# Draft
S ampling Plan Allegheny Energy’s Hatfield’s Ferry Steam Electric Plant

Masontown , PA
Sampling Ep isode 6564

Prepared for:



## U.S. Environmental Protection Agency

Engineering and Analysis Division
Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared by:



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

September 2 7

, 20 10

EPA Contract No. 68

- C

- 02

- 095 Work Assignment 7

- 2 9i TABLE OF CONTENTS

Page

1. I NTRODUCTION

................................ ................................ ................................ ................. 1

- 1

1.1 Background

................................ ................................ ................................ .......... 1

- 1

1.2 Objectives and Scope

................................ ................................ ........................... 1

- 1

1.3 Plant Selection

................................ ................................ ................................ ..... 1

- 2

2. F ACILITY O VERVIEW

................................ ................................ ................................ ........ 2

- 1

2.1 FGD Scrubber Systems

................................ ................................ ........................ 2

- 1

2.2 FGD Wastewater Treatment System

................................ ................................ ... 2

- 3

3. S AMPLING P ROCEDURES

................................ ................................ ................................ ... 3

- 1

3.1 Sampling Point Selection

................................ ................................ ..................... 3

- 1

3.2 Analyte Selection

................................ ................................ ................................ . 3

- 1

3.3 Sample Collection Procedures

................................ ................................ ............. 3

- 2

3.3.1 Influent to the FGD Wastewater Treatment System (SP

- 1)

.................... 3

- 3

3.3.2 Effluent from FGD Wastewater Treatment System (SP

- 2)

..................... 3

- 8

3.4 Sample Preservation, Shipping, and Analysis

................................ ................... 3

- 16

3.5 Field Measurements and Engineering Data Collection

................................ ..... 3

- 17

3.6 Sample Labeling

................................ ................................ ................................ 3

- 18

3.7 Traffic Reports

................................ ................................ ................................ ... 3

- 19

3.8 Quality Assurance/Quality Control

................................ ................................ .... 3

- 19

3.9 Sample Splitting

................................ ................................ ................................ . 3

- 21

4. S AMPLING A CTIVITIES

................................ ................................ ................................ ...... 4

- 1

4.1 Sampling Team Organization

................................ ................................ .............. 4

- 1

4.2 Presampling Preparation

................................ ................................ ...................... 4

- 1

4.3 Field Sampling Activities

................................ ................................ .................... 4

- 1

4.4 Logistics

................................ ................................ ................................ ............... 4

- 2

4.4.1 Hatfield’s Ferry Steam Electric Pla nt

................................ ...................... 4

- 2

4.4.2 EPA Contacts

................................ ................................ ........................... 4

- 2

4.4.3 Analytical Laboratories

................................ ................................ ............ 4

- 3

4.4.4 ERG Contacts

................................ ................................ ........................... 4

- 3

4.4.5 Freight Forwarders

................................ ................................ ................... 4

- 3

5. S AMPLE S HIPMENT

................................ ................................ ................................ ........... 5

- 1

5.1 Sample Set Preparation

................................ ................................ ........................ 5

- 1

5.2 Sample Packing

................................ ................................ ................................ .... 5

- 1

6. S ITE

- S PECIFIC H EALTH AND S AFETY P ROCEDURES

................................ .......................... 6

- 1

6.1 Emergency/Medical Procedures

................................ ................................ .......... 6

- 1

6.1.1 First Aid

................................ ................................ ................................ 6

- 1

6.1.2 Site Evacuati on/Emergency Response Plan

................................ ............. 6

- 1

6.1.3 Emergency Showers and Eye Washes

................................ ..................... 6

- 1

6.1.4 Local Hospital

................................ ................................ .......................... 6

- 1

6.2 ERG Health and Safety Responsibilities and Authority

................................ ...... 6

- 1

6.2.1 Work Assignment Manager

................................ ................................ ..... 6

- 2TABLE OF CONTENTS (Continued)

Page

ii 6.2.2 Crew Chief

................................ ................................ ............................... 6

- 2

6.2.3 Sampling Team Members

................................ ................................ ........ 6

- 2

6.3 Briefings

................................ ................................ ................................ ............... 6

- 2

6.3.1 Off

- Site Briefings

................................ ................................ ..................... 6

- 2

6.3.2 On

- Site Briefings

................................ ................................ ..................... 6

- 3

6.4 Safety Procedures

................................ ................................ ................................ . 6

- 3

6.4.1 PPE

................................ ................................ ................................ 6

- 3

6.4.2 Safety Practices

................................ ................................ ........................ 6

- 3

6.4.3 Safe Work Practices

................................ ................................ ................. 6

- 4

6.5 Sampling

- Point

- Specific Safety Procedures

................................ ........................ 6

- 4

6.5.1 Physical Hazards

................................ ................................ ...................... 6

- 4

6.5.2 Thermal H azards

................................ ................................ ...................... 6

- 5

6.5.3 Chemical Hazards

................................ ................................ .................... 6

- 5

6.6 Temperature Extremes

................................ ................................ ......................... 6

- 5

6.6.1 Heat Stress

................................ ................................ ............................... 6

- 5

6.6.2 Heat Stress Monitoring

................................ ................................ ............ 6

- 6

6.7 First Aid

................................ ................................ ................................ ............... 6

- 7

6.8 Sample Preservation and Safety Considerations

................................ .................. 6

- 7

6.9 Training and Medical Monitoring Requirements

................................ ................ 6

- 8

6.10 Shif t Work Protocol

................................ ................................ ............................. 6

- 9

7. R EFERENCES

................................ ................................ ................................ ..................... 7

- 1iii LIST OF TABLES

Page

3

- 1 Sample Collection at Hatfield’s Ferry Steam Electric Plant

................................ .......... 3

- 22

3

- 2 Analytical Methods

................................ ................................ ................................ ........ 3

- 23

3

- 3 Summary of Sample Containers and Planned Preservation

................................ ........... 3

- 24

3

- 4 Sampling Point Field Measurements

................................ ................................ ............. 3

- 25

6

- 1 Sample

- Point

- Specific PPE and Potential Hazards

................................ ....................... 6

- 10

LIST OF FIGURES

Page

2.1 Simplified Diagram of the FGD Wastewater Treatment System, Hatfield’s Ferry Power

Station

................................ ................................ ................................ .............................. 2

- 6

2.2 Detailed Diagram of the FGD Wastewater Treatment System, Hatfield’s Ferry Power

Station

................................ ................................ ................................ .............................. 2

- 7

3

- 1 Sample Preservation Log Sheet

................................ ................................ ..................... 3

- 26

3

- 2 Field Sampling Log Sheet

................................ ................................ .............................. 3

- 27

3

- 3 Engineering Data Collection Sheet (Page 1 of 3)

................................ .......................... 3

- 28

3

- 4 Engineering Data Collection Sheet (Page 2 of 3)

................................ .......................... 3

- 29

3

- 5 Engineering Data Collection Sheet (Page 3 of 3)

................................ .......................... 3

- 30

3

- 6 Example Traffic Report

................................ ................................ ................................ . 3

- 311

- 1 1. I NTRODUCTION

The Engineering and Analysis Division (EAD) of the U.S. Environmental Protection Agency (EPA) is currently conducting a sampling program at steam electric power plants

. The sampling program will characterize raw wastewaters generated by coal

- fired steam electric power plants, as well as evaluate treatment technologies and best management practices used to reduce pollutant discharges

. This sampling plan , deve loped for the Allegheny Energy Hatfield’s Ferry Steam Electric Plant ( Hatfield’s Ferry )

, located in Masontown , Pennsylvania

, provides plant

- specific sampling procedures and methods EPA and its contractors will follow when conducting sampling activities

. Sa mpling will be performed by EPA’s technical contractor, Eastern Research Group, Inc. (ERG), under Contract No. 68

- C

- 02

- 095

. This document, in

combination with the Generic Sampling and Analysis Plan for Coal

- Fired Steam Electric Power

Plants [ 1 ] , is intende d to serve as a guide to the ERG field sa mpling crew, a review mechanism for EPA personnel, and a source of procedural information for plant personnel

.

1.1

During its recently completed detailed study of the steam electric industry, EPA

identifie d metals and certain other constituents present in the wastewater discharges from steam electric power plants that are contributing the majority of the toxic loadings for the industry. Additionally, EPA determined that one of the waste streams contributing most of these toxic loadings are associated with wet flue gas desulfurization (FGD) systems present at coal

- fired power plants. Background

This sampling plan will focus on characterizing wastewaters and treatment system discharges at Hatfield’s Ferry

. For a genera l description of the steam electric process and the wastewaters generated during the operation of a coal

- fired steam electric power plant, see Chapters 3 and 4 of the Steam Electric Power Generating Point Source Category: Final Detailed Study Report [ 2 ].

1.2

EPA and ERG are preparing to collect and analyze samples to characterize wastewater streams generated at coal

- fired steam electric power plants. This sampling plan describes the approach EPA and ERG will use to collect and analyze samples to characterize untreated FGD scrubber purge and treated FGD wastewater from a chemical precipitation FGD wastewater
treatment system . A chemical precipitation system utilizes physical and chemical treatment to remove heavy meta ls using hydroxide, or a combination of hydroxide and sulfide precipitation. Objectives and Scope

Generally, the analytical results collected during this sampling program will support EPA in answering the following key questions:

**•** What are the characteristics (i.e., pollutant s present, pollutant concentrations, flow rate/volume) of untreated FGD scrubber purge wastewater?

**•** What are the effluent concentrations for pollutants present in treated FGD

wastewater?1

- 2 **•** What are the pollutant loadings associated with discharges of FGD wa stewater following treatment?

EPA and ERG conduct ed a one

- day presampling site visit at Hatfield’s Ferry on February

3 , 2010

, and collected t he following information :

**•** I nformation about the plant’s operations , including existing sampling data and

results ;

**•** P rocess

- specific information ;

**•** I nformation on pollution prevention and wastewater treatment o perations ;

**•** P lant

- specific information to tailor sampling plans ; and

**•** Information on potential sampling points

.

The sampling program will consist of four

- day samp ling episodes at selected plants. The sampling will characterize the wastewater generated by the wet FGD scrubbers and the treatment performance of the systems used to treat the FGD scrubber purge wastewater

. EPA and ERG will also collect field quality con trol (QC) samples consisting of bottle blanks, field blanks, equipment blanks, field duplicate samples, and laboratory QC aliquot s used for matrix spike/matrix spike duplicate analyses.

EPA’s sampling program will provide data to perform an engineering a ssessment of the design, operation, and performance of treatment systems at steam electric power plants

. In addition to sampling the wastewater, EPA and ERG will collect information regarding system design and day

- to

- day operation

.

1.3

EPA e xpects to select up to seven coal

- fired steam electric plants for FGD wastewater sampling , basing the plant selection on the process configurations and characteristics of the plants. Plant Selection

Hatfield’s Ferry was selected by EPA for sampling based on the followi ng site

characteristics :

**•** The plant is a coal

- fired power plant that burns a blend of bituminous and PRB in

each of its three generating units;

**•** The plant operates limestone forced oxidation wet FGD system s on all three units ;

**•** The plant operates a segrega ted FGD wastewater treatment system, which includes the following steps:

— Equalization,

— L ime addition ( pH adjustment /metal hydroxide precipitation)

— Organosulfide addition,

— Ferric chloride addition,

— Polymer addition,

— Clarification,1

- 3 — Hydrochloric acid additi on (pH adjustment),

— Filtration ( sand filters) ; and

**•** The plant operates a selective non

- catalytic re duction (S NCR) system on Unit 3

.2

- 1 2. F ACILITY O VERVIEW

Hatfield’s Ferry operates three steam electric units and each has a coal

- fired boil er. Units

1 , 2

, and 3 , which came on line in 19 6 9, 1970, and 1971 respectively, each have a net capacity of

570 megawatts (MW )

. All three generating units burn a blend of 75% b ituminous and 25% PRB

coal [QUESTION FOR HATFIELD’S FERRY: Is this still the cor rect blend ratio?]

. The Hatfield’s Ferry plant and supporting facilities are located on XXX acres in Masontown , Pa

. [QUESTION FOR HATFIELD’S FERRY: What is the size of the Hatfield’s Ferry property?]

Hatfield’s Ferry recently retrofitted all three units with wet FGD scrubber system s to control the sulfur dioxide (SO 2 ) releases from the plant. The Unit 1 FGD system was installed in

June 200 9 , and the Unit 2 and Unit 3 FGD systems w ere both installed in October 200 9 . With the

recent addition of the FGD scr ubber systems, Hatfield’s Ferry also installed an FGD wastewater treatment system to control the discharges of the wastewater generated during the operation of the FGD scrubbers. The FGD scrubber systems are discussed further in Section 2.1 and the FGD

was tewater treatment system is discussed further in Section 2.2.

The plant operates a selective non

- catalytic reduction (S N CR) system only on Unit 3 to control nitrogen oxide (NO

x ) releases from that unit

. Hatfield’s Ferry also uses low NO

x burners

on all three units to control NO

x releases from the plant.

The electrostatic precipitators ( ESPs ) at Hatfield’s Ferry are particulate control devices that remove the fly ash and other particulates from the flue gas. Hatfield’s Ferry utilizes cold

side ESPs to r emove the fly ash from all three units. The ESPs are designed to remove 99.5 percent of the fly ash from the flue gas. [ QUESTION FOR HATFIELD’S FERRY : Please confirm the particulate removal percent of the ESPs. ] The fly ash and other particulates are

colle cted in hoppers and are pneumatically transferred to fly ash silos.

Units 1 and 2 have the following configuration:

**•** Boiler;

**•** Air heater;

**•** ESP; and

**•** FGD scrubber system.

Unit 3 has the following configuration:

**•** Boiler (SNCR system located in boiler) ;

**•** Air heater;

**•** ESP ; and

**•** FGD scrubber system.

2.1

Hatfield’s Ferry operates t hree forced oxidation wet FGD scrubber system s (one per unit)

to control the emission of SO 2 from the unit s . The plant uses limestone slurry as the sorbent for

SO 2 ab sorption. Limestone and service water are fed to three on

- site ball mills (one per unit)

, which pulverize the limestone to create the slurry

. From the ball mills, the slurry is trans ferred to FGD Scrubber Systems2

- 2 hydro cy clones to collect limestone particles that are too large for use in the FGD system

. The

underflow from t he hydrocyclones is sent back to the ball mill s for processing. The overflow from the hydro cy clones , which ranges from 2 2 to 2 5 percent solids (by weight), is transferred to

the limestone slurry storage tank a nd then used as fresh limestone slurry in the absorber

.

The fresh limestone slurry is fed to the reaction tank of the FGD system s where the slurry is pumped to the various levels of the FGD scrubber s with the recycle pumps

. All three absorbers

have five spray levels, but the plant usually only operate s four spray levels at one time

. The slurry is pressurized and sprayed downward into the scrubber vessel through spray nozzles. As the slurry falls downward and the flue gas flows counter

- current to the slur ry, the spray droplets of the limestone slurry contact the flue gas and absorb the SO 2 , which reacts with the limestone particles and produces calcium sulfite. The spray droplets flow downward until they settle on the

first of two dual flow tray s , forming a layer of slurry that the flue gas must pass through to exit the FGD system. The tray has small holes in it that allow the flue gas to bubble through the limestone slurry layered on the tray, which provides additional contact between the limestone slurry and the flue gas. The spray droplets fall downward to the second dual flow tray and then

continue to flow downward in the scrubber until it reaches the reaction tank. Hatfield’s Ferry bubbles air through the reaction tank to oxidize the calcium sulfite to calcium sulfate (i.e., gypsum).

The source of approximately 50% of the make

- up water used in the FGD system s at Hatfield’s Ferry is recycled wastewater treatment lagoon water. The rest of the make

- up water

comes directly from the Monongahela River . Hatfi eld’s Ferry personnel stated they cannot use lagoon water for more than 50% of the makeup water

, otherwise it is difficult for the plant to control the pH within the FGD system

. All wastewater generated at the plant

, except for FGD

wastewater , is transferr ed to the wastewater treatment lagoon, which includes bottom ash sluice

water (after initial settling and pH adjustment) , floor drain wastes, and boiler wash water.

Hatfield’s Ferry intermittently blows down the gypsum slurry from the reaction tank to

co ntrol the solids and chlorides concentration in each of the scrubbers. T he plant initiates a blow

down once solids reach 21% within the absorber. The plant continues to blowdown until the

solid s reduce to 16

- 17% within the absorber . The plant also monitors the chloride level in the

absorber ; h owever, by maintaining the correct level of solids, the plant maintains an adequate chloride level in the absorber at around 10, 5 00 ppm without the need for additional blowdown.

The maximum allowable chloride concentra tion for the absorber is 12,500 ppm. For all three units, blowdown from the absorbers occurs in six hour increments with four to five hours in

between each blowdown. Hatfield’s Ferry transfers the blowdown from the scrubber absorber to the gypsum dewaterin g operations.

The scrubber blowdown is pumped to the primary hydrocyclones (one per unit) where the solid gypsum is separated from the water by centrifugal force. The solid gypsum is forced outward to the walls of the hydrocyclones and falls downward, w hile the water exits the top of the hydrocyclones. The underflow from the primary hydrocyclones is transferred to the vacuum

filter belts. The overflow from the primary hydrocyclone s is monitored. If the chloride or solids level is low, the waste stream is transferred to the reclaim tanks and ultimately goes back to the

absorber. [ QUESTION FOR HATFIELD’S FERRY : At what chloride and solids concentrations does the plant transfer the primary hydroclone overflow back to the absorber? ] Otherwise, the

overflow is pumped to the secondary hydrocyclones. The underflow from the secondary2

- 3 hydrocyclones is transferred to the reclaim tank and recycled back to the absorber . The overflow from the secondary hydrocyclones is pumped to the FGD wastewater treatment system. The secondary hydrocyclone overflow is never recycled back to the absorber.

Hatfield’s Ferry does not wash the gypsum sent to the vacuum filter belts as the gypsum is poured onto the belts . The plant state d that although the system is designed to wash the

g ypsum to remove chlorides

, there is no need to conduct this wash since Hatfield’s Ferry does not have any contracts in place to sell the gypsum. Additionally, washing the gypsum would

cause their average monthly discharge flow rate to rise above their curr ent NPDES permit limit (160 gpm). [QUESTION FOR HATFIELD’S FERRY: Has the plant started washing the

gypsum ?] The gypsum contains a moisture content of 1 0% after the vacuum belt filters

. Hatfield’s Ferry transfers the gypsum to an on

- site landfill for dispo sal. The landfill is lined and has a leachate collection system.

2.2

The FGD wastewater treatment system is designed to receive intermittent transfers of secondary hydroclone overflow

. The design flow rate for the treatment s ystem is 500 gpm. FGD Wastewater Treatment System

Hatfield’s Ferry operates the FGD wastewater treatment system 24 hours per day

, 7 days per week . The wastewater treatment system was installed to treat the FGD scrubber purge

wastewater to meet the plant’s permit limits

. The plant’s FGD wastewater treatment system contains the following treatment operations:

**•** Equalization ;

**•** L ime addition ( pH adjustment /metal hydroxide precipitation) ;

**•** Organosulfide addition ;

**•** Ferric chloride addition ;

**•** Polymer addition ;

**•** Clarification ;

**•** Hydrochloric acid addit ion (pH adjustment) ; and

**•** Filtration (s and filters)

.

Figures 2

- 1 and 2

- 2 located at the end of this section, present process flow diagrams of the FGD wastewater treatment system, as well as the planned sampling locations for EPA’s sampling episode. Figur e 2

- 1 presents a simplified diagram of the FGD wastewater treatment system. Figure 2

- 2 pr esents a more complex diagram providing more detail on the chemical precipitation treatment operations.

The secondary hydrocyclone overflow from the scrubbers is tr ansferred to the equalization tank at the start of the wastewater treatment system. Th e secondary hydroclone

overflow typically contain s 3

- 5% percent solids and ha s a pH of approximately 5.5 S.U. The equalization tank also receives waste water from the wast ewater treatment sump and effluent from the FGD wastewater treatment system, which the plant recirculates to maintain a steady flow of wastewater through the system

. The wastewater treatment sump includes wastewater

such as filter backwash and filtrate fro m the filter presses that dewater the sludge from the clarifiers. Sumps from the dewatering area are also transferred to the equalization tank ; however,

the sumps in the limestone preparati on area are not transferred to the equalization tank.2

- 4 From the e qualization tank, the wastewater flows into the bottom of reaction tank 1

. Hatfield’s Ferry adds l ime to reaction tank 1 to encourage metal hydroxide precipitation and to increase the pH from 5.5 S.U. (pH in the absorber) to between 8.5 and 9.0 S.U . Servic e water is used to create the hydrated lime. Hatfield’s Ferry also adds an o rganosulfide , Nalmet® 1689, to

reaction tank 1 to encourage the formation of sulfide complexes

. The overflow from reaction

tank 1 flows to reaction tank 2 where ferric chloride is added

.

From reaction tank 2, the wastewater is split e venly between two solids contact clarifiers. Right before this split, a polymer is added to the wastewater

. As of the time of the site visit, one clarifier was out of service and being repaired, and all wastewater was being transferred to the

second clarifier. [QUESTION FOR HATFIELD’S FERRY: Are both clarifiers expected to be operating in November during the sampling episode?] Both solids contact clarifiers contain a sludge bed that attracts the solid s in the wastewater. A portion of the sludge from the clarifiers is recycled to reaction tank 1 , while the majority is transferred to the sludge tank and then pumped to a filter press for dewatering

. [ QUESTION FOR HATFIELD’S FERRY : What percentage of

the s ludge is recycled to reaction tank 1 ? ] The dewatered sludge , which contains approximately 75% solids, is transferred to the on

- site landfil l , along with the gypsum . The filter press filtrate is

transferred to the wastewater treatment area sump and recycled back to the equalization tank

.

The clarifier overflow is transferred to the sand filters (gravity filtration); however, prior to reaching the sand filters, hydrochloric acid is injected into the waste stream to decrease the pH

to 7.0 S.U. The backwash f rom the sand filters is transferred to the wastewater treatment area sump, which is recycled back to the equalization tank.

After treatment wi th the sand filters, the wastewater is collected in the treated wastewater storage tank. From this tank, the w astewater is either recirculated back to the equalization tank or mixed with the effluent from the treatment lagoon and discharged to the Monongahela River

.

Discharge from the wastewater treatment system is not continuous; this is largely because

treate d wastewater is sent back to the beginning of the treatment system in order to make sure that wastewater is circulating through the system at all times. The plant attempts to keep the average daily discharge at 160 gpm because the ir permit limits the avera ge monthly discharge

flow rate to less than 160 gpm. However, the plant s ometimes discharges at a flow as high as 600 gpm and sometimes there is no discharge. The wastewater treatment system is designed for typical flow rates between 100 and 500 gpm. [ QUES TION FOR HATFIELD’S FERRY : What is the HRT of the FGD wastewater treatment system? ]

Figure 2

- 2 shows the planned sampling points for the sampling episode at Hatfield’s Ferry

. The FGD wastewater influent sampling point must be upstream of any chemical ad dition

and before the secondary hydrocyclone overflow is mixed with any recycle streams. Because wastewater collected from the sample tap between the equalization tank and reaction tank 1

would contain recycle streams

, ERG will not sample at this location

. In order to get a sample that represents only the secondary hydroclone overflow

, ERG will collect the overflow directly from

each of the secondary hydro cy clone s

. [QUESTION FOR HATFIELDS’S FERRY: Will the plant

be able to install a 3/8 inch hose barb at ea ch Units’ secondary hydrocyclone overflow sample tap? ] Overf low from the secondary hydro cy clones will be intermittent.2

- 5 The FGD wastewater treatment effluent sampling point must have a continuous flow

because 24

- hour composite samples will be collected a t this point

. Therefore, E RG plans to collect the effluent samples from a sample tap that is located after the treated wastewater storage tank, but prior to the discharge pumps and the split that directs the flow to either the equalization

tank or to be di scharged to the river. [QUESTION FOR HATFIELD’S FERRY: Please confirm that the sample location is on the suction side of the discharge pumps. Are the discharge pumps operated continuously? Will EPA be able to pull water from the sample tap continuously?]

Treated FGD wastewater (internal outfall 306) and the effluent from the lagoon (internal outfall 206) are combined and discharged via the final outfall 006 to the Monongahela River

. Hatfield’s Ferry has limits at internal outfall 306 for TSS, oil and g rease, beryllium, copper, lead, mercury, selenium, and silver

.Phys / Chem Separation FGD Scrubber Purge Internal
Outfall 306 Final
Outfall 006 Lagoon Wastewater

Monongahela

River Internal
Outfall 206

Figure 2.1

. Simplified Diagram of the FGD Wastewater Treatment System, Hatfield’s Ferry Power StationFGD Scrubber Purge

Lime

Reaction Tank 1 SP

- 1

. 1

Indicates a Sampling Point Gravity

Filter Clarifier 1

Sludge Storage

Tank Filter Press

Sump Gravity

Filter

Solids to On

site Landfill

Wastewater Flow

Sludge Flow Intermittent Wastewater Flow Clarifier Sludge

Clarifier 2 Gravity Filter

Backwash Reaction

Tank 2 Ferric Chloride

Treated

Wastewater

Storage

Tank Equalization

Tank Effluent Recycle

Monongahela

River Wastewater from Sump

SP

- 2

Effluent Recycle Polymer

Hydrochloric

Acid Organosulfide Secondary Hydroclone

for Unit 1

Secondary Hydroclone

for Unit 2

Secondary Hydroclone

for Unit 3 Hydroclone

overflow

Hydroclone

overflow

Hydroclone

overflow SP

- 1

. 2

SP

- 1

. 3

Figure 2.2. Detailed Diagra m of the FGD Wastewater Treatment System, Hatfield’s Ferry Power Station3

- 1 3. S AMPLING P ROCEDURES

This section discusses the planned sampling procedures to be followed during the sampling episode at Hatfield’s Ferry

. This section also provides the necessary in formation to plan for the logistics of this sampling episode

. All tables and figures in this section are presented

at the end of the section.

3.1

EPA and ERG selected the following five sampling points for Hatfield’s Ferry ( the two

p roposed sampling locations for the plant’s FGD wastewater treatment system as well as the

related Quality Assurance/Quality Control (QA/QC) samples ) : Sampling Point Selection

**•** SP

- 1 Influent to the FGD Wastewater Treatment System (which includes SP

- 1.1

for Unit 1

, SP

- 1.2 for Unit 2 , and SP

- 1.3 for Unit 3) ;

**•** SP

- 2 Effluent from the FGD Wastewater Treatment System ;

**•** SP

- 3 Field Duplicate of Effluent from the FGD Wastewater Treatment System ( same location as SP

- 2 );

**•** SP

- 4 Field Blank for Influent to the FGD Wastewater Treatment Syste m ( same location as SP

- 1); and

**•** SP

- 5 Field Blank for Effluent from the FGD Wastewater Treatment System ( same location as SP

- 2)

.

3.2

Analytes that will be included in EPA’s Hatfield’s Ferry sampling episode include those in the following cla sses of pollutants: Analyte Selection

**•** Classicals:

— Biochemical oxygen demand, 5

- day (BOD 5 ),

— Chemical oxygen demand (COD)

,

— Total suspended solids (TSS),

— Total dissolved solids (TDS),

— Sulfate,

— Chloride,

— Total Kjeldahl nitrogen (TKN),

— Ammonia as nitrogen,

— Nitrate/nitrite as ni trogen,

— Total phosphorus

,

— Total c yanide;3

- 2 **•** Total m etals:

— Aluminum, antimony, arsenic, barium, beryllium, boron, cadmium, calcium, chromium, cobalt, copper, iron, lead, magnesium, manganese, mercury, molybdenum, nickel, selenium, silver, sodium, thallium, ti n, titanium, vanadium, and zinc.

**•** Dissolved m etals:

— Same parameters as listed for total metals, plus hexavalent chromium

.

The analytes selected for analysis reflect the current understanding of coal

- fired power plant FGD wastewaters, including contributi ons from coal, scrubber sorbents, treatment chemicals, and other sources. Table 3

- 1 lists the potential analytes for each sampling point, Table

3

- 2 lists the analytical methods that will be used, and Table 3

- 3 lists the sample container and volume and plan ned on

- site preservation for each parameter or parameter group.

3.3

To characterize the influent to the FGD wastewater treatment system (SP

- 1 ) and the effluent from the FGD wastewater treatment system (SP

- 2 ) at Hatfield’s Ferry

, the sampling

team will use varying methods to collect the samples depending on the sampling point and pollutant parameters. This sub section describes in detail the sample collection techniques. Sample Collection Procedures

Samples will be collected as a series of “fractions,” or b ottles designated for particular analyses requiring the same preservation. The comprehensive sample set will consist of sample fractions for all pollutant classes listed in Section 3.2. Note that some sample fractions will be collected in the same sample b ottle , such as Group I analytes (TSS, TDS, sulfate, and chloride) and Group II analytes (ammonia as nitrogen, COD, nitrate/nitrite as nitrogen, TKN, and total phosphorus).

In general, samplers will work in teams of two to ensure that proper sampling tec hniques are followed and adequate notes are taken at each sampling location. Samplers will wear disposable gloves, Tyvek® suits, masks (when sampling for mercury by EPA Method 1631E ),

steel

- toed boots, hard hats, and safety eyewear, and will observe precau tions while collecting samples, remaining aware of their surroundings. Note that the use of masks is to prevent contamination of the mercury samples and not for respiratory protection.

Sample containers and bottles will be purchased precleaned and certif ied and will not require rinsing with sample. The sample bottles for the metals analyses will be cleaned according

to EPA Method 1669. For this sampling episode, ERG will collect 24

- hour composite samples at

the effluent from the FGD wastewater treatment s ystem sampling point for most analytes; however, cyanide will be collected as a single grab sample and mercury will be collected as four grab samples. ERG will collect individual grab samples at the influent to the FGD wastewater treatment system sampling point for all analytes

. ERG will collect one sample at each sampling point each day over four consecutive 24

- hour periods ( mercury will be collected as four grab samples each day for the effluent from the FGD wastewater treatment system sampling point )

. ER G will follow protocols described in EPA Method 1669 to collect metal sample fractions. All sampling equipment (e.g., tubing) and sample bottles will be cleaned according to the procedures3

- 3 described in EPA Method 1669. Samplers will use “clean hands / dirt y hands” sample collection techniques when collecting metal sample fractions, as described in EPA Method 1669.

Samplers will take care not to touch the insides of bottles or lids/caps during sampling. Samples that require cooling to ≤6 **°** C for preservatio n will be cooled immediately in an ice

- water bath and then placed into coolers containing bagged ice throughout sample storage, shipment, and receipt at the analytical laboratories. The Crew Chief will confirm that samples are actually

≤6 **°** C before being pa cked for shipment to the laboratory and the temperature reading will be documented in the traffic report for the samples. Samples that require cooling to ≤6 **°** C shall not be shipped until that temperature is reached. In addition, the length of time required for the samples to reach ≤6 **°** C shall be documented in the field log sheet.

3.3.1 Influent to the FGD Wastewater Treatment System (SP

- 1)

The influent to the FGD wastewater treatment system (SP

- 1) must be upstream of the equalization tank (i.e., prior to recycle streams mixing with the secondary hydroclone overflow )

. Because Hatfield’s Ferry does not have a sample tap located after the secondary hydrocyclone overflow from each unit is combined, ERG will sample the secondary hydrocyclone overflow

from each unit s eparately. ERG will sample one units secondary hydrocyclone overflow each day. Because Units 1 and 2 do not have an SNCR and Unit 3 does have an SNCR, ERG plans to

collect sample s of the secondary hydrocyclone overflow from each unit according to the

foll owing frequency:

**•** Unit 1 (SP

- 1.1)

– One day of secondary hydrocyclone samples;

**•** Unit 2 (SP

- 1.2)

– One day of secondary hydrocyclone samples; and

**•** Unit 3 (SP

- 1.3)

– Two days of secondary hydrocyclone samples.

Because the purge from the secondary hydroclones may not be continuous, ERG will need to

coordinate closely with Hatfield’s Ferry personnel during the sampling episode to determine

when grab samples can be collected (i.e., when wastewater is being transferred to the FGD
wastewater treatment system )

. ERG will follow protocols described in EPA Method 1669 to collect metal sample fractions from SP

- 1

.

ERG plans to collect split samples with Hatfield’s Ferry (or its representative) , where possible; therefore, ERG plans to attach a piece of silicone tubing to the sample tap with a “Y” splitter at the other end of the tubing to allow ERG and Hatfield’s Ferry (or its representative) to collect samples simultaneously

. The sample tap located upstream of the equalization tank

c urrently has a large diameter tubing ; for the sample collection, the plant will need to install a 3/8 inch hose barb to the sample tap for ERG to attach its tubing

. [ QUESTION FOR HATFIELD’S

FERRY : Please confirm that the plant will be able to install a 3/8 inch hose barb to the sample

tap s loc ated on the overflow line on each of the secondary hydroclones

. ] To prevent potential contamination from the hose barb, ERG will flush sample through the hose barb for at least two minutes prior to collecting any samples. I f problems occur during the colle ction of split samples (e.g., the splitters become clogged and the flow is split unevenly between the sampling crews), then EPA may stop the split sample collection and offer instead to collect duplicate samples with Hatfield’s Ferry or its representative

. For all analyses (except dissolved metals and hexavalent chromium) , the samplers will collect samples through the tubing directly into the specified3

- 4 containers

. For the dissolved metals (excluding mercury) and hexavalent chromium samples, the samplers wil l fill one 10

- L container, allow the solids to settle for approximately one hour, and then pump the aqueous portion of the sample through a 0.45

- μm filter and then through a “Y” splitter into the specified containers; therefore, the dissolved metals and he xavalent chromium samples will be collected as split samples.

Due to the high suspended solids content (1 to 5 percent) of the samples collected at the influent to the FGD wastewater treatment system, EPA may analyze the samples as biphasic samples. If the TSS content of the sample is greater than one percent , the n the laboratory will separate the aqueous and solid portion s of the sample and analyze both for the analyte of interest. In this instance, Group I (chloride and sulfate only), Group II (ammonia as nitrogen, nitrate/nitrite as nitrogen, and total phosphorus only), and total metals (including mercury, but not hexavalent chromium because it is filtered in the field during sample collection) samples will be analyzed as biphasic samples. Group I (TSS and TDS only), Group II (COD only), BOD 5 , hexavalent chromium, and dissolved metals (including mercury ) samples will not be analyzed as biphasic samples. Scrubber purge samples with less than one percent TSS will not require biphasic separation and analys is.

The samples for the influent to the FGD wastewater treatment system (SP

- 1) will be

collected from a sample tap. The sampling equipment will consist of the following:

**•** Colorless, electronic

- grade, non

- nitrile gloves;

**•** Silicone tubing with “Y” splitter;

**•** 10

- L containers;

**•** Teflon® tubing;

**•** Silicone tubing;

**•** 0.45

- μm filter;

**•** Funnel;

**•** Peristaltic pump;

**•** Small table;

**•** Cleanbox;

**•** Tyvek® suits (for me tals samples);

**•** Masks (for mercury samples); and

**•** Sample containers.

ERG will follow all procedures and protocols described in EPA Method 1669 to clean a ll metals sampling equ ipment and to collect metal sample fractions. Two or more ERG samplers ( one designated as “clean hands” and the other as “dirty hands”) will follow the protocols described in the steps below to set up the sampling point, collect the field blank samples, an d collect wastewater samples. In addition to the specific instances noted in the steps below, the samplers will change gloves any time that the sampler has reason to believe his/her gloves have

become contaminated. This section describes the set

- up of the sample point and collection of the EPA samples 1

1 For the sample collection, the samples will be split with the plant (or the plant’s representative) and, therefore, the sample set

- up describes equipment needed for split samples. However, EPA is not responsible for the collection of the split samples collected by the plant and, therefore, the collection of the plant’s samples is not described in this plan. .3

- 5 1. Samplers remove the bags containing the gloves and high

- density polyethelene ( HDPE ) plastic wrap from the coolers or storage containers in which they are packed

. Samplers identify which coolers or boxes con tain the double

- bagged sample bottles, precleaned tubing, blank water, and cleanbox

. Depending on the condition of the sample tap, samplers may need to wipe the tap with a clean paper towel to remove any buildup on the tap that could potentially fall in th e sample bottles during sample collection.

2. Both samplers put on Tyvek® suits, masks, and gloves

. “Dirty hands” covers work surfaces (ground or table) with HDPE plastic wrap and places the double

bagged sample bottles within easy access on the covered surf ace.

3. “Dirty hands” opens the outer bag of the cleanbox and “clean hands” opens the inner bag

. “Clean hands” places the cleanbox at the point of sample collection and secures it open with the clips located inside the box.

4. “Dirty hands” opens the outer bag containing a length of precleaned silicone tubing

. “Clean hands” opens the inner bag inside of the cleanbox

, removes the tubing , and places clean plastic bags over the ends of the silicone tubing.

5. “Dirty hands” opens the outer bag of the funnel and “clea n hands” opens the inner bag inside of the cleanbox and attaches the funnel to the tubing.

6. “Dirty hands” opens the outer bags of the mercury field blank water and tota l

mercury field blank sample bottles

. “Clean hands” opens the inner bag for the

field bl ank water, unscrews the lid and places it in the inner bag

. “Clean hands” passes the funnel end of the tubing with a plastic bag shrouding the funnel to another “clean hands” person to hold outside the cleanbox

. “Clean hands” removes the inner bag for the total mercury field blank sample bottle and places it

in the cleanbox

. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a bucket, with the plastic bag still covering the end of the tubing

. “Dirty hands” pours field blank water t hrough the funnel and tubing

. After the tubing has been purged with sufficient volume, “clean hands” places the silicone tubing back in the cleanbox

. Working inside the cleanbox, “clean hands” unscrews the lid of the field blank sample bottle, removes the tubing from the plastic bag, and prepares to fill the field blank sample bottle

. “Dirty hands” pours field blank water into the funnel and tubing, and “clean hands” fills the total

mercury field blank sample bottle

. “Clean hands” places the end of the sili cone tubing into the plastic bag, replaces the lid on the sample bottle, and closes the inner bag

. “Clean hands” removes the bottle from the cleanbox and places it in the outer bag

. “Dirty hands” closes the outer bag

. The samplers repeat this procedure

for the total metals field blank samples 2

2 ERG will collect field blank samples at the influent to the FGD wastewater treatment system on Day 1 of the sampling episode. Because ERG will collect the dissolved mercury sample using the same technique as the total mercury sample and will send the sample to the laboratory where it will be filtered to yield the dissolved fraction, the laboratory will be responsible for analyzing a filter blank sample to assess any mercury contamination from the .3

- 6 7. “Dirty hands” opens the outer bag for a precleaned 10

- L container. “Clean hands” opens the inner bag and loosens the lid. “Clean hands” holds the end of the silicone tubing at the mouth of the 10

- L container and rem oves the lid. “Dirty hands” pours field blank water through the funnel and tubing, and “clean hands”

fills the 10

- L container with enough field blank water to collect the dissolved metals field blank samples. “Clean hands” places the lid back on the 10

- L

c ontainer, places the plastic bag over the end of the silicone tubing, and places the tubing in the cleanbox. “Clean hands” screws the lid on the 10

- L container and closes the inner bag. “Dirty hands” closes the outer bag of the 10

- L container.

8. After coll ecting the field blank samples, “clean hands” removes the funnel from the tubing

. “Clean hands” and “dirty hands” work to attach the end of the silicone tubing to the sample tap

.

9. “Clean hands” holds the opposite end of the silicone tubing outside the cle anbox over a bucket, with the plastic bag covering the end of the tubing

. “Dirty hands” opens the valve to the sample tap to purge the piping for a minimum of 2 minutes

. “Clean hands” places the end of the silicone tubing back in the cleanbox.

10. “Dirty hand s” opens the outer bag for the total mercury sample bottle

. “Clean hands” removes the inner bag and bottle and places it in the cleanbox

. “Clean hands” opens the inner bag and bottle lid

. “Clean hands” removes the plastic bag from the tubing and fills the sample bottle

. “Clean hands” places the tubing back in the plastic bag, replaces the lid on the sample bottle and closes the inner bag

. “Clean hands” removes the sample bottle from the cleanbox and places it in the outer bag

. “Dirty hands” closes the outer bag

. The samplers repeat this procedure

for the d issolved mercury and total metals samples.

11. “Dirty hands” opens the outer bag for a precleaned 10

- L container

. “Clean hands”

op e ns the inner bag and loosens the lid

. “Clean hands” holds the end of the

sili cone tubing at the mouth of the 10

- L container and removes the lid

. “Dirty hands” opens the sample valve to allow sample to flow into the 10

- L container

. “Clean hands” fill s the 10

- L container with sample to be analyzed for dissolved

metals and hexavalent chromium, which is required to be filtered for these analyses. The samplers will allow the solids to settle for one hour while collecting the remaining samples

. “Clean hands” places the lid back on the 10

- L container, places the plastic bag over the end of the silicone tubing , and places the tubing

into the cleanbox. ”Clean hands” screws the lid on the 10

- L container and closes the inner bag. “Dirty hands” closes the outer bag of the 10

- Liter container. Both samplers change their gloves.

12. “Dirty hands” p l ac es an ERG label on the outer bags of the sample bottles.

filtering performed at the laboratory. Therefore, ERG does not need to collect a separate dissolved mercury field blank sample in the field.3

- 7 13. “Clean hands” holds the tubing outside the cleanbox over a bucket and removes the plastic bag covering the end of the tubing. “Dirty hands” opens the lid of a 1

- L plastic container for field measur ements and holds the bottle above the bucket while “clean hands” fills the bottle with sample from the tubing. T he samplers will give the container to another sampling team member to measure the temperature and pH

.

14. “Dirty hands” opens the lid of the BOD 5 sample container and holds the bottle above the bucket while “clean hands” fills the bottle with sample from the tubing. The samplers repeat this procedure for the Group I, Group II , and total cyanide samples.

15. Immediately after all samples have been co llected, the samplers test the total cyanide samples for sulfides and oxidants and preserve the samples according to the preservation protocols outlined in Section s 3.4 and 3.5

.

Dissolved Metals Sample Collection

16. Samplers allow the 10

- L sample container to continue to settle if one hour has not elapsed since the sample was collect ed

.

17. “Dirty hands” covers the work surfaces (ground or table) with HDPE plastic wrap and places the double

- bagged sample bottles within easy access on the covered

surface.

18. “Dirt y hands” opens the outer bag of the clean box and “Clean hands” opens the inner bag

. “Clean hands” places the cleanbox at the point of sample collection

. “Clean hands” secures the cleanbox open with the clips located inside the box.

19. “Dirty hands” opens th e opening on the peristaltic pump head so the tubing can be placed in the pump head

. “Dirty hands” opens the outer bag containing a length of precleaned Teflon® tubing attached to a 5

- foot length of precleaned silicone tubing, a “Y” splitter, and two addit ional pieces of precleaned silicone tubing

. “Clean hands” moves the tubing into the cleanbox, opens the inner bag

, and removes the tubing

. “Clean hands” places a clean plastic bag over the end s of the

Teflon® and silicone tubing.

20. “Dirty hands” threads the silicone tubing into the peristaltic pump head.

21. Both samplers change gloves.

22. “Dirty hands” opens the outer bag of a capsule filter

. “Clean hands” opens the inner bag and removes the capsule filter

. “Clean hands” attaches the capsule filter

to the silico ne tubing just before the “Y” splitter.

23. “Dirty hands” opens the outer bag of the 10

- L container that was used to collect the field blank water for the dissolved metals fractions. “Clean hands” opens the3

- 8 inner bag of the 10

- L container. “Clean hands” remov es the Teflon® tubing from the cleanbox, opens the lid of the 10

- L plastic container, removes the plastic bag from the Teflon® tubing, and places the Teflon® into the 10

- L container. “Dirty hands” opens the dissolved metals field blank sample bottle

. “Clea n hands”

removes the dissolved metals field blank sample bottle and places it in the

cleanbox

. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a bucket, with the plastic bag still covering the end of the tubing and “dirty

hands ” operates the pump to pump about 750 mL of blank water from the field

blank water bottle

. “Clean hands” places the end of the silicone tubing in the cleanbox, opens the inner bag of the dissolved metals field blank sample bottle,

and removes the lid

. “Dir ty hands” operates the pump to collect the dissolved metals field blank sample and then stops the pump . The samplers repeat the procedure for the dissolved metals and hexavalent chromium field blank samples. If a new filter is needed, “clean hands” removes the used filter and samplers follow step 2 1 to replace the filter 3

.

24. Both samplers change gloves.

25. “Dirty hands” opens the outer bag of one of the 10

- L containers

. “Clean hands” opens the inner bag, removes the lid, and places the end of the Teflon® tubin g into the container

. “Clean hands” holds the end of the silicone tubing outside the cleanbox, with the plastic bag still covering the end of the tubing

. “Dirty hands” starts the pump and passes approximately 7 50 mL through the tubing and filter

and then s tops the pump.

26. “Dirty hands” opens the outer bag of the dissolved metals sample bottle

. “Clean hands” removes the inner bag and bottle and places it in the cleanbox

. “Clean hands” opens the inner bag and removes the lid

. “Dirty hands” operates the pump

to collect the dissolved metals sample and then stops the pump

. “Clean hands” closes the lid on the sample bottle and closes the inner bag. “Clean hands” places the inner bag and bottle in the outer bag and “dirty hands” closes the outer bag

. The samplers re peat this procedure for the di ssolved metals and hexavalent

chromium samples

.

27. “Dirty hands” places an ERG label on the outer bags of the sample bottles.

EPA and ERG plan to collect samples at the i nfluent to the FGD w astewater t reatment

s ystem (SP

- 1) o n four consecutive days. The sample collection setup and sampling technique for

each day of sampling will be the same , except for the unit from which the samples are collected

.

3.3.2 Effluent from FGD Wastewater Treatment System (SP

- 2 )

The effluent from the F GD wastewater treatment system (SP

- 2 ) will be collected from the sample tap located downstream of the treated wastewater storage tank and upstream of the

3 ERG will collect field blank samples at the influent to the FGD wastewater treatment system during only one day of the sampling episode.3

- 9 split that directs the wastewater to the equalization tank or to the river for discharge

. [ QUESTION FO R HATFIELD’s FERRY : Would the plant be able to set up the sample tap to

have a three

- way splitter with each splitter having a 3/8 inch hose barb and its own valve to

control flow? ] ERG will follow protocols described in EPA Method 1669 to collect metal sam ple

fractions from SP

- 2

.

ERG will collect the effluent from the FGD wastewater treatment system composite samples using two automatic compositors that will be programmed to collect individual sample volumes into two large containers (e. g. , two 20

- liter H PDE containers). ERG will collect 20 liters of sample volume for the metals compositor and 20 liters of sample for the classicals compositor, which will provide sufficient sample volume to collect all EPA samples as well as plant split sample s and addition al volume for purging tubing and contingencies. The volume will then be programmed to be collected in one

- hour intervals during the 24

- hour composite period. Following the composite period, ERG will pump off the specific sample volumes into the

individual sample containers.

ERG will use one automatic compositor to collect sample volume for the metals analyses (excluding mercury) and another automatic compositor to collect sample volume for all classical analytes (i.e., BOD 5 , Group I, and Group II). In ad dition to collecting automatic composite samples for the analytes listed above, ERG will collect total and dissolved mercury grab samples every six hours during each compositing period. ERG will also collect one grab sample for cyanide during each composit ing period.

ERG plans to collect split samples with Hatfield’s Ferry (or its representative), where possible; therefore, when pump ing off the composite samples, a “Y” splitter will be used with two pieces of silicone tubing attached to the “Y” splitter t o allow ERG and Hatfield’s Ferry (or its representative) to collect samples simultaneously. I f problems occur during the collection of split samples (e.g., the splitters become clogged and the flow is split unevenly between the sampling crews), then EPA ma y stop the split sample collection and offer instead to collect duplicate samples with Hatfield’s Ferry ( or its representative ).

ERG will collect the total and dissolved mercury grab samples by shrouding one of the three taps on the three

- way splitter ( the other two taps are used for the two compositors) and collecting the samples directly from the tap. Because the samples are collected directly from the

tap , ERG will not be able to collect split samples with Hatfield’s Ferry (or its representative);

the refore, duplicate samples will be collected.

For all analytes, ERG will collect laboratory QC aliquot s at the effluent from the FGD

wastewater treatment system (SP

- 2 ) on Day 3 of the sampling episode . In addition, for all analytes, ERG will collect a fi eld duplicate sample of the effluent from FGD wastewater

treatment system (SP

- 3 ) on Day 2 of the sampling episode

.

The sample of the effluent from the FGD wastewater treatment system (SP

- 2 ) will be

collected from a sample tap. The sampling equipment will consist of the following:

**•** Colorless, electronic

- grade, non

- nitrile gloves;

**•** Peristaltic pump (automatic compositor

– battery powered);3

- 10 **•** Large composite containers (e.g., 20

- liter containers);

**•** Funnel;

**•** “Y” splitter;

**•** “T” splitter;

**•** Teflon® tubing;

**•** Silicone tub ing;

**•** 0.45

- μm filter;

**•** Cleanbox;

**•** Tyvek® suits (for me tals samples);

**•** Masks (for mercury samples); and

**•** Sample containers.

All metals sampling equipment will be specially cleaned according to the procedures

described in EPA Method 1669. The supplier of the c leaned bottles, tubing, and composite containers will prepare and analyze bottle blanks and equipment blanks to evaluate possible

contamination. ERG will follow protocols described in EPA Method 1669 to collect metal sample fractions. Two or more ERG sampl ers (“clean hands” and “dirty hands”) will follow the protocols described in the steps below to set up the sampling point, collect the field blank samples, and collect wastewater samples. In addition to the specific instances noted in the steps below, the samplers will change gloves any time that the sampler has reason to believe his/her gloves have become contaminated. This section describes the set up of the sample point and collection of the EPA samples 4

.

1. Samplers remove the bags containing the gloves and HDPE plastic wrap from the coolers or storage containers in which they are packed. Samplers identify which

coolers or boxes contain the double

- bagged composite containers, precleaned tubing , blank water, and cleanbox

.

2. Both samplers put on Tyvek® suit s, masks, and gloves. “Dirty hands” covers work surfaces (ground or table) with HDPE plastic wrap and places the double

bagged composite containers within easy access on the covered surface.

3. “Dirty hands” opens the outer bag of the cleanbox and “clean han ds” opens the clear inner bag. “Clean hands” places the cleanbox at the point of sample

collection. “Clean hands” opens the cleanbox and secures it open with the clips

located inside the box.

4. “Dirty hands” opens up the peristaltic pump portion of the auto matic compositor so the tubing can be added. “Dirty hands” opens the outer bag containing a length

of precleaned silicone tubing , a “T” splitter, and two additional pieces of silicone tubing

. “Clean hands” takes the inner bag containing the tubing and move s it into

the cleanbox. “Clean hands” opens the inner bag and removes the tubing. “Clean hands” places a clean plastic bag over each end of the silicone tubing. The tubing

4 For the sample collection, the samples will be split with the plant (or the plant’s representative) and therefore, the sample set

- up describes equipment needed for split sa mples. However, EPA is not responsible for the collection of the split samples collected by the plant and therefore, the collection of the plant’s samples is not described.3

- 11 configuration will be set up such that one end will be connected to the sample tap, one end will be threaded through the automatic compositor and connected to the large composite container, and one end will be placed next to a sump/drain near the sampling point. To collect the samples, the sample tap will be left open during

the entire sa mple collection time period and will flow directly to the sump/drain; however, the automatic compositor will pull sample from the flow ing stream as dictated by the sampling program. Additionally, the automatic compositor will be capable of purging the line back to the flowing stream between each individual sample aliquot.

5. “Dirty hands” threads one portion of the silicone tubing through the peristaltic pump portion of the automatic compositor.

6. Both samplers change gloves.

7. “D irty hands” opens the outer bag of the metals field blank water and the field

blank composite container

. “Clean hands” opens the inner bag for the field blank water, unscrews the lid

, and places it in the inner bag. “Clean hands” then places

one end of the silicone tubing into the blank water. “Clean hands” also opens the inner bag for the field blank composite container and loosens the lid. “Clean hands” holds the silicone tubing with the plastic bag covering the end out of the

cleanbox and over a bucket and “ d irty hands” operates the p ump to pump blank

water through the tubing

. After the tubing has been purged with sufficient volume, “clean hands” holds the silicone tubing at the mouth of the field blank composite container and fills the composite container with sufficient volume to

the collect the total and dissolved metals field blank samples at the pump

- off

location. “Dirty hands” stops the pump. During the purging of the tubing and collection of the field blank sample volume, “dirty hands” holds t he end of the silicone tubing that wi ll be placed by the sump/drain above the composite container to prevent this portion of the tubing configuration from filling with blank water during the pumping process. “Clean hands” places the plastic bag over the end of the silicone tubing, replaces th e lid on the field blank composite container, places the silicone tubing back in the cleanbox, and closes the inner bag of the field blank composite container. “ Dirty hands” closes the outer bag of the field blank composite container 5

.

8. Both samplers work together to move the sampling tubing, automatic compositor, and composite containers into position for the sample collection. Samplers will ensure that the tubing will stay in place during the 24

- hour sample collection period.

9. “Dirty hands” changes glov es.

5 ERG will collect field blank samples for all metals samples at the effluent from the FGD wastewater treatment system on Day 1 of the sampling episode. Additionally, ERG will collect a total mercury field blank sample during one of the grab samples for each day of sample collection at the effluent from the FGD wastewater treatment

syste m.3

- 12 10. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a bucket, with the plastic bag still covering the end of the tubing. “Dirty hands” places the end of the silicone tubing near the sump/drain and opens the sample tap

valve to allow the wastewater to flow through the tubing. “Dirty hands” operates the pump to purge the pump portion of the tubing for a minimum of 2 minutes.

11. “Dirty hands” programs the automatic compositor to collect the 20 liters of sample over a 24

- hour time pe riod in one

- hour intervals (i.e., collect 8 3 0 mL of sample every hour)

. “Dirty hands” calibrates the compositor to ensure that approximately 8 3 0 mL is collected for each individual grab.

12. “Dirty hands” opens the outer bag of the large composite container. “Clean hands” opens the inner bag and connects the silicone tubing to the port on the composite container, securing the connection with a cable tie. “Clean hands” closes the inner bag around the composite bottle, and “dirty hands” closes the outer bag. The samplers put ice around the composite container to keep the samples cold during the compositing time period.

13. Samplers repeat steps 1

- 1 2 to set up the automatic compositor for the classical analy t es (skipping step 7). Samplers will use another composite c ontainer.

14. “Dirty hands” and “clean hands” then work to collect the total mercury field blank sample. “Dirty hands” shrouds the sample tap with a clear plastic bag that covers the end of the sample tap and provides enough room for samplers to work in with their hands. “Dirty hands” then opens the outer bag of the mercury field blank water and the total mercury field blank sample bottle. “Clean hands” opens the inner bag for the field blank water and the total mercury field blank sample bottle,

unscrews the lids, and places each in its inner bag. “Clean hands” pours the field blank water into the field blank sample bottle, closes the lids, and closes the inner bags. “Clean hands” places the total mercury field blank sample bottle in the outer bag and “dirty hands” closes the outer bag.

15. “ Dirty hands” positions a bucket under the sample tap, opens the valve and purges the valve for at least one minute, and then closes the tap. Dirty hands” then opens the outer bag of the total mercury sample bottle. “Clean han ds” takes the bottles and positions himself/herself at the tap with the bottle under the shrouding and opens the inner bag. “Dirty hands” opens the sample tap and adjusts the flow. “Clean hands” opens the lid of the total mercury sample bottle and places t he bottle under the flowing stream to fill the bottle. “Clean hands” then closes the lid on the bottle and closes the inner bag. “Dirty hands” closes the sample tap. “Clean hands” places the bottle in the outer bag and “dirty hands” closes the outer bag.

T he samplers repeat this procedure to collect the dissolved mercury sample.

The samplers will fill the bottle directly from the sample tap; therefore, the total and dissolved mercury samples will not be collected as split samples with Hatfield’s Ferry (or its representative), but will be collected as duplicate samples.3

- 13 16. The samplers will collect total and dissolved mercury grab samples every six hours during the compositing time period.

17. Samplers collect a total cyanide grab sample from the same sample tap used for the mercury sample collection

. The samplers will fill the bottle directly from the

tap ; therefore, the cyanide sample will not be collected as a split sample with Hatfield’s Ferry (or its representative). Immediately after collection, the samplers need to test for sulfides and oxidants and preserve the sample according to the preservation protocols outlined in Section s 3.4 and 3.5

.

18. Samplers fill a 1

- L jar for the field measurements. The samplers will give the jar to another sampling team member to measure the temperature and pH.

19. The samplers will collect field measurement samples every six hours during the compositing time period. The field measurement samples will be collected from

the sample tap used for the mercury collection

.

20. At the end of the composite sampling period, “dirty hands” stops each of the automatic compositors and opens the outer bag of each composite container. For each container, “clean hands” opens the inner bag and detaches the used tubing from the composite container and co vers the port with a closed lid or small plastic bag. The samplers transport each of the composite containers, including the field blank composite container, to the pump

- off area to pump off the samples into the specified containers.

21. The samplers then rep eat steps 1 through 20 to collect the composite samples for the next day of sample collection.

After collecting the composite samples

, the sampling team then needs to transfer the sample into the individual sample containers at the pump

- off area

. For th is sampling point, ERG

will use a sample pump

- off approach to transfer the composite samples to the individual sample

bottles , because the samples are expected to have a low solids content. For this sample pump

- off procedure, the dissolved metals samples w ill be collected before the total metals and classical samples to prevent cross

- contamination within the tubing

, which could lead to greater

concentrations in the dissolved metals fractions.

Sample Pump

- Off Procedures

22. S amplers remove the bags containing the gloves and HDPE plastic wrap from the coolers or storage containers in which they are packed. Samplers identify which

coolers or boxes contain the double

- bagged sample bottles

, precleaned tubing , and

cleanbox

.

23. Both samplers put on Tyvek® suits and gl oves. “Dirty hands” covers work surfaces with HDPE plastic wrap and places the double

- bagged sample bottles

and precleaned tubing within easy access on the covered surface.3

- 14 24. “Dirty hands” opens the outer bag of the cleanbox and “clean hands” opens the

clea r inner bag. “Clean hands” places the cleanbox at the point of sample

collection. “Clean hands” opens the cleanbox and secures it open with the clips

located inside the box.

25. “Dirty hands” opens the peristaltic pump head so the tubing can be placed in the pump head. “Dirty hands” opens the outer bag con taining a length of precleaned Teflon® tubing connected to a length of precleaned silicone tubing , a “Y” splitter, and two additional pieces of silicone tubing

. “Clean hands” moves the tubing into

the cleanb ox and opens the inner bag and removes the tubing. “Clean hands” places a clean plastic bag over the end of the Teflon® and silicone tubing.

26. “Dirty hands” threads the silicone tubing into the peristaltic pump head.

27. Both samplers change gloves.

28. “Dirty ha nds” opens the outer bag of the field blank composite container and total

me t als field blank sample bottle. “Clean hands” removes the total metals field blank sample bottle and places it in the cleanbox. “C lean hands” opens the inner bag of the field blank composite container. “Clean hands” removes the lid from

the field blank composite container and places the end of the Teflon® tubing in

the blank water. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a bucket, with the plasti c bag still covering the end of the tubing

and “ d irty hands” operates the pump to pump about 75 0 mL of blank water from

the field blank composite container

. “Clean hands” places the end of the silicone tubing in the cleanbox, opens the inner bag of the tot al metals field blank sample bottle, and removes the lid. “Dirty hands” operates the pump to collect the total metals field blank sample and then stops the pump. “Clean hands” closes the lid on the sample bottle and closes the inner bag. “Clean hands” plac es the inner bag and bottle in the outer bag and “dirty hands” closes the outer bag.

29. “Dirty hands” opens the outer bag of a capsule filter. “Clean hands” opens the inner bag and removes the capsule filter. “Clean hands” attaches the capsule filter

to the silicone tubing just before the “Y” splitter

.

30. “Dirty hands” opens the outer bag of the dissolved me t als field blank sample

bottle. “Clean hands” removes the dissolved metals field blank sample bottle and places it in the cleanbox. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a bucket, with the plastic bag still covering the end of the tubing and “ d irty hands” operates the pump to pump about 75 0 mL of blank

water from the field blank composite container

. “Clean hands” places the end of the silicone tubing in the cleanbox, opens the inner bag of the dissolved metals field blank sample bottle, and removes the lid. “Dirty hands” operates the pump to collect the dissolved metals field blank sample and then stops the pump. “Clean hands” closes the lid on the sample bottle and closes the inner bag. “Clean hands” places the inner bag and bottle in the outer bag and “dirty hands” closes the outer3

- 15 bag. The samplers repeat this procedure for the hexavalent chromium field blank samples 6

. “Clean hands” closes the inner bag of the field blank composite container and “dirty hands” closes the outer bag. Note: 75 0 mL of blank water does not need to be purge d for each sample, just at the beginning of each new

filter. If a new filter is needed, “clean hands” removes the used filt er and samplers follow step 29 to replace the filter

.

31. “Dirty hands” opens the outer bag of the large composite container for the metals samples and “clean hands” opens the inner bag. “Clean hands” transfers the

Teflon® tubing from the field blank composite container to the metals sample composite container. “Clean hands” holds the end of the silicone tubing outside the cleanbox over a bucket, with the plastic bag still covering the end of the tubing and “ d irty hands” ope rates the pump to pump about one liter of sample through the tubing and filter and then stops the pump.

32. “Dirty hands” opens the outer bag of the dissolved metals sample bottle. “Clean hands” removes the inner bag and bottle and places it in the cleanbox. “Clean hands” opens the inner bag and removes the lid. “Dirty hands” operates the pump to collect the dissolved metals sample and then stops the pump. “Clean hands” closes the lid on the sample bottle and closes the inner bag. “Clean hands” places

the inn er bag and bottle in the outer bag and “dirty hands” closes the outer bag. The samplers repeat this procedure for the hexavalent chromium samples. During Day 2 of the sampling episode, the samplers will collect additional sample

volume for the field duplic ate samples and during Day 3 of the sampling episode,

t he samplers will collect additional sample volume for the laboratory QC analyses

.

33. “Clean hands” removes the capsule filter from the sample tubing configuration and reconnects the two pieces of tubing.

34. “Clean hands” holds the silicone tubing outside the cleanbox over a bucket, with the plastic bag covering the end of the tubing

. “Dirty hands” pumps about one liter of sample through the tubing and then stops the pump. “Clean hands” places

the end of the silicone tubing back in the cleanbox.

35. “ Dirty hands” opens the outer bag of the total metals sample bottle. “Clean hands” removes the inner bag and bottle and places it in the cleanbox. “Clean hands” opens the inner bag and removes the lid. “Dirty hands” operates the pump to

collect the total metals sample and then stops the pump. “Clean hands” closes the lid on the sample bottle and closes the inner bag. “Clean hands” places the inner bag and bottle in the outer bag and “dirty hands” closes the outer bag. D uring Day

6 ERG will collect field blank samples at the influent to the FGD wastewater treatment system on Day 1 of the sampling episode. Because ERG will collect the dissolved mercury sample using the same technique as the total mercury sample and will send the sample to the laboratory where it will be filtered to yield the dissolved fraction, the laboratory will be responsible for analyzing a filter blank sample to assess any mercury contamination from the filtering performed at the laboratory. Therefore, ERG do es not need to collect a separate dissolved mercury field blank sample in the field.3

- 16 2 of the sampling episode, the samplers will collect additional sample volume for

the field duplicate samples and during D ay 3 of the sampling episode, the samplers will collect additional sample volume for the laboratory QC analyses

.

36. “Dirty h ands” places an ERG label on the outer bags of the sample bottles.

37. “Dirty hands” shakes the large composite containers for the classical analytes to mix the sample. “Dirty hands” opens the outer bag for the composite container

. “Clean hands” opens the inn er bag and transfers the Teflon® tubing from the metals composite container to the composite container for the classical analytes.

38. “Clean hands” holds the silicone tubing outside the cleanbox over a bucket, with the plastic bag covering the end of the tub ing

. “Dirty hands” pumps about one liter of sample through the tubing and then stops the pump.

39. “Dirty hands” opens the lid of a 1

- L plastic container for field measurements and

holds the bottle above the bucket while “clean hands” fills the bottle with sa mple from the tubing. T he samplers will give the container to another sampling team member to measure the temperature and pH

.

40. “Dirty hands” opens the lid of the BOD 5 sample container and holds the bottle

above the bucket while “clean hands” fills the bot tle with sample from the tubing. The samplers repeat this procedure for the Group I, Group II , and total cyanide samples. During Day 2 of the sampling episode, the samplers will collect additional sample volume for the field duplicate samples and during D ay 3 of the sampling episode, the samplers will collect additional sample volume for the laboratory QC analyses.

41. Immediately after all samples have been collected, the samplers test the total cyanide samples for sulfides and oxidants and preserve the samp les according to the preservation protocols outlined in Section 3.4.

EPA and ERG plan to collect samples at the effluent from the FGD wastewater treatment system (SP

- 2 ) on four consecutive days. The sample collection setup and sampling technique for

each day of sampling will be the same.

3.4

All samples will be maintained on ice immediately upon collection (except metals samples that do not require cooling). Because the classical and hexava lent chromium samples are required to be cooled, all composite containers will be maintained on ice. After pumping off the composite samples into the individual sample containers, the classical and hexavalent chromium samples will be put in an ice

- water ba th; however, the other metals samples, which do not require cooling, will Sample Preservation, Shipping, and Analysis

not be placed on ice. The classical and hexavalent chromium grab samples collected at the FGD influent sampling point will also be placed on ice immediately after

collection.3

- 17 The dissolved metals ( excluding mercury) and hexavalent chromium samples will be

filtered in the field. The dissolved mercury samples will be filtered upon receipt at the laboratory. All metals samples, except hexavalent chromium, will be acid

- preserved prior to extraction at the laboratory. H exavalent chromium samples will be preserved on site, according

to the method

- specified protocols. If the hexavalent chromium samples do not reach the required pH (9.3 to 9.7 S.U.) after 3 mL of ammonium sulfate buffer add ition, the samplers will add ammonium hydroxide to achieve the required pH. Samplers will filter samples within 15 minutes

after the compositing period ends (or as soon thereafter as possible). The dissolved samples of

the FGD influent will be filtered app roximately one hour after they are collected to allow for solids settling because the samples’ high solids content that would clog the filter.

The total cyanide grab samples will be preserved according to the method

- specific protocols immediately followi ng collection. During a presampling set

- up day , the samplers will test the wastewater at each sampling point for sulfide using lead acetate test strips. If sulfide is present, the samplers will use the procedure identified in Section 3.5 to determine the m inimal amount of dilution necessary to reduce sulfide to a nondetectable concentration. After determining this minimal dilution factor for the sampling point, the samplers will dilute all samples collected at this sampling point using blank water . After di lution, the samplers will retest the sample for sulfides. If sulfides are still detected, the sample will be diluted further using the same technique as identified in Section 3.5 to ensure that the sample is not over

diluted. The samplers will then test th e diluted sample for the presence of oxidants (i.e., chlorine) using potassium

- iodide starch paper. If total chlorine is present, the samplers will add sodium

arsenite in small increments until the oxidants are at nondetectable concentrations in the sample

. The samplers will then carefully adjust the pH to >10 S.U. using sodium hydroxide and place the sample on ice. The preservation, including the amount of dilution, will be reported to the

lab oratory on the traffic reports.

Table 3

- 3 lists the parameters , bottle types, sample volume, and on

- site preservation requirements for each type of analysis. The type and amount of preservation used will be recorded on sample preservation log sheets (Figure 3

- 1). With the exception of total cyanide samples, if 10 perc ent of the sample volume is added and the required pH is not achieved

, ERG

will discontinue preservation to prevent the sample from being diluted any further and the final pH will be noted it on the traffic report . The wastewater samples, except metals sam ples that do not require cooling , will be packed in ice chests with a sufficient quantity of ice to maintain a temperature of ≤6 **°** C. All samples will be prepared for overnight shipment via Federal Express to

laboratories.

3.5

During the presampling set

- up day (i.e., the day before the sampling episode begins), the samplers will test the wastewater at each sampling point for sulfide using lead acetate test strips to determine if preservation is needed for cyanide. If sulfide is present, the samplers will

determine the minimal amount of d ilution necessary to reduce the sulfide concentration to below detection by the lead acetate test strips. To identify the minimal amount of dilution, the samplers

will dilute the sample by a factor of two (1:1) and retest for sulfide. If sulfide is still d etected, the samplers will dilute the original sample by a factor of 3 (2:1). They will continue t his process until sulfide is not detected in the sample. After this minimal dilution factor is determined for the Field Measurements and Engineering Data Collection3

- 18 sampling point, the samplers will use this m inimal dilution factor to dilu te all samples collected

at the sampling point. The samplers will also test both the original (i.e., nondiluted) and diluted sample for the presence of oxidants (e.g., chlorine) during the presampling set

- up day using potassiu m

- iodide starch paper.

Temperature

, pH , sulfide

, and oxidants will be measured and recorded by the sampling crew at each sampling point (SP

- 1 and SP

- 2 )

. The samplers will measure temperature and pH

when the automatic composite samplers are initially set up and every six hours during the compositing period. The samplers will test the wastewater for sulfide and oxidants at the time the total cyanide grab sample is collected. For temperature and pH , the samplers will fill a 1

- liter glass jar with sample and test the wastewater immediately after collect ing the aliquot. For sulfide and oxidants, the samplers will fill the cyanide sample bottle directly and test for sulfide and oxidants using test strips immediately after sample collection.

Samplers will foll ow applicable test kit calibration procedures specified by the

manufacturer. Table 3

- 4 summarizes the field measurements, the method to be used for the measurement, and the detection range of each field test instrument. In addition, EPA and ERG

will collec t flow rate data for each sampled waste stream. The flow rates for all the sampling points will be collected from the plant’s existing flow recorders.

Field sampling log sheets (Figure 3

- 2) will be completed at each sampling point. This

sheet will recor d the sampling methodology, names of the samplers, sample collection time, field measurements, and any notes and observations.

Samplers will also collect e ngineering information with regard to design and operation of the plant. For example, they will col lect information such as coal usage, plant capacity, wastewater flow rates, sludge generation rates (if applicable), and retention times in wastewater treatment process stages. Engineering data collection sheets (Figures 3

- 3, 3

- 4, and 3

- 5) will be complete d for the plant. This information will be used to determine if the specific design or operational criteria of the steam electric operations affect the wastewater characteristics.

3.6

Each sample will be coded with a uniq ue sample number and labeled at the time of

collection

. Typically, labels are printed prior to arrival in the field, al though they may also be completed by hand

. Each self

- adhesive label will be completed in indelible ink and contain the following informat ion: Sample Labeling

**•** Sample number;

**•** Sampling episode number;

**•** Sampling point/description;

**•** Date of sample collection;

**•** Analysis to be performed;

**•** Sample bottle type; and

**•** Required preservation.3

- 19 If any of the preprinted information is incorrect, it will be revised using inde lible ink

. In particular, if a required preservation is not used, it will be marked out (additional preservation details will be noted on the traffic report)

. Once applied to the sample container, labels are covered with clear tape to prevent tampering, ab rasion, smearing, or loss during transit

. For metal samples, the samplers will not label the sample bottles, but will label the outer plastic bag of the sample bottle.

3.7

To maintain a record of sample collection, trans fer between personnel, shipment, and receipt by the laboratory

, samplers will complete a traffic report for each sample set at each sampling location

. These forms are used to document sample custody transfer from the field to the laboratory

. T raffic report forms will be completed for all samples sent to all laboratories

. Figure 3

- 6 includes an example of a traffic report

. At the time of sample shipment, a copy of the traffic report will be sent to ERG , another copy will be kept by sampling personnel, and tw o copies will be transmitted with the samples to the analytical laboratory. Traffic Reports

In addition to the transfer of custody, the traffic report provides information to the analytical laboratory on the sample number, type of water sample (in

- line process, untreate d wastewater, treated effluent), sample description, whether the sample is preserved, pH of the sample after preservation, type of sample (grab, composite), sample collection date and time, and the analyses requested

. Samplers will use t he comment section to provide special notes or instructions to the laboratory, such as whether samples have been filtered on site or how to composite separate samples prior to analysis

. The sampling team will also comment if sample bottles are not completely filled (i.e., le ss than 75 percent full)

. In addition, the comments section

will be used to note deviations from standard sampling protocols (for example, if a sample could

not be acid

- preserved because of excessive buffering).

3.8

The QA/QC program for sample collection at Hatfield’s Ferry will include the following: Quality Assurance/Qua lity Control

**•** Documentation for samples through laboratory traffic reports;

**•** Collection of field duplicate samples for all analytes ;

**•** Collection of bottle blank(s) for metals;

**•** Collection of field blank(s) for m etals;

**•** Collection of equipment blank(s) for metals; and

**•** Collection of laboratory QC aliquot s for matrix spike/matrix spike duplicate and laboratory duplicate analyses

.

Field d uplicate sample sets will be coll ected as part of the quality assurance program for sampling. During Day 2 of the sampling episode, ERG will collect one field duplicate sample3

- 20 (SP

- 3 ) of the effluent from the FGD wastewater treatment system (SP

- 2 ). The field duplicate samples will be colle cted as separate aliquots in the field. Results of the field duplicate analyses will be used to evaluate precision, including variability in sample collection, handling, preparation, and analysis.

Bottle blanks will be used to evaluate possible contamin ation from the sample bottles.

The bottle blank will consist of an analyte

- free matrix (Ultra Pure Blank Water DI+ TM ) poured into the appropriate sample bottles ( e.g., 250

- mL plastic bottle for metals ) and stored for several days prior to shipment to the l aboratory . The supplier of the cleaned metals bottles will prepare and analyze the bottle blanks prior to shipping the equipment to the sampling episode.

Field blanks will be used to evaluate possible contamination caused by sampling equipment or by samp ling equipment decontamination procedures. Field blanks will be prepared in the field prior to sample collection and analyzed for all sampling equipment, other than sample bottles, that come into direct contact with samples (e.g., tubing or filters).

E R G will prepare field blanks for each of the total and dissolved metals analyses at each

of the two sampling points during Day 1 of the sampling episode 7

. Additionally, ERG will collect total mercury field blanks at the effluent from the FGD wastewater trea tment system sampling point during the collection of one of the grab samples each day of the sampling episode. ERG samplers will use “clean hands / dirty hands” sampling techniques to prepare the

metals field blanks , as discussed in more detail in Section 3.3. The total metals field blanks (including mercury) at the influent to the FGD wastewater treatment system will be prepared by gravity

- feeding ASTM Type 1 water through the silicone tubing into the sample bottles. The total metals field blanks (excludin g mercury) at the effluent from the FGD wastewater treatment system sampling point will be prepared by pumping ASTM Type 1 water through the composite tubing set into a large composite container where it will be held for the 24

- hour compositing period, the n pumping the ASTM Type 1 water from the large composite container through the Teflon® and silicone tubing and into the sample bottles. The total mercury field blank at the effluent from the FGD wastewater treatment system sampling point will be prepared b y pouring ASTM Type 1 water directly into the sample bottles. The dissolved metals field blank at the influent to the FGD wastewater treatment system sampling points will be prepared by gravity

feeding ASTM Type 1 water through the silicone tubing set into a large composite container where it will be held for approximately one hour, then pumping the ASTM Type 1 water from the large composite container through the Teflon® and silicone tubing, through a 0.45

- μm filter, and into the sample bottles. T he dissolved metals field blank at the effluent from the FGD

wastewater treatment system sampling points will be prepared by pumping ASTM Type 1 water through the composite tubing set into a large composite containe r where it will be held for the

24

- hour compositing period, then pumping the ASTM Type 1 water from the large composite container through the Teflon® and silicone tubing, through a 0.45

- μm filter, and into the sample

bottles. The field blanks will determin e if there is any contamination from the sampling equipment, atmospheric contamination

, or other contamination from the surroundings.

7 ERG will not collect a field blank for dissolved mercury because a filter blank will be prepared and analyzed by the laboratory.3

- 21 EPA Method 1669 requires that equipment blanks also be prepared and analyzed for

metals to evaluate possible contaminati on of metals caused by the sampling equipment . The supplier of the tubing and composite containers will prepare and analyze these equipment blanks and provide a report certifying the equipment as clean

.

As part of standard laboratory quality control , ma trix effects on analytical performance are assessed through the analysis of matrix spikes and laboratory duplicates. Consequently, additional sample volume must be collected for these laboratory QC analyses. The sampling team will collect, label, and ship the necessary laboratory QC volumes. L aboratory QC volumes ( e.g.
, matrix spike ( MS ) / matrix spike duplicate ( MSD ) sample) will be collected for every 10 samples collected at a sampling event, excluding field blank samples. For all analytes requiring

laborat ory QC volumes , the sampling team will collect laboratory QC aliquots from the effluent

from the FGD wastewater treatment system (SP

- 2 ) during Day 3 of the sampling episode

.

3.9

Hatfield’s Ferry or it s representative h as elected to collect split samples at each of the sampling points

. Hatfield’s Ferry or its representative will supply all of the personnel, equipment, glassware, and reagents required to collect the split samples and to coordinate the analysis of samples

. For each of the sampling points , excluding the total and dissolved mercury grab sample at SP

- 2, the sampling crew will attempt to collect split samples with Hatfield’s Ferry or its representative as described in this plan ; however, if problems occur (e.g. , the splitters become clogged and the flow is split unevenly between the sampling crews), then EPA may stop the split sample collection and offer instead to collect duplica te samples with Hatfield’s Ferry o r its representative

. For the total and dissolved mercury grab samples at SP

- 2, ERG will not be able to collect split samples with Hatfield’s Ferry due to sample configuration issues discussed previously is Section 3.3.2 ; t herefore, duplicate samples will be collected. Sample Splitting3-22 Table 3

- 1 . Sample Collection at Hatfield’s Ferry Steam Electric Plant

Sampling

Point

Number Sampling Point NameTotal Metals(EPA Method 200.8 withcollision cell)Total Metals(EPA Method 200.7)Dissolved Metals(EPA Method 200.8 withcollision cell)Dissolved Metals(EPA Method 200.7)Total MercuryDissolved MercuryHexavalent ChromiumBOD5Group IaGroup IIbTotal Cyanide

SP

- 1 Influent to the FGD Wastewater Treatment System 4 4 4 4 4 4 4 4 4 4 4

SP

- 2 Effluent from the FGD Wastewater Treatment System 4+1QC 4+1QC 4+1QC 4+1QC 4+1QC 4+1QC 4+1QC 4+1QC 4+1QC 4+1QC 4+1QC

SP

- 3 Field Duplicate of the Effluent

from FGD Wastewater Treatment System 1 1 1 1 1 1 1 1 1 1 1

SP

- 4 Influent to the FGD Wastewater Treatment Sys tem Field Blank 1 1 1 1 1 1

SP

- 5 Effluent from the FGD Wastewater Treatment System

Field Blank 1 1 1 1 4 1

Total Number of Samples 11+1QC 11+1QC 11+1QC 11+1QC 14+1QC 9+1QC 11+1QC 9+1QC 9+1QC 9+1QC 9+1QC

a

– Group I includes total suspended sol ids (TSS), total dissolved solids (TDS), sulfate

, and chloride.

b

– Group II includes ammonia as nitrogen, nitrate/nitrite as nitrogen, total Kjeldahl nitrogen (TKN), chemical oxygen demand (CO D), and total phosphorus.3

- 23 Table 3

- 2

. Analytical Methods

Parameter Method Number Maximum Holding

Time a

Classicals

Biochemical o xygen d emand (BOD 5 ) SM 5210 B 48 hours

Chemical o xygen d emand (COD) EPA 410. 4 28 days

Total s uspended s olids (TSS) SM 2540 D 7 days

Tota l d issolved s olids (TDS) SM 2540 C 7 days

Sulfate EPA 300.0 28 days

Chloride EPA 300.0 28 days

Ammonia as n itrogen EPA 350.1 28 days

Nitrate/ n itrate as n itrogen EPA 353.2 28 days

Total Kjeldahl n itrogen (TKN) EPA 351.2 28 days

Total p hosphorus EPA 365. 1 28 days

Total c yanide SM 4500 CN E 14 days

Total and Dissolved Metals

Mercury EPA 1631 E 90 days b

Hexavalent c hromium (dissolved only) EPA 218.6 28 days

A ntimony, a rsenic, cadmium, chromium, copper, lead, nickel, selenium, silver, thallium, and vanadium EPA 200.8 with

collision cell 6 months

Aluminum, barium, beryllium, boron, calcium, cobalt, iron, magnesium, manganese, molybdenum, sodium, tin, titanium , and zinc EPA 200.7 6 months

a The holding times are based on the on

- site field preserva tion identified in Table 3

- 3.

b The dissolved mercury samples must be filtered in the laboratory within 24 hours after sample collection. Additionally, the samples must be preserved by the laboratory within 48 hours after sample collection.3

- 24 Table 3

- 3

. Summary of Sample Container s and Planned Preservation

Parameter Sample

Container and

Volume Laboratory QC Sample

Container and

Volume On

- Site Preservation

Classicals

BOD 5 One 1

- L plastic

bottle One 1

- L plasti c bottle ≤6 **°** C

Group I a One 1

- L plastic

bottle One 1

- L plastic

bottle ≤6 **°** C

Group II b Two 1

- L plastic

bottle s Two 1

- L plastic

bottle s H 2 SO 4 to pH <2, ≤6 **°** C

Total c yanide One 1

- L plastic

bottle One 1

- L plastic

bottle NaOH to pH >10, dilution until

sulfide is not present, NaAsO 2 until total chlorine is not present, ≤6 **°** C

Metals

T otal metals (EPA Method 200.8 with collision cell) One 5 0 0

- mL plastic bottle No additional

volume needed None (acid preserve at laboratory)

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

- mL plastic bottle No additional

volume needed None (acid preserve at laboratory)

D issolved metals (EPA Method 200.8 with collision cell) One 5 0 0

- mL plastic bottle No additional

volume needed 0.45

- μm filter (performed in field) (acid preserve at laborator y)

D issolved metals (EPA Method 200.7) One 5 0 0

- mL plastic bottle No additional

volume needed 0.45

- μm filter (performed in field) (acid preserve at laboratory)

T otal mercury : None (acid preserve at laboratory) Manual composite grab samples Four 125

- mL glass bottle No additional

volume needed

Influent samples and field blank samples Two 250

- mL glass bottle No additional

volume needed

D issolved mercury : None ( filter and acid preserve at laboratory) Manual composite grab samples Four 125

- mL glas s bottle No additional

volume needed

Influent samples One 250

- mL glass bottle No additional

volume needed

Hexavalent chromium One 2 50

- mL plastic bottle No additional

volume needed 0.45

- μm filter (performed in field)

Ammonium sulfate buffer to pH 9.3

– 9.7

, ≤6 **°** C

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.3

- 25 Table 3

- 4

. Sampling Point Field Measurements

Field Measur ements Method Detection Range (or Gradation of Scale)

Temperature Thermometer

- 20 to 150 ± 1oC

pH (Standard Units) Four

- color indicator strip pH meter 0 to 12 ± 1 pH S.U.

- 1.0 to 15.0 ± 0.1 pH S.U.

Sulfide L ead acetate test strip >50 mg/L sulfide (S 2

- )

Oxidants (i.e., chlorine) P otassium

- iodide starch paper >1 mg/L free chlorine ( Cl 2 )3

- 26 Sampling Episode

____________

Preservation Chemicals

– List Strength of Solution from Bottle and Lot Number

H 2 SO 4

_____________________ NH 4 SO 4

________________________

NaOH

_____________________

Sample

Numb er Analysis Date Time Name Chemical Initial pH Final pH Number of Drops

Figure 3

- 1

. Sample Preservation Log Sheet3

- 27 Sampling Episode:

________________________________ _

Sampling Point :

________________________________ ___

Sample Numbers :

________________________________ __

Date :

Manual Composite 

## □ Grab 

## □

Automatic Composite 

## □

Time of Grab Sample Collection:

Start Time 

## □ AM 

## □ PM

End Time 

## □ AM 

## □ PM

Time of Automatic Sample Collection:

Start Time 

## □ AM 

## □ PM

End Time 

## □ AM 

## □ PM

Equipment Used: _______________________

__________________________

Samplers’ Names: ________________________________________________

Grab Sample Time Temp

° C pH (S.U.) meter / strips Waste Stream Flow Rate (MGD)

1

2

3

4

Notes: (include observations of odor and color of each aliquot, take pictures if necessary)

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

Figure 3

- 2

. Field Sampling Log SheetPlant Name:

________________________________ ________________________________ _______________ Plant Contact:

________________________________ ________________________________ ______________ Dates of Sample Collection :

________________________________ ________________________________ ___ Data Collected by:

________________________________ ________________________________ __________

Instructions: In the tables below, fill out information on the generating units and FGD systems operating at the plant based on all four days of t he sampling episode. Note any changes in operation that occur during the four

- day period. Provide actual data if possible. If actu al data are not available, provide estimates for the specific information. Some of the data requested may not be susceptible to estimation. Enter “URE” for “unable to rea sonably estimate.” Otherwise, specify whether data provided are actual or estimated by writing in “ACT” or EST” wherever appropriate.

Generating Unit Operating Characteristics During Sample Collection

Unit

ID Boiler Type Capacity (MW) Electricity

Production

(MW) (or Percent Capacity % ) a SCR (No, On,

Off) Particulate Control System (HS/CS E SP, or BH)

a The electricity production should be measured on a daily basis from midnight of the 1 st day of sample collection to midnight of the last day of sample collection.

FGD System Operating Characteristics During Sample Collection

Unit

ID Wet FGD System (Yes/No) Type of

Scrubber Forced

Oxidation (Yes/No) Sorbent Additives (DBA, formic

acid, etc.) FGD Make

up Water

Source SO 2 Removal Percentage Type of

Solids Separation

Note changes in operation over the past mo nth (e.g., turned off SCRs on October 1 or burned 5 percent petroleum coke previous week);

Figure 3

- 3

. Engineering Data Collection Sheet (Page 1 of 3)3

- 29 Plant Name:

________________________________ ________________________________ _______________ Plant Contact:

________________________________ ________________________________ ______________ Dates of Sample Collection:

________________________________ ________________________________ ___ Data Collected by:

________________________________ ________________________________ __________

Instructions: In the tables below, provide information on the coal burned and FGD scrubber slurry at the plant for each day of the sampling episode. Provide actual data if possible. If actual data are not available, provide estimates for the specif ic information. Some of the data requested may not be susceptible to estimation. Enter “URE” for “unable to reasonably estimate.” Otherwise, specify whether data provided are actual or estimated by writing in “ACT” or EST” wherever appropriate.

Coal Infor mation

Day of Sampling Unit ID Coal T ype Amount of

Coal Used

During Day of Sampling Source of Coal ( Coal

Region

and/or

S tate) Percent

Sulfur in

Coal Chlorine

Content of

Coal

1

2

3

4

Note changes in operation over the past month (e.g., turned off SCRs on October 1 or burned 5% petroleum coke previous week) as well as conditions and changes during the sampling episode:

Scrubber Slurry Information

Day of Sampling FGD System ID Associated

Unit ID s S crubber Slurry

Blowdown Flow Rate Scrubber

S lurry

P ercent
S olids Time of Dewatering

During Sampling Day Percent

Filtrate Recycled

Back to

S crubber Flow Rate

(gpm) Duration

1

2

3

4

Figure 3

- 4. Engineering Data Collection Sheet (Page 2 of 3)Plant Name:

________________________________ ________________________________ ________________ Plant Contact:

________________________________ ________________________________ ______________ Dates of Sample Collection:

________________________________ ________________________________ ___ Data Collected by:

________________________________ ________________________________ ___________

Instructions: In the table below, provide information on the FGD wastewater trea tment system for each day of the sampling episode and the volumes of the FGD wastewater treatment system tanks and reactors. If possible, provide the name of the acid and polymer used during the samplin g episode. Provide actual data if possible. If actual data are not available, provide estimates for the specific information. Some of the data requested may not be susceptible to estimation. Enter “URE” for “unable to reasonably estimate.” Otherwise, specify whether data provided are actual or estimated by wr iting in “ACT” or EST” wherever appropriate.

FGD Wastewater Treatment System Operation Information

Day of Sampling Scrubber Purge Chemical Usage (specify units)

Flow Rate

(gpm) Duration Lime Ferric

Chloride Organo

- sulfide

_________ (specify product ) Po lymer:

_________ (specify product ) Acid:

_________ (specify product )

1

2

3

4

Volume of equalization tank:

________________ Volume of reaction tanks: 1)

________________ 2)

________________ 3)

________________ Volu me of clarifiers: 1)

________________ 2)

________________

Figure 3

- 5. Engineering Data Collection Sheet (Page 3 of 3)3

- 31 EPISODE NO:

RANGE OF SAMPLE NOS:

Return completed form to:

FOR LAB USE ONLY

NAME: SHIP TO: DATE REC'D:

CITY: ATTN: REC'D BY:

STATE: CARRIER: SAMPLE CONDITION ON RECEIPT:

INDUSTRIAL CATEGORY: AIRBILL:

DATE SHIPPED:

CONFIDENTIAL (Y/N): SAMPLING OFFICE/SAMPLER:

SAMPLE

NUMBERSOURCE WATER(city, river, well)IN LINE PROCESSUNREATED EFFLUENT(raw wastewater)TREATED EFFLUENTOTHER(specify) ADDITIONAL

SAMPLE

DESCRIPTIONPH LEVELPRESERVED (Y/N)G=GRAB / C=COMPOSITESAMPLE COLLECTIONTIME / DATE

Comments: United States


# EPA Environmental Protection Agency
Washington, DC 20460

TRAFFIC REPORT P.O. BOX 1407

USEPA ENGINEERING AND ANALYSIS DIVISION ALEXANDRIA, VA 22313

SAMPLE CONTROL CENTER (703) 519-1140

INDUSTRIAL FIRM SAMPLED SHIPPING & INFORMATION

SAMPLE POINT DESCRIPTION SAMPLE ANALYSES Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151

Figure 3

- 6

. Example Traffic Report4

- 1 4. S AMPLING A CTIVITIES

This section discusses the sampling team organiz ation, sampling preparation, and sampling activities.

4.1

The sampling crew will consist of a crew chief a nd four crew members from ERG and

one EPA representative

. The crew chief will be responsible for all health and safety, sampl e collection, preservation, and shipping activities while at Hatfield’s Ferry

. Following the sampling episode

, ERG will collate the analytical results from each laboratory and summarize and transmit

t his information in a trip report to EPA

. After EPA revie w, the report will be forwarded to Hatfield’s Ferry for review. Sampling Team Organization

4.2

On February 1, 2010 , ERG and EPA conducted a site visit at Hatfield’s Ferry

. The site

visit and subsequent follow

- up telephone calls to Hatfield’s Ferry representativ es provided ERG and EPA the necessary information to prepare for the sampling episode and to create this

s ampling p lan

. Pre s ampling Preparation

As part of preparing the team for the sampling episode at Hatfield’s Ferry , the ERG crew

chief will distribute this s ampling p lan to each team member and ensure they are completely familiar with the sampling plan and the health and safety requirements specific to Hatfield’s Ferry

. The crew chief will also give copies of this sampling plan to Hatfield’s Ferry personnel before sampling be gins

.

The ERG crew chief will also coordinate the procurement and shipment of all necessary sampling and health and safety equipment

.

4.3

Upon arrival at Hatfield’s Ferry , the ERG crew chief , in conjunction with the EPA representative

, will meet with Hatfield’s Ferry personnel to determine whether samples can be collected as planned at each of the planned sampling points

. Upon confirming the methods to collect samples, the ERG crew chief will update the desc riptions of the proposed sampling points, if necessary, in consultation with EPA and Hatfield’s Ferry personnel

. The changes to the sampling point collection techniques will be described in the trip report prepared by ERG after the sampling episode, descri bed in Section 4.1. If necessary, the crew chief will obtain additional equipment

. The revised sampling description will include: Field Sampling Activities

**•** A sampling point description and collection procedure for each sampling point ;

**•** A list of the sample fractions to be collected at each point ;

**•** A list of potential physical hazards (e.g., pH, temperature, and potentially hazardous equipment);

**•** A list of potential chemical hazards associated with each sampling point ; and

**•** A list of proposed health and safety procedures.4

- 2 Prior to sa mpling, the ERG crew chief will notify the ERG Health and Safety Coordinator (HSC) of any revised sampling activity descriptions along with recommended revisions to the proposed health and safety procedures

. Together, the crew chief and HSC will

review the proposed health and safety procedures

. The crew chief will incorporate any plant

specific changes indicated by the HSC and receive approval for sampling from the HSC before proceeding with sampling activities.

All sample bottles will be labeled, collect ed, and preser v ed, according to method protocols

. Sample fractions requiring ≤6 o C preservation will be placed on ice

. Sample fractions will then be sealed, and placed in coolers for shipment to the laboratory

. The Traffic Report forms will be completed and placed in plastic sleeves inside the coolers

. The coolers will then be taken to the nearest Federal Express office and shipped to the analytical laboratories

. At the conclusion of the sampling episode, the sampling equipment will be prepared for return shipping.

4.4

This sub sect i on summarizes Hatfield’s Ferry contacts, analytical laboratory contacts and addresses, and sampling team personnel and support functions. Logistics

4.4.1 Hatfield’s Ferry Steam Electric Plant

Joe Lapcevic Allegheny Energy

800 Cabin Hill Drive Greensburg, PA 15601 (7 24) 838

- 6099

Randy Jones Allegheny Ene rgy Hatfield’s Ferry Steam Electric Plant 2907 E Roy Furman Highway Masontown, PA 15461

724

- 966

- 3016

[ QUESTION FOR HATFIELD’S FERRY : Who will be the plant contact for the sampling episode , including the point of c ontact for shipping supplies to the plant ? ]

4.4.2 EPA Contacts

Ron Jordan Engineering and Analysis Division

U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW (4303T) Washington, D.C

. 20460 (202) 566

- 10034

- 3 J ezebele Alicea Engineering and Analysis Division U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW (4303T) Washington, D.C

. 20460 (202) 566

- 1 755

4.4.3 Analytical Laboratories

Classicals and Metals by 200.7 and 200.8 with Collision Cell TestAmerica, Inc. :

4955 Yarrow Street Arvada, C O 80002 Phone: (303) 736

- 0138 Contact: Elizabeth Eichelberger

Frontier GeoSciences, Inc. Mercury and Dissolved Hexavalent Chromium :

414 Pontius Ave. North Seattle, WA 98109 Phone: (206) 957

- 1428

Contact: Patrick Garcia

- Strickland

4.4.4 ERG Contacts

TJ Finseth ( Crew Chief ) Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 (703) 633

- 1698

Deborah Bartram ( Work Assignment Manager ) Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 (703) 633

- 1669

4.4.5 Freight F orwarders

Federal Express (FedEx) General Information (800) 463

- 3339

[ QUESTION FOR HATFIELD’S FERRY: Does FedEx pick up at the plant? If so, what is the latest possible pick

- up time? ]

FedEx Express Ship Center ( 25 miles from plant) 260 Greenbag Rd

Mo rgantown, WV 265084

- 4 H ours of Operation: Mon.

– Fri.: 8:30 a.m. to 7: 00 p.m. Last Express Drop

- off: Mon.

– Fri.: 7: 00 p.m.

FedEx Office Print & Ship Center ( 40 miles from plant)

401 Painterville Rd Hunker, PA 15639 Hours of Operation: Mon.

– Fri.: 9:00 a.m . to 7 :00 p.m. Last Express Drop

- off: Mon.

– Fri.: 7 :0 0 p.m.

FedEx Authorized Ship Center Jolene’s Post Pack & Ship (11 miles from plant) 101 Atlas Crossing North Union Twp, PA 15401 (724) 438

- 7447 Hours of Operation: Mon.

– Fri.: 9:00 a.m. to 6 :00 p.m. Last Express Drop

- off: Mon.

– Fri.: 5 :00 p.m.5

- 1 5. S AMPLE S HIPMENT

All sample containers will be labeled with ERG's standard address labels

. All samples will be tracked using Traffic Report forms

. Custody will be maintained by the sampling crew

chief from sample collection until samples are delivered to Federal Express.

All samples will be packaged and shipped in accordance with U.S. Department of Transportation ( DOT ) or International Air Transport Association ( IATA ) regulations

. The general IATA pac kaging requirements for air shipment are as follows:

**•** “Inner packaging must be so packed, secured or cushioned as to prevent their breakage or leakage and so as to control their movement within the outer packaging during normal conditions of transport

. Cus hioning material must not react dangerously with the contents of the inner packaging

. Any leakage of the contents must not substantially impair the protective properties of the cushioning

material

. Unless otherwise provided in this paragraph or in the Pack ing Instructions, liquids in Classes, 3, 4, 5, 6, or 8 of Packing Groups I or II in glass or earthenware inner packaging, must be packaged using material capable of absorbing the liquid

. Absorbent material must not react dangerously with the liquid

. Abso rb ent material is not required. ..” (IATA Dangerous Goods Regulations, 5.0.16).

**•** “When filling receptacles for liquids, sufficient ullage (outage) must be left to ensure that neither leakage nor permanent distortion of the receptacle will occur

as a result of an expansion of the liquid caused by temperatures likely to prevail during transport

. Liquids must not completely fill a receptacle at a temperature of

55 ° C (130 ° F).” (IATA Dangerous Goods Regulations, 5.0.12).

The packing and labeling procedures in the following subsections may be used for nonhazardous samples

. Hazardous samples will be identified based on consultation with the

hazardous shipments contact, Steve Strackbein (ERG), and appropriate hazardous shipping procedures will be followed

. Based on p rocess considerations, samples collected at Hatfield’s Ferry will not be classified as IATA dangerous goods.

5.1

Samples will be collected as a series of “fractions,” or bottles designated for particular analyses requiring the same preservation

. The comprehensive water sample set will consist of sample fractions for all pollutants listed in Section 3.2, collected as grab samples directly into the individual sample containers or composite samples that are transferre d to individual sample containers using a pump

- off approach

. Sample Set Preparation

5.2

All dilute samples from the plant will be packed according to the following guidelines (there is no limit on the amount of liquid each sample container may contain): Sample Packing5

- 2 1. Label each sample bottle

. If a required preservation is not used, cross it off with

indelible ink

. Cover the label with clear tape to protect this information

. Do not

label m etal sample bottles , but the outer plastic bag for each bottle instead

.

2. Tighten the lid on e ach 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

. Do not clean t he bottle

threads for the metals sample bottles.

3. Prior to packaging , p lace 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 i n two “bubble bags”)

. The bubble wrap must fit snugly and completely cover the sample bottle

. Enclose e ach “bubble

- wrapped” container and plastic container in an individual sealable plastic freezer bag

.

5. Place two garbage bags inside each other in the coo ler.

6. Place sample bottles in garbage bags in the cooler with proper end up, close the interior garbage bag by tying or with a twist

- tie.

7. Add ice to cooler to keep samples cold during shipment

. Arrange blue ice or sealed plastic freezer bags filled with w et 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 m ore ice when ambient temperatures are very high

. Place t he ice inside the second garbage bag and c lose the second garbage bag with a twist

tie.

8. Fill in around the bottles and any free space with addition al cushioning material

. Use s ufficient packing material so that the sample containers will not shift during shipment.

9. Seal the Traffic Report form in a plastic zip

- lock bag and tape it securely to the

inside of the cooler lid.

10. Place a "Return to ..." la bel on the inside of the cooler lid.

11. Close cooler.

12. Make several wraps with tape around the cooler perpendicular to the seal to ensure that the lid will remain closed if the latch is accidentally released or damaged.5

- 3 13. Tape the cooler drain plug so it will not open.

14. Place a completed address label on the lid of the cooler including name, address, and telephone number of the receiving laboratory and the return address and telephone number of the shipper.6

- 1 6. S ITE

- S PECIFIC H EALTH AND S AFETY P ROCEDURES

This se ction specifies the health and safety procedures and practices to be used by the sampling team during sampling at Hatfield’s Ferry . This section provides general health and safety information for this sampling episode. The sampling team is obligated to fol low all safety procedures specified in this section.

6.1

The following procedures will be followed in the event of a medical or other emergency

situation

. Emergency/Medical Procedures

6.1.1 First Aid

Hatfield’s Ferry has first aid kits ava ilable throughout the plant. In addition, ERG will also bring a first aid kit. In case of an emergency, EPA/ERG will immediately call the control room for safety response. [ QUESTION FOR HATFIELD’S FERRY : Do es the plant have a first responder team and would EPA/ERG have access to the team if necessary? ]

6.1.2 Site Evacuation/Emergency Response Plan

The sampling team will be informed of the Hatfield’s Ferry evacuation procedures and routes by plant personnel

.

6.1.3 Emergency Showers and Eye Washes

Emergency showers and eye wash stations are located throughout the plant

. Before collecting samples at any point, sampling team members will locate the nearest operating safety shower and eye wash station.

6.1.4 Local Hospital

The nearest hospital is Uniontown Hospital

, located in Uniontown , PA , and is approximately 12 miles from Hatfield’s Ferry Power Plant

. The hospital address is:

Uniontown Hospital 500 West Berkeley Street Uniontown, PA 15401

[QUESTION FOR HATFIELD’S FERRY : Is this the closest hospital listing for the area ?]

The local emergency phone number in Masontown , PA is 911.

6.2

The ERG Work Assignment Manager (WAM), crew chief, and sampling team members have different responsibilities to maintain a safe sampling e nvironment

. These responsibilities

are described below. ERG Health and Safety Responsibilities and Authority6

- 2 6.2.1 Work Assignment Manager

The ERG WAM, Deborah Bartram, has the overall responsibility to ensure that these health and safety procedures are developed and implemented in accordance with regulations an d corporate guidelines, that proper health and safety procedures have been initiated, and that all ERG activities are conducted in accordance with the health and safety plan

. The ERG WAM will also ensure that proper resources are allocated so that the proj ect is conducted in a safe manner, and that the crew chief is competent in his ability to oversee health and safety during the sampling episode.

6.2.2 Crew Chief

The ERG crew chief, TJ Finseth , is responsible for ensuring that ERG sampling team

members adhere to this plan

. The ERG cr e w chief and ERG night crew chief are responsible for overseeing all activities. The crew chiefs must report any accident, near miss, or injury to any sampling team member to the ERG Chantilly Office Health and Safety Coordinator (H SC), Kevin Sikora, verbally within eight hours, or sooner

. The HSC will investigate the incident to identify the cause of the accident, near miss, or injury

. If sufficient cause exists, ERG’s general health and safety plan and in

- house training program wil l be modified to avoid similar accidents

in the future.

At the start of the sampling visit, the crew chief s will inspect all sampling points and review sample collection procedures with the Hatfield’s Ferry personnel to ensure that all potential hazards have been identified.

The crew chief s ha ve the authority to enforce ERG’s health and safety requirements contained in this plan, and any facility

- specific requirements

. Changes to this plan or the sampling plan can be made if the crew chief

, the Chantill y HSC , and EPA representative agree that the changes are appropriate.

6.2.3 Sampling Team Members

All field personnel are responsible for following the requirements of this plan, adhering to plant

- specific health and safety procedures, and donning required/rec ommended personal protective equipment (PPE). They are also responsible for bringing health and safety issues to

the attention of the crew chiefs.

6.3

ERG sampling t e am personnel will attend on

- and off

- site health and safety briefings. Briefings

6.3.1 Off

- Site B riefings

Prior to arriving on site, all members of the sampling team will receive a copy of this sampling plan and attend a presampling meeting to review th e sampling plan and the proposed sample collection activities. All ERG employees will be required t o sign a health and safety sign

off sheet stating that they have read, understood, and agree with this health and safety plan prior to participating in field sampling activities.6

- 3 6.3.2 On

- Site Briefings

ERG samplin g team personnel must attend a half

- hour safet y course given by Hatfield’s Ferry personnel prior to conducting sampling activities at Hatfield’s Ferry

. This safety course will review plant

- specific health and safety procedures, including:

**•** Locat ions of on

- site first aid/ descriptions of emergency medic al procedures;

**•** Required PPE;

**•** High hazard areas and other specific areas or hazards of concern;

**•** Emergency alarms and evacuation procedures; and

**•** Other site safety requirements and procedures that ERG personnel must follow.

[ QUESTION FOR HATFIELD’S FERRY : P lease confirm this information is correct .]

6.4

ERG personnel will follow general safety procedures, which include wearing PPE and engaging in safe work practices. Safety Procedures

6.4.1 PPE

The PPE listed below will be worn by ERG personnel at all tim es while inside the premises of Hatfield’s Ferry :

**•** Steel

- toed safety shoes;

**•** Long sleeves (when collecting sampl es ) and pants;

**•** Hard hat, where required by Hatfield’s Ferry ;

**•** Hearing protection, where needed;

**•** Nitrile or noncolored, electronic grade gloves, when collec ting or preserving samples ; and

**•** Safety glasses with side shields or chemical splash goggles, when collecting or preserving samples

.

For all phases of sam ple collection, disposa b l e PPE will be used, so decontamination of the PPE may not be necessary

. If g loves become torn or degraded, they will be thrown away and replaced with a new pair

. Disposable PPE, including gloves, will be removed, b agged, and left at

the site in a controlled manner.

6.4.2 Safety Practices

ERG personnel will conduc t themselves at all times in a manner judged to be safe by site supervisors.

All sample collection will be scheduled so that no ERG employee collects samples alone

. Each worker will maintain visual contact with at least one other worker at all times

. Th is buddy system will ensure against an employee becoming injured or contaminated with chemicals without a coworker being aware of his or her condition

. Workers should “watch out” for each other while working close to potential chemical and physical hazards

. A Hatfield’s Ferry or EPA6

- 4 employee may be used as a buddy by ERG personnel

. This arrangement will be agreed to and acknowledged by the employee

.

ERG employees will not enter any permit

- required confined space areas

.

6.4.3 Safe Work Practices

ERG sampler s will obey t he following safety rules while working in the facility:

**•** Wearing PPE, where required;

**•** Staying within designated areas;

**•** Not wearing loose clothing or jewelry;

**•** Keeping long hair in hard hat or tied back;

**•** Not eating in t he sampling or staging areas; and

**•** Not smoking in the sampling or staging areas

.

6.5

All sampling team members will be advised of any sampling

- point

- specific safety protocols during the on

- site health and safety brief ing

. Table 6

- 1 summarizes all potential sampling

- point

- specific safety hazards as well as the PPE required at each sampling point

. During the day shift, t he sampling team health and safety officer (HSO) for this sampling episode is the crew chief, TJ Finse th (ERG)

. During the night shift, the HSO for this sampling episode is the ERG night crew chief (to be determined at a later date). The HSO and the sampling team will inspect each sampling point area to identify unique or additional hazards not already cov ered in this plan or during the formal health and safety briefing

. If additional hazards are found, the sampling team will be informed of each hazard and required control measures prior to the start of work

. Where identi fied hazards may affect the plant ’s personnel, the HSO will notify the appropriate Hatfield’s Ferry personnel. Sampling

- Point

- Specific Safety Procedures

6.5.1 Physical Hazards

ERG personnel will be alert for all physical hazards present while on site

. Physical hazards may arise from using catwalks, hitting low

- hanging overhead piping, a nd working around moving equipment or vehicles

. ERG personnel will be aware of the potential splash

hazard s at SP

- 1 and SP

- 2 due to the location of the sample tap s

. To prevent splashing, ERG personnel will ensure that the sample tubing is connected securel y to the sample tap and will open the sample valve slowly when collecting samples

. Other potential hazards may include falling hazards during sample collection, tripping on metal grates, or operation of large trucks and machinery in the vicinity of the sam ple collection area

. See Table 6

- 1 for potential hazards that may be associated with specific sampling points.

Noise may be a hazard in certain areas of the facility

. The sampling team will use h earing protection where required by the plant , when they ar e having trouble hearing or being heard when standing three feet or less away from another person, or when deemed necessary by the Hatfield’s Ferry personnel or ERG crew chief

.6

- 5 6.5.2 Thermal Hazards

Heat stres s may be a concern during the sampling episode

. S a mplers may be suited in Tyvek® and temperatures could reach extremes

.

Wastewater sampling points are not expected to be too hot for safe handling using typical

PP E

. Thicker nitrile gloves may be used during sampling if sample bottles are too hot to hold

. S amplers will handle extremely hot samples with heat

- resistant gloves.

6.5.3 Chemical Hazards

The only chem i cal hazards expected are chemicals used to preserve samples

. All sampling team members will be advised of any potential chemical hazards at each sampl ing point as well as any special PPE recommendations during the formal health and safety briefing

. If the sample tap (i.e., the point from which the wastewater flows) is above waist height, a face shield or goggles must be worn during sample collection

. To avoid ingesting chemicals, sampling team members will be required to wash hands thoroughly before eating or drinking

. ERG personnel will not be permitted to enter areas where the facility has determined that respiratory protection equipment is necessary t o protect against inhalation hazards

.

6.6

Extremely hot temperatures can be a health and safety hazard for this sampling episode

. ERG personnel will take precautions to avoid injuries due to extreme temperatures. Temperature Extremes

6.6.1 Heat Stress

Heat stress is not only a concern in hot/humid outdoor environments, it is a concern due to the thermal or radiant heat generated by equipment and/or processes

. Sampling team personnel will monitor each other for the following symptoms:

**•** Heat rash that may result from continuous exposure to heat or humid air

. Treatment: Wear cotton clothing under coveralls or Tyvek®.

**•** Heat cramps that are caused by heavy sweating and inadequate electrolyte replacement

. Many times, cramps may not occur until aft er work or until the worker is sleeping

. Signs and symptoms include muscle spasms and pain in the hands, feet, and abdomen

.

**•** Treatment: Gently stretch and massage muscles and replace fluids. Have worker

rest in a cool shaded area.

**•** Heat exhaustion that oc cu r s from increased stress on various body organs including inadequate blood circulation due to cardiovascular insufficiency or dehydration

. Signs and symptoms include:

— Pale, cool, moist, clammy skin

— Heavy sweating6

- 6 — Headache and dizziness

— Nausea

— Fainting o r fatigue

— Elevated pulse rate (above 150)

Treatment: Replace fluids, pour cool water over face, neck, hands, arms, and legs

. Place worker in cool air and seek medical care.

**•** Heat stroke is the most serious form of heat stress

. Temperature regulation fails

and the body temperature rises to critical levels

. Immediate action must be taken to cool the body before serious injury and death occur

. Competent medical help

must be obtained

. Signs and symptoms are:

— Red, hot, usually dry skin, body core temperature 1 08 ° F (oral)

— Lack of or reduced perspiration

— Nausea

— Headache, dizziness, and confusion

— Strong, rapid pulse

— Coma

Treatment: Remove worker to cool area, saturate clothes with cold water, wrap worker in wet cold sheets (if possible), monitor ABC (airway, brea thing, circulation), treat for shock, and call emergency services for basic life support (BLS) or advanced life support (ALS).

6.6.2 Heat Stress Monitoring

A worker who exhibits any of the above symptoms will be immediately relieved of responsibilities and req uested to consume electrolyte fluid or cool water while resting in a shaded

area

. The individual should not return to work until symptoms are no longer recognizable

. If symptoms appear critical, persist, or get worse, the crew chief will seek immediate med ical attention for the employee

. If the individual does resume work, he/she will be monitored for any

increase in heart rate for the remainder of his/her shift

. In addition, the worker will be requested to consume electrolyte fluid or cool water every hour

.

The crew chief will visually monitor workers hourly when:

**•** Symptoms of heat stress are reported or observed;

**•** Ambient temperatures exceed 70 ° F and workers are dressed in impervious clothing; or

**•** Ambient temperatures exceed 90 ° F and workers are dressed in normal clothing.

For sampling on this project , work periods will be considered to be approximately two hours in length.6

- 7 At ambient temperatures of 87 ° F and above, workers will be monitored for heat stress conditions by measuring the heart rate (HR) by radial (wrist) pulse for 30 seconds after one

minute of rest

. The HR after one minute of rest should not exceed 110 beats per minute

. If the

heart beat is higher, the next work period will be shortened by 33 percent , while the length of rest period rema ins the same

. If the pulse rate is still higher than 110 beats per minute after one minute of rest in the next rest period, the following work cycle will be sho rtened by another 33

percent

. This shortening of the work period must continue until the worker' s HR is no greater than 110 beats per minute.

6.7

First ai d procedures in response to chemical exposures will be conducted in accordance with the appropriate Material Safety Data Sheets ( MSDS ) for the chemical involved

. If an incident occurs and MSDSs are not available for a particular hazardous chemical (e.g., wastewater), the following general first aid procedures will be performed: First Aid

**•** Skin Contact

– Rinse t he affected area thoroughly and copiously with clean water

. Seek medica l attention if irritation is experienced after cleaning.

**•** Eye Contact

– Flush t he eyes thoroughly at the nearest eyewash station for 15

minutes

. Follow up with medical attention.

**•** Ingestion

– Notify t he hospital and carry out any procedures recommended

.

The first aid kit will be maintained on each site in the equipment staging area

. The

contents of the first aid kit will include at a minimum:

**•** Adhesive bandages;

**•** Antiseptic wipes;

**•** A compress;

**•** An eyewash solution;

**•** Gauze pads;

**•** A cold pack; and

**•** A triangula r bandage.

The injuries most likely to be encountered at Hatfield’s Ferry are cuts and bruises; the first aid kit will be maintained and stocked accordingly.

6.8

Water samples to be analyz ed for various contaminants may be preserved with sulfuric acid (H 2 SO 4 ), hydrochloric acid (HCl), sodium hydroxide (NaOH), an ammonium sulfate buffer solution (NH 4 SO 4 ) , and/or sodium arsenite (NaAsO 2 ) before shipment to the analytical laboratory

. Nitrile g loves and splash goggles must be worn when handling these corrosive chemicals to prevent chemical burns

. Sample preservation must be performed in a well

ventilated area (preferably an operational lab hood) to avoid potential accumulation and

inhalation of any toxic vapors

. When pouring samples, skin protection must also be worn (long

sleeved cotton coveralls or uncoated Tyvek®, safety glasses with side shields or splash goggles, Sample Preservation and Safety Considerations6

- 8 and nitrile gloves). Sodium arsenite is a known carcinogen and toxic so extra c are should be taken when handling any solutions containing sodium arsenite.

In some instances, the use of these preservation chemicals c ould create a chemical

reaction ( i.e., generation of heat or release of toxic vapors )

. For instance, if acids are adde d to a wastewater sample containing cyanide or sulfides, dangerous and toxic vapors will be emitted

. If the sample reacts violently, notify the crew chief and stop preserving the sample immediately.

In the case of a chemical spill, the following procedur es must be followed:

**•** Don protective clothing (nitrile gloves as a minimum).

**•** Ventilate area (open doors, windows, or turn on ventilation).

**•** Use spill control pillows or prepared neutralizers to contain/clean up spill

. Do not

add water to acid.

**•** Place spil led material in a heavy plastic container, label the container, and contact site for disposal information.

**•** Notify the crew chief of the spill and the procedures used.

At any time, if personnel do not feel comfortable about cleaning up the spilled materi al or if a large quantity has been spilled, notify site personnel

. The site may have an emergency response team who will respond to the chemical spill.

In the case of fire, notify the site contact

. If the fire can be easily extinguished using a portable fire extinguisher, and personnel have received fire extinguisher training, extinguish the fire using the portable extinguisher.

6.9

All ERG sampling crew personnel have participated in ERG's annual eight

- hour health and safety training program as specified by ERG's Corporate Health and Safety Policy. Training and Medical Monitoring Requirements

This training includes:

**•** Toxicology;

**•** Exposure limits;

**•** Chemical, biological, and physical hazards;

**•** Heat and cold stress;

**•** Confined spaces;

**•** PPE;

**•** De contamination; and

**•** Emergency plans and procedures.

All ERG personnel involved with sample collection and preservation are active participants in the Medical Monitoring Program

. Field sampling personnel have received a

baseline medical information review

.6

- 9 6.10

This sub section provides guidance for field personnel project schedules and field work, particularly overtime

. It is important to remember extended work schedules will contribute to poor production and motivati on

. All field teams will rotate to ensure that sampling team members receive sufficient rest to avoid injuries resulting from fatigue or inattention. Shift Work Protocol

It is common practice to perform 12

- hour work days under project management direction

. If this work sche dule is exceeded

, the following guidelines will be recognized:

1. A maximum work day will be 15 hours , provided that it does not occur on consecutive days, or more than three times in ANY SEVEN

- DAY PERIOD.

2. Each shift will be followed by nine hours off per 2 4

- hour period, excluding driving time to and from the hotel.

3. No more than seven consecutive days of work will be allowed without a

minimum of 24 hours off.

4. Each work day will be reviewed a s a 24

- hour cycle to assure all field workers receive adequate time off.6

- 10 Table 6

- 1

. Sample

- Point

- Specific PPE and Potential Hazards

Sampling

Point Number Sampling Point Description PPE Required a Potential Physical Hazards b

SP

- 1 Influent to the FGD

Was tewater Treatment System Steel

- toed boots, hard hats,

g loves

, safety glasses , and face shield while connecting and disconnecting tubing from the sample tap. Splash hazard: Potential for splashing from the sample tap

. Sample tap will be above waist

level

.

SP

- 2 Effluent from the FGD Wastewater Treatment System Steel

- toed boots, hard hats, gloves, safety glasses , and face shield while connecting and disconnecting tubing from the sample tap. Splash hazard: Potential for splashing from the sample tap

. Sample ta p will be above waist

level.

a

– Splash protection ( face shield) required if sampling port is waist high or above

. Hearing protection (ear plugs)

will be worn if needed.

b

– Additional physical hazards, if any, will be identified during the formal on

- site health and safety briefing

. Updates to this table will be made as needed.7

- 1 7. R EFERENCES

1. Eastern Research Group, Inc. 2009. Generic Sampling and Analysis Plan for

Coal

- Fired Steam Electric Power Plants

. (February)

.

2. U.S. EPA. 200 9

. Steam Electric Power Ge nerating Point Source Category: Final Detailed Study Report . EPA 821

- R

- 0 9

- 0 08 . Washington, DC. ( Octob er).

Available online at: http://www.epa.gov/guide/steam/finalreport.pdf. DCN

S E00003

.