/25/2010 0 0 0 

6569 11/26/2010 0 0 0 

6569 11/27/2010 0 0 0 

6569 11/28/2010 0 0 0 

6569 11/29/2010 1,814 0 1,814 

6569 11/30/2010 2,038 0 2,038 

6569 12/1/2010 3,040 1 15 

6569 12/2/2010 2,624 2,543 2,293 

6569 12/3/2010 2,805 3,330 3,482 

6569 12/4/2010 2,087 2,112 2,112 

6569 12/5/2010 2,307 2,367 2,349 

6569 12/6/2010 3,315 3,042 2,800 
Table E4-8. Daily Power Generation During Sampling Period, Dickerson 

Episode Number Date 

Daily Power Generation 

(MW-hrs) 

Unit 1 Unit 2 Unit 3 

6569 12/7/2010 2,972 3,076 3,009 

6569 12/8/2010 3,070 3,137 3,251 

6569 12/9/2010 4,171 4,115 4,243 

6569 12/10/2010 4,340 4,370 3,615 

6569 12/11/2010 4,004 4,007 3,877 

6569 12/12/2010 2,896 2,989 2,119 

6569 12/13/2010 3,362 3,516 3,495 

6569 12/14/2010 4,392 4,447 4,499 

6569 12/15/2010 4,184 4,233 4,219 

6569 12/16/2010 4,385 4,387 4,465 

6569 12/17/2010 4,443 4,432 2,769 

6569 12/18/2010 4,039 4,147 0 

6569 12/19/2010 2,364 2,962 0 

6569 12/20/2010 1,267 4,306 2,682 

6569 12/21/2010 0 3,101 3,106 

6569 12/22/2010 5 3,243 3,241 

6569 12/23/2010 2,440 2,892 2,850 

6569 12/24/2010 2,519 2,615 2,604 

6569 12/25/2010 2,913 2,904 2,951 

6569 12/26/2010 3,396 3,752 3,807 

6569 12/27/2010 3,864 4,154 2,885 

6569 12/28/2010 2,894 2,908 810 

6569 12/29/2010 2,922 2,908 0 

6569 12/30/2010 2,362 2,800 0 

6569 12/31/2010 78 2,211 0 

6569 1/1/2011 0 1,954 0 

6569 1/2/2011 0 2,040 0 

6569 1/3/2011 880 2,993 1,159 

6569 1/4/2011 3,272 3,223 3,327 

6569 1/5/2011 3,094 3,100 3,126 

6569 1/6/2011 3,056 2,820 2,815 

6569 1/7/2011 3,469 2,353 2,304 

6569 1/8/2011 128 3,436 3,449 

6569 1/9/2011 0 4,191 4,110 

6569 1/10/2011 0 3,307 3,365 

6569 1/11/2011 0 3,519 3,517 

6569 1/12/2011 0 3,930 3,935 

6569 1/13/2011 2,821 4,183 4,186 

6569 1/14/2011 3,759 3,862 3,571 

6569 1/15/2011 2,789 2,961 2,905 

6569 1/16/2011 1,942 1,941 1,979 

6569 1/17/2011 3,308 3,242 2,126 

6569 1/18/2011 3,112 3,093 3,056 
Table E4-8. Daily Power Generation During Sampling Period, Dickerson 

Episode Number Date 

Daily Power Generation 

(MW-hrs) 

Unit 1 Unit 2 Unit 3 

6569 1/19/2011 2,298 2,288 2,305 

6569 1/20/2011 2,248 2,244 2,303 

6569 1/21/2011 1,621 3,495 3,472 

6569 1/22/2011 0 3,924 4,260 

6569 1/23/2011 0 4,174 4,156 

6569 1/24/2011 2,623 4,036 4,031 

6569 1/25/2011 3,049 3,092 3,051 

6569 1/26/2011 3,193 3,197 3,186 

6569 1/27/2011 3,048 2,979 3,012 

6569 1/28/2011 2,972 2,684 2,943 

6569 1/29/2011 2,997 2,797 2,870 

6569 1/30/2011 2,089 2,063 2,006 

6569 1/31/2011 3,061 2,972 3,052 

6569 2/1/2011 3,142 3,022 3,046 

6569 2/2/2011 2,801 2,654 2,730 

6569 2/3/2011 2,905 2,874 2,985 

6569 2/4/2011 3,120 3,099 3,208 

6569 2/5/2011 3,031 2,930 3,019 

6569 2/6/2011 1,945 1,934 1,942 

6569 2/7/2011 2,340 2,265 2,255 

6569 2/8/2011 2,456 2,420 2,431 

6569 2/9/2011 4,224 4,114 4,368 
Table E4-9. FGD Wastewater Treatment System Flow Rate during Sampling Period, Dickerson 

Episode 

Number Date 

FGD Wastewater Treatment System Flow Rates 

(gpd) 

Chemical 

Precipitation 

Effluent 

Dilution Water 

Addition Prior to 

Biological Treatment 

System 

Biological 

Treatment System 

Effluent 

6569 9/14/2010 64,817 0 91,590 

6569 9/15/2010 95,944 0 82,017 

6569 9/16/2010 80,067 0 68,457 

6569 9/17/2010 88,304 0 91,408 

6569 9/18/2010 89,547 0 81,408 

6569 9/19/2010 85,794 0 84,852 

6569 9/20/2010 96,836 0 90,936 

6569 9/21/2010 108,965 0 83,712 

6569 9/22/2010 125,312 0 105,928 

6569 9/23/2010 130,480 0 101,155 

6569 9/24/2010 123,776 0 115,187 

6569 9/25/2010 108,573 0 108,160 

6569 9/26/2010 349 0 77,313 

6569 9/27/2010 89,888 0 84,783 

6569 9/28/2010 84,038 0 91,930 

6569 9/29/2010 84,296 0 71,893 

6569 9/30/2010 88,951 0 89,912 

6569 10/1/10 93,184 0 56,775 

6569 10/2/10 88,897 0 84,881 

6569 10/3/10 87,742 0 81,744 

6569 10/4/10 88,433 0 83,043 

6569 10/5/10 98,028 0 90,106 

6569 10/6/10 101,384 0 92,489 

6569 10/7/10 86,140 0 97,559 

6569 10/8/10 85,046 0 66,037 

6569 10/9/10 87,950 0 69,826 

6569 10/10/10 85,096 0 75,475 

6569 10/11/10 87,184 0 60,686 

6569 10/12/10 86,494 0 60,567 

6569 10/13/10 86,412 0 73,958 

6569 10/14/10 86,369 0 52,155 

6569 10/15/10 86,233 0 96,234 

6569 10/16/10 83,281 0 67,099 

6569 10/17/10 87,052 0 69,942 

6569 10/18/10 85,344 0 74,270 

6569 10/19/10 86,021 0 55,319 

6569 10/20/10 83,884 0 15,640 

6569 10/21/10 86,479 0 22,461 
Table E4-9. FGD Wastewater Treatment System Flow Rate during Sampling Period, Dickerson 

Episode 

Number Date 

FGD Wastewater Treatment System Flow Rates 

(gpd) 

Chemical 

Precipitation 

Effluent 

Dilution Water 

Addition Prior to 

Biological Treatment 

System 

Biological 

Treatment System 

Effluent 

6569 10/22/10 0 0 14,228 

6569 10/23/10 0 0 0 

6569 10/24/10 0 0 0 

6569 10/25/10 0 0 0 

6569 10/26/10 0 0 0 

6569 10/27/10 0 0 0 

6569 10/28/10 0 0 0 

6569 10/29/10 0 0 0 

6569 10/30/10 0 0 0 

6569 10/31/10 0 0 0 

6569 11/1/10 0 0 0 

6569 11/2/10 0 0 0 

6569 11/3/10 0 0 0 

6569 11/4/10 0 0 0 

6569 11/5/10 * 0 0 

6569 11/6/10 * 0 0 

6569 11/7/10 * 0 31,923 

6569 11/8/10 80,507 0 75,197 

6569 11/9/10 79,102 0 61,198 

6569 11/10/10 79,869 0 37,511 

6569 11/11/10 80,183 0 62,691 

6569 11/12/10 79,962 0 76,753 

6569 11/13/10 80,914 0 58,442 

6569 11/14/10 79,445 0 56,313 

6569 11/15/10 78,779 0 48,774 

6569 11/16/10 79,533 0 59,596 

6569 11/17/10 80,076 0 61,447 

6569 11/18/10 81,532 0 68,221 

6569 11/19/10 160,636 0 58,316 

6569 11/20/10 * 0 37,679 

6569 11/21/10 * 0 60,585 

6569 11/22/10 79,099 0 77,756 

6569 11/23/10 79,905 0 63,420 

6569 11/24/10 75,069 0 41,205 

6569 11/25/10 79,326 0 49,730 

6569 11/26/10 81,199 0 46,487 

6569 11/27/10 76,173 0 46,843 

6569 11/28/10 77,610 0 42,596 

6569 11/29/10 76,061 0 16,458 

6569 11/30/10 77,321 0 0 
Table E4-9. FGD Wastewater Treatment System Flow Rate during Sampling Period, Dickerson 

Episode 

Number Date 

FGD Wastewater Treatment System Flow Rates 

(gpd) 

Chemical 

Precipitation 

Effluent 

Dilution Water 

Addition Prior to 

Biological Treatment 

System 

Biological 

Treatment System 

Effluent 

6569 12/1/10 80,450 0 55,184 

6569 12/2/10 77,860 0 * 

6569 12/3/10 78,525 0 * 

6569 12/4/10 78,971 0 38,519 

6569 12/5/10 77,623 0 40,032 

6569 12/6/10 80,170 0 * 

6569 12/7/10 77,766 0 68,048 

6569 12/8/10 79,627 0 42,024 

6569 12/9/10 79,525 0 46,836 

6569 12/10/10 90,845 0 72,164 

6569 12/11/10 97,928 0 93,946 

6569 12/12/10 96,248 0 82,078 

6569 12/13/10 103,831 0 58,670 

6569 12/14/10 115,731 0 102,291 

6569 12/15/10 119,194 0 125,522 

6569 12/16/10 131,236 0 111,103 

6569 12/17/10 143,028 0 105,932 

6569 12/18/10 143,124 0 122,269 

6569 12/19/10 140,686 0 125,456 

6569 12/20/10 146,051 0 111,126 

6569 12/21/10 151,506 0 129,959 

6569 12/22/10 147,581 0 123,339 

6569 12/23/10 145,040 0 119,704 

6569 12/24/10 132,887 0 131,357 

6569 12/25/10 130,977 0 130,101 

6569 12/26/10 130,908 0 126,660 

6569 12/27/10 130,001 0 107,832 

6569 12/28/10 128,746 0 116,087 

6569 12/29/10 122,104 0 115,750 

6569 12/30/10 107,461 0 77,954 

6569 12/31/10 104,195 0 96,515 

6569 1/1/11 108,050 0 89,267 

6569 1/2/11 106,746 0 82,695 

6569 1/3/11 91,481 0 91,270 

6569 1/4/11 86,329 0 77,309 

6569 1/5/11 87,258 0 74,804 

6569 1/6/11 98,259 0 59,826 

6569 1/7/11 96,989 0 90,105 

6569 1/8/11 93,850 0 95,492 

6569 1/9/11 87,237 0 88,360 
Table E4-9. FGD Wastewater Treatment System Flow Rate during Sampling Period, Dickerson 

Episode 

Number Date 

FGD Wastewater Treatment System Flow Rates 

(gpd) 

Chemical 

Precipitation 

Effluent 

Dilution Water 

Addition Prior to 

Biological Treatment 

System 

Biological 

Treatment System 

Effluent 

6569 1/10/11 90,516 0 73,861 

6569 1/11/11 84,640 0 86,543 

6569 1/12/11 85,048 0 72,430 

6569 1/13/11 88,955 0 69,931 

6569 1/14/11 89,601 0 81,500 

6569 1/15/11 102,333 0 91,380 

6569 1/16/11 106,732 0 89,591 

6569 1/17/11 106,966 0 108,218 

6569 1/18/11 114,950 0 97,875 

6569 1/19/11 121,130 0 81,948 

6569 1/20/11 69,087 0 64,822 

6569 1/21/11 116,450 0 116,730 

6569 1/22/11 126,527 0 114,143 

6569 1/23/11 130,219 0 109,878 

6569 1/24/11 113,871 0 91,443 

6569 1/25/11 98,485 0 94,663 

6569 1/26/11 109,031 0 113,100 

6569 1/27/11 99,320 0 81,873 

6569 1/28/11 90,893 0 97,304 

6569 1/29/11 89,532 0 93,304 

6569 1/30/11 87,329 0 104,292 

6569 1/31/11 114,960 0 108,963 

6569 2/1/11 120,610 0 102,346 

6569 2/2/11 128,402 0 77,660 

6569 2/3/11 127,802 0 129,681 

6569 2/4/11 121,765 0 104,942 

6569 2/5/11 129,773 0 101,354 

6569 2/6/11 129,287 0 100,741 

6569 2/7/11 131,251 0 114,879 

6569 2/8/11 126,259 0 103,253 

6569 2/9/11 130,857 0 129,053 
Section 5

Analytical Data
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. B – Analyte was found in the blank and sample. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. s – Seed correction blank recovery low. 

Table E5-1. Influent to FGD Wastewater Treatment System, Dickerson 

Analyte Units Method 

Influent to FGD Wastewater Treatment S

Set 1 Set 2 Set 3 

ClassicalsAmmonia mg/L 350.1 3.90 3.80 6.70 Nitrate Nitrite as N mg/L 353.2 83.0 94.0 94.0 Nitrogen, Total Kjeldahl mg/L 351.2 23.0 B, Min 17.0 15.0 Biochemical Oxygen Demand mg/L 5210B NQ (2.50) s 40.0 26.0 Chemical Oxygen Demand mg/L 410.4 260 450 310 Chloride mg/L 300.0 9,900 9,800 9,800 Sulfate mg/L 300.0 1,600 1,500 1,500 Cyanide, Total mg/L 4500 CN E 0.540 1.10 3.10 Total Dissolved Solids mg/L 2540C 23,000 B 15,000 20,000 Total Suspended Solids mg/L 2540D 4,100 4,200 5,600 Phosphorus, Total mg/L 365.1 1.90 1.20 B 2.50 Total MetalsAluminum ug/L 200.7 120,000 69,000 77,000 Antimony ug/L 200.8 21.0 14.0 10.0 Arsenic ug/L 200.8 170 120 92.0 Barium ug/L 200.7 4,000 1,700 1,600 Beryllium ug/L 200.7 13.0 8.60 5.60 Boron ug/L 200.7 220,000 B 170,000 B 190,000 Cadmium ug/L 200.8 19.0 15.0 24.0 
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. B – Analyte was found in the blank and sample. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. s – Seed correction blank recovery low. 

Table E5-1. Influent to FGD Wastewater Treatment System, Dickerson 

Analyte Units Method 

Influent to FGD Wastewater Treatment S

Set 1 Set 2 Set 3 

Calcium ug/L 200.7 3,600,000 3,700,000 B 3,900,000 Chromium ug/L 200.8 610 350 310 Cobalt ug/L 200.7 100 99.0 100 Copper ug/L 200.8 650 540 600 Iron ug/L 200.7 150,000 95,000 88,000 Lead ug/L 200.8 160 110 98.0 Magnesium ug/L 200.7 2,000,000 B 1,600,000 B 1,800,000 Manganese ug/L 200.7 12,000 B 11,000 B 10,000 Mercury ng/L 1631E 81,400 31,300 30,100 Molybdenum ug/L 200.7 320 140 320 Nickel ug/L 200.8 600 560 510 Selenium ug/L 200.8 2,800 2,400 1,300 Silver ug/L 200.8 ND (2.00) ND (2.00) ND (2.00) Sodium ug/L 200.7 300,000 B 180,000 210,000 Thallium ug/L 200.8 2.70 4.40 4.20 Tin ug/L 200.7 NQ (200) NQ (200) NQ (200) Titanium ug/L 200.7 5,200 2,400 2,600 Vanadium ug/L 200.8 410 230 200 Zinc ug/L 200.7 1,300 1,200 2,500 
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. S – Seed correction blank recovery low. 

Table E5-2. Influent to SBR System, Dickerson 

Analyte Units Method 

Influent to SBR System (SP-2) 

Set 1 Set 2 Set 

ClassicalsAmmonia mg/L 350.1 3.20 2.30 4.00 Nitrate Nitrite as N mg/L 353.2 61.0 11.0 57.0 Nitrogen, Total Kjeldahl mg/L 351.2 12.0 B, Min 8.80 3.50 Biochemical Oxygen Demand mg/L 5210B 5.80 s 61.0 17.0 Chemical Oxygen Demand mg/L 410.4 220 260 E,F 100 Chloride mg/L 300.0 9,100 6,300 7,800 Sulfate mg/L 300.0 1,600 1,500 1,400 Cyanide, Total mg/L 4500 CN E NQ (0.100) NQ (0.100) F 0.570 Total Dissolved Solids mg/L 2540C 20,000 B 13,000 14,000 Total Suspended Solids mg/L 2540D 29.0 56.0 17.0 Phosphorus, Total mg/L 365.1 NQ (0.0500) 0.110 B NQ (0.05Total MetalsAluminum ug/L 200.7 580 450 320 Antimony ug/L 200.8 4.70 2.70 3.20 Arsenic ug/L 200.8 NQ (4.00) NQ (4.00) NQ (4.0Barium ug/L 200.7 350 230 320 Beryllium ug/L 200.7 ND (2.00) ND (2.00) ND (2.0
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. S – Seed correction blank recovery low. 

Table E5-2. Influent to SBR System, Dickerson 

Analyte Units Method 

Influent to SBR System (SP-2) 

Set 1 Set 2 Set 

Boron ug/L 200.7 170,000 B 110,000 B,4 130,00Cadmium ug/L 200.8 NQ (4.00) ND (4.00) ND (4.0Calcium ug/L 200.7 3,300,000 2,300,000 B,4 3,100,0Chromium ug/L 200.8 NQ (8.00) ND (8.00) ND (8.0Cobalt ug/L 200.7 NQ (20.0) NQ (20.0) NQ (20Copper ug/L 200.8 130 6.50 16.0 Iron ug/L 200.7 1,000 1,200 430 Lead ug/L 200.8 5.60 NQ (2.00) NQ (2.0Magnesium ug/L 200.7 1,700,000 B 970,000 B,4 1,100,0Manganese ug/L 200.7 98.0 B 1,300 B 230 Mercury ng/L 1631E 667 910 270 Molybdenum ug/L 200.7 220 70.0 200 Nickel ug/L 200.8 71.0 79.0 22.0 Selenium ug/L 200.8 190 370 4 170 Silver ug/L 200.8 ND (2.00) ND (2.00) F ND (2.0Sodium ug/L 200.7 300,000 B 170,000 180,00Thallium ug/L 200.8 NQ (2.00) ND (2.00) ND (2.0Tin ug/L 200.7 ND (200) ND (200) ND (20
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. S – Seed correction blank recovery low. 

Table E5-2. Influent to SBR System, Dickerson 

Analyte Units Method 

Influent to SBR System (SP-2) 

Set 1 Set 2 Set 

Titanium ug/L 200.7 43.0 27.0 29.0 Vanadium ug/L 200.8 NQ (10.0) NQ (10.0) NQ (10Zinc ug/L 200.7 44.0 NQ (40.0) 47.0 
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. S – Seed correction blank recovery low. 

Table E5-3. Effluent from SBR System, Dickerson 

Analyte Units Method 

Effluent from the SBR System (SP-

Set 1 Set 2 Set 3 

ClassicalsAmmonia mg/L 350.1 NQ (1.00) NQ (1.00) NQ (1.00) Nitrate Nitrite as N mg/L 353.2 0.130 0.140 ND (1.00) Nitrogen, Total Kjeldahl mg/L 351.2 16.0 B, Min 24.0 3.80 Biochemical Oxygen Demand mg/L 5210B 6.20 s ND (2.00) 5.90 Chemical Oxygen Demand mg/L 410.4 210 630 230 Chloride mg/L 300.0 8,600 5,900 8,300 Sulfate mg/L 300.0 1,700 1,600 1,500 Cyanide, Total mg/L 4500 CN E NQ (0.100) NQ (0.100) NQ (0.100) Total Dissolved Solids mg/L 2540C 18,000 B 11,000 17,000 Total Suspended Solids mg/L 2540D 14.0 62.0 6.00 Phosphorus, Total mg/L 365.1 NQ (0.0500) 0.200 B NQ (0.0500Total MetalsAluminum ug/L 200.7 1,400 1,200 430 Antimony ug/L 200.8 4.30 NQ (2.00) 3.30 Arsenic ug/L 200.8 NQ (4.00) 5.20 NQ (4.00) Barium ug/L 200.7 280 160 320 
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. S – Seed correction blank recovery low. 

Table E5-3. Effluent from SBR System, Dickerson 

Analyte Units Method 

Effluent from the SBR System (SP-

Set 1 Set 2 Set 3 

Beryllium ug/L 200.7 ND (2.00) ND (2.00) ND (2.00) Boron ug/L 200.7 180,000 B 100,000 B 120,000 Cadmium ug/L 200.8 ND (4.00) ND (4.00) ND (4.00) Calcium ug/L 200.7 3,000,000 2,100,000 B 3,100,000 Chromium ug/L 200.8 ND (8.00) ND (8.00) ND (8.00) Cobalt ug/L 200.7 NQ (20.0) NQ (20.0) NQ (20.0) Copper ug/L 200.8 51.0 NQ (4.00) 9.60 Iron ug/L 200.7 NQ (200) 480 NQ (200) Lead ug/L 200.8 NQ (2.00) ND (2.00) ND (2.00) Magnesium ug/L 200.7 1,500,000 B 910,000 B 1,100,000 Manganese ug/L 200.7 73.0 B 1,100 B 220 Mercury ng/L 1631E 52.5 68.4 8.07 Molybdenum ug/L 200.7 230 68.0 200 Nickel ug/L 200.8 89.0 70.0 17.0 Selenium ug/L 200.8 110 51.0 110 Silver ug/L 200.8 ND (2.00) ND (2.00) ND (2.00) Sodium ug/L 200.7 300,000 B 190,000 200,000 Thallium ug/L 200.8 NQ (2.00) ND (2.00) ND (2.00) 
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. Min – Minimum value. S – Seed correction blank recovery low. 

Table E5-3. Effluent from SBR System, Dickerson 

Analyte Units Method 

Effluent from the SBR System (SP-

Set 1 Set 2 Set 3 

Tin ug/L 200.7 ND (200) ND (200) ND (200) Titanium ug/L 200.7 ND (20.0) NQ (20.0) NQ (20.0) Vanadium ug/L 200.8 NQ (10.0) NQ (10.0) NQ (10.0) Zinc ug/L 200.7 NQ (40.0) NQ (40.0) NQ (40.0) 
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 

Table E5-4. Classical Pollutants 3-Set Average Data Summary for FGD Wastewater Treatment Sys

Analyte Unit Method

Influent to FGD 

Wastewater Treatment 

System (SP-1) 3-Set Average 

Influent to SBR 

System (SP-2) 3-Set Average 

E

ClassicalsAmmonia mg/L 350.1 4.80 3.17 Nitrate Nitrite as N mg/L 353.2 90.3 43.0 Nitrogen, Total Kjeldahl mg/L 351.2 18.3 8.10 Biochemical Oxygen Demand mg/L 5210B < 22.4 27.9 Chemical Oxygen Demand mg/L 410.4 340 193 Chloride mg/L 300.0 9,830 7,730 Sulfate mg/L 300.0 1,530 1,500 Cyanide, Total mg/L 4500 CN E 1.58 < 0.223 Total Dissolved Solids mg/L 2540C 19,300 15,700 Total Suspended Solids mg/L 2540D 4,630 34.0 Phosphorus, Total mg/L 365.1 1.87 < 0.0533 
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 

Table E5-5. Metal Pollutants 3-Set Average Data Summary for FGD Wastewater Treatment System, 

Analyte Unit Method

Influent to FGD 

Wastewater Treatment 

System (SP-1) 3-Set Average 

Influent to SBR System 

(SP-2) 

3-Set Average 

Effluent 

System 3-Set A

Total MetalsAluminum ug/L 200.7 88,700 450 1,0Antimony ug/L 200.8 15.0 3.53 < 2Arsenic ug/L 200.8 127 NQ (4.00) < 3Barium ug/L 200.7 2,430 300 2Beryllium ug/L 200.7 9.07 ND (2.00) ND (Boron ug/L 200.7 193,000 137,000 133Cadmium ug/L 200.8 19.3 NQ (4.00) ND (Calcium ug/L 200.7 3,730,000 2,900,000 2,73Chromium ug/L 200.8 423 NQ (8.00) ND (Cobalt ug/L 200.7 99.7 NQ (20.0) NQ (Copper ug/L 200.8 597 50.8 < 2Iron ug/L 200.7 111,000 877 < 2Lead ug/L 200.8 123 < 2.53 NQ (Magnesium ug/L 200.7 1,800,000 1,260,000 1,17Manganese ug/L 200.7 11,000 543 4Mercury ng/L 1631E 47,600 616 43Molybdenum ug/L 200.7 260 163 1Nickel ug/L 200.8 557 57.3 58Selenium ug/L 200.8 2,170 243 90Silver ug/L 200.8 ND (2.00) ND (2.00) ND (
< - Average result includes at least one value measured below the quantitation limit. (Calculation uses 1⁄2 the quantitation limit for values below the qu

ND – Not detected (number in parentheses is the quantitation limit). NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit

presented in Tables E5-7 through E5-22 with a J flag designation. A “NQ” for the 3-set average result indicates that all results were below the quantita

result is a J-value. 

Table E5-5. Metal Pollutants 3-Set Average Data Summary for FGD Wastewater Treatment System, 

Analyte Unit Method

Influent to FGD 

Wastewater Treatment 

System (SP-1) 3-Set Average 

Influent to SBR System 

(SP-2) 

3-Set Average 

Effluent 

System 3-Set A

Sodium ug/L 200.7 230,000 217,000 230Thallium ug/L 200.8 3.77 NQ (2.00) NQ (Tin ug/L 200.7 NQ (200) ND (200) ND Titanium ug/L 200.7 3,400 33.0 NQ (Vanadium ug/L 200.8 280 NQ (10.0) NQ (Zinc ug/L 200.7 1,670 < 37.0 NQ (
Table E5-6. Field Blank Analytical Results, Dickerson 

Analyte Sample Point Method Unit Concentration 

Total Metals 

Boron 

Effluent from SBR System 

Field Blank - Set 1 200.7 ug/L 200 

Mercury 

Effluent from SBR System 

Field Blank - Set 2 1631E ng/L 0.730 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. Min – Minimum value. s – Seed correction blank recovery low. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-7. Influent to FGD Wastewater Treatment System, Set 1 Analytical Results, Dick

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Co

Classicals Ammonia 350.1 mg/L 1 0.055 1 3.Nitrate Nitrite as N 353.2 mg/L 10 0.19 1 83 Nitrogen, Total Kjeldahl 351.2 mg/L 1 0.38 5 23 Biochemical Oxygen Demand 5210B mg/L 1 0.3 2.5 2.Chemical Oxygen Demand 410.4 mg/L 5 20 100 26Chloride 300.0 mg/L 500 130 1,500 9,9Sulfate 300.0 mg/L 50 12 250 1,6Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.5Total Dissolved Solids 2540C mg/L 1 47 100 23,0Total Suspended Solids 2540D mg/L 1 92 330 4,1Phosphorus, Total 365.1 mg/L 5 0.025 0.25 1.Total MetalsAluminum 200.7 ug/L 2 9.4 200 120,Antimony 200.8 ug/L 2 0.72 2 21 Arsenic 200.8 ug/L 10 6.1 20 17Barium 200.7 ug/L 2 2.5 20 4,0Beryllium 200.7 ug/L 2 0.71 2 13 Boron 200.7 ug/L 250 830 25,000 220,Cadmium 200.8 ug/L 2 1.2 4 19 Calcium 200.7 ug/L 50 1,700 10,000 3,600Chromium 200.8 ug/L 2 3.3 8 61
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. Min – Minimum value. s – Seed correction blank recovery low. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-7. Influent to FGD Wastewater Treatment System, Set 1 Analytical Results, Dick

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Co

Cobalt 200.7 ug/L 2 1.1 20 10Copper 200.8 ug/L 2 0.96 4 65Iron 200.7 ug/L 2 32 200 150,Lead 200.8 ug/L 2 0.73 2 16Magnesium 200.7 ug/L 50 540 10,000 2,000Manganese 200.7 ug/L 2 0.51 20 12,0Mercury 1631E ng/L 100,000 24,800 52,000 81,4Molybdenum 200.7 ug/L 2 1.6 40 32Nickel 200.8 ug/L 2 0.89 4 60Selenium 200.8 ug/L 10 3.1 20 2,8Silver 200.8 ug/L 2 0.59 2 ND Sodium 200.7 ug/L 2 180 10,000 300,Thallium 200.8 ug/L 2 0.47 2 2.Tin 200.7 ug/L 2 4.8 200 29 Titanium 200.7 ug/L 2 1.6 20 5,2Vanadium 200.8 ug/L 2 1.7 10 41Zinc 200.7 ug/L 2 9.1 40 1,3
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-8. Influent to FGD Wastewater Treatment System, Set 2 Analytical Results, Dick

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL C

Classicals Ammonia 350.1 mg/L 1 0.055 1 Nitrate Nitrite as N 353.2 mg/L 10 0.19 1 Nitrogen, Total Kjeldahl 351.2 mg/L 2 0.15 2 Biochemical Oxygen Demand 5210B mg/L 1 2.8 24 Chemical Oxygen Demand 410.4 mg/L 5 20 100 Chloride 300.0 mg/L 500 130 1,500 Sulfate 300.0 mg/L 100 23 500 Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 Total Dissolved Solids 2540C mg/L 1 94 200 Total Suspended Solids 2540D mg/L 1 28 100 Phosphorus, Total 365.1 mg/L 5 0.025 0.25 Total MetalsAluminum 200.7 ug/L 2 9.4 200 Antimony 200.8 ug/L 2 0.72 2 Arsenic 200.8 ug/L 2 1.2 4 Barium 200.7 ug/L 2 2.5 20 Beryllium 200.7 ug/L 2 0.71 2 Boron 200.7 ug/L 50 170 5,000 Cadmium 200.8 ug/L 5 2.9 10 Calcium 200.7 ug/L 50 1,700 10,000 Chromium 200.8 ug/L 2 3.3 8 Cobalt 200.7 ug/L 2 1.1 20 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-8. Influent to FGD Wastewater Treatment System, Set 2 Analytical Results, Dick

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL C

Copper 200.8 ug/L 2 0.96 4 Iron 200.7 ug/L 2 32 200 Lead 200.8 ug/L 2 0.73 2 Magnesium 200.7 ug/L 50 540 10,000 Manganese 200.7 ug/L 50 13 500 Mercury 1631E ng/L 4,000 994 2,080 Molybdenum 200.7 ug/L 2 1.6 40 Nickel 200.8 ug/L 2 0.89 4 Selenium 200.8 ug/L 5 1.6 10 Silver 200.8 ug/L 2 0.59 2 Sodium 200.7 ug/L 2 180 10,000 Thallium 200.8 ug/L 2 0.47 2 Tin 200.7 ug/L 2 4.8 200 Titanium 200.7 ug/L 2 1.6 20 Vanadium 200.8 ug/L 2 1.7 10 Zinc 200.7 ug/L 2 9.1 40 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. F – MS and/or MSD not within laboratory control limits. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-9. Influent to FGD Wastewater Treatment System, Set 3 Analytical Results, Dick

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Classicals Ammonia 350.1 mg/L 1 0.055 1 Nitrate Nitrite as N 353.2 mg/L 10 0.19 1 Nitrogen, Total Kjeldahl 351.2 mg/L 5 0.38 5 Biochemical Oxygen Demand 5210B mg/L 1 1.2 10 Chemical Oxygen Demand 410.4 mg/L 5 20 100 Chloride 300.0 mg/L 500 130 1,500 Sulfate 300.0 mg/L 50 12 250 Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 Total Dissolved Solids 2540C mg/L 1 94 200 Total Suspended Solids 2540D mg/L 1 55 200 Phosphorus, Total 365.1 mg/L 5 0.025 0.25 Total MetalsAluminum 200.7 ug/L 2 9.4 200 Antimony 200.8 ug/L 2 0.72 2 Arsenic 200.8 ug/L 2 1.2 4 Barium 200.7 ug/L 2 2.5 20 Beryllium 200.7 ug/L 2 0.71 2 Boron 200.7 ug/L 50 170 5,000 Cadmium 200.8 ug/L 2 1.2 4 Calcium 200.7 ug/L 50 1,700 10,000 Chromium 200.8 ug/L 2 3.3 8 Cobalt 200.7 ug/L 2 1.1 20 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. F – MS and/or MSD not within laboratory control limits. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-9. Influent to FGD Wastewater Treatment System, Set 3 Analytical Results, Dick

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Copper 200.8 ug/L 2 0.96 4 Iron 200.7 ug/L 2 32 200 Lead 200.8 ug/L 2 0.73 2 Magnesium 200.7 ug/L 50 540 10,000 Manganese 200.7 ug/L 2 0.51 20 Mercury 1631E ng/L 20,000 4,970 10,400 Molybdenum 200.7 ug/L 2 1.6 40 Nickel 200.8 ug/L 2 0.89 4 Selenium 200.8 ug/L 2 0.62 4 Silver 200.8 ug/L 2 0.59 2 Sodium 200.7 ug/L 2 180 10,000 Thallium 200.8 ug/L 2 0.47 2 Tin 200.7 ug/L 2 4.8 200 Titanium 200.7 ug/L 2 1.6 20 Vanadium 200.8 ug/L 2 1.7 10 Zinc 200.7 ug/L 2 9.1 40 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. Min – Minimum value. s – Seed correction blank recovery low. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-10. Influent to SBR System, Set 1 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Co

Classicals Ammonia 350.1 mg/L 1 0.055 1 3Nitrate Nitrite as N 353.2 mg/L 10 0.19 1 6Nitrogen, Total Kjeldahl 351.2 mg/L 2 0.15 2 1Biochemical Oxygen Demand 5210B mg/L 1 0.3 2.5 5Chemical Oxygen Demand 410.4 mg/L 2 8.1 40 22Chloride 300.0 mg/L 500 130 1,500 9,1Sulfate 300.0 mg/L 50 12 250 1,6Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.0Total Dissolved Solids 2540C mg/L 1 47 100 20,Total Suspended Solids 2540D mg/L 1 1.1 4 2Phosphorus, Total 365.1 mg/L 1 0.005 0.05 0.0Total MetalsAluminum 200.7 ug/L 2 9.4 200 58Antimony 200.8 ug/L 2 0.72 2 4Arsenic 200.8 ug/L 2 1.2 4 3Barium 200.7 ug/L 2 2.5 20 35Beryllium 200.7 ug/L 2 0.71 2 ND Boron 200.7 ug/L 250 830 25,000 170Cadmium 200.8 ug/L 2 1.2 4 1Calcium 200.7 ug/L 50 1,700 10,000 3,300
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. Min – Minimum value. s – Seed correction blank recovery low. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-10. Influent to SBR System, Set 1 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Co

Chromium 200.8 ug/L 2 3.3 8 4Cobalt 200.7 ug/L 2 1.1 20 2 Copper 200.8 ug/L 2 0.96 4 13Iron 200.7 ug/L 2 32 200 1,0Lead 200.8 ug/L 2 0.73 2 5Magnesium 200.7 ug/L 50 540 10,000 1,700Manganese 200.7 ug/L 2 0.51 20 9Mercury 1631E ng/L 200 48.3 101 66Molybdenum 200.7 ug/L 2 1.6 40 22Nickel 200.8 ug/L 2 0.89 4 7Selenium 200.8 ug/L 5 1.6 10 19Silver 200.8 ug/L 2 0.59 2 ND Sodium 200.7 ug/L 2 180 10,000 300Thallium 200.8 ug/L 2 0.47 2 1Tin 200.7 ug/L 2 4.8 200 ND (Titanium 200.7 ug/L 2 1.6 20 4Vanadium 200.8 ug/L 2 1.7 10 5Zinc 200.7 ug/L 2 9.1 40 4

. 
ND – Not detected (number in parentheses is the quantitation limit). 

4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-11. Influent to SBR System, Set 2 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Classicals Ammonia 350.1 mg/L 1 0.055 1 Nitrate Nitrite as N 353.2 mg/L 2 0.038 0.2 Nitrogen, Total Kjeldahl 351.2 mg/L 2 0.15 2 Biochemical Oxygen Demand 5210B mg/L 1 2.8 24 Chemical Oxygen Demand 410.4 mg/L 2 8.1 40 Chloride 300.0 mg/L 200 51 600 Sulfate 300.0 mg/L 100 23 500 Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 Total Dissolved Solids 2540C mg/L 1 47 100 Total Suspended Solids 2540D mg/L 1 1.1 4 Phosphorus, Total 365.1 mg/L 1 0.005 0.05 Total MetalsAluminum 200.7 ug/L 2 9.4 200 Antimony 200.8 ug/L 2 0.72 2 Arsenic 200.8 ug/L 2 1.2 4 Barium 200.7 ug/L 2 2.5 20 Beryllium 200.7 ug/L 2 0.71 2 Boron 200.7 ug/L 50 170 5,000 Cadmium 200.8 ug/L 2 1.2 4 Calcium 200.7 ug/L 50 1,700 10,000 2
ND – Not detected (number in parentheses is the quantitation limit). 

4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. E – MS and/or MSD exceeded the calibration range. F – MS and/or MSD not within laboratory control limits. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-11. Influent to SBR System, Set 2 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Chromium 200.8 ug/L 2 3.3 8 Cobalt 200.7 ug/L 2 1.1 20 Copper 200.8 ug/L 2 0.96 4 Iron 200.7 ug/L 2 32 200 Lead 200.8 ug/L 2 0.73 2 Magnesium 200.7 ug/L 50 540 10,000 Manganese 200.7 ug/L 2 0.51 20 Mercury 1631E ng/L 100 24.8 52 Molybdenum 200.7 ug/L 2 1.6 40 Nickel 200.8 ug/L 5 2.2 10 Selenium 200.8 ug/L 5 1.6 10 Silver 200.8 ug/L 2 0.59 2 Sodium 200.7 ug/L 2 180 10,000 Thallium 200.8 ug/L 2 0.47 2 Tin 200.7 ug/L 2 4.8 200 NTitanium 200.7 ug/L 2 1.6 20 Vanadium 200.8 ug/L 2 1.7 10 Zinc 200.7 ug/L 2 9.1 40 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-12. Influent to SBR System, Set 3 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Classicals Ammonia 350.1 mg/L 1 0.055 1 Nitrate Nitrite as N 353.2 mg/L 10 0.19 1 Nitrogen, Total Kjeldahl 351.2 mg/L 1 0.077 1 Biochemical Oxygen Demand 5210B mg/L 1 0.59 5 Chemical Oxygen Demand 410.4 mg/L 1 4.1 20 Chloride 300.0 mg/L 200 51 600 Sulfate 300.0 mg/L 50 12 250 Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 Total Dissolved Solids 2540C mg/L 1 94 200 Total Suspended Solids 2540D mg/L 1 1.1 4 Phosphorus, Total 365.1 mg/L 1 0.005 0.05 Total MetalsAluminum 200.7 ug/L 2 9.4 200 Antimony 200.8 ug/L 2 0.72 2 Arsenic 200.8 ug/L 2 1.2 4 Barium 200.7 ug/L 2 2.5 20 Beryllium 200.7 ug/L 2 0.71 2 Boron 200.7 ug/L 50 170 5,000 Cadmium 200.8 ug/L 2 1.2 4 Calcium 200.7 ug/L 50 1,700 10,000 3Chromium 200.8 ug/L 2 3.3 8 Cobalt 200.7 ug/L 2 1.1 20 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-12. Influent to SBR System, Set 3 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Copper 200.8 ug/L 2 0.96 4 Iron 200.7 ug/L 2 32 200 Lead 200.8 ug/L 2 0.73 2 Magnesium 200.7 ug/L 50 540 10,000 Manganese 200.7 ug/L 2 0.51 20 Mercury 1631E ng/L 100 24.1 50.5 Molybdenum 200.7 ug/L 2 1.6 40 Nickel 200.8 ug/L 2 0.89 4 Selenium 200.8 ug/L 2 0.62 4 Silver 200.8 ug/L 2 0.59 2 Sodium 200.7 ug/L 2 180 10,000 Thallium 200.8 ug/L 2 0.47 2 Tin 200.7 ug/L 2 4.8 200 NTitanium 200.7 ug/L 2 1.6 20 Vanadium 200.8 ug/L 2 1.7 10 Zinc 200.7 ug/L 2 9.1 40 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. Min – Minimum value. s – Seed correction blank recovery low. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-13. Effluent from SBR System, Set 1 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL C

Classicals Ammonia 350.1 mg/L 1 0.055 1 0Nitrate Nitrite as N 353.2 mg/L 1 0.019 0.1 0Nitrogen, Total Kjeldahl 351.2 mg/L 2 0.15 2 Biochemical Oxygen Demand 5210B mg/L 1 0.3 2.5 6Chemical Oxygen Demand 410.4 mg/L 2 8.1 40 2Chloride 300.0 mg/L 500 130 1,500 8,Sulfate 300.0 mg/L 50 12 250 1,Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.Total Dissolved Solids 2540C mg/L 1 47 100 18Total Suspended Solids 2540D mg/L 1 1.1 4 Phosphorus, Total 365.1 mg/L 1 0.005 0.05 0.Total MetalsAluminum 200.7 ug/L 2 9.4 200 1,Antimony 200.8 ug/L 2 0.72 2 4Arsenic 200.8 ug/L 2 1.2 4 2Barium 200.7 ug/L 2 2.5 20 2Beryllium 200.7 ug/L 2 0.71 2 ND Boron 200.7 ug/L 250 830 25,000 180Cadmium 200.8 ug/L 2 1.2 4 ND Calcium 200.7 ug/L 50 1,700 10,000 3,00Chromium 200.8 ug/L 2 3.3 8 ND Cobalt 200.7 ug/L 2 1.1 20 2Copper 200.8 ug/L 2 0.96 4 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. Min – Minimum value. s – Seed correction blank recovery low. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-13. Effluent from SBR System, Set 1 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL C

Iron 200.7 ug/L 2 32 200 1Lead 200.8 ug/L 2 0.73 2 1Magnesium 200.7 ug/L 50 540 10,000 1,50Manganese 200.7 ug/L 2 0.51 20 7Mercury 1631E ng/L 20 4.83 10.1 5Molybdenum 200.7 ug/L 2 1.6 40 2Nickel 200.8 ug/L 2 0.89 4 Selenium 200.8 ug/L 2 0.62 4 1Silver 200.8 ug/L 2 0.59 2 ND Sodium 200.7 ug/L 2 180 10,000 300Thallium 200.8 ug/L 2 0.47 2 1Tin 200.7 ug/L 2 4.8 200 ND Titanium 200.7 ug/L 2 1.6 20 ND Vanadium 200.8 ug/L 2 1.7 10 3Zinc 200.7 ug/L 2 9.1 40 

. 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-14. Effluent from SBR System, Set 2 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Classicals Ammonia 350.1 mg/L 1 0.055 1 Nitrate Nitrite as N 353.2 mg/L 1 0.019 0.1 Nitrogen, Total Kjeldahl 351.2 mg/L 5 0.38 5 Biochemical Oxygen Demand 5210B mg/L 1 0.24 2 Chemical Oxygen Demand 410.4 mg/L 5 20 100 Chloride 300.0 mg/L 200 51 600 Sulfate 300.0 mg/L 100 23 500 Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 Total Dissolved Solids 2540C mg/L 1 47 100 Total Suspended Solids 2540D mg/L 1 2.8 10 Phosphorus, Total 365.1 mg/L 1 0.005 0.05 Total MetalsAluminum 200.7 ug/L 2 9.4 200 Antimony 200.8 ug/L 2 0.72 2 Arsenic 200.8 ug/L 2 1.2 4 Barium 200.7 ug/L 2 2.5 20 Beryllium 200.7 ug/L 2 0.71 2 Boron 200.7 ug/L 50 170 5,000 Cadmium 200.8 ug/L 2 1.2 4 Calcium 200.7 ug/L 50 1,700 10,000 Chromium 200.8 ug/L 2 3.3 8 Cobalt 200.7 ug/L 2 1.1 20 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-14. Effluent from SBR System, Set 2 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Copper 200.8 ug/L 2 0.96 4 Iron 200.7 ug/L 2 32 200 Lead 200.8 ug/L 2 0.73 2 Magnesium 200.7 ug/L 50 540 10,000 Manganese 200.7 ug/L 2 0.51 20 Mercury 1631E ng/L 20 4.83 10.1 Molybdenum 200.7 ug/L 2 1.6 40 Nickel 200.8 ug/L 2 0.89 4 Selenium 200.8 ug/L 2 0.62 4 Silver 200.8 ug/L 2 0.59 2 Sodium 200.7 ug/L 2 180 10,000 Thallium 200.8 ug/L 2 0.47 2 Tin 200.7 ug/L 2 4.8 200 Titanium 200.7 ug/L 2 1.6 20 Vanadium 200.8 ug/L 2 1.7 10 Zinc 200.7 ug/L 2 9.1 40 
ND – Not detected (number in parentheses is the quantitation limit). 

4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. F – MS and/or MSD not within laboratory control limits. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-15. Effluent from SBR System, Set 3 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Classicals Ammonia 350.1 mg/L 1 0.055 1 Nitrate Nitrite as N 353.2 mg/L 10 0.19 1 Nitrogen, Total Kjeldahl 351.2 mg/L 1 0.077 1 Biochemical Oxygen Demand 5210B mg/L 1 0.3 2.5 Chemical Oxygen Demand 410.4 mg/L 2 8.1 40 Chloride 300.0 mg/L 200 51 600 Sulfate 300.0 mg/L 50 12 250 Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 Total Dissolved Solids 2540C mg/L 1 94 200 Total Suspended Solids 2540D mg/L 1 1.1 4 Phosphorus, Total 365.1 mg/L 1 0.005 0.05 Total MetalsAluminum 200.7 ug/L 2 9.4 200 Antimony 200.8 ug/L 2 0.72 2 Arsenic 200.8 ug/L 2 1.2 4 Barium 200.7 ug/L 2 2.5 20 Beryllium 200.7 ug/L 2 0.71 2 Boron 200.7 ug/L 50 170 5,000 Cadmium 200.8 ug/L 2 1.2 4 Calcium 200.7 ug/L 50 1,700 10,000 Chromium 200.8 ug/L 2 3.3 8 
ND – Not detected (number in parentheses is the quantitation limit). 

4 – MS and/or MSD did not meet laboratory criteria, but sample concentration is four times greater than the matrix spike amount, so control limits are 

B – Analyte was found in the blank and sample. F – MS and/or MSD not within laboratory control limits. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-15. Effluent from SBR System, Set 3 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL 

Cobalt 200.7 ug/L 2 1.1 20 Copper 200.8 ug/L 2 0.96 4 Iron 200.7 ug/L 2 32 200 Lead 200.8 ug/L 2 0.73 2 Magnesium 200.7 ug/L 50 540 10,000 Manganese 200.7 ug/L 2 0.51 20 Mercury 1631E ng/L 1 0.24 0.5 Molybdenum 200.7 ug/L 2 1.6 40 Nickel 200.8 ug/L 2 0.89 4 Selenium 200.8 ug/L 2 0.62 4 Silver 200.8 ug/L 2 0.59 2 Sodium 200.7 ug/L 2 180 10,000 Thallium 200.8 ug/L 2 0.47 2 Tin 200.7 ug/L 2 4.8 200 Titanium 200.7 ug/L 2 1.6 20 Vanadium 200.8 ug/L 2 1.7 10 Zinc 200.7 ug/L 2 9.1 40 
ND – Not detected (number in parentheses is the quantitation limit). 

^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits. B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-16. Influent to FGD Wastewater Treatment System Field Blank, Set 1 Analytical R

Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concen

Total MetalsAluminum 200.7 ug/L 2 9.4 200 13 Antimony 200.8 ug/L 2 0.72 2 ND (2) Arsenic 200.8 ug/L 2 1.2 4 ND (4) Barium 200.7 ug/L 2 2.5 20 ND (20) Beryllium 200.7 ug/L 2 0.71 2 ND (2) Boron 200.7 ug/L 2 6.7 200 21 Cadmium 200.8 ug/L 2 1.2 4 ND (4) Calcium 200.7 ug/L 2 69 400 ND (400) Chromium 200.8 ug/L 2 3.3 8 ND (8) Cobalt 200.7 ug/L 2 1.1 20 ND (20) Copper 200.8 ug/L 2 0.96 4 ND (4) Iron 200.7 ug/L 2 32 200 ND (200) Lead 200.8 ug/L 2 0.73 2 ND (2) Magnesium 200.7 ug/L 2 21 400 25 Manganese 200.7 ug/L 2 0.51 20 2 Mercury 1631E ng/L 1 0.24 0.5 ND (0.5) Molybdenum 200.7 ug/L 2 1.6 40 ND (40) Nickel 200.8 ug/L 2 0.89 4 ND (4) Selenium 200.8 ug/L 2 0.62 4 ND (4) Silver 200.8 ug/L 2 0.59 2 ND (2) Sodium 200.7 ug/L 2 180 10,000 320 
ND – Not detected (number in parentheses is the quantitation limit). 

^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits. B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-16. Influent to FGD Wastewater Treatment System Field Blank, Set 1 Analytical R

Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concen

Thallium 200.8 ug/L 2 0.47 2 ND (2) Tin 200.7 ug/L 2 4.8 200 ND (200) Titanium 200.7 ug/L 2 1.6 20 ND (20) Vanadium 200.8 ug/L 2 1.7 10 ND (10) Zinc 200.7 ug/L 2 9.1 40 ND (40) 
ND – Not detected (number in parentheses is the quantitation limit). 

^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits. B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-17. Influent to SBR System Field Blank, Set 1 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concen

Total MetalsAluminum 200.7 ug/L 2 9.4 200 ND (20Antimony 200.8 ug/L 2 0.72 2 ND (2Arsenic 200.8 ug/L 2 1.2 4 ND (4Barium 200.7 ug/L 2 2.5 20 ND (20Beryllium 200.7 ug/L 2 0.71 2 ND (2Boron 200.7 ug/L 2 6.7 200 31 Cadmium 200.8 ug/L 2 1.2 4 ND (4Calcium 200.7 ug/L 2 69 400 230 Chromium 200.8 ug/L 2 3.3 8 ND (8Cobalt 200.7 ug/L 2 1.1 20 ND (20Copper 200.8 ug/L 2 0.96 4 ND (4Iron 200.7 ug/L 2 32 200 ND (20Lead 200.8 ug/L 2 0.73 2 ND (2Magnesium 200.7 ug/L 2 21 400 110 Manganese 200.7 ug/L 2 0.51 20 ND (20Mercury 1631E ng/L 1 0.24 0.5 ND (0.5Molybdenum 200.7 ug/L 2 1.6 40 ND (40Nickel 200.8 ug/L 2 0.89 4 ND (4Selenium 200.8 ug/L 2 0.62 4 ND (4Silver 200.8 ug/L 2 0.59 2 ND (2Sodium 200.7 ug/L 2 180 10,000 290 Thallium 200.8 ug/L 2 0.47 2 ND (2
ND – Not detected (number in parentheses is the quantitation limit). 

^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits. B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-17. Influent to SBR System Field Blank, Set 1 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concen

Tin 200.7 ug/L 2 4.8 200 ND (20Titanium 200.7 ug/L 2 1.6 20 ND (20Vanadium 200.8 ug/L 2 1.7 10 ND (10Zinc 200.7 ug/L 2 9.1 40 ND (40
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-18. Influent to SBR System Field Blank, Set 2 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Conce

Total MetalsAluminum 200.7 ug/L 2 9.4 200 10 Antimony 200.8 ug/L 2 0.72 2 ND (2Arsenic 200.8 ug/L 2 1.2 4 ND (4Barium 200.7 ug/L 2 2.5 20 ND (2Beryllium 200.7 ug/L 2 0.71 2 ND (2Boron 200.7 ug/L 2 6.7 200 92 Cadmium 200.8 ug/L 2 1.2 4 ND (4Calcium 200.7 ug/L 2 69 400 330 Chromium 200.8 ug/L 2 3.3 8 ND (8Cobalt 200.7 ug/L 2 1.1 20 ND (2Copper 200.8 ug/L 2 0.96 4 ND (4Iron 200.7 ug/L 2 32 200 33 Lead 200.8 ug/L 2 0.73 2 ND (2Magnesium 200.7 ug/L 2 21 400 240 Manganese 200.7 ug/L 2 0.51 20 7.8 Mercury 1631E ng/L 1 0.24 0.5 ND (0Molybdenum 200.7 ug/L 2 1.6 40 ND (4Nickel 200.8 ug/L 2 0.89 4 ND (4Selenium 200.8 ug/L 2 0.62 4 ND (4Silver 200.8 ug/L 2 0.59 2 ND (2Sodium 200.7 ug/L 2 180 10,000 290 Thallium 200.8 ug/L 2 0.47 2 ND (2
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-18. Influent to SBR System Field Blank, Set 2 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Conce

Tin 200.7 ug/L 2 4.8 200 ND (20Titanium 200.7 ug/L 2 1.6 20 ND (2Vanadium 200.8 ug/L 2 1.7 10 2.5 Zinc 200.7 ug/L 2 9.1 40 ND (4
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-19. Influent to SBR System Field Blank, Set 3 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Conc

Total MetalsAluminum 200.7 ug/L 2 9.4 200 ND (Antimony 200.8 ug/L 2 0.72 2 ND Arsenic 200.8 ug/L 2 1.2 4 ND Barium 200.7 ug/L 2 2.5 20 ND (Beryllium 200.7 ug/L 2 0.71 2 ND Boron 200.7 ug/L 2 6.7 200 34 Cadmium 200.8 ug/L 2 1.2 4 ND Calcium 200.7 ug/L 2 69 400 ND (Chromium 200.8 ug/L 2 3.3 8 ND Cobalt 200.7 ug/L 2 1.1 20 ND (Copper 200.8 ug/L 2 0.96 4 ND Iron 200.7 ug/L 2 32 200 ND (Lead 200.8 ug/L 2 0.73 2 ND Magnesium 200.7 ug/L 2 21 400 ND (Manganese 200.7 ug/L 2 0.51 20 ND (Mercury 1631E ng/L 1 0.24 0.5 ND (Molybdenum 200.7 ug/L 2 1.6 40 ND (Nickel 200.8 ug/L 2 0.89 4 ND Selenium 200.8 ug/L 2 0.62 4 ND Silver 200.8 ug/L 2 0.59 2 ND Sodium 200.7 ug/L 2 180 10,000 ND (10Thallium 200.8 ug/L 2 0.47 2 ND 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-19. Influent to SBR System Field Blank, Set 3 Analytical Results, Dickerson 

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Conc

Tin 200.7 ug/L 2 4.8 200 ND (Titanium 200.7 ug/L 2 1.6 20 ND (Vanadium 200.8 ug/L 2 1.7 10 ND (Zinc 200.7 ug/L 2 9.1 40 ND (
ND – Not detected (number in parentheses is the quantitation limit). 

^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits. B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-20. Effluent from SBR System Field Blank, Set 1 Analytical Results, Dickerso

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concent

Total MetalsAluminum 200.7 ug/L 2 9.4 200 ND (200) Antimony 200.8 ug/L 2 0.72 2 ND (2) Arsenic 200.8 ug/L 2 1.2 4 ND (4) Barium 200.7 ug/L 2 2.5 20 ND (20) Beryllium 200.7 ug/L 2 0.71 2 ND (2) Boron 200.7 ug/L 2 6.7 200 200 Cadmium 200.8 ug/L 2 1.2 4 ND (4) Calcium 200.7 ug/L 2 69 400 ND (400) Chromium 200.8 ug/L 2 3.3 8 ND (8) Cobalt 200.7 ug/L 2 1.1 20 ND (20) Copper 200.8 ug/L 2 0.96 4 1 Iron 200.7 ug/L 2 32 200 ND (200) Lead 200.8 ug/L 2 0.73 2 ND (2) Magnesium 200.7 ug/L 2 21 400 39 Manganese 200.7 ug/L 2 0.51 20 0.6 Mercury 1631E ng/L 1 0.24 0.5 ND (0.5) Molybdenum 200.7 ug/L 2 1.6 40 ND (40) Nickel 200.8 ug/L 2 0.89 4 ND (4) Selenium 200.8 ug/L 2 0.62 4 0.8 Silver 200.8 ug/L 2 0.59 2 ND (2) Sodium 200.7 ug/L 2 180 10,000 ND (10,000Thallium 200.8 ug/L 2 0.47 2 ND (2) 
ND – Not detected (number in parentheses is the quantitation limit). 

^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits. B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-20. Effluent from SBR System Field Blank, Set 1 Analytical Results, Dickerso

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concent

Tin 200.7 ug/L 2 4.8 200 ND (200) Titanium 200.7 ug/L 2 1.6 20 ND (20) Vanadium 200.8 ug/L 2 1.7 10 ND (10) Zinc 200.7 ug/L 2 9.1 40 ND (40) 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-21. Effluent from SBR System Field Blank, Set 2 Analytical Results, Dickerso

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Con

Total MetalsAluminum 200.7 ug/L 2 9.4 200 ND (Antimony 200.8 ug/L 2 0.72 2 ND Arsenic 200.8 ug/L 2 1.2 4 ND Barium 200.7 ug/L 2 2.5 20 ND Beryllium 200.7 ug/L 2 0.71 2 ND Boron 200.7 ug/L 2 6.7 200 6Cadmium 200.8 ug/L 2 1.2 4 ND Calcium 200.7 ug/L 2 69 400 ND (Chromium 200.8 ug/L 2 3.3 8 ND Cobalt 200.7 ug/L 2 1.1 20 ND Copper 200.8 ug/L 2 0.96 4 ND Iron 200.7 ug/L 2 32 200 ND (Lead 200.8 ug/L 2 0.73 2 ND Magnesium 200.7 ug/L 2 21 400 2Manganese 200.7 ug/L 2 0.51 20 ND Mercury 1631E ng/L 1 0.24 0.5 0.7Molybdenum 200.7 ug/L 2 1.6 40 ND Nickel 200.8 ug/L 2 0.89 4 ND Selenium 200.8 ug/L 2 0.62 4 ND Silver 200.8 ug/L 2 0.59 2 ND Sodium 200.7 ug/L 2 180 10,000 21Thallium 200.8 ug/L 2 0.47 2 ND 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-21. Effluent from SBR System Field Blank, Set 2 Analytical Results, Dickerso

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Con

Tin 200.7 ug/L 2 4.8 200 ND (Titanium 200.7 ug/L 2 1.6 20 ND Vanadium 200.8 ug/L 2 1.7 10 ND Zinc 200.7 ug/L 2 9.1 40 ND 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-22. Effluent from SBR System Field Blank, Set 3 Analytical Results, Dickerso

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concent

Total MetalsAluminum 200.7 ug/L 2 9.4 200 46 Antimony 200.8 ug/L 2 0.72 2 ND (2) Arsenic 200.8 ug/L 2 1.2 4 ND (4) Barium 200.7 ug/L 2 2.5 20 ND (20) Beryllium 200.7 ug/L 2 0.71 2 ND (2) Boron 200.7 ug/L 2 6.7 200 93 Cadmium 200.8 ug/L 2 1.2 4 ND (4) Calcium 200.7 ug/L 2 69 400 ND (400) Chromium 200.8 ug/L 2 3.3 8 ND (8) Cobalt 200.7 ug/L 2 1.1 20 ND (20) Copper 200.8 ug/L 2 0.96 4 ND (4) Iron 200.7 ug/L 2 32 200 56 Lead 200.8 ug/L 2 0.73 2 ND (2) Magnesium 200.7 ug/L 2 21 400 380 Manganese 200.7 ug/L 2 0.51 20 7.5 Mercury 1631E ng/L 1 0.24 0.5 ND (0.5) Molybdenum 200.7 ug/L 2 1.6 40 ND (40) Nickel 200.8 ug/L 2 0.89 4 ND (4) Selenium 200.8 ug/L 2 0.62 4 ND (4) Silver 200.8 ug/L 2 0.59 2 ND (2) Sodium 200.7 ug/L 2 180 10,000 ND (10,00Thallium 200.8 ug/L 2 0.47 2 ND (2) 
ND – Not detected (number in parentheses is the quantitation limit). 

B – Analyte was found in the blank and sample. J – Result measured above the MDL, but less than the quantitation limit. U – Result below the MDL. (Number shown in parentheses is the quantitation limit). 

Table E5-22. Effluent from SBR System Field Blank, Set 3 Analytical Results, Dickerso

Analyte Method Unit 

Dilution 

Factor 

SampleSpecific MDL Sample- Specific QL Concent

Tin 200.7 ug/L 2 4.8 200 ND (200) Titanium 200.7 ug/L 2 1.6 20 1.9 Vanadium 200.8 ug/L 2 1.7 10 ND (10) Zinc 200.7 ug/L 2 9.1 40 11 
Section 6 

Data Review Narratives 

[A concentration noted as “XXX” indicates that the sample result applies to a different power plant and has been 

removed.] 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Donna Tedder, ERG 

Date: 2/9/2012

Subject: FGS Data Review Narrative for Total Mercury – Long-Term Monitoring: 

Month 1 (Part 1)

Frontier Global Sciences (FGS) generated analytical data for total mercury. FGS 

analyzed the samples according to EPA Method 1631E for mercury by Cold Vapor 

Atomic Fluorescence Spectrometry (CVAFS) analysis. 

Table 1 summarizes the 14 samples (excluding laboratory prep blanks) FGS extracted 

and analyzed for total mercury. 

Table 1. Long-Term Monitoring Month 1 (Part 1) Mercury – Sample Identification 

EPA 

Sample # 

Lab Sample 

ID # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72041 1010010-01 Aqueous FGD Influent, Set 1 9/30/2010 

72045 1010010-02 Aqueous FGD Effluent, Set 1 9/30/2010

72049 1010010-04 Aqueous FGD Influent Field Blank 9/30/2010

72050 1010010-03 Aqueous FGD Effluent Field Blank, Set 1 9/30/2010 

72091 1009237-07 Aqueous FGD Influent, Set 1 9/28/2010

72095 1009237-08 Aqueous FGD Effluent, Set 1 9/28/2010

72099 1009237-10 Aqueous FGD Influent Field Blank 9/28/2010

72100 1009237-09 Aqueous FGD Effluent Field Blank, Set 1 9/27/2010

72191 1009237-01 Aqueous FGD Influent Set 1 9/29/2010 

72195 1009237-02 Aqueous FGD SBR Influent, Set 1 9/29/2010

72199 1009237-03 Aqueous FGD SBR Effluent, Set 1 9/29/2010

72203 1009237-06 Aqueous FGD Influent Field Blank 9/29/2010

72204 1009237-04 Aqueous FGD SBR Influent Field Blank, Set 1 9/28/2010

72208 1009237-05 Aqueous FGD SBR Effluent Field Blank, Set 1 9/28/2010

SUMMARY 

The samples were prepared according to EPA Method 1631E to be analyzed by CVAFS. 
2

There were no findings from the data review that required additional qualifiers in this 

dataset. 

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES 

There were no sample receipt issues in this data package. 

INITIAL CALIBRATION 

FGS performed the initial calibrations on each analysis day. The initial calibration for 

the CVAFS analysis consisted of a blank and five calibration standards with a correlation 

coefficient ≥ 0.995. All method-specified criteria were met. 

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

All initial and continuing calibration verifications (ICVs, CCVs) met method-specified 

criteria. 

BLANKS 

All the preparation blanks or laboratory reagent blanks (LRBs) and the continuing 

calibration blanks (CCBs) met method-specified criteria. Some preparation blanks had 

mercury levels greater than the MDL (0.24 ng/L), but less than the RL associated with 

each individual blank (different RLs based on preparation). Because all of the blank 

results were less than the RL, no samples were qualified based on these preparation blank 

results. 

DUPLICATES 

No field duplicate samples were collected with these sampling episodes. Two samples 

were analyzed in duplicate at the laboratory, samples 72095 and 72195. The relative 

percent difference (RPD) for samples 72095 and 72195 were 2.45% and 3.32%, 

respectively. The laboratory’s RPD criteria between analytical duplicates is 24%. 

LABORATORY CONTROL SAMPLES 

All laboratory control samples were within FGS’s control limits of 80-120% recovery 

and 24% RPD. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES 

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on samples 

72095, 72199, and 72195 for the total mercury analyses. All aqueous MS/MSD 

recoveries were within method specifications of 71-125%. All RPDs met methodspecified criteria. 
3

DETECTION LIMITS 

The laboratory MDL in the synthetic matrix was 0.239 ng/L. Results below this MDL 

were reported as not detected (ND). 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Total Metals by 200.8 – Long-Term 

Monitoring: Month 1 (Part 1)

TestAmerica generated analytical data for total metals (antimony, arsenic, cadmium, 

chromium, copper, lead, nickel, selenium, silver, thallium, and vanadium) for these longterm monitoring samples. The samples were analyzed according to EPA Method 200.8. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA Method 200.8. 

Table 1. Long-Term Monitoring Month 1 (Part 1) Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

72041 FGD Influent, Set 1 280-7918-1 Aqueous 9/30/2010 10/1/2010

72045 FGD Effluent, Set 1 280-7918-2 Aqueous 9/30/2010 10/1/2010

72049 FGD Influent Field Blank 280-7918-4 Aqueous 9/30/2010 10/1/2010

72050 FGD Effluent Field Blank, Set 1 280-7918-3 Aqueous 9/30/2010 10/1/2010

72091 FGD Influent, Set 1 280-7817-1 Aqueous 9/28/2010 9/29/2010

72095 FGD Effluent, Set 1 280-7817-2 Aqueous 9/28/2010 9/29/2010

72099 FGD Influent Field Blank, Set 1 280-7817-4 Aqueous 9/28/2010 9/29/2010

72100 FGD Effluent Field Blank, Set 1 280-7817-3 Aqueous 9/28/2010 9/29/2010

72191 FGD Influent, Set 1 280-7870-1 Aqueous 9/29/2010 9/30/2010

72195 FGD SBR Influent, Set 1 280-7870-2 Aqueous 9/29/2010 9/30/2010

72199 FGD SBR Effluent, Set 1 280-7870-3 Aqueous 9/29/2010 9/30/2010

72203 FGD Influent Field Blank 280-7870-6 Aqueous 9/29/2010 9/30/2010

72204 FGD SBR Influent Field Blank, 

Set 1 

280-7870-4 Aqueous 9/29/2010 9/30/2010

72208 FGD SBR Effluent Field Blank, 

Set 2 

280-7870-5 Aqueous 9/29/2010 9/30/2010
2

SUMMARY 

The samples were prepared for total metals analysis according to TestAmerica’s “FGD 

ICP/MS SOP: Inductively Coupled Plasma Mass Spectrometry for Trace Elements 

Analysis in Flue Gas Desulfurization Wastewaters,” dated October 6, 2010, based on 

EPA Method 200.8, by ICP/MS analysis. 

Any significant findings are summarized below. No additional data qualifiers were 

required. 

• The matrix spike (MS) and matrix spike duplicate (MSD) recoveries for total 

silver for samples 72045 and 72095 failed the EPA Method 200.8 control limits of 

70–130%. 

• The MS/MSD relative percent difference (RPD) for total silver for sample 72095 

failed the FGD ICP/MS SOP control limits of ±20%. 

• The post digestion spike (PDS) recoveries for the following analytes failed 

TestAmerica’s control limits of 85–115%: arsenic, chromium, selenium, silver, 

and vanadium. 

INTERNAL STANDARDIZATION 

All internal standards used by TestAmerica were within the method criteria. 

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP-MS analysis consisted of a blank and four calibration standards. 

INITIAL AND CONTINUING CALIBRATION VERIFICATION (ICV/CCV) 

The initial calibration verifications (ICV) and continuing calibration verifications (CCV) 

performed by TestAmerica all had recoveries within the method criteria. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit (RL); however, some elements 

were above the MDL and flagged with a “J” qualifier. No additional qualifiers were 

required for method blanks. 

All instrument blanks (initial calibration blank (ICB) and continuing calibration blank 

(CCB)) were less than the RL; however, some elements were above the MDL and 

flagged with a “J” qualifier. No additional qualifiers were required for instrument blanks. 
3

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed TestAmerica’s SOP control limits of 50–150% recovery. 

LABORATORY CONTROL SAMPLES (LCS) 

All LCS samples passed the method QC limits of 85–115% recovery. 

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION 

Based on TestAmerica’s SOP, all interference check sample A (ICSA) results had 

analytes of interest with concentrations less than the RL or less than five times the RL 

when known inherent contaminants are present in the stock solution used to make the 

ICS. 

All interference check sample B (ICSAB) synthetic spikes recovered within 

TestAmerica’s SOP criteria of 70–130% of the true value. 

SERIAL DILUTION 

The serial dilution performed on sample 72095 passed TestAmerica’s criteria of ±10% 

difference. 

FIELD DUPLICATES 

No field duplicate samples were collected with these sampling episodes. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES 

MS and MSD were performed on samples 72045 and 72095. The total selenium results in 

the MS and MSD samples for sample 72045 and the MS sample for sample 72095 failed 

the 70-130% recovery method control limits and were flagged with a “4” qualifier 

indicating concentrations in the parent samples were greater than four times the spike 

amounts. These data were considered acceptable based on the LCS passing the method 

control limits. 

The total silver results in the MS and MSD samples for both samples 72045 and 72095 

failed the 70-130% method control limits with low recoveries and were flagged with an 

“F” qualifier. Additionally, the RPD for silver between the MS and MSD for sample 

72095 failed the ICP/MS SOP ±20% control limits. The poor recoveries and RPD of 

silver are probably due to high sulfates in this episode’s samples capable of forming 

insoluble silver sulfide and/or silver sulfate. 
4

Otherwise, all MS/MSD spike recoveries were within the method control limits of 70-

130% and the RPD for the MS/MSDs were within the FGD ICP/MS SOP control limits 

of ±20 percent. No additional data qualifiers were required. 

POST DIGESTION SPIKES 

The PDS performed on sample 72095 passed TestAmerica’s control limits of 85–115% 

recovery for all analytes, except for arsenic, chromium, selenium, silver, and vanadium, 

which were all flagged with a “W” qualifier. No additional data qualifiers were required 

for PDS samples. 

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 2/9/2012 

Subject: TestAmerica Data Review Narrative for Total Metals by 200.7 – Long-Term 

Monitoring: Month 1 (Part 1)

TestAmerica generated analytical data for total metals (aluminum, boron, barium, 

beryllium, calcium, cobalt, iron, magnesium, manganese, molybdenum, sodium, tin, 

titanium, and zinc) for these long-term monitoring samples. The samples were analyzed 

according to EPA Method 200.7. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA Method 200.7.

Table 1. Long-Term Monitoring Month 1 (Part 1) Total Metals – Sample 

Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

72041 FGD Influent, Set 1 280-7918-1 Aqueous 9/30/2010 10/1/2010

72045 FGD Effluent, Set 1 280-7918-2 Aqueous 9/30/2010 10/1/2010

72049 FGD Influent Field Blank 280-7918-4 Aqueous 9/30/2010 10/1/2010

72050 FGD Effluent Field Blank, 

Set 1 

280-7918-3 Aqueous 9/30/2010 10/1/2010

72091 FGD Influent, Set 1 280-7817-1 Aqueous 9/28/2010 9/29/2010

72095 FGD Effluent, Set 1 280-7817-2 Aqueous 9/28/2010 9/29/2010

72099 FGD Influent Field Blank, 

Set 1 

280-7817-4 Aqueous 9/28/2010 9/29/2010

72100 FGD Effluent Field Blank, 

Set 1 

280-7817-3 Aqueous 9/28/2010 9/29/2010

72191 FGD Influent, Set 1 280-7870-1 Aqueous 9/29/2010 9/30/2010

72195 FGD SBR Influent, Set 1 280-7870-2 Aqueous 9/29/2010 9/30/2010

72199 FGD SBR Effluent, Set 1 280-7870-3 Aqueous 9/29/2010 9/30/2010

72203 FGD Influent Field Blank 280-7870-6 Aqueous 9/29/2010 9/30/2010

72204 FGD SBR Influent Field 

Blank, Set 1 

280-7870-4 Aqueous 9/29/2010 9/30/2010

72208 FGD SBR Effluent Field 

Blank, Set 2 

280-7870-5 Aqueous 9/29/2010 9/30/2010
2

SUMMARY 

The samples were prepared for total metals analysis according to TestAmerica’s SOP for 

ICP Analysis for Trace Metals by Method 200.7. Any significant findings are 

summarized below. No additional data qualifiers were required. 

• The matrix spike (MS) and matrix spike duplicate (MSD) recoveries for total 

barium for sample 72095 failed the EPA Method 200.7 control limits of 70–

130%. 

• The MS/MSD relative percent difference (RPD) for total magnesium for sample 

72095 failed TestAmerica’s SOP control limits of ±20%. 

• The post digestion spike (PDS) for titanium for sample 72095 failed 

TestAmerica’s control limits of 85–115% recovery. 

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES 

There were no sample receipt issues in this data package. 

INTERNAL STANDARDIZATION 

While the internal standard (ISTD) yttrium was used for these analyses, no checks for the 

ISTD recoveries within the ±30% criterion of the calibration blank as per Section 9.11 of 

the SOP were seen. All ISTD were within the control limits. 

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP analysis consisted of a blank and one calibration standard. 

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

The initial calibration verifications (ICV) and continuing calibration verifications (CCV) 

performed by TestAmerica all had recoveries within the method criteria. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit (RL); however, some elements 

were above the method detection limit (MDL) and were flagged with the “J” qualifier. 

All instrument blanks (initial calibration blank (ICB) and continuing calibration blank 

(CCB)) were less than the RL; however, some elements were above the MDL and were 

flagged with the “J” qualifier. 
3

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed TestAmerica’s SOP control limits of 50–150% recovery. 

LABORATORY CONTROL SAMPLES (LCS) 

All LCSs passed the method control limits of 85–115% recovery. 

INTERFERENCE CHECK SOLUTIONS 

Interference checks were performed using the synthetic matrix as the check solution. All 

data quality objectives met TestAmerica’s SOP criteria.

SERIAL DILUTION (SRD) 

Serial dilutions were performed for each batch of total samples. All serial dilution percent 

differences were less than 10% as required by TestAmerica’s SOP. 

FIELD DUPLICATES 

No field duplicate samples were collected with these sampling episodes. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

MS and MSDs were performed on the total samples of 72095 and 72045. Some elements 

with high concentrations failed the EPA 200.7 Method spike recovery control limits of 

70–130% but were flagged with a “4” qualifier indicating that the concentration in the 

parent sample was greater than 4 times the spike and could not be reliably calculated. 

These data were considered acceptable based on the LCS passing the method control 

limits. Otherwise, all MS/MSD spike recoveries were within the method control criteria 

of 70-130%, except for barium for sample 72095, which had a recovery of 65% and was 

qualified with an “F”. The RPD for all MS/MSDs were within TestAmerica’s ± 20% 

requirement, except for magnesium for sample 72095. No additional data qualifiers were 

needed. 

POST DIGESTION SPIKE (PDS) 

The PDS performed on sample 72095 passed TestAmerica’s control limits of 85–115% 

recovery for all analytes except titanium, which was qualified with a “W”. No additional 

data qualifiers were required. 

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 
1 

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Donna Tedder, ERG 

Date: 2/9/2012 

Subject: TestAmerica Data Review Narrative for Classicals Analyses – Long-Term 

Monitoring: Month 1 (Part 1) 

TestAmerica Denver Laboratory generated analytical data for classical wet chemistry 

analyses for these long-term monitoring samples. All samples were tested for the 

following analytes: 

• Ammonia by EPA method 350.1, 

• Biochemical Oxygen Demand – 5 day (BOD5) by SM 5210B, 

• Chloride and Sulfate by EPA method 300.0, 

• Chemical Oxygen Demand (COD) by EPA method 410.4, 

• Cyanide (total) by SM 4500 CN- E, 

• Nitrate/Nitrite by EPA method 353.2, 

• Phosphorus (total) by EPA method 365.1, 

• Total Dissolved Solids (TDS) by SM 2540C, 

• Total Kjeldahl Nitrogen (TKN) by EPA method 351.2, and 

• Total Suspended Solids (TSS) by SM 2540D. 

Table 1 summarizes the seven samples that TestAmerica analyzed for the above analytes. 

Table 1. Long-Term Monitoring Month 1 (Part 1) Classical Analytes – Sample 

Identification 

EPA 

Sample # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72041 Water FGD Influent, Set 1 9/30/10 

72045 Water FGD Effluent, Set 1 9/30/10 

72091 Water FGD Influent, Set 1 9/28/10 

72095 Water FGD Effluent, Set 1 9/28/10 

72191 Water FGD Influent, Set 1 9/29/10 

72195 Water FGD SBR Influent, Set 1 9/29/10 

72199 Water FGD SBR Effluent, Set 1 9/29/10 
2 

SUMMARY 

All samples were analyzed within the holding time specified in 40 CFR 136 Table II. All 

samples were preserved appropriately unless otherwise specified below. 

 

Field duplicate samples were not collected for these episodes. Depending on the method, 

a laboratory duplicate was analyzed, instead. The Relative Percent Difference (RPD) 

between the sample and its duplicate was less than 20% unless otherwise noted below. 

If applicable, the appropriate number of standards was used to create a calibration curve. 

If sample results were above the highest standard used to create the curve, the sample was 

diluted and reanalyzed. All sample results were between the lowest and highest standards 

unless noted below. Additionally, unless otherwise noted, all calibration blanks and 

calibration verification samples met the criteria specified in the method. 

If required by the method, the quality control sample (QCS), a secondary source standard 

used to verify calibration, was always within the control limits specified by the method. 

As described below, the analyte of interest was detected above the method detection limit 

(MDL) in some laboratory reagent blanks (LRB). However, the analyte of interest was 

never detected above the reporting limit (RL) in the LRBs. If required by the method, all 

laboratory fortified blanks (LFB) met the criteria specified in the method unless specified 

below. 

If required by the method, a matrix spike (MS) sample was analyzed on sample 72045 for 

each analyte to check for matrix interferences. For some analytes, TestAmerica spiked 

more samples than required. All MS samples analyzed met the criteria specified in the 

method unless described below. 

DATA NOTES/ISSUES 

Ammonia 

No issues were identified by the data reviewer. 

BOD5 

TestAmerica analyzed five dilutions, but no dilutions had a dissolved oxygen (DO) 

depletion greater than 2.0 mg/L for sample 72041 and 72091. Therefore, BOD5 was 

reported as not detected for these samples. The rest of the samples had at least one 

dilution with a DO depletion greater than 2.0 mg/L. As required in the method, the final 

result was calculated by taking the average of the results for all dilutions with a DO 

depletion greater than 2.0 mg/L and a final DO greater than 1.0 mg/L. 

BOD was not detected above the RL in any method blanks. However, for one batch, the 

results for the three water/unseeded blanks were 0.22 mg/L, 0.14 mg/L, and 0.16 mg/L. 
3 

One of these water blanks was above the method control criteria of 0.20 mg/L. However, 

all samples contained in this batch (samples 72041 and 72045) were either qualified with 

a “J” meaning that the sample result was an estimated value because it was below the RL 

or BOD was not detected in the sample, so no further qualification was necessary. 

One of the three batches had a seed correction factor lower than 0.6 mg/L. The seed 

correction factors were 0.6267 mg/L, 0.5776 mg/L, and 0.6384 mg/L for batches 33523, 

33769, and 33938, respectively. Unlike previous episodes, TestAmerica did not flag 

samples in batch 33769 with an “s” indicating the seed correction blank (SCB) recovery 

was low. This low seed correction factor suggests that samples 72191, 72195, and 72199 

may be biased low. Therefore, these samples were also flagged with an “s”. Sample 

72191 was already flagged by TestAmerica with a “J” meaning that the sample result was 

an estimated value because it was below the RL, so no further qualification was 

necessary. However, samples 72195 and 72199 were flagged as minimum values. Due to 

the short holding time for the analysis, the samples could not be reanalyzed. 

All glucose-glutamic acid standards and laboratory duplicates were analyzed 

appropriately and met the criteria specified in SM 5210B. 

Chloride and Sulfate 

The MS and matrix spike duplicate (MSD) results for sample 72045 for sulfate and 

chloride were above the calibration curve. TestAmerica did not reanalyze the samples 

with a higher dilution factor because the percent recoveries were within EPA method 

300.0 control limits. If reported, these MS/MSD results will be qualified as estimated 

values. The LFB associated with this sample met the method criteria. The analyzed result 

for sample 72045 was within the calibration curve, so there was no need to qualify this 

sample. 

COD 

The percent recovery for the MSD analyses for sample 72045 was below the control 

limits of 90-110% required by EPA method 410.4. The percent recoveries for the MS and 

MSD analyses for this sample were 109% and 87%, respectively. Because the MS 

percent recovery met the method criteria and an MSD is not required by the method, 

sample 72045 was not qualified. The LFB percent recoveries associated with sample 

72045 met the method criteria. 

Cyanide 

Samples 72041 and 72045 were received by the laboratory at neutral pH. The lab added 

more NaOH to increase the pH to greater than 10 S.U. These samples are qualified as 

estimated values. 

Results for the following samples were less than the lowest calibration standard (0.01 

mg/L): 72095, 72195, and 72199. Because all of these samples were already flagged by 
4 

TestAmerica with a “J”, meaning the sample result was an estimated value because it was 

below the RL, no further qualification was necessary. 

The percent recoveries for the MS and MSD analyses of sample 72045 were both 85%, 

which is outside of the laboratory control criteria of 90-110%. However, because there 

are no criteria for MS/MSD analyses specified in SM 4500 CN- E, no further 

qualification was necessary. 

Nitrate/Nitrite 

No issues were identified by the data reviewer. 

Phosphorus 

The percent recoveries for the MS/MSD analysis of sample 72045 were not within the 

control limits of 90-110% specified in EPA Method 365.1 or within the laboratory 

control limits of 71-128%. The percent recoveries of the MS and MSD samples were 

19% and 21%, respectively. The result for sample 72045 was only slightly above the RL. 

This low sample result could have caused the low percent recovery. Nevertheless, sample 

72045 was qualified as a minimum value. The LFB percent recovery met the method 

criteria. 

TDS 

Constant weight was not achieved after 3 drying cycles for all samples. It should be noted 

that the weight increased from the first weighing to the second weighing for all samples. 

Method 2540C warns that samples which contain high levels of calcium, magnesium, 

chloride, and sulfate may be hygroscopic meaning they absorb moisture from the air. 

FGD wastewater contains high concentrations of all of these species. This was likely the 

cause for the inconsistent weight calculations. The samples were not qualified, but results 

may be biased high. 

The RPDs for laboratory duplicates from samples 72045 and 72191 were less than 10% 

as required by SM 2540C. However, the RPD for sample 72091 was 14%. Because the 

RPD was greater than the method control limits, sample 72091 was qualified as an 

estimated value. 

TDS was detected at 6.0 mg/L in the method blank associated with samples 72191, 

72195, and 72199. The method blank result was greater than the MDL (4.7 mg/L), but 

less than the RL (10 mg/L). No qualification was necessary because the blank result was 

less than the RL. 

TKN 

The percent recovery for the LFB associated with samples 72041, 72045, 72091, 72095, 

72191, 72195, and 72199 was not within the method control limits of 90-110%, but was 
5 

within the laboratory control limits of 77-115%. The percent recoveries for the LFB and 

LFBD were 84% and 86%, respectively. Because the percent recovery of the LFB was 

below the method criteria, samples 72041, 72045, 72091, 72095, 72191, 72195, and 

72199 were qualified as minimum values. 

TestAmerica performed MS/MSD analysis on sample 72045. The percent recoveries for 

the MS and MSD samples were 77% and 93%, respectively. The MS sample did not meet 

the method control limits of 90-110%, but did meet the laboratory control limits of 54-

131%. The LFB associated with this batch was also not within the laboratory control 

limits, so this may have caused the low MS percent recovery. Also, the sample 

concentration was greater than 4 times the spike amount in the MS and MSD samples, so 

TestAmerica stated that the percent recoveries and RPDs could not be reliably calculated. 

Therefore, sample 72045 was not additionally qualified based on the MS failure because 

it is not possible to determine if the MS failure was a result of matrix interferences or the 

low spiking level. 

TKN was detected at 0.133 mg/L in the LRB associated with samples 72041, 72045, 

72091, 72095, 72191, 72195, and 72199. The blank result was greater than the MDL 

(0.077 mg/L), but less than the RL (1.0 mg/L). Because the blank result was less than the 

RL, no samples were qualified based on the LRB result. 

TSS 

The RPD for the laboratory duplicate of sample 72045 was 13%. This RPD was greater 

than the method control criteria of 10%. Sample 72045 and its duplicate were already 

qualified by TestAmerica with a “J” meaning that the result is an estimated value because 

the result is below the RL, so no further qualification was necessary. 

Table 2. Data Review Summary Table 

Sample Analyte Qualifier/Ac

tion 

Reason Level Detected

72191 BOD s SCB Recovery Low 2.4 mg/L 

72195 BOD s, Minimum 

Value 

SCB Recovery Low 5.8 mg/L 

72199 BOD s, Minimum 

Value 

SCB Recovery Low 6.2 mg/L 

72041 Cyanide Estimated 

Value 

Sample pH < 10 S.U. 

at receipt 

XXX mg/L 

72045 Cyanide Estimated 

Value 

Sample pH < 10 S.U. 

at receipt 

XXX mg/L 

72045 Phosphorus Minimum 

Value 

MS % recovery < 

method-specified 

criteria 

XXX mg/L 
6 

Table 2. Data Review Summary Table 

Sample Analyte Qualifier/Ac

tion 

Reason Level Detected

72091 TDS Estimated 

Value 

Lab duplicate RPD > 

method-specified 

criteria 

XXX mg/L 

72041 TKN Minimum 

Value 

LFB% recovery < 

method-specified 

criteria 

XXX mg/L 

72045 TKN Minimum 

Value 

LFB% recovery < 

method-specified 

criteria 

XXX mg/L 

72091 TKN Minimum 

Value 

LFB% recovery < 

method-specified 

criteria 

XXX mg/L 

72095 TKN Minimum 

Value 

LFB% recovery < 

method-specified 

criteria 

XXX mg/L 

72191 TKN Minimum 

Value 

LFB% recovery < 

method-specified 

criteria 

23 mg/L 

72195 TKN Minimum 

Value 

LFB% recovery < 

method-specified 

criteria 

12 mg/L 

72199 TKN Minimum 

Value 

LFB% recovery < 

method-specified 

criteria 

16 mg/L 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Donna Tedder, ERG 

Date: 2/9/2012

Subject: FGS Data Review Narrative for Total Mercury – Long-Term Monitoring: 

Month 3

Frontier Global Sciences (FGS) generated analytical data for total mercury. FGS 

analyzed the samples according to EPA Method 1631E for mercury by Cold Vapor 

Atomic Fluorescence Spectrometry (CVAFS) analysis. 

Table 1 summarizes the 24 samples (excluding laboratory prep blanks) FGS extracted 

and analyzed for total mercury. 

Table 1. Long-Term Monitoring Month 3 Mercury – Sample Identification 

EPA 

Sample # 

Lab Sample 

ID # 

Sample 

Matrix Sample Description 

Sampling 

Date 

71993 1012119-01 Aqueous FGD Influent, Set 3 12/8/2010

71997 1012119-06 Aqueous FGD Bioreactor Influent, Set 3 12/8/2010

72001 1012119-11 Aqueous FGD Bioreactor Effluent, Set 3 12/8/2010

72006 1012119-12 Aqueous FGD Bioreactor Influent Field Blank, Set 3 12/8/2010

72010 1012119-13 Aqueous FGD Bioreactor Effluent Field Blank, Set 3 12/8/2010

72043 1012094-01 Aqueous FGD Influent, Set 3 12/8/2010

72047 1012094-02 Aqueous FGD Effluent, Set 3 12/7/2010

72052 1012094-03 Aqueous FGD Effluent Field Blank, Set 3 12/7/2010

72093 1012077-01 Aqueous FGD Influent Set 3 12/7/2010 

72097 1012077-02 Aqueous FGD Effluent, Set 3 12/7/2010

72102 1012077-03 Aqueous FGD Effluent Field Blank, Set 3 12/7/2010

72143 1012080-01 Aqueous FGD Influent, Set 3 12/6/2010

72147 1012080-06 Aqueous FGD Bioreactor Influent, Set 3 12/6/2010

72151 1012080-11 Aqueous FGD Bioreactor Effluent, Set 3 12/6/2010

72156 1012080-12 Aqueous FGD Bioreactor Influent Field Blank, Set 3 12/6/2010

72160 1012080-13 Aqueous FGD Bioreactor Effluent Field Blank, Set 3 12/6/2010

72192 1012105-01 Aqueous FGD Influent, Set 1 12/8/2010

72196 1012105-02 Aqueous FGD SBR Influent, Set 1 12/8/2010

72200 1012105-03 Aqueous FGD SBR Effluent, Set 1 12/8/2010
2

Table 1. Long-Term Monitoring Month 3 Mercury – Sample Identification 

EPA 

Sample # 

Lab Sample 

ID # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72205 1012105-04 Aqueous FGD SBR Influent Field Blank, Set 1 12/8/2010

72209 1012105-05 Aqueous FGD SBR Effluent Field Blank, Set 1 12/8/2010

72243 1012117-01 Aqueous FGD Influent, Set 3 12/9/2010

72247 1012117-06 Aqueous FGD Effluent, Set 3 12/9/2010

72252 1012117-07 Aqueous FGD Effluent Field Blank, Set 3 12/8/2010

SUMMARY 

The samples were prepared according to EPA Method 1631E to be analyzed by CVAFS. 

There were no findings from the data review that required additional qualifiers in this 

dataset. 

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES 

There were no sample receipt issues in this data package. 

INITIAL CALIBRATION 

FGS performed the initial calibrations on each analysis day. The initial calibration for 

the CVAFS analysis consisted of a blank and five calibration standards with a correlation 

coefficient ≥ 0.995. All method-specified criteria were met. 

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

All initial and continuing calibration verifications (ICVs, CCVs) met method-specified 

criteria. 

BLANKS 

All the preparation blanks or laboratory reagent blanks (LRBs) and the continuing 

calibration blanks (CCBs) met method-specified criteria. Some preparation blanks had 

mercury levels greater than the MDL (0.24 ng/L), but less than the RL associated with 

each individual blank (different RLs based on preparation). Because all of the blank 

results were less than the RL, no samples were qualified based on these preparation blank 

results. 

DUPLICATES 

No field duplicate samples were collected with these sampling episodes. Three samples 

were analyzed in duplicate at the laboratory, Bioreactor Influent sample 72147, SBR 

Influent sample 72196, and Effluent sample 72247. The relative percent difference (RPD) 
3

for samples 72147, 72196, and 72247 were 9.74%, 4.36%, and 9.10%, respectively. A 

sample from another work order was analyzed in duplicate with these batches that 

resulted in an RPD of 79.7%, which is outside of the laboratory’s criteria. The 

laboratory’s RPD criteria between analytical duplicates is 24%. No sample qualifications 

were needed based on these analytical duplicate results.

LABORATORY CONTROL SAMPLES 

All laboratory control samples were within FGS’s control limits of 80-120% recovery 

and 24% RPD. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on samples 

72097, 72147, and 72196. Additionally, an MS/MSD was performed on sample 72296, 

which was a rerun from the long-term monitoring, month 2 set of samples. All aqueous 

MS/MSD recoveries were within method specifications of 71-125%. All RPDs met 

method-specified criteria. 

DETECTION LIMITS 

The laboratory MDL in the synthetic matrix was 0.239 ng/L. Results below this MDL 

were reported as not detected (ND). 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Total Metals by 200.8 – Long-Term 

Monitoring: Month 3 

TestAmerica generated analytical data for total metals (antimony, arsenic, cadmium, 

chromium, copper, lead, nickel, selenium, silver, thallium and vanadium) for these longterm monitoring samples. The samples were analyzed according to EPA Method 200.8. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA method 200.8.

Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

71993 FGD Influent, Set 3 280-10586-1 Aqueous 12/08/2010 12/09/2010

71997 FGD Bioreactor Influent, Set 3 280-10586-2 Aqueous 12/08/2010 12/09/2010

71997 FGD Bioreactor Influent, Set 3 280-10654-1 Aqueous 12/09/2010 12/10/2010

72001 FGD Bioreactor Effluent, Set 3 280-10654-2 Aqueous 12/09/2010 12/10/2010

72006 FGD Bioreactor Influent Field 

Blank, Set 3 

280-10654-3 Aqueous 12/09/2010 12/10/2010

72010 FGD Bioreactor Effluent Field 

Blank, Set 3 

280-10654-4 Aqueous 12/09/2010 12/10/2010

72043 FGD Influent, Set 3 280-10584-1 Aqueous 12/08/2010 12/09/2010

72047 FGD Effluent, Set 3 280-10584-2 Aqueous 12/08/2010 12/09/2010

72052 FGD Bioreactor Effluent Field 

Blank, Set 3 

280-10584-3 Aqueous 12/08/2010 12/09/2010

72093 FGD Influent, Set 3 280-10515-1 Aqueous 12/07/2010 12/08/2010

72097 FGD Effluent, Set 3 280-10515-2 Aqueous 12/07/2010 12/08/2010

72102 FGD Effluent Field Blank, Set 3 280-10515-3 Aqueous 12/07/2010 12/08/2010

72143 FGD Influent, Set 3 280-10455-1 Aqueous 12/06/2010 12/07/2010

72147 FGD Bioreactor Influent, Set 3 280-10517-1 Aqueous 12/07/2010 12/08/2010

72151 FGD Bioreactor Effluent, Set 3 280-10517-2 Aqueous 12/07/2010 12/08/2010

72156 FGD Bioreactor Influent Field 

Blank, Set 3 

280-10517-3 Aqueous 12/07/2010 12/08/2010

72160 FGD Bioreactor Effluent Field 280-10517-4 Aqueous 12/07/2010 12/08/2010
2

Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

Blank, Set 3

72192 FGD Influent, Set 1 280-10585-1 Aqueous 12/08/2010 12/09/2010

72196 FGD SBR Influent, Set 1 280-10585-2 Aqueous 12/08/2010 12/09/2010

72200 FGD SBR Effluent, Set 1 280-10585-3 Aqueous 12/08/2010 12/09/2010

72205 FGD SBR Influent Field Blank, 

Set 1 

280-10585-4 Aqueous 12/08/2010 12/09/2010

72209 FGD SBR Effluent Field Blank, 

Set 1 

280-10585-5 Aqueous 12/08/2010 12/09/2010

72243 FGD Influent, Set 3 280-10655-1 Aqueous 12/09/2010 12/10/2010

72247 FGD Effluent, Set 3 280-10655-2 Aqueous 12/09/2010 12/10/2010

72252 FGD Effluent Field Blank, Set 3 280-10655-3 Aqueous 12/09/2010 12/10/2010

SUMMARY 

The samples were prepared for total metals analysis according to TestAmerica’s “FGD 

ICP/MS SOP: Inductively Coupled Plasma Mass Spectrometry for Trace Elements 

Analysis in Flue Gas Desulfurization Wastewaters,” dated October 6, 2010, based on 

EPA Method 200.8, by ICP/MS analysis. 

Any significant findings are summarized below. No additional data qualifiers were 

required. 

• One of the continuing calibration verifications (CCV) performed on 12/21/2010 

failed the method criteria for selenium. 

• The matrix spike (MS) and matrix spike duplicate (MSD) recoveries for total 

silver for sample 72196 failed the EPA Method 200.8 control limits of 70-130%. 

The MSD recovery for total silver for sample 72147 also failed the method 

control limits. 

• The MS/MSD relative percent difference (RPD) for total silver for samples 72147 

and 72196 failed the FGD ICP/MS SOP control limits of ±20%. 

• The post digestion spike (PDS) recoveries for copper, nickel, and silver for 

sample 72147 failed TestAmerica’s control limits of 85–115%. The PDS 

recovery for silver for sample 71997 also failed TestAmerica’s control limits. 

INTERNAL STANDARDIZATION 

All internal standards used by TestAmerica were within the method criteria. 
3

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP-MS analysis consisted of a blank and four calibration standards. 

INITIAL AND CONTINUING CALIBRATION VERIFICATION (ICV/CCV) 

The initial calibration verifications (ICV) and CCV performed by TestAmerica all had 

recoveries within the method criteria, except for selenium for one CCV on 12/21/2010. 

Samples associated with this CCV that had selenium values less than the reporting limit 

were reported. Any samples with selenium values above the reporting limit were 

reanalyzed. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit (RL); however, some elements 

were above the MDL and flagged with a “J” qualifier. No additional qualifiers were 

required for method blanks. 

All instrument blanks (initial calibration blank (ICB) and continuing calibration blank 

(CCB)) were less than the RL; however, some elements were above the MDL and 

flagged with a “J” qualifier. No additional qualifiers were required for instrument blanks. 

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed TestAmerica’s SOP control limits of 50–150% recovery. 

LABORATORY CONTROL SAMPLES (LCS) 

All LCS samples passed the method QC limits of 85–115% recovery. 

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION 

Based on TestAmerica’s SOP, all interference check sample A (ICSA) results had 

analytes of interest with concentrations less than the RL or less than five times the RL 

when known inherent contaminants are present in the stock solution used to make the 

ICS. 

All interference check sample B (ICSAB) synthetic spikes recovered within 

TestAmerica’s SOP criteria of 70–130% of the true value. 

SERIAL DILUTION 

The serial dilution performed on samples 72147 and 72196 passed TestAmerica’s criteria 

of ±10% difference. 
4

FIELD DUPLICATES 

No field duplicate samples were collected with these sampling episodes. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

MS and MSD were performed on samples of 72147, 72196, and 71997. The MSD of 

sample 72147 failed the method control limits of 70–130% recovery for silver at 69%, 

which was flagged with an “F” qualifier. The MS/MSD of sample 72196 failed the 

method control limits of 70–130% recovery for silver, which was flagged with an “F” 

qualifier. These silver failures are likely due to matrix interference from the high 

concentration of sulfates, which can form insoluble silver sulfide and/or silver sulfate. 

The silver recoveries in the associated LCS/LCSDs were acceptable. The RPD for the 

MS/MSDs for samples 72147 and 72196 failed the FGD ICP/MS SOP ±20% control 

limits for silver. 

Otherwise, all MS/MSD spike recoveries were within the method control limits of 70-

130% and the RPD for the MS/MSDs were within the FGD ICP/MS SOP control limits 

of ±20 percent. No additional data qualifiers were required. 

POST DIGESTION SPIKES (PDS) 

The PDS performed on samples 72147 and 71997 passed TestAmerica’s control limits of 

85–115% recovery for all analytes, except for copper, nickel, and silver for PDS sample 

72147 and silver for PDS sample 71997, which were flagged with a “W” qualifier. No 

additional data qualifiers were required. 

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Total Metals by 200.7 – Long-Term 

Monitoring: Month 3

TestAmerica generated analytical data for total metals (aluminum, boron, barium, 

beryllium, calcium, cobalt, iron, magnesium, manganese, molybdenum, sodium, tin, 

titanium and zinc). The samples were analyzed according to EPA Method 200.7. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA Method 200.7 

Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

71993 FGD Influent, Set 3 280-10586-1 Aqueous 12/08/2010 12/09/2010

71997 FGD Bioreactor Influent, Set 3 280-10654-1 Aqueous 12/09/2010 12/10/2010

72001 FGD Bioreactor Effluent, Set 3 280-10654-2 Aqueous 12/09/2010 12/10/2010

72006 FGD Bioreactor Influent Field 

Blank, Set 3 

280-10654-3 Aqueous 12/09/2010 12/10/2010

72010 FGD Bioreactor Effluent Field 

Blank, Set 3 

280-10654-4 Aqueous 12/09/2010 12/10/2010

72043 FGD Influent, Set 3 280-10584-1 Aqueous 12/08/2010 12/09/2010

72047 FGD Effluent, Set 3 280-10584-2 Aqueous 12/08/2010 12/09/2010

72052 FGD Bioreactor Effluent Field 

Blank, Set 3 

280-10584-3 Aqueous 12/08/2010 12/09/2010

72093 FGD Influent, Set 3 280-10515-1 Aqueous 12/07/2010 12/08/2010

72097 FGD Effluent, Set 3 280-10515-2 Aqueous 12/07/2010 12/08/2010

72102 FGD Effluent Field Blank, Set 3 280-10515-3 Aqueous 12/07/2010 12/08/2010

72143 FGD Influent, Set 3 280-10455-1 Aqueous 12/06/2010 12/07/2010

72147 FGD Bioreactor Influent, Set 3 280-10517-1 Aqueous 12/07/2010 12/08/2010

72151 FGD Bioreactor Effluent, Set 3 280-10517-2 Aqueous 12/07/2010 12/08/2010

72156 FGD Bioreactor Influent Field 

Blank, Set 3 

280-10517-3 Aqueous 12/07/2010 12/08/2010

72160 FGD Bioreactor Effluent Field 

Blank, Set 3 

280-10517-4 Aqueous 12/07/2010 12/08/2010

72192 FGD Influent, Set 1 280-10585-1 Aqueous 12/08/2010 12/09/2010
2

Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

72196 FGD SBR Influent, Set 1 280-10585-2 Aqueous 12/08/2010 12/09/2010

72200 FGD SBR Effluent, Set 1 280-10585-3 Aqueous 12/08/2010 12/09/2010

72205 FGD SBR Influent Field Blank, 

Set 1 

280-10585-4 Aqueous 12/08/2010 12/09/2010

72209 FGD SBR Effluent Field Blank, 

Set 1 

280-10585-5 Aqueous 12/08/2010 12/09/2010

72243 FGD Influent, Set 3 280-10655-1 Aqueous 12/09/2010 12/10/2010

72247 FGD Effluent, Set 3 280-10655-2 Aqueous 12/09/2010 12/10/2010

72252 FGD Effluent Field Blank, Set 3 280-10655-3 Aqueous 12/09/2010 12/10/2010

SUMMARY 

The samples were prepared for total metals analysis according to TestAmerica’s SOP for 

ICP Analysis for Trace Metals by Method 200.7. Any significant findings are 

summarized below. Additional data qualifiers were required (see Table 2). 

• The serial dilution for cobalt, iron, and zinc for sample 72143 failed 

TestAmerica’s SOP control limit of percent differences less than 10%. 

• The post digestion spike (PDS) for calcium, iron, magnesium, and zinc for sample 

72143 failed TestAmerica’s control limits of 85–115% recovery. 

• The PDS for manganese for sample 72147 failed TestAmerica’s control limits of 

85–115% recovery. 

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES 

The samples associated with Episode 6569 (72192, 72196, 72200, 72205, and 72209) did

not have a sample date or time on the traffic report. 

INTERNAL STANDARDIZATION 

While the internal standard (ISTD) yttrium was used for these analyses, no checks for the 

ISTD recoveries within the ±30% criterion of the calibration blank as per Section 9.11 of 

the SOP were seen. All ISTD were within the control limits. 

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP analysis consisted of a blank and one calibration standard. 
3

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

The initial calibration verifications (ICV) and continuing calibration verifications (CCV) 

performed by TestAmerica all had recoveries within the method criteria. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit (RL); however, some elements 

were above the method detection limit (MDL) and were flagged with the “J” qualifier. 

All instrument blanks (initial calibration blank (ICB) and continuing calibration blank 

(CCB)) were less than the RL; however, some elements were above the MDL and were 

flagged with the “J” qualifier. 

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed TestAmerica’s SOP control limits of 50–150% recovery. 

LABORATORY CONTROL SAMPLES (LCS) 

All LCSs passed the method control limits of 85–115% recovery. 

INTERFERENCE CHECK SOLUTIONS 

Interference checks were performed using the synthetic matrix as the check solution. All 

data quality objectives met TestAmerica’s SOP criteria.

SERIAL DILUTION (SRD) 

Serial dilutions were performed for each batch of total samples. All serial dilution percent 

differences were less than 10% as required by TestAmerica’s SOP, except for cobalt, 

iron, and zinc for sample 72143, which were flagged with a “V” qualifier. 

FIELD DUPLICATES 

No field duplicate samples were collected with these sampling episodes. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on the total 

samples of 72143, 72147, and 72196. Some elements with high concentrations failed the 

EPA 200.7 Method spike recovery control limits of 70–130% but were flagged with a “4” 

qualifier indicating that the concentration in the parent sample was greater than 4 times 

the spike and could not be reliably calculated. These data were considered acceptable 

based on the LCS passing the method control limits. Otherwise, all MS/MSD spike 

recoveries were within the method control criteria of 70-130%. The RPD for all 
4

MS/MSDs were within TestAmerica’s ± 20% requirement. No additional data qualifiers 

were needed. 

POST DIGESTION SPIKE (PDS) 

The PDS performed on sample 72143 passed TestAmerica’s control limits of 85–115% 

recovery for all analytes except aluminum, boron, calcium, iron, magnesium, titanium, 

and zinc. Calcium, magnesium, and zinc were qualified with a “W”. Calcium and 

magnesium did pass in the matrix spike for this sample. Aluminum, boron, iron and 

titanium failed the PDS; however, the percent recoveries were not calculated by the 

laboratory because their concentrations were greater than 4 times the PDS spike level. 

Aluminum, boron, and titanium passed TestAmerica’s requirement of percent differences 

less than 10% for the serial dilution for this sample demonstrating that there were no 

significant matrix interference with these elements. Iron and zinc failed TestAmerica’s 

requirements for the serial dilution; therefore, based on these cumulative results, iron and 

zinc are being qualified as suspect due to matrix interference. These additional qualifiers 

appear in Table 2. 

The PDS performed on sample 72147 passed TestAmerica’s control limits of 85–115% 

recovery for all analytes except boron and manganese. Manganese was qualified with a 

“W”. Boron failed the PDS; however, the percent recovery was not calculated by the 

laboratory because its concentration was greater the 4 times the PDS spike level. Both 

boron and manganese passed TestAmerica’s requirement of percent differences less than 

10% for the serial dilution for sample 72147 demonstrating that there were no significant 

matrix interferences. No additional qualifier is required due to this PDS. 

The PDS performed on sample 72196 passed TestAmerica’s control limits of 85–115% 

recovery for all analytes except boron and manganese; however, the percent recoveries 

were not calculated by the laboratory because their concentrations were greater than 4 

times the PDS spike level. Both boron and manganese passed TestAmerica’s requirement 

of percent differences less than 10% for the serial dilution for sample 72196 

demonstrating that there were no significant matrix interferences. No additional qualifier 

is required due to this PDS. 

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 

Table 2. Data Review Summary 

Sample Analyte Qualifier/Action Reason Level Detected 

72143 Iron (total) Matrix 

Interference 

PDS and SD Failed XXX μg/L 

72143 Zinc (total) Matrix 

Interference 

PDS and SD Failed XXX ug/L 
1 

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Jennifer Colby, ERG 

Date: 2/9/2012 

Subject: TestAmerica Data Review Narrative for Classicals Analyses – Long-Term 

Monitoring: Month 3 

TestAmerica Denver Laboratory generated analytical data for classical wet chemistry 

analyses for these long-term monitoring samples. All samples were tested for the 

following analytes: 

• Ammonia by EPA method 350.1, 

• Biochemical Oxygen Demand – 5 day (BOD5) by SM 5210B, 

• Chloride and Sulfate by EPA method 300.0, 

• Chemical Oxygen Demand (COD) by EPA method 410.4, 

• Cyanide (total) by SM 4500 CN- E, 

• Nitrate/Nitrite by EPA method 353.2 

• Phosphorus (total) by EPA method 365.1, 

• Total Dissolved Solids (TDS) by SM 2540C, 

• Total Kjeldakl Nitrogen (TKN) by EPA method 351.2, and 

• Total Suspended Solids (TSS) by SM 2540D. 

Table 1 summarizes the 15 samples that TestAmerica analyzed for the above analytes. 

Table 1. Long-Term Monitoring Month 3 Classical Analytes – Sample 

Identification 

EPA 

Sample # 

Sample 

Matrix Sample Description 

Sampling 

Date 

71993 Water FGD Influent, Set 3 12/08/2010 

71997 Water FGD Bioreactor Influent, Set 3 12/09/2010 

72001 Water FGD Bioreactor Effluent, Set 3 12/09/2010 

72043 Water FGD Influent, Set 3 12/08/2010 

72047 Water FGD Effluent, Set 3 12/08/2010 

72093 Water FGD Influent, Set 3 12/07/2010 

72097 Water FGD Effluent, Set 3 12/07/2010 

72143 Water FGD Influent, Set 3 12/06/2010 

72147 Water FGD Bioreactor Influent, Set 3 12/07/2010 
2 

Table 1. Long-Term Monitoring Month 3 Classical Analytes – Sample 

Identification 

EPA 

Sample # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72151 Water FGD Bioreactor Effluent, Set 3 12/07/2010 

72192 Water FGD Influent, Set 1 12/08/2010 

72196 Water FGD SBR Influent, Set 1 12/08/2010 

72200 Water FGD SBR Effluent, Set 1 12/08/2010 

72243 Water FGD Influent, Set 3 12/09/2010 

72247 Water FGD Effluent, Set 3 12/09/2010 

SUMMARY 

All samples were analyzed within the holding time specified in 40 CFR 136 Table II 

unless otherwise noted below. All samples were preserved appropriately unless 

otherwise specified below. Samples 72192, 72196, and 72200 had no collection dates or 

times listed on the traffic report, and were given the date of relinquishment. Many of the 

traffic reports did not have receipt temperatures.

 

Field duplicate samples were not collected for this episode. Depending on the method, a 

laboratory duplicate was analyzed instead. The Relative Percent Difference (RPD) 

between the sample and its duplicate was less than 20% unless otherwise noted below. 

If applicable, the appropriate number of standards was used to create a calibration curve. 

If sample results were above the highest standard used to create the curve, the sample was 

diluted and reanalyzed. All sample results were between the lowest and highest standards 

unless noted below. Additionally, unless otherwise noted, all calibration blanks and 

calibration verification samples met the criteria specified in the method. 

If required by the method, the quality control sample (QCS), a secondary source standard 

used to verify calibration, was always within the control limits specified by the method. 

As described below, the analyte of interest was detected above the method detection limit 

(MDL) in some laboratory reagent blanks (LRB). However, the analyte of interest was 

never detected above the reporting limit (RL) in the LRBs. If required by the method, all 

laboratory fortified blanks (LFB) met the criteria specified in the method unless specified 

below. 

If required by the method, a matrix spike (MS) analysis was run on sample 72147 and 

sample 72196 for each analyte to check for matrix interferences. All MS samples 

analyzed met the criteria specified in the method unless described below. 
3 

DATA NOTES/ISSUES 

Ammonia 

The result for the method blank associated with one of the batches was greater than the 

MDL. All associated samples were flagged with a “B” qualifier. This affects samples 

72147, 72143, 72093, 72097, and 72151. No further action is required. 

The percent recoveries for the MS and matrix spike duplicate (MSD) for sample 72147 

were 93% and 102%, respectively, which is within the method control criteria; however, 

the results exceeded the calibration range. These MS and MSD and results were flagged 

with an “E” qualifier. 

BOD5 

TestAmerica analyzed five dilutions, but no dilutions had a dissolved oxygen (DO) 

depletion greater than 2.0 mg/L for samples 72143, 72151, 72043, 71993, and 72247. 

Therefore, BOD5 was reported as not detected for these samples. Additionally, for sample 

72200, the dilutions did not have a residual DO criteria of greater than 1.0 mg/L; 

therefore, BOD5 was reported as not detected for this sample. The rest of the samples had 

at least one dilution with a DO depletion greater than 2.0 mg/L. As required in the 

method, the final result was calculated by taking the average of the results for all 

dilutions with a DO depletion greater than 2.0 mg/L and a final DO greater than 1.0 

mg/L. 

Chloride and Sulfate 

MS and MSD were performed on samples 72147 and 72196. The MS/MSD recoveries 

for both samples were within the method control for both chloride and sulfate; however, 

the MS and MSD results for chloride exceeded the calibration range. Both sets of 

MS/MSD results were flagged with “E” qualifiers. 

COD 

MS and MSD were performed on samples 72147 and 72196. The MS and MSD 

recoveries for sample 72147 were 66% and 71%, respectively, which is outside the 

method control criteria. These MS/MSD results were flagged with an “F” qualifier. The 

MS and MSD recoveries for sample 72196 were 72% and 70%, respectively, which is 

outside the method control criteria. These MS/MSD results were flagged with an “F” 

qualifier. 

Cyanide 

Because of the nature of the sample matrix, all of the samples in this sampling episode 

used a lower volume, which resulted in elevated RLs being calculated and reported by 

TestAmerica with the sample results. 
4 

MS and MSD were performed on samples 72147 and 72196. The MS and MSD 

recoveries for sample 72147 were 76% and 75%, respectively. The MS and MSD 

recoveries for sample 72196 were 59% and 57%, respectively. The LCS/LCSD 

recoveries associated with these batches were acceptable, which indicates the analytical 

system was operating within control. Additionally, there is no method requirement for the 

analysis of a MS/MSD and therefore, no corrective action is necessary. 

Nitrate/Nitrite 

No MS/MSD data was reported for batch 45200 in the sample and QC sample report 

summary. The method requires that a known amount of analyte be added to 10% of 

samples per batch. The general chemistry worksheet indicates that MS samples were 

performed on a sample outside of these episodes, but no spiking concentrations or percent 

recoveries are indicated. The MS/MSD recoveries for the other batches were within 

control limits. 

Phosphorus 

The results for the method blanks associated with two of the batches was greater than the 

MDL, but less than the RL. The blank results were flagged with a “J” qualifier. All 

associated samples were qualified with a “B” flag. No additional corrective action is 

necessary. 

MS and MSD were performed on sample 72001, 72147 and 72196. The percent 

recoveries for the MS and MSD for sample 72147 were 69% and 70%, respectively, 

which is outside the method control criteria. These MS/MSD results were flagged with 

an “F” qualifier. The LCS/LCSD recoveries for this batch were acceptable and indicate 

that the analytical system was operating within control. The percent recoveries for the 

MS and MSD for sample 72196 were 91% and 85%, respectively. The MSD recovery is 

outside the method control criteria, but within the laboratory criteria and therefore, was 

not flagged. If reported, the MSD result should be flagged with an “F” qualifier. The 

LCS/LCSD recoveries for this batch were acceptable and indicate that the analytical 

system was operating within control. Additionally, the MS/MSD performed on sample 

72001 was in the same batch as the MS/MSD for 72196 and the percent recoveries for the 

MS and MSD were 96% and 97%, respectively, with are within the method control 

criteria. 

TDS 

TA reports that constant weight was not achieved after 3 drying cycles for the following 

samples: 72097, 72143, 72147, 72151, 71993, 72196, 72200, 71997, 72004, and 72243. 

Review of the general chemistry worksheets indicates that constant weight was achieved 

for all samples. No further action was necessary. 
5 

Because of the nature of the sample matrix, some of the samples in this sampling episode 

used a lower volume, which resulted in elevated RLs being calculated and reported by 

TestAmerica with the sample results. 

The analytical duplicate associated with sample 72143 exceeded the recovery criteria. 

The duplicate result was qualified with an “F” flag. Because an analytical duplicate was 

not required by the method, no further corrective action is necessary. 

TKN 

MS and MSD were performed on samples 72147 and 72196. The MS and MSD 

recoveries for sample 72147 were 76% and 57%, respectively. The concentration in the 

original sample was greater than four times the spike amount; therefore, the recoveries 

cannot be reliably calculated and the results were flagged with a “4” qualifier. The MS 

and MSD recoveries for sample 72196 were 81% and 78%, respectively, which do not 

meet the method control criteria, but do meet the laboratory control criteria and therefore, 

these results were not flagged by the laboratory. If reported, the MS and MSD results 

should be flagged with “F” qualifiers. The LCS/LCSD recoveries associated with these 

batches were acceptable, which indicates the analytical system was operating within 

control. 

TSS 

Because of the nature of the sample matrix, some of the samples in this sampling episode 

used a lower volume, which resulted in elevated RLs being calculated and reported by 

TestAmerica with the sample results. 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Donna Tedder, ERG 

Date: 2/9/2012

Subject: FGS Data Review Narrative for Total Mercury – Long-Term Monitoring: 

Month 4 and 5

Frontier Global Sciences (FGS) generated analytical data for total mercury. FGS 

analyzed the samples according to EPA Method 1631E for mercury by Cold Vapor 

Atomic Fluorescence Spectrometry (CVAFS) analysis. 

Table 1 summarizes the 30 samples (excluding laboratory prep blanks) FGS extracted 

and analyzed for total mercury. 

Table 1. Long-Term Monitoring Month 4 and 5 Mercury – Sample Identification 

EPA 

Sample # 

Lab Sample 

ID # 

Sample 

Matrix Sample Description 

Sampling 

Date 

71994 1101223-48 Aqueous FGD Influent, Set 4 1/17/2011

71998 1101223-53 Aqueous FGD Bioreactor Influent, Set 4 1/17/2011

72002 1101223-58 Aqueous FGD Bioreactor Effluent, Set 4 1/17/2011

72007 1101223-59 Aqueous FGD Bioreactor Influent Field Blank, Set 4 1/17/2011

72011 1101223-60 Aqueous FGD Bioreactor Effluent Field Blank, Set 4 1/17/2011

72044 1101308-01 Aqueous FGD Influent, Set 4 1/26/2011

72048 1101308-06 Aqueous FGD Effluent, Set 4 1/25/2011

72053 1101308-07 Aqueous FGD Effluent Field Blank, Set 4 1/25/2011

72094 1101223-41 Aqueous FGD Influent, Set 4 1/14/2011

72098 1101223-46 Aqueous FGD Effluent, Set 4 1/14/2011

72103 1101223-47 Aqueous FGD Effluent Field Blank, Set 4 1/13/2011

72144 1101223-21 Aqueous FGD Influent, Set 4 1/12/2011

72148 1101223-26 Aqueous FGD Bioreactor Influent, Set 4 1/12/2011

72152 1101223-31 Aqueous FGD Bioreactor Effluent, Set 4 1/12/2011

72157 1101223-32 Aqueous FGD Bioreactor Influent Field Blank, Set 4 1/12/2011

72161 1101223-33 Aqueous FGD Bioreactor Effluent Field Blank, Set 4 1/12/2011

72193 1101223-08 Aqueous FGD Influent, Set 3 1/12/2011

72197 1101223-13 Aqueous FGD SBR Influent, Set 3 1/12/2011

72201 1101223-18 Aqueous FGD SBR Effluent, Set 3 1/12/2011
2

Table 1. Long-Term Monitoring Month 4 and 5 Mercury – Sample Identification 

EPA 

Sample # 

Lab Sample 

ID # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72206 1101223-19 Aqueous FGD SBR Influent Field Blank, Set 3 1/12/2011

72210 1101223-20 Aqueous FGD SBR Effluent Field Blank, Set 3 1/12/2011

72244 1101223-34 Aqueous FGD Influent, Set 4 1/12/2011

72248 1101223-39 Aqueous FGD Effluent, Set 4 1/13/2011

72253 1101223-40 Aqueous FGD Effluent Field Blank, Set 4 1/12/2011

72293 1101223-01 Aqueous FGD Influent, Set 3 1/12/2011 

72297 1101223-06 Aqueous FGD Effluent, Set 3 1/12/2011

72302 1101223-07 Aqueous FGD Effluent, Field Blank, Set 3 1/12/2011

72294 1102108-01 Aqueous FGD Influent, Set 4 2/9/2011

72298 1102108-06 Aqueous FGD Effluent, Set 4 2/9/2011

72303 1102108-07 Aqueous FGD Effluent Field Blank, Set 4 2/9/2011

SUMMARY 

The samples were prepared according to EPA Method 1631E to be analyzed by CVAFS. 

There were no findings from the data review that required additional qualifiers in this 

dataset. The following summarizes the findings from the data review: 

• The sample number for Sample 72157 was labeled incorrectly on the traffic 

report. 

• The sample description for Sample 72148 was entered incorrectly by FGS at the 

time of sample receipt. 

• Two laboratory duplicates were out of the method-suggested relative percent 

difference (RPD) criteria. 

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES 

Sample 72157 was labeled incorrectly as Sample 721557 in the traffic report submitted to 

the laboratory. The error was identified and corrected during the data review based on 

the sample description. FGS incorrectly labeled Sample 72148 as the FGD Bioreactor 

Effluent, Set 4, when the correct sample description is FGD Bioreactor Influent, Set 4. 

This error was identified and corrected during the data review and confirmed based on 

the traffic report. 
3

INITIAL CALIBRATION 

FGS performed the initial calibrations on each analysis day. The initial calibration for 

the CVAFS analysis consisted of a blank and five calibration standards with a correlation 

coefficient ≥ 0.995. All method-specified criteria were met. 

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

All initial and continuing calibration verifications (ICVs, CCVs) met method-specified 

criteria. 

BLANKS 

All the preparation blanks or laboratory reagent blanks (LRBs) and the continuing 

calibration blanks (CCBs) met the method-specified criteria. Because all of the blank 

results were less than the RL, no samples were qualified based on these preparation blank 

results. 

DUPLICATES 

No field duplicate samples were collected with these sampling episodes. Four samples 

were analyzed in duplicate at the laboratory, Influent samples 72144 and 71994 and 

Effluent samples 72048 and 72298. The relative percent difference (RPD) for samples 

72144, 71994, 72048, and 72298 were 30.6%, 7.66%, 19.4% and 43.9%, respectively. 

Two of these RPDs were outside of laboratory criteria. The samples from another 

sampling episode were also analyzed in duplicate with RPDs of 13.3%, 22.4%, and 

3.03%. The laboratory’s RPD criteria between analytical duplicates is 24%. Analytical 

duplicates are not a method requirement; therefore, no samples were qualified based on 

analytical duplicates. 

LABORATORY CONTROL SAMPLES 

All laboratory control samples were within Frontier’s control limits of 80-120% recovery 

and 24% RPD. 

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on Influent 

sample 72144 and Effluent samples 72048 and 72298. MS/MSDs were also performed 

on samples from another sampling episode. All aqueous MS/MSD recoveries were 

within method specifications of 71-125%. All RPDs met method-specifiec criteria. 

DETECTION LIMITS 

The laboratory MDL in the synthetic matrix was 0.239 ng/L. Results below this MDL 

were reported as not detected (ND). 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Total Metals by 200.8 – Long-Term 

Monitoring: Month 4 

TestAmerica generated analytical data for total metals (antimony, arsenic, cadmium, 

chromium, copper, lead, nickel, selenium, silver, thallium and vanadium) for these longterm monitoring samples. The samples were analyzed according to EPA Method 200.8. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA Method 200.8.

Table 1. Long-Term Monitoring Month 4 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

71994 FGD Influent, Set 4 280-11658-1 Aqueous 1/17/2011 1/18/2011

71998 FGD Bioreactor Influent, Set 4 280-11690-1 Aqueous 1/18/2011 1/19/2011

72002 FGD Bioreactor Effluent, Set 4 280-11690-2 Aqueous 1/18/2011 1/19/2011

72007 FGD Bioreactor Influent Field 

Blank, Set 4 

280-11690-3 Aqueous 1/18/2011 1/19/2011

72011 FGD Bioreactor Effluent Field 

Blank, Set 4 

280-11690-4 Aqueous 1/18/2011 1/19/2011

72094 FGD Influent, Set 4 280-11635-1 Aqueous 1/14/2011 1/15/2011

72098 FGD Effluent, Set 4 280-11635-2 Aqueous 1/14/2011 1/15/2011

72103 FGD Effluent Field Blank, Set 4 280-11635-3 Aqueous 1/14/2011 1/15/2011

72144 FGD Influent, Set 4 280-11555-1 Aqueous 1/12/2011 1/13/2011

72148 FGD Bioreactor Influent, Set 4 280-11597-1 Aqueous 1/13/2011 1/14/2011

72152 FGD Bioreactor Effluent, Set 4 280-11597-2 Aqueous 1/13/2011 1/14/2011

72157 FGD Bioreactor Influent Field 

Blank, Set 4 

280-11597-3 Aqueous 1/13/2011 1/14/2011

72161 FGD Bioreactor Effluent Field 

Blank, Set 4 

280-11597-4 Aqueous 1/13/2011 1/14/2011

72193 FGD Influent, Set 3 280-11552-1 Aqueous 1/12/2011 1/13/2011

72197 FGD SBR Influent, Set 3 280-11552-2 Aqueous 1/12/2011 1/13/2011

72201 FGD SBR Effluent, Set 3 280-11552-3 Aqueous 1/12/2011 1/13/2011
2

Table 1. Long-Term Monitoring Month 4 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

72206 FGD SBR Influent Field Blank, 

Set 3 

280-11552-4 Aqueous 1/12/2011 1/13/2011

72210 FGD SBR Effluent Field Blank, 

Set 3 

280-11552-5 Aqueous 1/12/2011 1/13/2011

72244 FGD Influent, Set 4 280-11598-1 Aqueous 1/13/2011 1/14/2011

72248 FGD Effluent, Set 4 280-11598-2 Aqueous 1/13/2011 1/14/2011

72253 FGD Effluent Field Blank, Set 4 280-11598-3 Aqueous 1/13/2011 1/14/2011

72293 FGD Influent, Set 3 280-11553-1 Aqueous 1/12/2011 1/13/2011

72297 FGD Effluent, Set 3 280-11553-3 Aqueous 1/12/2011 1/13/2011

72302 FGD Effluent Field Blank, Set 3 280-11553-4 Aqueous 1/12/2011 1/13/2011

SUMMARY 

The samples were prepared for total metals analysis according to TestAmerica’s “FGD 

ICP/MS SOP: Inductively Coupled Plasma Mass Spectrometry for Trace Elements 

Analysis in Flue Gas Desulfurization Wastewaters,” dated October 6, 2010, based on 

EPA Method 200.8, by ICP/MS analysis. 

Any significant findings are summarized below. No additional data qualifiers were 

required. 

• The sample for FGD Effluent, Set 3 associated with Episode 6571 was incorrectly 

labeled as sample 72295 on the traffic report. The correct sample number (72297) 

was found on the sample bottle label and confirmed with ERG prior to analysis. 

• The matrix spike (MS) and matrix spike duplicate (MSD) recoveries for total 

silver for sample 72248 failed the EPA Method 200.8 control limits of 70-130%. 

The MSD recovery for total silver for sample 72201 also failed the method 

control limits. 

• The MS/MSD relative percent difference (RPD) for total silver for samples 72201 

and 72248 failed the FGD ICP/MS SOP control limits of ±20%. 

• The post digestion spike (PDS) recoveries for silver for samples 72201 and 72002 

failed TestAmerica’s control limits of 85–115%. 

INTERNAL STANDARDIZATION 

All internal standards used by TestAmerica were within the method criteria. 
3

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP-MS analysis consisted of a blank and four calibration standards. 

INITIAL AND CONTINUING CALIBRATION VERIFICATION (ICV/CCV) 

The initial calibration verifications (ICV) and continuing calibration verifications (CCV) 

performed by TestAmerica all had recoveries within the method criteria. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit (RL); however, some elements 

were above the MDL and flagged with a “J” qualifier. No additional qualifiers were 

required for method blanks. 

All instrument blanks (initial calibration blank (ICB) and continuing calibration blank 

(CCB)) were less than the RL; however, some elements were above the MDL and 

flagged with a “J” qualifier. No additional qualifiers were required for instrument blanks. 

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed TestAmerica’s SOP control limits of 50–150% recovery. 

LABORATORY CONTROL SAMPLES (LCS) 

All LCS samples passed the method QC limits of 85–115% recovery. 

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION 

Based on TestAmerica’s SOP, all interference check sample A (ICSA) results had 

analytes of interest with concentrations less than the RL or less than five times the RL 

when known inherent contaminants are present in the stock solution used to make the 

ICS. 

All interference check sample B (ICSAB) synthetic spikes recovered within 

TestAmerica’s SOP criteria of 70–130% of the true value. 

SERIAL DILUTION 

The serial dilution performed on samples 72201 and 72002 passed TestAmerica’s criteria 

of ±10% difference. 

FIELD DUPLICATES 

No field duplicate samples were collected with these sampling episodes. 
4

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

MS and MSD were performed on samples of 72201, 72248, and 72002. The MSD of 

sample 72201 failed the method control limits of 70–130% recovery for silver at 61%, 

which was flagged with an “F” qualifier. The MS/MSD of sample 72248 failed the 

method control limits of 70–130% recovery for silver at 66% and 45% respectively, 

which were flagged with an “F” qualifier. These silver failures are likely due to matrix 

interference from the high concentration of sulfates, which can form insoluble silver 

sulfide and/or silver sulfate. The silver recoveries in the associated LCS/LCSDs were 

acceptable. The RPD for the MS/MSDs for samples 72201 and 72248 failed the FGD 

ICP/MS SOP ±20% control limits for silver. 

Otherwise, all MS/MSD spike recoveries were within the method control limits of 70-

130% and the RPD for the MS/MSDs were within the FGD ICP/MS SOP control limits 

of ±20 percent. No additional data qualifiers were required. 

POST DIGESTION SPIKES (PDS) 

The PDS performed on samples 72201 and 72002 passed TestAmerica’s control limits of 

85–115% recovery for all analytes, except for silver for both PDS samples, which were 

flagged with a “W” qualifier. Additional data qualifiers would be required; however 

silver was not detected in these samples. 

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 
1

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Randy Mercurio, ERG 

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Total Metals by 200.7 – Long-Term 

Monitoring: Month 4

TestAmerica generated analytical data for total metals (aluminum, boron, barium, 

beryllium, calcium, cobalt, iron, magnesium, manganese, molybdenum, sodium, tin, 

titanium and zinc) for these long-term monitoring samples. The samples were analyzed 

according to EPA Method 200.7. 

Table 1 summarizes the samples TestAmerica extracted and analyzed for total metals by 

EPA Method 200.7. 

Table 1. Long-Term Monitoring Month 4 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

71994 FGD Influent, Set 4 280-11658-1 Aqueous 1/17/2011 1/18/2011

71998 FGD Bioreactor Influent, Set 4 280-11690-1 Aqueous 1/18/2011 1/19/2011

72002 FGD Bioreactor Effluent, Set 4 280-11690-2 Aqueous 1/18/2011 1/19/2011

72007 FGD Bioreactor Influent Field 

Blank, Set 4 

280-11690-3 Aqueous 1/18/2011 1/19/2011

72011 FGD Bioreactor Effluent Field 

Blank, Set 4 

280-11690-4 Aqueous 1/18/2011 1/19/2011

72094 FGD Influent, Set 4 280-11635-1 Aqueous 1/14/2011 1/15/2011

72098 FGD Effluent, Set 4 280-11635-2 Aqueous 1/14/2011 1/15/2011

72103 FGD Effluent Field Blank, Set 4 280-11635-3 Aqueous 1/14/2011 1/15/2011

72144 FGD Influent, Set 4 280-11555-1 Aqueous 1/12/2011 1/13/2011

72148 FGD Bioreactor Influent, Set 4 280-11597-1 Aqueous 1/13/2011 1/14/2011

72152 FGD Bioreactor Effluent, Set 4 280-11597-2 Aqueous 1/13/2011 1/14/2011

72157 FGD Bioreactor Influent Field 

Blank, Set 4 

280-11597-3 Aqueous 1/13/2011 1/14/2011

72161 FGD Bioreactor Effluent Field 

Blank, Set 4 

280-11597-4 Aqueous 1/13/2011 1/14/2011

72193 FGD Influent, Set 3 280-11552-1 Aqueous 1/12/2011 1/13/2011

72197 FGD SBR Influent, Set 3 280-11552-2 Aqueous 1/12/2011 1/13/2011

72201 FGD SBR Effluent, Set 3 280-11552-3 Aqueous 1/12/2011 1/13/2011
2

Table 1. Long-Term Monitoring Month 4 Total Metals – Sample Identification 

EPA 

Sample # EPA Sample Description 

Lab Sample 

ID # 

Sample 

Matrix 

Sampling 

Date 

Receipt 

Date 

72206 FGD SBR Influent Field Blank, 

Set 3 

280-11552-4 Aqueous 1/12/2011 1/13/2011

72210 FGD SBR Effluent Field Blank, 

Set 3 

280-11552-5 Aqueous 1/12/2011 1/13/2011

72244 FGD Influent, Set 4 280-11598-1 Aqueous 1/13/2011 1/14/2011

72248 FGD Effluent, Set 4 280-11598-2 Aqueous 1/13/2011 1/14/2011

72253 FGD Effluent Field Blank, Set 4 280-11598-3 Aqueous 1/13/2011 1/14/2011

72293 FGD Influent, Set 3 280-11553-1 Aqueous 1/12/2011 1/13/2011

72297 FGD Effluent, Set 3 280-11553-3 Aqueous 1/12/2011 1/13/2011

72302 FGD Effluent Field Blank, Set 3 280-11553-4 Aqueous 1/12/2011 1/13/2011

SUMMARY 

The samples were prepared for total metals analysis according to TestAmerica’s SOP for 

ICP Analysis for Trace Metals by Method 200.7. Any significant findings are 

summarized below. No additional data qualifiers were required for this set of data. 

• Several samples did not have the date and time of sample collection listed on the 

traffic reports. 

• One sample was listed with the wrong sample number on the traffic report. 

• The post digestion spike (PDS) for sodium for sample 72002 failed 

TestAmerica’s control limits of 85–115% recovery. 

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES 

Samples associated with Episode 6569 (72193, 72197, 72201, 72206, and 72210) did not 

have a sample date or time on the traffic report or sample labels. 

Samples associated with Episode 6571 (72293, 72297, and 72302) did not have a sample 

date or time on the traffic report or sample labels. Additionally, a field sampler name was 

not present on the traffic report. The sample FGD Effluent, Set3 was listed on the traffic 

report as sample 72295, which is incorrect; however, the sample bottle was labeled 

correctly as sample 72297. TestAmerica used 72297 for processing the sample. 

Samples of 72144 FGD Influent, Set 4 did not have a sample date or time listed on the 

sample bottles. 
3

INTERNAL STANDARDIZATION 

While the internal standard (ISTD) yttrium was used for these analyses, no checks for the 

ISTD recoveries within the ±30% criterion of the calibration blank as per Section 9.11 of 

the SOP were seen. All ISTD were within the control limits. 

INITIAL CALIBRATION 

TestAmerica performed the initial calibrations on each analysis day. The initial 

calibration for the ICP analysis consisted of a blank and one calibration standard. 

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS 

The initial calibration verifications (ICV) and continuing calibration verifications (CCV) 

performed by TestAmerica all had recoveries within the method criteria. 

METHOD/INSTRUMENT BLANKS 

All the method blanks were less than the reporting limit (RL); however, some elements 

were above the method detection limit (MDL) and were flagged with the “J” qualifier. 

All instrument blanks (initial calibration blank (ICB) and continuing calibration blank 

(CCB)) were less than the RL; however, some elements were above the MDL and were 

flagged with the “J” qualifier. 

REPORTING LIMIT VERIFICATION STANDARD (CRI) 

All CRI samples passed TestAmerica’s SOP control limits of 50–150% recovery. 

LABORATORY CONTROL SAMPLES (LCS) 

All LCSs passed the method control limits of 85–115% recovery. 

INTERFERENCE CHECK SOLUTIONS 

Interference checks were performed using the synthetic matrix as the check solution. All 

data quality objectives met TestAmerica’s SOP criteria.

SERIAL DILUTION (SRD) 

Serial dilutions were performed for each batch of total samples. All serial dilution percent 

differences were less than 10% as required by TestAmerica’s SOP. 

FIELD DUPLICATES 

No field duplicate samples were collected with these sampling episodes. 
4

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD) 

Matrix spikes (MS) and matrix spike duplicates (MSD) were performed on the total 

samples of 72201, 72248, and 72002. Some elements with high concentrations failed the 

EPA 200.7 Method spike recovery control limits of 70–130% but were flagged with a “4” 

qualifier indicating that the concentration in the parent sample was greater than 4 times 

the spike and could not be reliably calculated. These data were considered acceptable 

based on the LCS passing the method control limits. Otherwise, all MS/MSD spike 

recoveries were within the method control criteria of 70-130%. The relative percent 

difference (RPD) for all MS/MSDs were within TestAmerica’s ± 20% requirement, 

except for magnesium for sample 72095. No additional data qualifiers were needed. 

POST DIGESTION SPIKE (PDS) 

The PDS performed on sample 72201 failed the method criteria of 85–115% recovery for 

boron; however, the result was not qualified with a “W” because the sample 

concentration was greater than 4 times the spike amount. 

The PDS performed on sample 72002 failed the method criteria of 85–115% recovery for 

boron, magnesium and manganese; however, these results were not qualified with a “W” 

because their sample concentrations were greater than 4 times the spike amount. Sodium 

also failed the method criteria and was flagged with a “W” qualifier. All elements passed 

the serial dilution for this sample demonstrating that there were no significant matrix 

interferences. No additional data qualifiers are required.

DETECTION LIMITS 

The laboratory performed an MDL study in the synthetic FGD wastewater matrix, instead 

of reagent water. 
1 

MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD 

CC: Jezebele Alicea, Alternate Work Assignment Manager, EPA EAD 

 Deb Bartram, ERG 

 TJ Finseth, ERG 

From: Jennifer Colby, ERG 

 Donna Tedder, ERG 

Date: 2/9/2012 

Subject: TestAmerica Data Review Narrative for Classicals Analyses – Long-Term 

Monitoring: Month 4 

TestAmerica Denver Laboratory generated analytical data for classical wet chemistry 

analyses for these long-term monitoring samples. All samples were tested for the 

following analytes: 

• Ammonia by EPA method 350.1, 

• Biochemical Oxygen Demand – 5 day (BOD5) by SM 5210B, 

• Chloride and Sulfate by EPA method 300.0, 

• Chemical Oxygen Demand (COD) by EPA method 410.4, 

• Cyanide (total) by SM 4500 CN- E, 

• Nitrate/Nitrite by EPA method 353.2 

• Phosphorus (total) by EPA method 365.1, 

• Total Dissolved Solids (TDS) by SM 2540C, 

• Total Kjeldakl Nitrogen (TKN) by EPA method 351.2, and 

• Total Suspended Solids (TSS) by SM 2540D. 

Table 1 summarizes the 15 samples that TestAmerica analyzed for the above analytes. 

Table 1. Long-Term Monitoring Month 4 Classical Analytes – Sample 

Identification 

EPA 

Sample # 

Sample 

Matrix Sample Description 

Sampling 

Date 

71994 Water FGD Influent, Set 4 1/21/2011 

71998 Water FGD Bioreactor Influent, Set 4 1/21/2011 

72002 Water FGD Bioreactor Effluent, Set 4 1/21/2011 

72094 Water FGD Influent, Set 4 1/18/2011 

72098 Water FGD Effluent, Set 4 1/18/2011 

72144 Water FGD Influent, Set 4 1/14/2011 

72148 Water FGD Bioreactor Influent, Set 4 1/17/2011 
2 

Table 1. Long-Term Monitoring Month 4 Classical Analytes – Sample 

Identification 

EPA 

Sample # 

Sample 

Matrix Sample Description 

Sampling 

Date 

72152 Water FGD Bioreactor Effluent, Set 4 1/17/2011 

72193 Water FGD Influent, Set 3 1/14/2011 

72197 Water FGD SBR Influent, Set 3 1/14/2011 

72201 Water FGD SBR Effluent, Set 3 1/14/2011 

72244 Water FGD Influent, Set 4 1/17/2011 

72248 Water FGD Effluent, Set 4 1/17/2011 

72293 Water FGD Influent, Set 3 1/14/2011 

72297 Water FGD Effluent, Set 3 1/14/2011 

SUMMARY 

All samples were analyzed within the holding time specified in 40 CFR 136 Table II 

unless otherwise noted below. All samples were preserved appropriately unless 

otherwise specified. Group II samples 72293 and 72297 were received at the laboratory 

at a neutral pH. The laboratory preserved the volume and proceeded with the requested 

analyses. 

 

Field duplicate samples were not collected for this episode. Depending on the method, a 

laboratory duplicate was analyzed instead. The Relative Percent Difference (RPD) 

between the sample and its duplicate was less than 20% unless otherwise noted below. 

If applicable, the appropriate number of standards was used to create a calibration curve. 

If sample results were above the highest standard used to create the curve, the sample was 

diluted and reanalyzed. All sample results were between the lowest and highest standards 

unless noted below. Additionally, unless otherwise noted, all calibration blanks and 

calibration verification samples met the criteria specified in the method. 

If required by the method, the quality control sample (QCS), a secondary source standard 

used to verify calibration, was always within the control limits specified by the method. 

As described below, the analyte of interest was detected above the method detection limit 

(MDL) in some laboratory reagent blanks (LRB). However, the analyte of interest was 

never detected above the reporting limit (RL) in the LRBs. If required by the method, all 

laboratory fortified blanks (LFB) met the criteria specified in the method unless specified 

below. 

If required by the method, a matrix spike (MS) analysis was run on samples 72002, 

72094, 72193, 72201, 72244, and 72297 for each analyte to check for matrix 

interferences. All MS samples analyzed met the criteria specified in the method unless 

described below. 
3 

DATA NOTES/ISSUES 

Ammonia 

Samples 72293 and 72297 were received by the laboratory at a neutral pH. Sample 

72293 was qualified as an estimated, as shown in Table 2. Sample 72297 had a result 

greater than the MDL, but less than the RL, so the result was already flagged with a ”J” 

qualifier, so further qualification was not necessary. 

The percent recoveries for the MS and MSD performed on sample 72094 were 77% and 

76%, respectively, which is outside of method control criteria. Additionally, the MS and 

MSD results exceeded the calibration range. The MS/MSD results for sample 72094 were 

flagged with “E” and “F” qualifiers. No further qualification is needed.

BOD5 

No issues were identified by the data reviewer. 

Chloride and Sulfate 

MS and MSD were performed on samples 72002, 72094, and 72201. The percent 

recoveries for the MS and MSD for all chloride and sulfate results were within the 

method control criteria; however, all the MS and MSD results exceeded the exceeded the 

calibration range, except for the MSD sulfate result for sample 72002. All these chloride 

and sulfate MS and MSD results were qualified with “E” qualifiers, except for the MSD 

sulfate result for sample 72002. 

COD 

Samples 72293 and 72297 were received by the laboratory at neutral pH. These results 

were qualified as estimated values, as shown in Table 2. 

MS and MSD were performed on samples 72002 and 72098. The percent recoveries for 

the MS and MSD for sample 72002 were 91% and 87%, respectively. The percent 

recoveries for the MS and MSD for sample 72098 were 90% and 88%, respectively. 

Both the MSD results are outside the method control criteria. These MSD results were 

flagged with “F” qualifiers. 

Cyanide 

MS and MSD were performed on samples 72193 and 72002. The percent recoveries for 

the MS and MSD for sample 72193 were 74% and 78%, respectively. The percent 

recoveries for the MS and MSD for sample 72002 were both 88%. The LCS/LCSD 

recoveries were acceptable, indicating that the analytical system was operating within 

control. Additionally, there is no method requirement for the analysis of a MS/MSD and 

no corrective action is necessary. 
4 

Nitrate/Nitrite 

Samples 72293 and 72297 were received by the laboratory at neutral pH. These results 

were qualified as estimated values, as shown in Table 2. 

Phosphorus 

Samples 72293 and 72297 were received by the laboratory at neutral pH. These results 

were qualified as estimated values, as shown in Table 2. 

The method blank associated with two of the batches detected phosphorus at levels 

greater than the MDL, but less than the RL. All affected samples were flagged with a “B” 

qualifier. No additional corrective action is necessary.

MS and MSD were performed on samples 72002 and 72297. The percent recoveries for 

the MS and MSD for sample 72002 were 72% and 56%, respectively, which are outside 

the method control criteria. The MS result was within the laboratory control criteria and 

therefore, was not flagged by the laboratory; however, the MSD result was outside the 

laboratory control criteria and was flagged with an “F” qualifier. The LCS/LCSD 

recoveries for this batch were acceptable, indicating the analytical system was operating 

within control. If reported, the MS result should be flagged with an “F” qualifier. 

The percent recoveries for the MS and MSD for sample 72297 were 66% and 58%, 

respectively, which are outside the method control criteria. There results were flagged 

with “F” qualifiers. The LCS/LCSD recoveries for this batch were acceptable, indicating 

the analytical system was operating within control. 

TDS 

TA reports that constant weight was not achieved after 3 drying cycles for the following 

samples: 72293, 72244, 71994, 72152, and 72248. Review of the general chemistry 

worksheets indicates that constant weight was achieved for all. No further action was 

necessary. 

The analytical duplicate performed on sample 72002 exceeded the recovery criteria. The 

duplicate result was flagged with an “F” qualifier. Because an analytical duplicate was 

not required by the method, no further corrective action is necessary. 

TKN 

Samples 72293 and 72297 were received by the laboratory at neutral pH. These results 

were qualified as estimated values, as shown in Table 2. 

MS and MSD were performed on samples 72001 and 72002. The percent recoveries for 

the MS and MSD for sample 72002 were both 93%, which is within the method control 
5 

criteria. The percent recoveries for the MS and MSD for sample 72001 were 48% and 

46%, respectively, which are outside the method control criteria. There results were 

flagged with “F” qualifiers. The LCS/LCSD recoveries for this batch were acceptable, 

indicating that the analytical system was operating within control. 

TSS 

Because of the nature of the sample matrix, some of the samples in this sampling episode 

used a lower volume, which resulted in elevated RLs being calculated and reported by 

TestAmerica with the sample results. 

The analytical duplicate performed on sample 72248 exceeded the recovery criteria. 

Because the sample result is below the RL, further qualification was not necessary. 

Table 2. Data Review Summary Table 

Sample Analyte Qualifier/Ac

tion 

Reason Level Detected

72293 Ammonia Estimated 

Value 

Received at neutral pH XXX mg/L 

72293 COD Estimated 

Value 

Received at neutral pH XXX mg/L 

72297 COD Estimated 

Value 

Received at neutral pH XXX mg/L 

72293 Nitrate/Nitrite Estimated 

Value 

Received at neutral pH XXX mg/L 

72297 Nitrate/Nitrite Estimated 

Value 

Received at neutral pH XXX mg/L 

72293 Phosphorus Estimated 

Value 

Received at neutral pH XXX mg/L 

72297 Phosphorus Estimated 

Value 

Received at neutral pH XXX mg/L 

72293 TKN Estimated 

Value 

Received at neutral pH XXX mg/L 

72297 TKN Estimated 

Value 

Received at neutral pH XXX mg/L