Final 

Sampling Episode Report 

Ohio Power Company’s 

Mitchell Plant 

Moundsville, WV 

Sampling Episode 6550 

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 

26 August 2008 

EPA Contract No. 68-C02-095 

Work Assignment 5-22
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CONTENTS 

Page 

1. INTRODUCTION .................................................................................................................1-1 

1.1 Background of Detailed Study.............................................................................1-1 

1.2 Power Plant Site Selection...................................................................................1-1 

1.3 Sampling Episode Overview................................................................................1-2 

2. FACILITY OVERVIEW ........................................................................................................2-1 

2.1 FGD Scrubber System .........................................................................................2-2 

2.2 FGD Wastewater Treatment System ...................................................................2-3 

2.3 Particulate Control Systems.................................................................................2-5 

2.4 Fly Ash Pond System...........................................................................................2-5 

3. SAMPLE COLLECTION .......................................................................................................3-1 

3.1 Sampling Points, Sample Collection Methods, and Field Measurements ...........3-1 

3.1.1 Influent to FGD Wastewater Treatment System......................................3-2 

3.1.2 FGD Primary Clarifier Effluent...............................................................3-4 

3.1.3 Effluent from FGD Wastewater Treatment System.................................3-5 

3.1.4 Effluent from Fly Ash Pond.....................................................................3-7 

3.2 List of Analytes and Sample Preservation...........................................................3-9 

3.3 Plant Operational Data.......................................................................................3-10 

3.4 Deviations from the Sampling and Analysis Plan .............................................3-10 

4. LABORATORY ANALYTICAL RESULTS AND DISCUSSION...................................................4-1 

4.1 Measured and Calculated Results for FGD Influent Samples .............................4-1 

4.2 FGD Wastewater Treatment System ...................................................................4-2 

4.3 Fly Ash Pond........................................................................................................4-3 

5. DATA QUALITY.................................................................................................................5-1 

5.1 Analytical Quality Control...................................................................................5-1 

5.2 Field Quality Control ...........................................................................................5-1 

5.2.1 Bottle Blanks............................................................................................5-1 

5.2.2 Equipment Blanks....................................................................................5-2 

5.2.3 Field Blanks .............................................................................................5-3 

5.2.4 Field Duplicates .......................................................................................5-4 

6. REFERENCES .....................................................................................................................6-1 

Appendix A: ANALYTICAL RESULTS

Appendix B: ANALYTICAL DATA FOR METALS, FGD WASTEWATER AND ASH POND

Appendix C: DATA REVIEW NARRATIVES

Appendix D: PICTURES FROM THE SAMPLING EPISODE
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LIST OF TABLES 

Page 

3-1 Sample Collection Information, Mitchell ...................................................................... 3-12 

3-2 Number of Samples Collected by Sampling Point, Mitchell......................................... 3-13 

3-3 Field Measurements, Mitchell ....................................................................................... 3-14 

3-4 Analytical Methods and Procedures for Samples Collected at Mitchell ....................... 3-15 

3-5 Summary of Sample Container and Planned Preservation ............................................ 3-16 

3-6 Sample Preservation Summary, Mitchell ...................................................................... 3-17 

3-7 Generating Unit Operating Characteristics during Sample Collection, Mitchell .......... 3-19 

3-8 FGD Scrubber System Operating Characteristics, Mitchell.......................................... 3-20 

3-9 FGD Wastewater Treatment System Operating Characteristics, Mitchell .................... 3-21 

3-10 Ash System Operating Characteristics During Sample Collection, Mitchell................ 3-22 

3-11 Fly Ash Pond System Operating Characteristics, Mitchell ........................................... 3-23 

4-1 Biphasic Sample Results for Low-Level Total Metals Measured Above the Report 

Limit, FGD Influent, Mitchell ......................................................................................... 4-4 

4-2 Classical Pollutants Measured Above the Report Limit for the FGD Wastewater 

Treatment System, Mitchell............................................................................................. 4-5 

4-3 Metals Measured Above the Report Limit for the FGD Wastewater Treatment 

System, Mitchell .............................................................................................................. 4-6 

4-4 Classical Pollutants Measured Above the Report Limit for the Fly Ash Pond 

Effluent, Mitchell............................................................................................................. 4-9 

4-5 Metals Measured Above the Report Limit for the Fly Ash Pond Effluent, Mitchell .... 4-10 

5-1 Field Blank Results Measured Above the Report Limit, Mitchell .................................. 5-5 

5-2 Field Duplicate Results, Mitchell .................................................................................... 5-6 

A-1 FGD Influent Analytical Data, Mitchell ......................................................................... A-1 

A-2 FGD Primary Clarifier Effluent Analytical Data, Mitchell ............................................ A-6 

A-3 FGD Effluent Analytical Data, Mitchell....................................................................... A-11 

A-4 Duplicate of FGD Effluent Analytical Data, Mitchell.................................................. A-16 
LIST OF TABLES (Continued) 

Page 

iii

A-5 Fly Ash Pond Effluent Analytical Data, Mitchell......................................................... A-20 

A-6 Bottle Blank and Equipment Blank Analytical Data, Mitchell..................................... A-24 

A-7 FGD Influent Field Blank Analytical Data, Mitchell ................................................... A-30 

A-8 FGD Primary Clarifier Effluent Field Blank Analytical Data, Mitchell ...................... A-31 

A-9 FGD Effluent Field Blank Analytical Data, Mitchell................................................... A-32 

A-10 Fly Ash Pond Effluent Field Blank Analytical Data, Mitchell..................................... A-36 

B-1 Analytical Results for Metals in the FGD Wastewater Treatment System, Mitchell......B-1 

B-2 Analytical Results for Metals in the Fly Ash Pond Effluent, Mitchell............................B-3 
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LIST OF FIGURES 

Page 

2-1 FGD Wastewater Treatment System, Mitchell Power Plant ........................................... 2-7 

D-1 Sampler Working Inside a “Cleanbox”........................................................................... D-1 

D-2 Sample Collection Set-Up at the Influent to FGD Wastewater Treatment System........ D-2 

D-3 Sample Tap and Tubing at the FGD Clarifier Effluent................................................... D-3 

D-4 Sample Collection Set-Up at the FGD Clarifier Effluent ............................................... D-4 

D-5 Sample Collection Set-Up at the Effluent from FGD Wastewater Treatment System... D-5 

D-6 Sample Collection Set-Up at the Effluent from the Fly Ash Pond................................. D-6 
1-1

1. INTRODUCTION

 The Engineering and Analysis Division (EAD) of the U.S. Environmental Protection 

Agency (EPA) has been conducting a program that consists of site visits and sampling at steam 

electric power plants to characterize raw wastewaters generated by coal-fired steam electric 

power plants, as well as to evaluate treatment technologies and best management practices used 

to reduce pollutant discharges. This Sampling Episode Report (SER) describes the sampling 

activities that took place on October 15, 17, and 18, 2007, at Ohio Power Company’s Mitchell 

Plant (Mitchell), located in Moundsville, West Virginia (Sampling Episode 6550). The focus of 

Episode 6550 was to characterize the influent to and effluent from the flue gas desulfurization 

(FGD) wastewater treatment system, the primary clarifier overflow within the FGD wastewater 

treatment system, and the effluent from the fly ash pond at Mitchell. 

1.1 Background of Detailed Study

 Section 304(m) of the Clean Water Act (CWA) requires EPA to develop and publish a 

biennial plan that establishes a schedule for the annual review and revision of national effluent 

limitations guidelines and standards (ELGs) required by CWA section 304(b). During EPA’s 

2005/2006 review of ELGs, EPA determined that the steam electric power generating point 

source category (40 CFR Part 423) was the second-largest discharger of toxic-weighted 

pollutants. EPA’s analyses indicated that the toxic-weighted loadings were predominantly driven 

by metals present in wastewater discharges, and that the waste streams contributing the majority 

of the metals are associated with air pollution controls. Other potential sources of metals include 

coal pile runoff, metal/chemical cleaning wastes, coal washing, and certain low-volume wastes. 

 In the 2005/2006 study, EPA noted certain data limitations that affected the Agency’s 

estimate of the potential hazards posed by discharges from this category. Therefore, EPA 

determined that further review of these discharges during the 2007/2008 ELG planning cycle 

was warranted. EPA has concentrated its efforts for the 2007/2008 study on better characterizing 

the sources generating the pollutants responsible for the majority of the toxic-weighted pollutant 

loadings and available pollution control technologies/practices for steam electric plants. 

1.2 Power Plant Site Selection

 EPA selected six coal-fired steam electric plants for wastewater sampling. EPA based the 

plant selection on the process configurations and characteristics of the plants, as well as the site 

visits conducted for the study. The following characteristics (not listed in any priority order) 

were used to select plants for sampling: 

• Coal-fired boilers; 

• Wet FGD scrubber system, including: 

— Type of scrubber, 

— Sorbent used, 

— Year operation began, 

— Chemical additives used, 

— Forced oxidation process, 

— Water cycling, and 

— Solids removal process; 
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• FGD wastewater treatment system; 

• Type of coal; 

• NOx controls; 

• Ash handling systems; 

• Ash treatment system; and 

• Mercury air controls. 

 EPA selected Mitchell for sampling based on the following site characteristics: 

• The plant is a coal-fired power plant that burns eastern bituminous coal in each of 

its two generating units; 

• The plant operates limestone forced oxidation wet FGD systems on both units; 

• The plant operates a segregated FGD wastewater treatment system, which 

includes the following steps: 

— Desaturation (lime addition); 

— Clarification; 

— Equalization; 

— Ferric chloride addition; 

— Polymer addition; and 

— Clarification. 

• The plant operates selective catalytic reduction (SCR) systems on both units 

(although the SCRs were not in service during the sampling episode); and 

• The plant produces a commercial-grade gypsum by-product. 

1.3 Sampling Episode Overview

 On May 15, 2007, EPA and its technical contractor, Eastern Research Group, Inc. (ERG), 

conducted a site visit at Mitchell. The purpose of the site visit was to learn about the wastewater 

treatment operations regarding the FGD scrubber purge and the fly ash pond and to gather 

information in order to collect wastewater samples at Mitchell. The information collected during 

the site visit was used to create Sampling Plan, Ohio Power Company’s Mitchell Plant 

(Sampling Plan) [1], which describes the sample collection procedures used during the sampling 

episode. 

 For this sampling episode, EPA arrived at Mitchell on Monday, October 15, 2007, to 

review the sampling points, determine the set-up for the sample collection, label sample bottles, 

and purchase any additional supplies needed for the sampling episode. EPA then collected the 

samples specified in the Sampling Plan on Wednesday and Thursday, October 17 and 18, 2007. 

The following personnel participated in EPA’s sample collection activities: 

• Ron Jordan, EPA/EAD; 

• Josh Hall, EPA/EAD; 

• TJ Finseth, ERG; 

• Sarah Holman, ERG; and 

• Jessica Wolford, ERG. 

In addition, during the sample collection, EPA collected split samples with the Utility Water Act 

Group (UWAG), acting on behalf of the plant. 
2-1

2. FACILITY OVERVIEW

 Mitchell operates two coal-fired steam electric generating units and burns approximately 

four million tons of eastern bituminous coal per year. Units 1 and 2, which both came on line in 

1971, each have a capacity of 800 megawatts (MW) and have been burning low-sulfur coal. The 

Mitchell plant is located on approximately 220 acres in Moundsville, WV, along the Ohio River. 

The American Electric Power Company (parent company to Ohio Power Company) also owns 

an additional 1,625 acres of land adjacent to the Mitchell plant. 

 Units 1 and 2 each have the following configuration: 

• Boiler; 

• Air preheater; 

• SCR system; 

• Trona injection; 

• Electrostatic precipitator (ESP); and 

• FGD scrubber system. 

 Mitchell recently retrofitted each unit with a wet FGD scrubber system to control the 

sulfur dioxide (SO2) releases from the plant. The Unit 1 and Unit 2 FGD systems were installed 

in April 2007 and January 2007, respectively. Adding the FGD scrubbers allows the plant to 

transition to a higher sulfur coal. At the time the sampling occurred, the plant had not fully 

transitioned to the higher sulfur coal, but was burning a blend of high sulfur and low sulfur coals 

to achieve a sulfur content of 2.5 lbs/MBTU and had been burning a blend of coal at this sulfur 

content for an extended period of time. The wet FGD scrubbers are designed to remove 98 

percent of the SO2 from the flue gas. Mitchell representatives estimate the average amount of 

SO2 their scrubbers remove is slightly lower than 98 percent due to the lower efficiency during 

startup and shutdown of the scrubbers. With the recent addition of the FGD scrubber systems, 

Mitchell also installed an FGD wastewater treatment system to control the discharges of the 

wastewater generated during the operation of the FGD scrubbers. Section 2.1 discusses the FGD 

system and Section 2.2 discusses the FGD wastewater treatment system. 

 In May 2007, Mitchell retrofitted both Units 1 and 2 with SCR systems to further control 

nitrogen oxide (NOx) releases from the plant. The plant had previously installed low NOx burners 

in the boilers in each unit to reduce the NOx emissions. The low NOx burners were installed on 

Unit 1 and Unit 2 in Spring 2006 and Fall 2005, respectively. Currently, Mitchell is operating the 

SCRs only seasonally, from May 1 through September 30; therefore, the SCRs were not 

operating during the sampling episode. However, in the future, Mitchell will begin operating the 

SCR systems year-round. The flue gas still passes over the SCR catalyst even when the SCRs are 

not operating. 

 As the flue gas passes over the catalyst in the SCR process, some of the sulfur dioxide is 

oxidized to sulfur trioxide. Emissions of this sulfur trioxide contribute to the formation of acid 

rain in the environment, as well as a blue plume. To remove the sulfur trioxide, Mitchell injects 

trona, a sodium-based carbonate (i.e., sodium carbonate and/or sodium bicarbonate) into the flue 

gas. Mitchell blows the trona into the flue gas as a dry powder downstream of the SCR but 

upstream of the electrostatic precipitators (ESPs). Mitchell does not operate the trona injection 
2-2

system when the SCRs are not operating (i.e., during nonozone season); therefore, the trona 

injection system was not operating during the sampling episode. 

 The ESPs at Mitchell are particulate control devices that remove 99.7 percent of the fly 

ash and other particulates from the flue gas. The fly ash and other particulates are collected in 

hoppers and sluiced to the fly ash pond. Section 2.3 discusses the ESPs and ash sluicing in more 

detail and Section 2.4 discusses the fly ash pond system. 

2.1 FGD Scrubber System

 Mitchell operates a wet FGD scrubber system on both Units 1 and 2, downstream of the 

ESP, to control the emission of sulfur dioxide from the unit. The plant uses a limestone slurry as 

the sorbent for sulfur dioxide absorption. Mitchell receives the limestone via barge and has onsite ball mills to pulverize the limestone. After the limestone is pulverized, Mitchell dilutes it 

with water to approximately 25 to 30 percent solids (by weight) and holds it in the reagent slurry 

storage tank until it is pumped to the scrubbers. 

 The fresh limestone slurry is fed to the bottom of the scrubbers in the reaction tank. 

Mitchell pulls a mixture of the fresh slurry and some of the reacted product from the reaction 

tank and pumps it up to the various spray levels in the scrubber. This slurry is pressurized and 

sprayed downward into the scrubber vessel through spray nozzles. As the slurry falls downward 

and the flue gas flows countercurrent to the slurry, the sulfur dioxide contacts and reacts with the 

limestone particles and produces calcium sulfite, which continues to flow downward in the 

scrubber until it reaches the reaction tank. Mitchell bubbles air through the reaction tank to 

oxidize the calcium sulfite to calcium sulfate (i.e., gypsum). 

 Mitchell intermittently blows down the gypsum slurry from the reaction tank to control 

the solids concentration in the scrubber to between 18 and 22 percent solids. Mitchell pumps the 

blowdown from the scrubber to two hydroclone feed tanks, each with a capacity of 0.75 million 

gallons. The gypsum slurry is stored in the two hydroclone feed tanks for a short period of time 

during the blowdown of the scrubber (no more than a few hours) to allow for a continuous feed 

to the hydroclones, which improves their performance. 

 Once there is enough volume in the hydroclone feed tanks, Mitchell begins dewatering 

the gypsum slurry by pumping the slurry to the hydroclones at a flow rate of 1,000 gallons per 

minute (gpm). Mitchell typically dewaters gypsum slurry for approximately 10 to 12 hours per 

day. The hydroclones separate solid gypsum from the water by centrifugal force. The solid 

gypsum is forced outward to the walls of the hydroclones and falls downward, while the water 

exits the top of the hydroclones. The gypsum from the hydroclones is transferred to the vacuum 

filter belts. The supernatant water from the hydroclone is transferred to the dewatering 

hydroclone overflow head tank and is expected to contain approximately 5.7 percent solids. 

 Mitchell rinses the gypsum with river water as it is poured onto the vacuum filter belts. 

The vacuum filter belts dry the gypsum to a 96 to 97 percent solids product. After temporary 

storage on site, the gypsum is hauled to a nearby wallboard manufacturer for beneficial reuse. 

Mitchell operates two hydroclones in parallel and two vacuum filter belts in parallel, and each 

unit has a designated hydroclone and filter belt. Each of the vacuum filter belts can produce 50 

tons of gypsum per hour when the dewatering process is operating. 
2-3

 Mitchell analyzes the chlorides in the wastewater that is sent to the dewatering 

hydroclone overflow head tank to determine whether the water should be directed to the reclaim 

tanks and recycled back to the reaction tank in the scrubbers or transferred to the FGD 

wastewater treatment system. If the chlorides are less than 8,000 parts per million (ppm), then 

the water is directed back to the scrubbers; however, if the chlorides are greater than 8,000 ppm, 

then a portion of the water is sent to the first stage of the FGD wastewater treatment system. The 

chlorides concentration in the scrubber typically ranges from 5,500 to 8,500 ppm, with a 

maximum allowable concentration of 12,000 ppm. According to plant representatives, the 

wastewater is usually sent to the reclaim tank and recycled back to the scrubbers. However, over 

the course of a day, the plant typically purges the hydroclone overflow tank to the FGD 

wastewater treatment system for approximately six to eight hours during the day shift at a rate of 

400 gpm; however, the flow rate and duration of the scrubber purge varies daily. Mitchell also 

has the capability of transferring water from the reclaim tanks to the FGD wastewater treatment 

system, if needed. 

2.2 FGD Wastewater Treatment System

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

FGD wastewater from the dewatering hydroclone overflow head tank at a maximum flow rate of 

550 gpm. The intermittent transfers typically occur for six to eight hours over the course of a 

day; however, during the sampling episode, the plant was purging the hydroclone overflow 

continuously to the FGD wastewater treatment system at a flow rate of approximately 500 gpm. 

 The plant operates the FGD wastewater treatment system 24 hours per day. Mitchell 

installed the wastewater treatment system to treat the wastewater discharge that is necessary to 

control the concentration of chlorides in the scrubber system. The FGD wastewater treatment 

system contains the following treatment operations: 

• Desaturation (lime addition); 

• Primary clarification; 

• Equalization; 

• Ferric chloride addition; 

• Polymer addition; and 

• Secondary clarification. 

 Figure 2-1 presents a process flow diagram of the FGD wastewater treatment system, as 

well as the sampling locations for EPA’s sampling episode. The wastewater treatment system 

was built with some redundancy so that it would still operate if one piece of equipment went out 

of service; therefore, the FGD wastewater treatment system has two of the following pieces of 

equipment operating in parallel: 

• Desaturation tank; 

• Primary clarifier; 

• Equalization tank; and 

• Secondary clarifier. 
2-4

During normal operation, Mitchell operates all of the tanks and clarifiers even though only one 

of each pair of tanks and clarifiers is needed. When one of the pair is taken out of service, the 

other redundant unit can still handle the maximum flow through the system. 

 The wastewater from the dewatering hydroclone overflow head tank is transferred to the 

two desaturation tanks if the chloride levels in the wastewater are greater than 8,000 ppm. This 

wastewater is expected to be 5.7 percent solids and the pH is approximately 6.5 to 7.0. Mitchell 

adds hydrated lime to the wastewater to increase the pH to between 8.2 and 8.7, which 

precipitates calcium sulfate. 

 From the desaturation tanks, the wastewater flows to the primary clarifiers, which remove 

most of the solids in the wastewater. According to the plant’s design specifications, the primary 

clarifiers are designed to reduce the solids concentration in the wastewater from 5.6 to 0.1 

percent solids. During the sampling episode, one of the primary clarifiers was out of service for 

maintenance; therefore, only one of the primary clarifiers was operating. The underflow from the 

primary clarifier is either transferred to the sludge feed tanks or recycled back to the primary 

clarifier influent to improve solids formation by providing seed crystals for nucleation, which 

improves settling of the suspended solids. 

 The two overflow streams from the primary clarifiers are first commingled, and then they 

are split again prior to entering the two equalization tanks. The equalization tanks also receive 

filter press filtrate and recycled water from the effluent storage tank when the treatment system is 

not discharging. The equalization tanks equalize the flow prior to ferric chloride addition and 

secondary clarification. The flow from the tanks is controlled based on the level in the tank. 

Some of the water from the equalization tanks is also used to flush the sludge lines from the 

primary and secondary clarifiers when the sludge pumps are shut down for an extended period of 

time. 

 Mitchell adds ferric chloride to the wastewater in the ferric chloride mix tank to coagulate 

the fine particles in the solution and make them easier to remove in the secondary clarifier. The 

wastewater from the ferric chloride mix tank is split and transferred to the two secondary 

clarifiers. As the wastewater is pumped to the secondary clarifiers, Mitchell adds an anionic 

polymer. The polymer helps the solids in the wastewater settle more easily in the secondary 

clarifier. The underflow from the secondary clarifiers is completely recycled within the treatment 

system, with most of it being recycled to the primary clarifier. In addition, some of the sludge is 

recycled to the ferric chloride mix tank to provide seed crystals to improve the 

coagulation/agglomeration. The secondary clarifiers are designed to reduce the solids 

concentration from 0.3 to 0.003 percent solids in the wastewater. 

 The overflow from the secondary clarifiers is commingled and transferred to the effluent 

storage tank. When the effluent storage tank is full, the plant discharges the wastewater to the 

bottom ash pond. In the bottom ash pond, the FGD wastewater is commingled with bottom ash 

sluice water, cooling tower blowdown, storm water runoff, and low-volume wastewater. 

However, when the effluent tank is not full, which typically occurs when the plant is not purging 

the hydroclone overflow to the FGD wastewater treatment system, the plant recycles the treated 

effluent in the storage tank back to the equalization tanks to enable continuous flow through the 

treatment system components. The typical retention time for the entire treatment system is 34.5 

hours. See Table 3-9 for the retention time for individual treatment system components. 
2-5

 EPA collected a sample of the influent to Mitchell’s FGD wastewater treatment system 

downstream of the dewatering hydroclone overflow head tank and upstream of the desaturation 

tanks (i.e., the sample was collected prior to any chemical addition). EPA collected an interim 

sample within the FGD wastewater treatment system downstream of the primary clarifiers and 

upstream of the equalization tanks. In addition, EPA collected a sample of the effluent from the 

FGD wastewater treatment system directly downstream of the effluent storage tank. 

2.3 Particulate Control Systems

 As the coal is combusted in the boilers, solid, noncombustible constituents of the coal, 

referred to as ash, are generated. The heavier ash particles collect on the bottom of the boiler and 

are referred to as bottom ash. The finer ash particles are light enough to be transferred out of the 

boiler with the flue gas exhaust and are referred to as fly ash. The bottom ash is removed from 

the bottom of the boiler using a stream of sluice water that transports the particles to the bottom 

ash pond. The fly ash flows with the flue gas through the SCRs and is removed from the flue gas 

in the ESP. 

 The ESP systems use high voltage to generate an electric charge on the particles 

contained in the flue gas. The charged particles then collect on a metal plate with an opposite 

electric charge. As the particles begin to layer on the metal plates, the plates are tapped/rapped to 

loosen the particles, which fall into collection hoppers. Each unit has multiple hoppers that 

collect ash from different places in the ESP. The hoppers located closer to the inlet of the ESP 

collect the larger fly ash particles that are removed more easily and the hoppers located closer to 

the outlet of the ESP collect the finer fly ash particles that are more difficult to remove. In 

addition, the hoppers at the inlet typically collect more fly ash than the hoppers at the outlet of 

the ESP. 

 Mitchell continually sluices the fly ash from the collection hoppers with cooling tower 

blowdown water or river water. The plant cycles through the collection hoppers based on which 

hopper needs to be sluiced. Because they collect more fly ash than the outlet hoppers, the inlet 

hoppers are sluiced more frequently. Mitchell simultaneously sluices the fly ash from both Units 

1 and 2, taking approximately 1.5 hours to cycle through all of the hoppers for each unit. The 

bottom ash for each unit is sluiced two times a day. 

2.4 Fly Ash Pond System

 The fly ash pond system at Mitchell receives the fly ash sluice water from Mitchell as 

well as the fly ash sluice water from Kammer, another Ohio Power Company power plant 

located one mile north of Mitchell. In addition, the fly ash pond receives wastewater from a 

nearby coal washing preparation plant and treated acid mine drainage (AMD). The flow rates of 

the influent streams to the Mitchell fly ash pond are listed below: 

• Mitchell fly ash sluice stream - 6.05 million gallons per day (MGD); 

• Kammer fly ash sluice stream - 1.4 MGD; 

• Coal washing preparation plant - 2.3 MGD; 

• AMD treatment plant – 0.4 MGD; 

• Stormwater runoff – 32.4 MGD (maximum); and 

• Rainfall – 7 MGD (maximum). 
2-6

 At the time of sampling, the fly ash pond had an open water area of approximately 63.5 

acres and a volume of approximately 1,863,000 cubic yards. Based on 2007 data, the nominal 

retention time of the pond is approximately 38 days. Mitchell began using the pond in 1969. The 

pond is not lined and Mitchell does not dredge the fly ash from the pond; therefore, the pond is 

expected to be completely filled in approximately 10 to 25 years, depending on the operation of 

the coal washing prep plant and the AMD treatment plant. 

 The four waste streams that enter the fly ash pond all enter at different locations in the 

pond. The two fly ash sluice streams enter the pond the farthest downstream, and therefore have 

the shortest residence time in the pond. As the wastewater flows through the pond system, the 

solids and particulates settle out. In addition, the plant controls the cenospheres (floating solids); 

using booms, the plant collects the cenospheres from the surface of the pond and sells them for 

beneficial reuse. As the wastewater reaches the end of the pond, there is a dam that controls the 

flow from the pond out to the channel where the wastewater is discharged to Fish Creek. The ash 

pond has a retention time of 38 days. 

 EPA collected a sample of the effluent from Mitchell’s fly ash pond from the channel that 

discharges to Fish Creek. EPA did not collect a sample of the influent to the fly ash pond. 
2-7 

Figure 2-1. FGD Wastewater Treatment System, Mitchell Power Plant 
3-1

3. SAMPLE COLLECTION

 During the Mitchell sampling episode, the sampling team followed the sample collection 

protocols specified in the Sampling Plan. Section 3.1 describes the sampling points, sample 

collection methods, and field measurements. Section 3.2 describes the list of analytes and the 

sample preservation procedures. Section 3.3 discusses the plant operational data collected during 

the sampling episode. Finally, Section 3.4 discusses any deviations from the planned sampling 

activities described in the Sampling Plan. 

 During the sampling episode, Unit 1 was tripped and shut down at approximately 1245 

on Wednesday, October 17, 2007. Due to the shutdown of Unit 1, the sampling team collected 

the effluent from the FGD wastewater treatment system samples as quickly as possible after the 

shut down. According to plant personnel, Unit 1 began operating again at approximately 1800 on 

the same day (October 17) and was operating at full load by 0430 on October 18. In addition, the 

plant’s FGD scrubber purge was tripped at approximately 0655 on October 17. See Section 3.1.1 

for more details regarding the FGD scrubber purge trip and its affect on the FGD wastewater 

treatment system. 

3.1 Sampling Points, Sample Collection Methods, and Field Measurements

 This section describes the sampling points, sample collection methods followed, and the 

field measurements obtained for this sampling episode. Additional details are available in 

Section 3 of the Sampling Plan. Figure 2-1 presents a flow diagram of the plant’s wastewater 

treatment system, including sampling point locations. 

 Table 3-1 lists the sampling points, sampling point descriptions, type of sample 

collection, sample collection dates and times, and the EPA Sample Control Center (SCC) sample 

numbers. Table 3-2 lists the sampling point numbers and descriptions, the number of samples 

collected, and the pollutant parameters analyzed for this sampling episode. Table 3-3 presents the 

field measurement data collected from sampling point. 

 The sampling points for this episode were: 

• SP-1: Influent to FGD Wastewater Treatment System; 

• SP-2: FGD Primary Clarifier Effluent; 

• SP-3: Effluent from FGD Wastewater Treatment System; 

• SP-4: Effluent from Fly Ash Pond; 

• SP-5: Duplicate of Effluent from FGD Wastewater Treatment System (SP-3); 

• SP-6: Influent to FGD Wastewater Treatment System (SP-1) Field Blank; 

• SP-7: FGD Primary Clarifier Effluent (SP-2) Field Blank; 

• SP-8: Effluent from FGD Wastewater Treatment System (SP-3) Field Blank; and 

• SP-9: Effluent from Fly Ash Pond (SP-4) Field Blank. 

 For all the sampling points, EPA collected split samples with Mitchell’s representative. 

EPA inserted a “Y” splitter into the sample tubing configuration at each sampling point to allow 

for split sample collection. For this sampling episode, EPA collected all analytes (other than 

HEM/SGT-HEM at all sampling points and BOD at the effluent from the FGD wastewater 

treatment system) as “true” splits (i.e., samples for the same analyte were collected 
3-2

simultaneously). The HEM/SGT-HEM samples were either collected using a bottle dipper or 

directly from a sample tap and the BOD samples at the effluent from the FGD wastewater 

treatment system were collected directly from the sample tap; therefore, for these samples, EPA 

and Mitchell’s representative collected duplicate samples, with one filling the bottle immediately 

after the other. 

 At each of the nine sampling points, EPA collected low-level metals sample fractions 

following EPA Method 1669 collection protocols. To collect these samples, EPA samplers 

donned Tyvek® suits and dust masks (dust masks were worn until all low-level mercury samples 

had been collected). In addition, EPA set up a “cleanbox,” which consists of a portable plastic 

rectangular box with a shallow lip and a flip-top lid that secures itself open with clips. The 

“cleanbox” is double-bagged with a clear inner bag, enclosed in a translucent outer bag. The 

“cleanbox” is handled using “clean hands / dirty hands” techniques, whereby the inner bag is 

handled only by the “clean hands” sampler. When the “cleanbox” is opened, the sampler is able 

to position his/her hands in the box and pull the bag over the opening of the box, but is still able 

to see the sample bottles and tubing. The “cleanbox” minimizes potential atmospheric 

contamination during sample collection. Figure D-1, in Appendix D, is a picture of a sampler 

working inside a “cleanbox.” To collect samples, EPA placed the sample bottles and the inner 

bag into the “cleanbox” following the protocols specified in Method 1669, also referred to as 

“clean hands / dirty hands” protocols. Sampling staff filled the sample container and closed the 

sample bottle lid and inner bag as quickly as possible within the “cleanbox.” The sample bottles 

were then placed into the outer bag following the “clean hands / dirty hands” protocols. 

3.1.1 Influent to FGD Wastewater Treatment System 

 The influent to FGD wastewater treatment system (SP-1) was collected from a sample tap 

located on the wastewater piping downstream of the dewatering hydroclone overflow head tank 

and upstream of the desaturation tanks. Figure 2-1 identifies the sampling location for SP-1. 

Mitchell does not have an equalization tank prior to the first chemical addition in the wastewater 

treatment system; therefore, the samples collected at the sampling point were not equalized prior 

to collection. This sample was collected as a grab sample because, according to plant 

representatives, the wastewater characteristics of the purge to the wastewater treatment system 

are fairly consistent during the purge. 

 The sampling point was located outside, near the desaturation tanks. The sampling team 

did not set up a tent or tarps to cover the samplers/samples from rain and/or wind. There was no 

rain during the sample collection; however, the samplers did note that the wind was blowing at 

an estimated 5 to 10 mph during some of the sample collection time period. In addition, during 

the sample collection, several cars drove past the sampling point, approximately 50 feet from the 

sample collection area. 

 Prior to collecting the samples at the influent to the FGD wastewater treatment system 

(SP-1), the sampling team collected field blanks (SP-6) for low-level total mercury and low-level 

total metals. See Section 5.2.3 for a description of the field blank sample collection procedures at 

the influent to the FGD wastewater treatment system. 

 After collecting the field blank samples, Mitchell notified the samplers that the FGD 

scrubber purge was tripped at approximately 0655 on Wednesday, October 17, 2007, and the 
3-3

plant was currently transferring service water to the desaturation tanks to remove the solid 

residuals from the wastewater piping leading to the desaturation tanks. According to plant 

personnel, the system began operating again at approximately 0720; therefore, the plant 

transferred service water to the desaturation tanks for approximately 25 minutes at a flow rate of 

400 gpm. After waiting approximately 25 minutes, the samplers checked the piping and observed 

that scrubber purge water was flowing through the piping. The samplers then waited an 

additional 15 minutes before flushing the sample tap with 10 gallons of scrubber purge. 

 EPA collected the wastewater samples at the influent to the FGD wastewater treatment 

system by attaching a 10-foot length of silicone tubing to the sample tap on the wastewater 

piping. The end of the silicone tubing had a “Y” splitter attached, with two additional lengths of 

silicone tubing attached to the “Y” splitter. After the samplers attached the silicone tubing to the 

sample tap, they opened the valve of the sample tap and purged the tubing for 90 seconds. Flow 

from the tap did not stop until all samples were collected (except HEM/SGT-HEM and the 

dissolved metals samples). 

 After the tubing was purged, the samplers filled a 10-liter container with sample, which 

was used later to pump off the low-level and routine dissolved metals sample fractions. Once the 

10-liter container was filled, one member of the sampling team transported the 10-liter container 

to the staging area to allow the solids in the wastewater to settle while the remainder of the 

sampling team stayed at the sampling point and continued sample collection. Figure D-2, in 

Appendix D, is a picture of the sampling set-up at the influent to the FGD wastewater treatment 

system. 

 EPA then collected the low-level total metals, low-level total and dissolved mercury, 

routine total metals, and the arsenic/selenium speciation samples in a “cleanbox,” as described in 

Section 3.1. The samplers then collected the BOD, Group I, and Group II samples by pouring the 

sample directly from the tubing into the sample bottles without using a “cleanbox.” To collect 

the HEM/SGT-HEM samples, the samplers shut off the valve for the sample tap, removed the 

tubing from the fitting, reopened the valve, and filled the sample bottles directly from the tap to 

prevent any oil and grease adhering to the sides of the tubing. 

 During the sample collection, the sampling team collected an aliquot of sample for field 

testing. Sample pH and temperature were measured immediately at the sampling point using a 

pH meter and four-color pH paper. The four-color pH paper was used as an independent check of 

the pH meter to ensure that similar results were measured. After returning to the staging area, the 

sampling team took measurements of free and total residual chlorine using a colorimeter. Table 

3-3 presents the field measurement data for the influent to the FGD wastewater treatment system. 

 The sampling team then moved to the staging area, where a pump-off station was set up, 

to collect the low-level and routine dissolved metals samples. The pump-off station consisted of 

a length of Teflon® tubing attached to a length of silicone tubing, which was threaded through 

an ISCO peristaltic pump. The sampling team attached a capsule filter to the silicone tubing, 

which was a short distance downstream of the pump. The sampling team attached another short 

length of silicone tubing to the capsule filter effluent, which was attached to a “Y” splitter and 

two lengths of silicone tubing. This set-up allowed EPA to collect “true” split samples with 

Mitchell’s representatives. Prior to collecting any dissolved metals samples of the FGD 

wastewater influent, the samplers collected a field blank sample (SP-6) for low-level dissolved 
3-4

metals. See Section 5.2.3 for a description of the dissolved metals field blank sample collection 

at the influent to the FGD wastewater treatment system. 

 After collecting the field blank samples, the sampling team transferred the end of the 

Teflon® tubing into the 10-liter container filled with wastewater from the influent to the FGD 

wastewater treatment system. By this time, the solids in the wastewater had been settling for 

approximately 1.25 hours, and there was a layer of solids at the bottom of the container. 

 The samplers first purged the tubing and filter with sample for one minute 

(approximately 2 liters) and then collected the low-level dissolved metals and routine dissolved 

metals samples. The samplers then installed a new capsule filter and purged the tubing and filter 

for 45 seconds (approximately 1.5 liters of sample). The samplers then collected the routine 

hexavalent chromium sample. 

3.1.2 FGD Primary Clarifier Effluent 

 The FGD primary clarifier effluent (SP-2) was collected from a sample tap located on the 

wastewater piping downstream of the point at which the two primary clarifier effluent streams 

commingle and upstream of the split to the equalization tanks. Figure 2-1 identifies the sampling 

location for SP-2. At the time that sampling occurred, one of the primary clarifiers was out of 

service; therefore, only one primary clarifier was operating, which likely did not affect the 

wastewater treatment because each of the clarifiers was designed to handle the maximum FGD 

wastewater treatment system flow rate. This sample was collected as a grab sample because the 

flow from the primary clarifiers is continuous, and the desaturation tanks and primary clarifiers 

provide some equalization of the waste stream. Because the sampling point was located inside, 

there were no wind or rain concerns during the sample collection. 

 Prior to collecting the samples at the FGD primary clarifier effluent (SP-2), the sampling 

team collected field blanks (SP-7) for low-level total mercury and low-level total metals. See 

Section 5.2.3 for a description of the field blank sample collection procedures at the FGD 

primary clarifier effluent. 

 EPA collected the wastewater samples at the FGD primary clarifier effluent by attaching 

a 10-foot length of silicone tubing to the sample tap on the wastewater piping. The end of the 

silicone tubing had a “Y” splitter attached, with two additional lengths of silicone tubing 

attached to the “Y” splitter. Figure D-3, in Appendix D, is a picture of the tubing attached to the 

sample tap at the FGD clarifier effluent sampling point. After the samplers attached the silicone 

tubing to the sample tap, they opened the valve of the sample tap and purged the tubing for three 

minutes. Flow from the tap did not stop until all samples were collected (except HEM/SGTHEM and the dissolved metals samples). 

 The samplers then collected the low-level total metals, low-level total and dissolved 

mercury, routine total metals, and the arsenic/selenium speciation samples in a “cleanbox,” as 

described in Section 3.1. The samplers then filled a 10-liter container with sample, which was 

used later to pump off the low-level and routine dissolved metals sample fractions. Once the 10-

liter container was filled, one member of the sampling team transported the 10-liter container to 

the staging area to allow the solids in the wastewater to settle while the remainder of the 
3-5

sampling team stayed at the sampling point and continued sample collection. Figure D-4, in 

Appendix D, is a picture of the sampling set-up at the FGD clarifier effluent. 

 The samplers then collected the BOD, Group I, and Group II samples by pouring the 

sample directly from the tubing into the sample bottles without using a “cleanbox.” To collect 

the HEM/SGT-HEM samples, the samplers shut off the valve for the sample tap, removed the 

tubing from the fitting, reopened the valve, and filled the sample bottles directly from the tap to 

prevent any oil and grease adhering to the sides of the tubing. 

 During the sample collection, the sampling team collected an aliquot of sample for field 

testing. Sample pH and temperature were measured immediately at the sampling point using a 

pH meter and four-color pH paper. The four-color pH paper was used as an independent check of 

the pH meter to ensure that similar results were measured. After returning to the staging area, the 

sampling team took measurements of free and total residual chlorine using a colorimeter. Table 

3-3 presents the field measurement data for the FGD primary clarifier effluent. 

 The sampling team then moved to the staging area, where a pump-off station was set up, 

to collect the low-level and routine dissolved metals samples. The pump-off station consisted of 

a length of Teflon® tubing attached to a length of silicone tubing, which was threaded through 

an ISCO peristaltic pump. The sampling team attached a capsule filter to the silicone tubing, 

which was a short distance downstream of the pump. The sampling team attached another short 

length of silicone tubing to the capsule filter effluent, which was attached to a “Y” splitter and 

two lengths of silicone tubing. This set-up allowed EPA to collect “true” split samples with 

Mitchell’s representatives. Prior to collecting any dissolved metals samples of the FGD primary 

clarifier effluent, the samplers collected field blank samples (SP-7) for low-level dissolved 

metals and low-level hexavalent chromium. See Section 5.2.3 for a description of the dissolved 

metals field blank sample collection at the FGD primary clarifier effluent. 

 After the field blank samples were collected, the samplers transferred the end of the 

Teflon® tubing into the 10-liter container filled with wastewater from the FGD primary clarifier 

effluent. By this time, the solids in the wastewater had been settling for approximately 40 

minutes. 

 The samplers first purged the tubing and filter with sample for 45 seconds (approximately 

1.5 liters) and then collected the low-level dissolved metals, low-level hexavalent chromium, 

routine dissolved metals, and routine hexavalent chromium samples. 

3.1.3 Effluent from FGD Wastewater Treatment System 

 The effluent from the FGD wastewater treatment system (SP-3) was collected from a 

sample tap located on the wastewater piping downstream of the effluent storage tank and 

upstream of the valve that directs the effluent flow to the bottom ash pond or the equalization 

tanks. Figure 2-1 identifies the sampling location for SP-3. At the time the samples were 

collected, the plant was discharging the FGD wastewater treatment system effluent to the bottom 

ash pond. This sample was collected as a grab sample because all the wastewater entering the 

effluent storage tank has been treated in the FGD wastewater treatment system and is discharged 

from the tank; therefore, the wastewater characteristics should be fairly homogeneous. Because 
3-6

the sampling point was located inside, there were no wind or rain concerns during the sample 

collection. 

 Prior to collecting the samples at the effluent from the FGD wastewater treatment system 

(SP-3), the sampling team collected field blanks (SP-8) for low-level total mercury, low-level 

total metals, and routine total metals. See Section 5.2.3 for a description of the field blank sample 

collection procedures at the effluent from the FGD wastewater treatment system. 

 As discussed in Section 3.0, Unit 1 was shut down at approximately 1245 on October 17, 

2007. EPA planned to collect the effluent from the FGD wastewater treatment system on 

October 18. After discussing the situation with the plant staff, EPA determined there was 

uncertainty whether there would be a scrubber purge to the FGD wastewater treatment system on 

October 18. Also, it was uncertain what effect that recirculating the effluent to the equalization 

tanks and continually retreating the wastewater would have on the effluent quality. Therefore, 

EPA decided to collect the effluent samples on October 17. 

 The samplers first collected the BOD, BOD QC, and BOD duplicate samples directly 

from the sample tap to ensure that the samples were iced long enough to reach the correct 

temperature for shipment that day (to meet the method-required hold time). In addition, the 

samplers also collected the HEM/SGT-HEM and HEM/SGT-HEM QC samples directly from the 

sample tap prior to collecting the other samples. Because the BOD and HEM/SGT-HEM samples 

were collected directly from the sample tap, they were not collected as split samples with 

Mitchell’s representative; instead, they were collected as duplicate samples. 

 EPA collected the wastewater samples at the effluent from the FGD wastewater treatment 

system by attaching a 10-foot length of silicone tubing to the sample tap on the wastewater 

piping. The end of the silicone tubing had a “Y” splitter attached, with two additional lengths of 

silicone tubing attached to the “Y” splitter. After the samplers attached the silicone tubing to the 

sample tap, they opened the valve of the sample tap and purged the tubing for two minutes. Flow 

from the tap did not stop until all samples were collected (except the dissolved metals samples). 

 The samplers collected the low-level total metals, low-level total and dissolved mercury, 

routine total metals, the QC and duplicate samples for each analyte, and the arsenic/selenium 

speciation samples in a “cleanbox,” as described in Section 3.1. The samplers then filled two 10-

liter containers with sample, which were used later to pump off the low-level and routine 

dissolved metals sample fractions. Once the 10-liter containers were filled, one member of the 

sampling team transported the 10-liter containers to the staging area to allow the solids in the 

wastewater to settle while the remainder of the sampling team stayed at the sampling point and 

continued sample collection. Figure D-5, in Appendix D, is a picture of the sampling set-up at 

the effluent from the FGD wastewater treatment system. 

 The samplers then collected the Group I and Group II samples, as well as the QC and 

duplicate samples for each analyte, by pouring the sample directly from the tubing into the 

sample bottles without using a “cleanbox.” 

 During the sample collection, the sampling team collected an aliquot of sample for field 

testing. Sample pH and temperature were measured immediately at the sampling point using a 

pH meter and four-color pH paper. The four-color pH paper was used as an independent check of 
3-7

the pH meter to ensure that similar results were measured. After returning to the staging area, the 

sampling team took measurements of free and total residual chlorine using a colorimeter. Table 

3-3 presents the field measurement data for the effluent from the FGD wastewater treatment 

system. 

 The sampling team then moved to the staging area, where a pump-off station was set up, 

to collect the low-level and routine dissolved metals samples. The pump-off station consisted of 

a length of Teflon® tubing attached to a length of silicone tubing, which was threaded through 

an ISCO peristaltic pump. The sampling team attached a capsule filter to the silicone tubing, 

which was a short distance downstream of the pump. The sampling team attached another short 

length of silicone tubing to the capsule filter effluent, which was attached to a “Y” splitter and 

two lengths of silicone tubing. This set-up allowed EPA to collect “true” split samples with 

Mitchell’s representative. Prior to collecting any dissolved metals samples of the FGD 

wastewater effluent, the samplers collected field blank samples (SP-8) for low-level dissolved 

metals, low-level hexavalent chromium, routine dissolved metals, and routine hexavalent 

chromium. See Section 5.2.3 for a description of the dissolved metals field blank sample 

collection at the effluent from the FGD wastewater treatment system. 

 After collecting the field blank samples, the samplers transferred the end of the Teflon® 

tubing into one of the 10-liter containers filled with wastewater from the effluent from the FGD 

wastewater treatment system. By this time, the solids in the wastewater had been settling for 

approximately one hour. 

 The samplers first purged the tubing and filter with sample for 50 seconds (approximately 

1.5 liters) and then collected the low-level dissolved metals and low-level hexavalent chromium 

samples, as well as the QC and duplicate samples for each analyte. The samplers then transferred 

the end of the Teflon® tubing into the other 10-liter container, installed a new capsule filter, and 

purged the tubing and filter for 30 seconds (approximately 1 L of sample). The samplers then 

collected the routine dissolved metals and the routine hexavalent chromium samples, as well as 

the QC and duplicate samples for each analyte. 

3.1.4 Effluent from Fly Ash Pond 

 The effluent from the fly ash pond (SP-4) was collected from the channel that discharges 

to Fish Creek. This sample was collected as a grab sample, because the wastewater is equalized 

through the long retention time within the fly ash pond; therefore, the wastewater characteristics 

should be fairly homogeneous. 

 The samples were collected outside from a bridge built over the channel. The sampling 

team was located along the side of the channel. Because the sample location was outside, the 

samplers set up a tent to cover the samplers/samples from rain; however, there was no rain 

during the sample collection. 

 Prior to collecting samples at the effluent from the fly ash pond (SP-4), the sampling 

team collected field blanks (SP-9) for low-level total mercury, low-level total metals, routine 

total metals, low-level dissolved metals, low-level hexavalent chromium, routine dissolved 

metals, and routine hexavalent chromium. See Section 5.2.3 for a description of the field blank 

sample collection at the effluent from the fly ash pond. 
3-8

 EPA collected the wastewater samples for the effluent from the fly ash pond by pumping 

samples from the channel into the sample containers. The sampling team attached one end of a 

25-foot length of Teflon® tubing to a piece of PVC pipe, and inserted the PVC pipe and tubing 

into the channel. The sampling team attached the PVC pipe to a rail on the bridge to secure the 

pipe and tubing in place for the duration of the sample collection. The sampling team positioned 

the tubing to reach the sampling team at the sampling point set-up area and attached it to a piece 

of silicone tubing, which was threaded through an ISCO peristaltic pump. The sampling team 

attached a “Y” splitter to the other end of the silicone tubing, with two additional pieces of 

silicone tubing attached to the “Y” splitter. The length of silicone tubing between the pump and 

the “Y” splitter consisted of two pieces with a small connector, which allowed EPA to attach and 

detach a capsule filter inline with the tubing configuration. The “Y” splitter allowed EPA to 

collect “true” split samples with Mitchell’s representative. Figure D-6, in Appendix D, is a 

picture of the sampling set-up for the effluent from the fly ash pond. 

 After configuring the tubing for the sampling point, the samplers purged the tubing and 

filter with sample for approximately one minute. The samplers first collected the low-level 

dissolved metals and low-level hexavalent chromium samples, as well as the QC samples, 

because the capsule filter was already inline with the tubing configuration from the dissolved 

metals field blank sample collection. The samplers then installed a new capsule filter and purged 

the tubing and filter for one minute. After purging the new filter, the sampling team collected the 

routine dissolved metals, routine dissolved metals QC, and routine hexavalent chromium 

samples. Each of these samples was collected in a “cleanbox,” as described in Section 3.1. 

 After collecting all the dissolved metals samples, the sampling team removed the capsule 

filter from the tubing configuration and purged the tubing for one minute. The samplers then 

collected the low-level total metals, low-level total and dissolved mercury, routine total metals, 

as well as the QC samples for each analyte, and arsenic/selenium speciation samples in a 

“cleanbox,” as described in Section 3.1. The samplers then collected the BOD, Group I, and 

Group II samples, by pouring the samples directly from the tubing into the samples bottles 

without using a “cleanbox.” 

 The samplers used a bottle dipper to collect the HEM/SGT-HEM samples directly from 

the channel to prevent any oil and grease adhering to the sides of the tubing. Therefore, EPA did 

not collect split samples with Mitchell’s representative for the HEM/SGT-HEM samples, but 

instead collected duplicate samples with Mitchell’s representative. Two members of the 

sampling team collected the HEM/SGT-HEM samples from the channel at approximately the 

same point within the channel at which the other samples were collected. 

 During the sample collection, the sampling team collected an aliquot of sample for field 

testing. Sample pH and temperature were measured immediately at the sampling point using a 

pH meter and four-color pH paper. The four-color pH paper was used as an independent check of 

the pH meter to ensure that similar results were measured. After returning to the staging area, the 

sampling team took measurements of free and total residual chlorine using a colorimeter. Table 

3-3 presents the field measurement data for the effluent from the fly ash pond. 
3-9

3.2 List of Analytes and Sample Preservation

 Analytes in EPA’s Mitchell sampling episode included those in the following classes of 

pollutants: 

• Classicals: 

— Biochemical oxygen demand, 5-day (BOD5), 

— Total suspended solids (TSS), 

— Total dissolved solids (TDS), 

— Sulfate, 

— Chloride, 

— Total Kjeldahl nitrogen (TKN), 

— Ammonia as nitrogen, 

— Nitrate/nitrite as nitrogen, 

— Total phosphorus, 

— Hexane extractable material (HEM), and 

— Silica-gel treated hexane extractable material (SGT-HEM); and 

• Metals: 

— Routine total metals (27 metals: aluminum, antimony, arsenic, barium, 

beryllium, boron, cadmium, calcium, chromium, cobalt, copper, iron, lead, 

magnesium, manganese, mercury, molybdenum, nickel, selenium, silver, 

sodium, thallium, tin, titanium, vanadium, yttrium, and zinc), 

— Routine dissolved metals (27 metals), 

— Routine hexavalent chromium, 

— Low-level total mercury, 

— Low-level dissolved mercury, 

— Low-level hexavalent chromium, 

— Low-level total metals (11 metals: antimony, arsenic, cadmium, 

chromium, copper, lead, nickel, selenium, silver, thallium, zinc), and 

— Low-level dissolved metals (11 metals). 

 The analytes selected reflect the current understanding of coal-fired power plant air 

pollution control wastewaters, including contributions from coal, scrubber sorbents, treatment 

chemicals, and other sources. Table 3-4 lists the analytical methods used to determine pollutant 

concentrations. 

 Table 3-5 lists the containers used for sample collection as well as the preservation 

requirements for each sample and Table 3-6 summarizes the chemical preservation for each of 

the samples that were preserved on site. The sampling team preserved samples in accordance 

with procedures described in Section 3.4 of the Sampling Plan. All samples except routine total 

and dissolved metals, low-level total and dissolved metals, and low-level hexavalent chromium 

samples were placed on ice and cooled to <6°C immediately following collection. All dissolved 

metals samples, except low-level dissolved mercury, were filtered in the field. The routine and 

low-level hexavalent chromium samples were preserved in the field, but all other metals samples 

were acid-preserved prior to extraction at the laboratory. The routine hexavalent chromium 

samples were supposed to be preserved to a pH between 9.3 and 9.7 using an ammonium sulfate 

buffer solution; however, the sampling team discontinued preservation for some samples because 

10 percent of the sample volume was added before the required pH was achieved (the pH of the 
3-10

preserved samples was approximately 9.0). The low-level hexavalent chromium sample bottles 

were prepreserved with 2 mL of 50-percent NaOH. The Group II and HEM/SGT-HEM samples 

were preserved with sulfuric acid to a pH of <2 immediately after collection in the staging area, 

and the pH was confirmed with four-color pH strips. 

3.3 Plant Operational Data

 During the sampling episode at Mitchell, plant personnel provided the sampling team 

with operational data for each of the generating units, the FGD scrubber system, and the ash 

collection system, as well as operational and flow data for the FGD wastewater treatment system 

and the fly ash pond. Table 3-7 presents the unit operating characteristics, Table 3-8 presents the 

FGD scrubber system operating characteristics, Table 3-9 presents the FGD wastewater 

treatment system operating characteristics, Table 3-10 presents the ash system operating 

characteristics, and Table 3-11 presents the fly ash pond operating characteristics during the 

sampling episode. 

 As noted in Section 3.0, Unit 1 was shut down during the sampling episode. According to 

plant personnel, the unit was tripped and forced to shut down, which was caused by an outside 

contractor working at the switchyard control building. After the plant determined the cause of 

trip, the unit was “hot” restarted. Unit 1 was shut down on Wednesday, October 17, 2007 at 1245 

and began operating again at approximately 1800 on the same day. By 0430 on October 18, the 

unit was operating at full load. In addition, the plant’s FGD scrubber purge was tripped at 

approximately 0655 on October 17; however, the plant was able to restart the purge within 20 

minutes after the purge was tripped. Plant personnel were unable to determine the cause of the 

trip to the plant’s FGD scrubber purge. 

3.4 Deviations from the Sampling and Analysis Plan

 The sampling episode proceeded as specified in the Sampling Plan with the exceptions 

described below: 

• Collection Containers for Dissolved Metals at SP-1 and SP-2. For the influent 

to the FGD wastewater treatment system (SP-1) and the FGD primary clarifier 

effluent (SP-2), EPA planned to collect volume for the pump off of sample to be 

analyzed for routine and low-level dissolved metal analytes into two precleaned 

10-liter containers. However, EPA collected the volume into one precleaned 10-

liter container, which was sufficient volume for sample collection. 

• Dissolved Metals Sample Filtration Time. For the influent to the FGD 

wastewater treatment system (SP-1), EPA planned to filter the dissolved metals 

samples approximately one hour after filling the 10-liter container with sample; 

however, the samples weren’t filtered until approximately one hour and 20 

minutes later. In addition, for the FGD primary clarifier effluent (SP-2) and 

effluent from the FGD wastewater treatment system (SP-3), EPA planned to filter 

the dissolved metals samples 15 minutes after filling the 10-liter containers with 

sample; however, the FGD clarifier effluent (SP-2) samples weren’t filtered until 

40 minutes later and the effluent from the FGD wastewater treatment system (SP3) samples weren’t filtered until one hour later. 
3-11

• Sample Collection Order at FGD Effluent (SP-3). EPA planned to collect the 

BOD and HEM/SGT-HEM samples after collecting the low-level and routine 

metals samples at the effluent from the FGD wastewater treatment system (SP-3). 

However, as discussed in Section 3.0, Unit 1 shut down at 1245 on October 17, 

2007. Because of the shut-down, EPA decided to collect the FGD effluent 

samples on October 17 rather than October 18 as originally planned to ensure that 

representative samples were collected. Sample collection began at approximately 

1430. Because the BOD samples have a 48-hour hold time, the samples must be 

shipped the day of sample collection and must be shipped at a temperature of 

≤6EC. For this reason, EPA decided to collect the BOD samples first, so the 

samplers could begin cooling the sample and preparing the sample for shipment. 

In order to collect the BOD sample first and not contaminate the tubing for the 

low-level metals sample collection, EPA determined that the sample would have 

to be collected directly from the sample tap, without using sample tubing. 

Therefore, EPA and Mitchell’s representative collected duplicate samples of 

BOD. In addition, because the BOD samples were collected from the sample tap 

first, EPA decided to also collect the HEM/SGT-HEM samples at the same time, 

because they were collected using the same sampling technique. 

• Preservation of Routine Hexavalent Chromium. The routine hexavalent 

chromium samples were supposed to be preserved to a pH between 9.3 and 9.7 

using an ammonium sulfate buffer solution; however, for some of the samples, 

preservation was discontinued because 10 percent of the sample volume was 

added before the required pH was achieved (the pH of these preserved samples 

was approximately 9.0). 
3-12

Table 3-1. Sample Collection Information, Mitchell 

Sampling 

Point Number Sampling Point Description 

Type of 

Sample 

Sample Collection 

Date and Time SCC Number

SP-1 Influent to FGD Wastewater Treatment 

System 

Grab 10/17/2007 

0800 a and 0920 b 

70620 

SP-2 FGD Primary Clarifier Effluent Grab 10/17/2007 

1030 a and 1127 b

70621 

SP-3 Effluent from FGD Wastewater Treatment 

System 

Grab 10/17/2007 

1434 a and 1602 b

70622 

SP-4 Effluent from Fly Ash Pond Grab 10/18/2007 

0913 

70623 

SP-5 Duplicate of Effluent from FGD 

Wastewater Treatment System 

Grab 10/17/2007 

1434 a

 and 1602 b

70624 

SP-6 Influent to FGD Wastewater Treatment 

System Field Blank 

Grab 10/17/2007 

0702 a

 and 0915 b 

70625 

SP-7 FGD Primary Clarifier Effluent Field 

Blank 

Grab 10/17/2007 

1017 a and 1120 b

70626 

SP-8 Effluent from FGD Wastewater Treatment 

System Field Blank 

Grab 10/17/2007 

1414 a and 1548 b

70627 

SP-9 Effluent from Fly Ash Pond Field Blank Grab 10/18/2007 

0844 

70628 

a – Collection of the total metals samples (low-level and routine), low-level total and dissolved mercury, and 

classicals. 

b – Collection of the dissolved metals samples (except low-level dissolved mercury). 
3-13 

Table 3-2. Number of Samples Collected by Sampling Point, Mitchell 

Sampling 

Point 

Number Sampling Point Description 

Low-Level Total Metals 

(11 analytes) 

Low-Level Dissolved Metals 

(11 analytes) 

Low-Level Total Mercury 

Low-Level Dissolved 

Mercury 

Low-Level Hexavalent 

Chromium 

Routine Total Metals (27 

analytes) 

Routine Dissolved Metals 

(27 analytes) 

BOD

5 

Group I 

a

 

Group II 

b

SP-1 Influent to FGD Wastewater 

Treatment System 1 1 1 1 1 1 1 1 1 

SP-2 FGD Primary Clarifier Effluent 1 1 1 1 1 1 1 1 1 1 SP-3 Effluent from FGD Wastewater 

Treatment System 1+QC 1+QC 1+QC 1+QC 1+QC 1+QC 1+QC 1+QC 1+QC 1+QC 

SP-4 Effluent from Fly Ash Pond 1+QC 1+QC 1+QC 1+QC 1+QC 1+QC 1+QC 1 1 1 SP-5 Duplicate of Effluent from FGD 

Wastewater Treatment System 1 1 1 1 1 1 1 1 1 1 

SP-6 Influent to FGD Wastewater 

Treatment System Field Blank 1 1 1 

SP-7 FGD Primary Clarifier Effluent 1 1 1 1 SP-8 Effluent from FGD Wastewater 

Treatment System Field Blank 1 1 1 1 1 1 

SP-9 Effluent from Ash Pond Field Blank 1 1 1 1 1 1 

Total Number of Samples 9+2QC 9+2QC 9+2QC 5+2QC 4+2QC 7+2QC 7+2QC 5+1QC 5+1QC 5+1QC 

a – Group I includes total suspended solids (TSS), total dissolved solids (TDS), sulfate and chloride. b – Group II includes ammonia as nitrogen, nitrate/nitrite as nitrogen, total Kjeldahl nitrogen (TKN), and total phosphorus. 

c – The selenium/arsenic speciation results from the sampling episode were not available at the time this report was finalized and therefore are not inc
3-14 

Table 3-3. Field Measurements, Mitchell 

Temp 

°C 

pH 

(S.U.) Sampling Point 

Number 

Sampling Point 

Description Time Meter Thermometer Meter a Strips 

Free 

Chlorine 

(mg/L) 

Total 

Chlorine 

(mg/L) 

Ma

Int

R

(

SP-1 Influent to FGD 

Wastewater Treatment System 

0827 41.1 44 6.75 7 0.57 0.11 

SP-2 FGD Primary Clarifier 

Effluent 

1048 34.6 38 8.52 9 2.20b 0.77 

SP-3 Effluent from FGD 

Wastewater Treatment System 

1504 33.3 34 8.56 9 2.20b 0.62 

SP-4 Effluent from Fly Ash 

Pond 

0947 18.2 NA 8.55 8 0.01 0.02 

a – The pH meter was calibrated on the morning of October 17 and 18, 2007 using pre-packaged buffer solutions at pHs 4.0, 7.0, and 1b – Based on the average flow value for the influent to the FGD wastewater treatment system on the day of sampling (October 17, 2007Note: The average flow value the day before sampling was 538 gpm. c – The test resulted in a “limit” reading. d – Based on the average flow value for the effluent from the FGD wastewater treatment system on the day of sampling (October 17, 20plant. Note: The average flow value the day before sampling was 530 gpm. e – Based on three measurements collected from the flume during the sampling episode. NA – Not analyzed. NM – Not measured. 
3-15

Table 3-4. Analytical Methods and Procedures for Samples Collected at Mitchell 

Method Number Parameter Method Type 

Classicals 

SM 5210 B Biochemical Oxygen Demand (BOD5) Probe 

SM 2540 D Total Suspended Solids (TSS) Gravimetric 

SM 2540 C Total Dissolved Solids (TDS) Gravimetric 

ASTM D516-90 Sulfate Turbidimetric 

SM 4500–Cl–C Chloride Titrimetric, mercuric 

nitrate 

SM 4500—NH3 F 

(18th ed.) 

Ammonia as Nitrogen Distillation, 

potentiometric 

SM 4500—NO3 -H Nitrate/Nitrate as Nitrogen Autoanalyzer 

SM 4500—N, C (18th 

ed.) 

Total Kjeldahl Nitrogen (TKN) Digestion, distillation, 

potentiometric 

EPA 365.3 (Rev 1978) Total Phosphorus Digestion, 

spectrophotometric 

EPA 1664A Hexane Extractable Material (HEM) Gravimetric 

EPA 1664A Silica Gel Treated Hexane Extractable Material (SGT-HEM) Gravimetric 

Metals 

EPA 1631 Mercury in Water by Oxidation, Purge and Trap, and Cold Vapor 

Atomic Fluorescence Spectrometry 

Oxidation, Purge and 

Trap, and CVAFS 

EPA 1636 Determination of Hexavalent Chromium by Ion Chromatography Ion Chromatography 

EPA 1638 Determination of Trace Elements in Ambient Waters by 

Inductively Coupled Plasma – Mass Spectroscopy (includes 

antimony, arsenic, cadmium, chromium, copper, lead, nickel, 

selenium, silver, thallium, and zinc) 

ICP/MS 

EPA 200.7, 245.1 Metals by Inductively Coupled Plasma Atomic Emission 

Spectrometry, and Atomic Absorption Spectroscopy 

ICP and CVAA 

ASTM D1687-92 Hexavalent Chromium Colorimetric 

CVAFS – Cold vapor atomic fluorescence spectrometry. 

ICP/MS – Inductively coupled plasma with mass spectrometry. 

ICP – Inductively coupled plasma. 

CVAA – Cold vapor atomic adsorption. 
3-16

Table 3-5. Summary of Sample Container and Planned Preservation 

Parameter Sample Container and Volume On-Site Preservation 

Classicals 

BOD5 One 1-L plastic bottle ≤6°C 

Group I a Two 1-L plastic bottles ≤6°C 

Group II b Two 1-L plastic bottles H2SO4 to pH <2, ≤6°C 

HEM/SGT-HEM Two 1-L wide mouth glass jars H2SO4 to pH <2, ≤6°C 

Metals 

Routine total metals, 27 element 

quantitation (Method 200.7, 200.8, 

200.9, 245.2) 

One 500-mL plastic bottle None 

(acid preserve at laboratory) 

Routine dissolved metals, 27 element 

quantitation (Method 200.7, 200.8, 

200.9, 245.2) 

One 500-mL plastic bottle 0.45 μm filter (performed in field) 

(acid preserve at laboratory) 

Routine hexavalent chromium One 250-mL plastic bottle 0.45 μm filter (performed in field) 

Ammonium sulfate buffer to pH 9.3 

– 9.7, ≤6°C 

Low-level total mercury (Method 

1631) 

One 250-mL glass (ultraclean), 

fluoropolymer lined cap 

None 

(acid preserve at laboratory) 

Low-level dissolved mercury (Method 

1631) 

Two 250-mL glasses (ultraclean), 

fluoropolymer lined caps 

None 

(acid preserve and filter at 

laboratory) 

Low-level total elements by ICP/MS 

(11 elements, Method 1638) 

One 250-mL LDPE (ultraclean), 

fluoropolymer lined cap 

None 

(acid preserve at laboratory) 

Low-level dissolved elements by 

ICP/MS (11 elements, Method 1638) 

Two 250-mL LDPE (ultraclean), 

fluoropolymer lined caps 

0.45 μm filter (performed in field) 

 (acid preserve at laboratory) 

Low-level hexavalent chromium 

(Method 1636) 

One 250-mL LDPE (ultraclean), 

fluoropolymer lined cap 

0.45 μm filter (performed in field) 

2 mL 50% NaOH per 250 mL 

sample (performed in field) c 

Selenium/arsenic speciation Two 125-mL amber glasses 

(ultraclean) 

None for original sample, ≤6°C 

Duplicate: HCl to pH <2, ≤6°C 

a – Group I includes TSS, TDS, sulfate, and chloride. 

b – Group II includes ammonia as nitrogen, nitrate/nitrite as nitrogen, TKN, and total phosphorus. 

c – Method 1636 has a preservation requirement that the low-level hexavalent chromium sample be cooled to ≤6EC; 

however, EPA did not cool the low-level hexavalent chromium samples due to contamination concerns. 
3-17

Table 3-6. Sample Preservation Summary, Mitchell 

Sampling Point 

Number Analysis Date Chemical Initial pH Final pH 

Amount 

Added 

70620 Group II V1 10/17/07 H2SO4 7 2 100 drops 

70620 Group II V2 10/17/07 H2SO4 7 2 100 drops 

70620 HEM/SGT-HEM V1 10/17/07 H2SO4 7 2 150 drops 

70620 HEM/SGT-HEM V2 10/17/07 H2SO4 7 2 150 drops 

70620 Routine Hexavalent 

Chromium 

10/17/07 Ammonium 

Sulfate Buffer 

7 9 250 drops a

70620 Arsenic/Selenium 

Speciation (Duplicate) 

10/17/07 HCl 7 2 30 drops 

70621 Group II V1 10/17/07 H2SO4 9 2 60 drops 

70621 Group II V2 10/17/07 H2SO4 9 2 60 drops 

70621 HEM/SGT-HEM V1 10/17/07 H2SO4 9 2 80 drops 

70621 HEM/SGT-HEM V2 10/17/07 H2SO4 9 2 80 drops 

70621 Routine Hexavalent 

Chromium 

10/17/07 Ammonium 

Sulfate Buffer 

9 9.5 250 drops

70621 Arsenic/Selenium 

Speciation (Duplicate) 

10/17/07 HCl 9 2 30 drops 

70622 Group II V1 10/17/07 H2SO4 9 2 60 drops 

70622 Group II V2 10/17/07 H2SO4 9 2 60 drops 

70622 Group II MS/MSD V1 10/17/07 H2SO4 9 2 80 drops 

70622 Group II MS/MSD V2 10/17/07 H2SO4 9 2 80 drops 

70622 HEM/SGT-HEM V1 10/17/07 H2SO4 9 2 80 drops 

70622 HEM/SGT-HEM V2 10/17/07 H2SO4 9 2 80 drops 

70622 HEM/SGT-HEM MS/MSD 

V1 

10/17/07 H2SO4 9 2 80 drops 

70622 HEM/SGT-HEM MS/MSD 

V2 

10/17/07 H2SO4 9 2 80 drops 

70622 Routine Hexavalent 

Chromium 

10/17/07 Ammonium 

Sulfate Buffer 

9 9.5 250 drops

70622 Routine Hexavalent 

Chromium MS/MSD 

10/17/07 Ammonium 

Sulfate Buffer 

9 9.5 250 drops

70622 Arsenic/Selenium 

Speciation (Duplicate) 

10/17/07 HCl 9 2 20 drops 

70623 Group II V1 10/18/07 H2SO4 8 2 100 drops 

70623 Group II V2 10/18/07 H2SO4 8 2 100 drops 

70623 HEM/SGT-HEM V1 10/18/07 H2SO4 8 2 120 drops 

70623 HEM/SGT-HEM V2 10/18/07 H2SO4 8 2 120 drops 

70623 Routine Hexavalent 

Chromium 

10/18/07 Ammonium 

Sulfate Buffer 

8 9 250 drops a 

70623 Arsenic/Selenium 

Speciation (Duplicate) 

10/18/07 HCl 8 2 30 drops 

70624 Group II V1 10/17/07 H2SO4 9 2 60 drops 

70624 Group II V2 10/17/07 H2SO4 9 2 60 drops 
3-18

Table 3-6. Sample Preservation Summary, Mitchell 

Sampling Point 

Number Analysis Date Chemical Initial pH Final pH 

Amount 

Added 

70624 Routine Hexavalent 

Chromium 

10/17/07 Ammonium 

Sulfate Buffer 

9 9.5 250 drops 

70628 Routine Hexavalent 

Chromium 

10/18/07 Ammonium 

Sulfate Buffer 

8 9 250 drops a

a – Preservation of this sample was stopped due to excessive buffering of the sample. The pH of the sample was not 

changing with the addition of the ammonium sulfate buffer solution; therefore, the preservation was stopped to 

prevent the sample from being diluted by the preservative. 
3-19 

Table 3-7. Generating Unit Operating Characteristics during Sample Collection, Mitch

Unit 

ID 

Boiler 

Type Coal Type 

Amount 

of Coal 

Used (tpd) 

Source of Coal 

(Coal Region and/or State) 

Sulfur 

Content of 

the Coal 

(lbs SO2/ 

MBTU) 

Capacity 

(MW) 

Electricity 

Production (or 

Percent 

Capacity) 

SCR 

(No, On, 

Off) 

(

1 a Supercritical 

wall-fired 

Eastern Bituminous blend of high and low sulfur coal b

5,500 c High Sulfur: 

N. WV 

Low Sulfur: 

S. WV 

2.95 800 798 (100% on 

10/16) 

459 (57% on 

10/17) 

Off d 

2 Supercritical 

wall-fired 

Eastern Bituminous blend of high and low sulfur coal b 

5,500 c High Sulfur: 

N. WV 

Low Sulfur: 

S. WV 

2.61 800 844 (106% on 

10/16) 

825 (103% on 

10/17) 

Off d 

a – Unit 1 was tripped and went down at approximately 1245 on 10/17 and came back up at approximately 1800 on the same day. Unit 0430 on 10/18/07. b – At the time of sample collection, the plant was using a 50/50 blend of high sulfur and low sulfur coal. c – Amount of coal was estimated based on 4 million tons of coal per year assuming a 50% split between both units. Actual coal burned 

10/16/07 and 7,883 tpd on 10/17/07. d – SCRs were turned off on September 30. HS ESP – Hot-side electrostatic precipitator. 
3-20 

Table 3-8. FGD Scrubber System Operating Characteristics, Mitchell 

Unit 

ID 

Type of 

Scrubber Sorbent 

Additives (DBA, 

Formic Acid, etc.)

FGD Make-up 

Water Source 

SO2 Removal 

Percentage 

(%) 

Forced 

Oxidation 

(Yes/No) 

Percent Sol

Absorber Blo

(%) 

1 Spray/tray Limestone none Ohio River >97 Yes 19.8 - 22 Spray/tray Limestone none Ohio River >97 Yes 19.8 - 2
3-21

Table 3-9. FGD Wastewater Treatment System Operating Characteristics, Mitchell 

FGD Solids Dewatering (for last cycle prior to sampling or while sampling)

Scrubber slurry blowdown flow rate 1,000 gpm 

Scrubber slurry blowdown duration Approximately 10-12 hr/day 

Scrubber slurry blowdown percent solids 19.8% – 23% 

Dewatering cycle frequency Approximately 10-12 hr/day 

Time since last cycle Unable to estimate 

Percent filtrate recycled back to scrubber Unable to estimate 

FGD Wastewater Treatment System Operation During Sample Collection

Scrubber purge flow rate 502 gpm a 

Scrubber purge duration Continuous 

Scrubber purge percent solids 0.6% (5.7% design basis) b

Lime addition 50 pounds/hr of lime slurry; adjusted to maintain pH of 8.5 

in desaturation tanks 

Ferric chloride addition Added to maintain concentration of 22 ppm in ferric 

chloride mix tank 

Anionic polymer addition Added to maintain concentration of 3 ppm in secondary 

clarifiers 

Sulfuric acid addition Added as needed to maintain pH between 8.0 and 8.5 in 

effluent 

Amount of solids generated 2.5 tons of dewatered sludge/day 

Effluent flow rate 541 gpm a

Frequency of effluent discharge Continuous during sampling episode c

Retention time of desaturation tanks 1.9 hours d

Retention time of primary clarifier 12.8 hours d

Retention time of equalization tank 14.8 hours d

Retention time of ferric chloride mix tank 0.34 hours d

Retention time of secondary clarifier 4.7 hours d

Retention time of entire FGD wastewater treatment 

system 

34.5 hours d

Note: Mitchell began discharging continuously to FGD WWT at 1600 on 10/12/07. Prior to that time, they had been 

sending blowdown to treatment approximately 1x/day for 5-6 hours. Typically, the plant transfers approximately 

400 gpm of scrubber purge to the FGD WWT; however, the average flows on 10/16 and 10/17 were 538 gpm and 

502 gpm, respectively. 

a – 502 gpm is the average of 96 flow rate measurements of the influent to the two desaturation tanks taken every 15 

minutes on 10/17/07; however, the plant typically transfers the scrubber purge to the wastewater treatment system at 

400 gpm. The effluent flow rate (541 gpm) is the average of 96 flow rate measurements of the effluent from the 

wastewater treatment system taken every 15 minutes on 10/17/07. The effluent flow rate is greater than the scrubber 

purge flow rate because of the chemical addition (e.g., lime) added to the FGD wastewater treatment system. 

b – Actual TSS: 0.6% on 10/17. 

c – Typically the plant only discharges 5 to 6 hours/day; however, during the sampling episode, the plant was 

discharging continuously over the two day period. 

d – Based on 400 gpm flow rate. 
3-22 

Table 3-10. Ash System Operating Characteristics During Sample Collection, Mitchel

Unit 

ID 

Fly Ash 

Generation 

(tph) a

Fly Ash 

Sluice Water 

Flow Rate 

(gph) b

Source of Fly 

Ash Sluice 

Water 

Sluice Cycle 

Duration and 

Frequency 

Continuous 

Sluicing 

(Yes/No) 

Bottom 

Ash 

Generation 

(tph) a

Bottom Ash 

Sluice 

Water Flow 

Rate (gph) b

Source of 

Bottom Ash 

Sluice Water 

S

F

1 21.9 126,000 Cooling tower 

blowdown and 

river water 

make-up 

Continuous Yes 5.5 39,000 Bottom ash 

pond overflow 

(including 

FGD WWT) & 

River water 

makeup 

2 21.9 126,000 Cooling tower 

blowdown and 

river water 

make-up 

Continuous Yes 5.5 39,000 Bottom ash 

pond overflow 

(including 

FGD WWT) & 

River water 

makeup 

a – Ash generation was estimated based on the assumption that ash is 12% of the mass of the total coal burned per unit. Fly ash is assum

amount and bottom ash is assumed to be 20 percent. Amount of coal was estimated based on 4 million tons of coal per year assuming a units. These numbers are not based on the coal usage during the sampling episode. b – Flows are assumed to be split 50% between both units based on typical flow rates on the Water Balance Diagram. These numbers a

measurements collected during the sampling episode. 
3-23

Table 3-11. Fly Ash Pond System Operating Characteristics, Mitchell 

Ash Sluice Information 

Total influent flow rate 10 MGD a 

Mitchell fly ash 6.05 MGD a 

Kammer fly ash 1.4 MGD a 

AMD treatment 0.4 MGD a 

Coal preparation wastewater 2.28 MGD a 

Stormwater Varies 

Rainfall Varies 

Influent Duration Continuous 

Fly Ash Pond Information 

pH control system N/A 

Chemicals added to pond system N/A 

Drainage area routed to pond system 1046 acres 

Pond size 63.5 acres 

Pond size 376,000,000 gallons 

Pond retention time 38 days (nominal) 

Frequency of pond dredging N/A 

Sections of pond 2 sections separated by boom 

Final discharge structure type Concrete settling basin followed by Cipolletti weir 

Effluent flow rate 7.8 MGD b 

Frequency of effluent discharge Continuous 

a – Typical flow rates for the fly ash pond system, as shown on the plants’ water flow diagram. These flow rates 

were not measured during the sampling episode. 

b – The effluent flow rate is based on three measurements from the flow meter measured during sample collection. 

These three measurements were taken randomly at differing frequencies. 

N/A – Not applicable. 
4-1 

4. LABORATORY ANALYTICAL RESULTS AND DISCUSSION

 This section summarizes and discusses the analytical data collected during this sampling 

episode. Section 4.1 discusses the methods used by the laboratories for the biphasic analysis of 

SP-1 and presents the results of the analyses. Section 4.2 presents the laboratory analytical data 

for the influent to and effluent from the FGD wastewater treatment system and the FGD primary 

clarifier effluent within the system. Section 4.3 presents the laboratory analytical data for the 

effluent from the fly ash pond. 

 Appendix A provides all analytical results for all samples collected at Mitchell, including 

all qualified results and all results that were measured above the method detection limit, but 

below the reporting limit (i.e., J-values). Appendix B presents the analytical results in a format 

similar to that used for Sections 4.2 and 4.3, but with the J-values shown (J-values are not 

included in the tables presented in Sections 4.2 and 4.3). 

4.1 Measured and Calculated Results for FGD Influent Samples

 The samples of the influent to the FGD wastewater treatment system were expected to 

contain significant amounts of readily settleable solids, to a large degree consisting of gypsum, 

unreacted limestone, and fly ash. Because of this, EPA was concerned that there could be 

analytical interferences for the metals analyses, since the acid digestion procedures used may not 

be sufficiently rigorous for samples with high solids loads. Therefore, EPA directed its contract 

laboratories to separate the aqueous and solid phases of the sample prior to conducting certain 

analyses, where allowed by the analytical method and if necessary to obtain acceptable analytical 

results. This biphasic approach provides EPA with measured or calculated pollutant 

concentrations for the following phases of the sample: 

• Aqueous phase; 

• Solid phase; and 

• Total sample. 

The routine metals laboratory, ProChem Analytical (ProChem), and the low-level laboratory, 

Battelle Marine Sciences Laboratory (Battelle), used two different approaches for the biphasic 

analysis because of the different methods used for routine versus low-level metals analyses. This 

section describes the approaches used by each laboratory and presents the results of the analyses. 

Routine Metals and Classicals Analyses 

 ProChem used EPA Method 200.7 to analyze the wastewater samples for routine metals, 

and EPA Method 245.1 to analyze for routine mercury. EPA Method 200.7 states, “Aqueous 

samples containing total suspended solids ≥1% (w/v) should be extracted as a solid type 

sample.” [3] Because EPA expected the solids content to be greater than one percent, ProChem 

developed an approach for the analysis of the FGD influent samples that consisted of filtering the 

solids from the sample and analyzing the solid and aqueous phases separately. However, upon 

receipt of the FGD influent samples, ProChem determined that the solids content of the samples 

was less than 1 percent; therefore, ProChem did not perform the phase separation prior to 

analyzing the samples. Instead, ProChem analyzed the total sample directly from the sample 

bottle. 
4-2 

Low-Level Metals Analyses 

 Battelle used EPA Method 1638 to analyze the wastewater samples for low-level metals, 

and EPA Method 1631E to analyze for low-level mercury. EPA Method 1638 does not contain 

any language stating how wastewater samples with high solid concentrations should be analyzed; 

therefore, Battelle developed an approach for the analysis of the FGD influent samples that 

minimized potential contamination to the samples. Battelle’s approach consisted of analyzing the 

total metals concentration and dissolved metals concentration for each analyte directly from the 

sample bottles, and calculating the solid phase concentration. By using this approach, the 

laboratory did not have to perform an extra filtration step to determine the individual metals 

concentrations for the various phases in the sample. Battelle did not have any problems with the 

digestion of the solids during the total sample analyses for the Mitchell FGD influent samples. 

 To calculate the solid phase concentration from the total and dissolved phase results, 

Battelle also measured the TSS level in the total metals sample bottle. EPA used the following 

equation to calculate the individual metal solid phase concentrations for the sample: 

TSS

Total Diss

Solid C

C - C C = (4-2) 

where: 

CSolid = concentration of the metal in the solid phase of the sample; 

CTotal = total concentration of the metal in the sample; 

CDiss = concentration of the metal in the dissolved phase of the sample; and 

CTSS = TSS concentration of the sample. 

 Table 4-1 presents the results of the biphasic analysis for low-level total metals. Only 

those analytes that were detected at the influent to the FGD wastewater treatment system (at 

levels above the reporting limit) are included in the table. Results are rounded to three significant 

figures. Appendix Table A-1 presents all the analytical results from the influent to the FGD 

wastewater treatment system sample analysis, including results that were measured above the 

method detection limit, but below the reporting limit (i.e., J-values). 

4.2 FGD Wastewater Treatment System

 Table 4-2 presents the analytical results of the classical pollutants in the influent to the 

FGD wastewater treatment system (SP-1), the FGD primary clarifier effluent (SP-2), and the 

effluent from the FGD wastewater treatment system (average of SP-3 and SP-5 results). Table 4-

3 presents the analytical results of the routine and low-level metals for these same sampling 

points. Only those analytes that were detected in one or more samples (at levels above the 

reporting limit) for the sampling episode are included in the table. Results are rounded to three 

significant digits. If an analyte was measured above the method detection limit, but below the 

report limit, “NQ” is reported followed by the sample-specific report limit in parentheses. If an 

analyte was not detected in a sample above the method detection limit, “ND” is reported 

followed by the sample-specific report limit in parentheses. Note that the results presented in 

Tables 4-2 and 4-3 are not paired results, meaning that sample collection across the treatment 

system was not timed to reflect the amount of time it takes the wastewater to pass through the 

treatment system (approximately 34.5 hours). 
4-3 

 Appendix Tables A-1, A-2, A-3, and A-4 present all the analytical results from the 

influent to the FGD wastewater treatment system (SP-1), the FGD primary clarifier effluent 

(SP-2), the effluent from the FGD wastewater treatment system (SP-3), and the duplicate of the 

effluent from the FGD wastewater treatment system (SP-5) sample analyses, including J-values. 

Appendix Table B-1 presents the analytical results for the metal analytes in a format similar to 

Table 4-3; however, Table B-1 also includes results where analytes were measured above the 

method detection level, but below the reporting limit (i.e., J-values). 

4.3 Fly Ash Pond

 Table 4-4 presents the analytical results of the classical pollutants in the effluent from the 

fly ash pond (SP-4). Table 4-5 presents the analytical results of the routine and low-level metals 

in the effluent from the fly ash pond (SP-4). Only those analytes that were detected in one or 

more samples (at levels above the reporting limit) for the sampling episode are included in the 

table. Results are rounded to three significant digits. If an analyte was measured above the 

method detection limit, but below the report limit, “NQ” is reported followed by the samplespecific report limit in parentheses. If an analyte was not detected in a sample above the method 

detection limit, “ND” is reported followed by the sample-specific report limit in parentheses. 

Appendix Table A-5 presents all the analytical results for the effluent from the fly ash pond (SP4) sample analysis, including J-values. Appendix Table B-2 presents the analytical results for the 

metal analytes in a format similar to Table 4-5; however, Table B-2 also includes results where 

analytes were measured above the method detection level, but below the reporting limit (i.e., Jvalues). 
4-4 

Table 4-1. Biphasic Sample Results for Low-Level Total Metals Measured Above the 

Report Limit, FGD Influent, Mitchell 

Analyte 

Dissolved Sample 

Result (ug/L) 

Calculated Solid Phase 

Result (mg/kg) 

Total Sample Result 

(ug/L) 

Low-level Total Metals 

Antimony 1.97 1.02 9.23 

Arsenic 20.2 5.55 59.9 

Cadmium NQ (1.00) NQ (0.699) 5.28 

Chromium ND (80.0) 24.6 176 L 

Copper NQ (20.0) 19.0 139 

Lead ND (0.500) 9.52 68.1 

Mercury 0.0111 19.3 138 

Nickel 433 30.3 650 

Selenium 443 216 1,990 

Thallium 4.47 0.260 6.33 

Zinc 160 79.7 730 

L – Sample result between 5x and 10x blank result. 

ND – Not detected (number in parenthesis is the report limit). 

NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is 

the report limit). The analytical result is presented in Appendix A with a J flag designation. 
4-5 

Table 4-2. Classical Pollutants Measured Above the Report Limit for the FGD Wastewater Treatment 

Analyte Method Unit FGD Influent (SP-1)

FGD Primary Clarifier 

Effluent (SP-2) 

Classical PollutantsAmmonia As Nitrogen (NH3-N) 4500-NH3F MG/L 1.89 2.68 Nitrate/Nitrite (NO3-N + NO2-N) 4500NO3H MG/L 20.6 23.0 Total Kjeldahl Nitrogen (TKN) 4500-N,C MG/L 13.3 10.4 Biochemical Oxygen Demand (BOD) SM 5210B MG/L 21.0 30.0 Chloride 4500-CL-C MG/L 7,200 7,000 Hexane Extractable Material (HEM) 1664A MG/L 11.0 9.00 Sulfate D516-90 MG/L 1,640 1,880 Total Dissolved Solids (TDS) 2540 C MG/L 18,100 19,400 Total Phosphorus 365.3 MG/L 3.57 0.120 Total Suspended Solids (TSS) 2540 D MG/L 7,320 192 

a – The FGD effluent results represent the average of the FGD effluent and the duplicate of the FGD effluent analytical measurements. 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

Note: Results shown are not paired samples. See Section 4.2. 
4-6 

a – The FGD effluent results represent the average of the FGD effluent and the duplicate of the FGD effluent analytical measurements. 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

L – Sample result between 5x and 10x blank result. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not Analyzed. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Th

presented in Appendix A with a J flag designation. A “NQ” for the average FGD effluent indicates that the original FGD effluent and/o

effluent is a J-value. The analytical result for the original FGD effluent and/or the duplicate of the FGD effluent is presented in Appenddesignation. Note: Results shown are not paired samples. See Section 4.2. 

Table 4-3. Metals Measured Above the Report Limit for the FGD Wastewater Treatment System

FGD Influent 

(SP-1) 

FGD Primary Clarifier Effluent 

(SP-2) 

FG

(SP

Analyte Method Unit Total Dissolved Total Dissolved Total 

Routine Metals Aluminum 200.7 UG/L 17,900 ND (50.0) ND (50.0) ND (50.0) ND (50.0) Antimony 200.7 UG/L 28.7 NQ (20.0) NQ (20.0) NQ (20.0) NQ (20.0) Arsenic 200.7 UG/L 72.5 NQ (10.0) 10.0 NQ (10.0) <10.3 Barium 200.7 UG/L 588 488 457 401 433 Beryllium 200.7 UG/L 8.04 6.02 NQ (5.00) NQ (5.00) NQ (5.00) Boron 200.7 UG/L 229,000 232,000 244,000 217,000 208,000 Cadmium 200.7 UG/L 19.7 NQ (5.00) NQ (5.00) NQ (5.00) NQ (5.00) Calcium 200.7 UG/L 3,030,000 2,350,000 2,650,000 2,450,000 2,380,000 Chromium 200.7 UG/L 70.7 ND (10.0) NQ (10.0) ND (10.0) ND (10.0) Hexavalent Chromium 

D1687-

92 

UG/L NA 5.00 NA 15.0 NA 

Cobalt 200.7 UG/L 68.0 NQ (50.0) NQ (50.0) NQ (50.0) NQ (50.0) Copper 200.7 UG/L 164 NQ (10.0) 16.6 12.0 16.2 Iron 200.7 UG/L 60,600 ND (100) 971 NQ (100) 318 Lead 200.7 UG/L 103 ND (50.0) NQ (50.0) ND (50.0) NQ (50.0) Magnesium 200.7 UG/L 1,470,000 1,370,000 1,480,000 1,300,000 1,280,000 Manganese 200.7 UG/L 28,800 27,900 7,380 7,000 4,440 
4-7 

a – The FGD effluent results represent the average of the FGD effluent and the duplicate of the FGD effluent analytical measurements. 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

L – Sample result between 5x and 10x blank result. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not Analyzed. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Th

presented in Appendix A with a J flag designation. A “NQ” for the average FGD effluent indicates that the original FGD effluent and/o

effluent is a J-value. The analytical result for the original FGD effluent and/or the duplicate of the FGD effluent is presented in Appenddesignation. Note: Results shown are not paired samples. See Section 4.2. 

Table 4-3. Metals Measured Above the Report Limit for the FGD Wastewater Treatment System

FGD Influent 

(SP-1) 

FGD Primary Clarifier Effluent 

(SP-2) 

FG

(SP

Analyte Method Unit Total Dissolved Total Dissolved Total 

Mercury 245.1 UG/L 67.5 ND (10.0) ND (10.0) ND (10.0) ND (10.0) Molybdenum 200.7 UG/L 65.0 22.2 24.5 21.9 22.9 Nickel 200.7 UG/L 554 355 55.5 NQ (50.0) NQ (50.0) Selenium 200.7 UG/L 2,130 46.9 121 82.3 83.6 Sodium 200.7 UG/L 314,000 324,000 315,000 305,000 305,000 Thallium 200.7 UG/L ND (10.0) ND (10.0) ND (10.0) ND (10.0) ND (10.0) Titanium 200.7 UG/L 377 ND (10.0) 10.5 ND (10.0) <10.1 Vanadium 200.7 UG/L 203 ND (20.0) NQ (20.0) ND (20.0) ND (20.0) Yttrium 200.7 UG/L 64.9 NQ (5.00) NQ (5.00) NQ (5.00) NQ (5.00) Zinc 200.7 UG/L 885 87.8 46.4 ND (10.0) 25.4 Low-Level Metals Antimony 1638 UG/L 9.23 1.97 2.00 1.75 <1.37 Arsenic 1638 UG/L 59.9 20.2 NQ (15.0) 20.9 <25.2 Cadmium 1638 UG/L 5.28 NQ (1.00) NQ (1.00) NQ (1.00) NQ (3.00) Chromium 1638 UG/L 176 L ND (80.0) NQ (80.0) NQ (80.0) NQ (120) Hexavalent Chromium 

1636 UG/L NA NA NA NQ (2.50) NA 

Copper 1638 UG/L 139 NQ (20.0) NQ (20.0) NQ (20.0) NQ (30.0) 
4-8 

a – The FGD effluent results represent the average of the FGD effluent and the duplicate of the FGD effluent analytical measurements. 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

L – Sample result between 5x and 10x blank result. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not Analyzed. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Th

presented in Appendix A with a J flag designation. A “NQ” for the average FGD effluent indicates that the original FGD effluent and/o

effluent is a J-value. The analytical result for the original FGD effluent and/or the duplicate of the FGD effluent is presented in Appenddesignation. Note: Results shown are not paired samples. See Section 4.2. 

Table 4-3. Metals Measured Above the Report Limit for the FGD Wastewater Treatment System

FGD Influent 

(SP-1) 

FGD Primary Clarifier Effluent 

(SP-2) 

FG

(SP

Analyte Method Unit Total Dissolved Total Dissolved Total 

Lead 1638 UG/L 68.1 ND (0.500) 2.01 NQ (0.500) NQ (1.50) Mercury 1631E UG/L 138 0.0111 2.38 0.0190 0.788 Nickel 1638 UG/L 650 433 NQ (100) 123 <155 Selenium 1638 UG/L 1,990 443 234 472 431 Thallium 1638 UG/L 6.33 4.47 4.08 4.11 3.96 Zinc 1638 UG/L 730 160 71.0 NQ (50.0) <83.5 
4-9 

Table 4-4. Classical Pollutants Measured Above the Report Limit for the Fly Ash Pond 

Effluent, Mitchell

Analyte Method Unit Fly Ash Pond Effluent (SP-4) 

Classical Pollutants 

Ammonia As Nitrogen (NH3-N) 4500-NH3F MG/L 0.150 

Nitrate/Nitrite (NO3-N + NO2-N) 4500NO3H MG/L 0.730 

Total Kjeldahl Nitrogen (TKN) 4500-N,C MG/L ND (0.100) 

Biochemical Oxygen Demand (BOD) SM 5210B MG/L 2.00 

Chloride 4500-CL-C MG/L 240 

Hexane Extractable Material (HEM) 1664A MG/L ND (5.00) 

Sulfate D516-90 MG/L 1,110 

Total Dissolved Solids (TDS) 2540 C MG/L 2,050 

Total Phosphorus 365.3 MG/L 0.200 

Total Suspended Solids (TSS) 2540 D MG/L 15.0 

ND – Not detected (number in parenthesis is the report limit). 
NA – Not analyzed. 

ND – Not detected (number in parenthesis is the report limit). 

NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is 

the report limit). The analytical result is presented in Appendix A with a J flag designation. 

4-10 

Table 4-5. Metals Measured Above the Report Limit for the Fly Ash Pond Effluent, 

Mitchell

Fly Ash Pond Effluent (SP-4) 

Analyte Method Unit Total Dissolved 

Routine Metals 

Aluminum 200.7 UG/L 404 241 

Antimony 200.7 UG/L 24.6 23.9 

Arsenic 200.7 UG/L 150 138 

Barium 200.7 UG/L 133 128 

Beryllium 200.7 UG/L ND (5.00) ND (5.00) 

Boron 200.7 UG/L 2,350 2,290 

Cadmium 200.7 UG/L ND (5.00) ND (5.00) 

Calcium 200.7 UG/L 115,000 113,000 

Chromium 200.7 UG/L 15.9 14.1 

Hexavalent Chromium D1687-92 UG/L NA 7.00 

Cobalt 200.7 UG/L NQ (50.0) NQ (50.0) 

Copper 200.7 UG/L NQ (10.0) NQ (10.0) 

Iron 200.7 UG/L NQ (100) ND (100) 

Lead 200.7 UG/L ND (50.0) ND (50.0) 

Magnesium 200.7 UG/L 21,000 20,300 

Manganese 200.7 UG/L NQ (15.0) NQ (15.0) 

Mercury 245.1 UG/L ND (0.200) ND (0.200) 

Molybdenum 200.7 UG/L 359 330 

Nickel 200.7 UG/L NQ (50.0) NQ (50.0) 

Selenium 200.7 UG/L 177 162 

Sodium 200.7 UG/L 526,000 514,000 

Thallium 200.7 UG/L ND (10.0) ND (10.0) 

Titanium 200.7 UG/L NQ (10.0) ND (10.0) 

Vanadium 200.7 UG/L 110 108 

Yttrium 200.7 UG/L ND (5.00) ND (5.00) 

Zinc 200.7 UG/L ND (10.0) ND (10.0) 

Low-Level Metals 

Antimony 1638 UG/L 25.8 22.5 

Arsenic 1638 UG/L 142 131 

Cadmium 1638 UG/L 1.32 1.17 

Chromium 1638 UG/L 20.4 16.0 

Hexavalent Chromium 1636 UG/L NA 17.4 

Copper 1638 UG/L 5.47 4.54 

Lead 1638 UG/L 0.580 NQ (0.250) 

Mercury 1631E UG/L 0.00212 NQ (0.000500) 
NA – Not analyzed. 

ND – Not detected (number in parenthesis is the report limit). 

NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is 

the report limit). The analytical result is presented in Appendix A with a J flag designation. 

4-11 

Table 4-5. Metals Measured Above the Report Limit for the Fly Ash Pond Effluent, 

Mitchell

Fly Ash Pond Effluent (SP-4) 

Analyte Method Unit Total Dissolved 

Nickel 1638 UG/L 11.0 9.57 

Selenium 1638 UG/L 191 161 

Thallium 1638 UG/L 1.72 1.42 

Zinc 1638 UG/L 10.1 9.51 
5-1

5. DATA QUALITY

 QA/QC procedures applicable to the Mitchell sampling episode are outlined in the 

Quality Assurance Project Plan for the Steam Electric Detailed Study (QAPP) [2]. This section 

describes the QC procedures used to assess the precision and accuracy of the analytical data 

presented in Section 4 and Appendices A and B. QC practices used for this sampling episode 

include the analysis of matrix spikes, blanks, duplicate samples, and QC standard checks. 

5.1 Analytical Quality Control

 EPA contracted directly with analytical laboratories for the analysis of samples collected 

during this episode. EPA’s Sample Control Center (SCC) verified that the performances of the 

laboratories selected by EPA was acceptable by conducting QC checks of the analytical data as 

specified by the SCC’s Quality Assurance Project Plan dated 15 February 2008. SCC data 

review chemists prepared written data review narratives describing any qualifications of the 

analytical data from this episode. The data review narratives are included in Appendix C. 

5.2 Field Quality Control

 This section discusses the bottle blanks, equipment blanks, field blanks, and field 

duplicate sample results. Section 3.8 of the Sampling Plan discusses field QC specifications. 

Tables presented in this section include results for only certain analytes (e.g., only those detected 

in the respective field QC sample or those detected during the sampling episode). Appendix A 

contains the results for all analytes, both detected and nondetected. 

5.2.1 Bottle Blanks 

 EPA collects bottle blanks to evaluate possible contamination from the sample collection 

bottles. Bottle blanks were collected and analyzed for low-level metals by the supplier of the precleaned bottles, Albion Environmental. 

 Albion Environmental collected the bottle blanks for the low-level metals and low-level 

hexavalent chromium samples bottles (250 mL LDPE), the speciation sample bottles (125 mL 

amber glass bottles), and the 2-L blank water bottles by filling the pre-cleaned bottle to the neck 

with ASTM Type 1 water, preserving the sample with nitric acid to a pH <2, and allowing the 

sample to sit for at least 24 hours. Albion Environmental then analyzed the samples using EPA 

Method 1638. 

 Albion Environmental collected the bottle blanks for the 4-liter blank water bottles by 

filling the pre-cleaned bottle with ASTM Type 1 water and allowing it to soak for approximately 

24 hours. Albion Environmental then poured a representative aliquot into a pre-cleaned LDPE 

sample bottle, preserved the sample with nitric acid to a pH <2, and allowed the sample to sit for 

at least 24 hours. Albion Environmental then analyzed the samples using EPA Method 1638. 

 Albion Environmental collected the bottle blanks for the low-level mercury sample 

bottles (250 flint glass bottles and 1-L borosilicate glass bottles) by filling the pre-cleaned bottle 

to the neck with ASTM Type 1 water, preserving the sample with bromine monochloride, and 
5-2

allowing the sample to sit for at least 24 hours. Albion Environmental then analyzed the samples 

using EPA Method 1631E. 

 Albion Environmental collected the bottle blank for the 10-liter composite containers by 

filling the container with approximately two liters of ASTM Type 1 water and allowing it to soak 

for approximately 24 hours. During this period, Albion Environmental shook the container 

periodically and changed its orientation to expose all surfaces of the container to the ASTM 

Type 1 water. Albion Environmental then shook the 10-liter container and poured a 

representative sample into a pre-cleaned sample bottle (a LDPE bottle for low-level metals and a 

glass bottle for low-level mercury). The blank samples were then preserved and analyzed 

according to the analytical methods (i.e., EPA Method 1638 or 1631E), as described above for 

the other bottle blank samples. 

 No metals were detected in the bottle blanks, indicating that there was no contamination 

from the sample containers. Appendix Table A-6 presents all of the analytical results from the 

bottle blank and equipment blank analyses for all of the equipment used for the collection of 

low-level samples. 

5.2.2 Equipment Blanks 

 EPA collects equipment blanks to evaluate possible contamination from the equipment 

used for sample collection. EPA did not collect specific equipment blanks for this sampling 

program; however, the field blanks as collected (as described in Section 5.2.3) include the 

sampling equipment. In addition, Albion Environmental collected and analyzed equipment 

blanks for low-level metals for each type of pre-cleaned equipment supplied for the episode. 

 Albion Environmental collected the equipment blanks for the capsule filters and 

fabricated tubing sets by pumping approximately 500 mL of ASTM Type 1 water through the 

pre-cleaned filter or tubing set and discarding the water. Albion Environmental then pumped 

additional water through the pre-cleaned filter or tubing set into a pre-cleaned bottle (a LDPE 

bottle for low-level metals and a glass bottle for low-level mercury). The blank samples were 

then preserved and analyzed according to the analytical methods (EPA Method 1638 or 1631E), 

as described in Section 5.2.1 for the bottle blank samples. For the fabricated tubing sets, Albion 

Environmental collected and analyzed equipment blanks for the individual components of the 

tubing sets, the assembled tubing sets, or both. 

 During the analysis of the equipment blanks, Albion Environmental detected barium at 

0.490 ug/L and 0.476 ug/L in 2 of the 14 pieces of #73 silicone tubing that were analyzed from 

the various cleaning batches used to assemble the tubing sets. Barium was not detected above the 

report limit in the equipment blanks for the other 12 analyses. In addition, barium was not 

detected in any of the field blank samples (above the report limit), as described in Section 5.2.3. 

Finally, barium was measured at a concentration greater than 250 times the equipment blank 

result at all of the sampling points for both the total and dissolved phases. Therefore, the 

potential contamination from the sampling equipment did not significantly affect the sampling 

results. 

 No other metals were detected in the equipment blanks, indicating that there was no other 

contamination from the sampling equipment. Appendix Table A-6 presents all of the analytical 
5-3

results from the bottle blank and equipment blank analyses for all of the equipment used for the 

collection of low-level samples. EPA assumed the barium equipment blank concentration to be 

0.490 ug/L for all tubing sets containing #73 silicone tubing because the tubing set may have 

been fabricated using #73 silicone from the cleaning batch that had a detection for barium at that 

concentration. 

5.2.3 Field Blanks 

 The sampling team collected field blanks (SP-6, SP-7, SP-8, and SP-9) to evaluate 

possible contamination from sampling equipment, sampling equipment decontamination 

procedures, sample collection procedures, or atmospheric contamination. EPA analyzed the field 

blank samples for the low-level and routine metals analyses, including both total and dissolved 

metals1

. 

 The low-level and routine total metals field blank samples for the influent to the FGD 

wastewater treatment system (SP-6), FGD primary clarifier effluent (SP-7), and effluent from the 

FGD wastewater treatment system (SP-8) were collected by pouring ASTM Type 1 water 

through a precleaned funnel attached to the silicone tubing used for sample collection. The 

sampling team shrouded the blank water and funnel with a plastic bag while pouring the blank 

water into the funnel to prevent potential atmospheric deposition. In addition, the sample bottles 

were placed in a “cleanbox” to prevent potential atmospheric deposition. The ASTM Type 1 

water flowed through the funnel, tubing, and “Y” splitter, and was poured into the sample 

bottles. EPA collected the field blank samples as “true” split samples with Mitchell’s 

representative, using the same procedure discussed in the sample collection description (Section 

3.1). 

 The low-level and routine total metals field blank samples for the effluent from the fly 

ash pond (SP-9) were collected by pumping ASTM Type 1 water through the tubing used for the 

sample collection. The container holding the ASTM Type 1 water was placed in a large plastic 

bag and the tubing was placed directly into the container. The large plastic bag was closed off as 

quickly as possible to minimize potential atmospheric deposition. The sample bottles were 

placed in a “cleanbox” and the ASTM Type 1 water was pumped through the tubing and “Y” 

splitter, and poured into the sample bottles. EPA collected the field blank samples as “true” split 

samples with Mitchell’s representative, using the same procedure discussed in the sample 

collection description (Section 3.1). 

 The low-level and routine dissolved metals field blank samples for the influent to the 

FGD wastewater treatment system (SP-6), the FGD primary clarifier effluent (SP-7), the effluent 

from the FGD wastewater treatment system (SP-8), and the effluent from the fly ash pond (SP-9) 

were collected by pumping ASTM Type 1 water through the tubing used for the dissolved metals 

sample collection and a capsule filter. The container holding the ASTM Type 1 water was placed 

in a large plastic bag and the tubing was placed directly into the container. The large plastic bag 

was closed off as quickly as possible to minimize potential atmospheric deposition. The sample 

 

1 EPA did not collect a low-level dissolved mercury field blank sample in the field because the sample filtration was 

performed at the laboratory to minimize potential mercury contamination. The laboratory performed a filtration 

blank prior to filtering the sample, which is assessed as the field blank for the low-level dissolved mercury sample. 

Mercury was not detected above the method detection limit (0.000188 ug/L) in the filtration blank performed for 

both the first and second day of samples, which includes all associated sampling points. 
5-4

bottles were placed in a “cleanbox” and the ASTM Type 1 water was pumped through the 

tubing, capsule filter, and “Y” splitter, and poured into the sample bottles. EPA collected the 

field blank samples as “true” split samples with Mitchell’s representative, using the same 

procedure discussed in the sample collection description (Section 3.1). 

 Table 5-1 presents the field blank analytical results for SP-6 through SP-9. Only those 

analytes that were detected in the field blank samples at levels above the reporting limit are 

included in the table. Results are rounded to three significant digits. Appendix Tables A-7, A-8, 

A-9, and A-10 present all the analytical results for the field blanks from the influent to the FGD 

wastewater treatment system (SP-6), FGD primary clarifier effluent (SP-7), the effluent from the 

FGD wastewater treatment system (SP-8), and the effluent from the fly ash pond (SP-9) sample 

analyses, including all qualified results and all results that were measured above the method 

detection limit, but below the reporting limit (i.e., J-values). 

5.2.4 Field Duplicates 

 The sampling team collected field duplicate samples to assess the sampling measurement 

precision for the episode. Field duplicate samples are separate samples collected from the same 

location as the original sample. The duplicate is filled immediately after the original sample, and 

is stored and analyzed independently. The relative percent difference (RPD) between the two 

sample results is examined to determine the precision of the data. EPA used the following 

equation to calculate the RPD for the duplicate sample results. 

100

2

S D

S D

RPD (%) ×

⎟

⎠

⎞ ⎜

⎝

⎛ +

− = (5-1) 

where: 

S = concentration of the analyte from original sample analysis; 

D = concentration of the analyte from the duplicate sample analysis; and 

RPD = relative percent difference between the original and duplicate sample 

result. 

 During this sampling episode, duplicate samples (SP-5) for all analytes (except 

HEM/SGT-HEM) were collected from the effluent from the FGD wastewater treatment system 

(SP-3). Table 5-2 presents analytical results and the RPD for SP-3 and SP-5 and includes 

analytical results for only those analytes that were detected in one or more samples for the 

sampling episode. Results are rounded to three significant digits. Appendix Tables A-3 and A-4 

present all the analytical results for the effluent from the FGD wastewater treatment system 

(SP-3) and the duplicate of the effluent from the FGD wastewater treatment system (SP-5) 

sample analyses, including all qualified results and all results that were measured above the 

method detection limit, but below the reporting limit (i.e., J-values). 
5-5 

Table 5-1. Field Blank Results Measured Above the Report Limit, Mitchell

Analyte Sample Point Method Unit

Concentration 

(ug/L) 

Routine Total Metals 

Calcium FGD Effluent 200.7 UG/L 235 

Calcium Fly Ash Pond Effluent 200.7 UG/L 113 L 

Routine Dissolved Metals 

Boron FGD Effluent 200.7 UG/L 140 

Magnesium FGD Effluent 200.7 UG/L 807 

Low-Level Dissolved Metals 

Hexavalent Chromium FGD Primary Clarifier 1636 UG/L 2.97 

L – Sample result between 5x and 10x blank result. 
5-6 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not analyzed.

NC – Not calculated. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Thpresented in Appendix A with a J flag designation. 

Table 5-2. Field Duplicate Results, Mitchell

Analyte

Original FGD Effluent 

Concentration (SP-3) 

Duplicate FGD Effluent 

Concentration (SP-5) Average Result 

Relat

Diffe

Classical Pollutants Ammonia As Nitrogen (NH3-N) 3.26 3.71 3.49 Nitrate/Nitrite (NO3-N + NO2-N) 25.4 25.3 25.4 Total Kjeldahl Nitrogen (TKN) 9.37 10.1 9.74 Biochemical Oxygen Demand (BOD) 

ND (2.00) 13.0 < 7.50 

Chloride 6,500 6,900 6,700 Hexane Extractable Material (HEM) 

5.00 NA 5.00 

Sulfate 1,760 1,770 1,770 Total Dissolved Solids (TDS) 17,400 17,900 17,700 Total Phosphorus 0.0700 0.0790 0.0745 Total Suspended Solids (TSS) 20.0 15.0 17.5 Routine Total Metals Aluminum ND (50.0) ND (50.0) ND (50.0) Antimony NQ (20.0) NQ (20.0) ND (20.0) Arsenic 10.6 NQ (10.0) < 10.3 Barium 434 431 433 Beryllium NQ (5.00) NQ (5.00) ND (5.00) Boron 210,000 206,000 208,000 Cadmium NQ (5.00) ND (5.00) ND (5.00) Calcium 2,390,000 2,360,000 2,380,000 
5-7 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not analyzed.

NC – Not calculated. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Thpresented in Appendix A with a J flag designation. 

Table 5-2. Field Duplicate Results, Mitchell

Analyte

Original FGD Effluent 

Concentration (SP-3) 

Duplicate FGD Effluent 

Concentration (SP-5) Average Result 

Relat

Diffe

Chromium ND (10.0) ND (10.0) ND (10.0) Cobalt NQ (50.0) NQ (50.0) ND (50.0) Copper 16.8 15.5 16.2 Iron 331 304 318 Lead NQ (50.0) NQ (50.0) ND (50.0) Magnesium 1,290,000 1,260,000 1,280,000 Manganese 4,510 4,360 4,440 Mercury ND (10.0) ND (10.0) ND (10.0) Molybdenum 23.3 22.4 22.9 Nickel NQ (50.0) NQ (50.0) ND (50.0) Selenium 85.1 R 82.0 83.6 Sodium 312,000 298,000 305,000 Thallium ND (10.0) ND (10.0) ND (10.0) Titanium 10.2 NQ (10.0) < 10.1 Vanadium ND (20.0) ND (20.0) ND (20.0) Yttrium NQ (5.00) NQ (5.00) ND (5.00) Zinc 15.4 35.4 25.4 Routine Dissolved Metals Aluminum ND (50.0) ND (50.0) ND (50.0) Antimony NQ (20.0) NQ (20.0) ND (20.0) Arsenic NQ (10.0) NQ (10.0) ND (10.0) Barium 390 388 389 
5-8 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not analyzed.

NC – Not calculated. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Thpresented in Appendix A with a J flag designation. 

Table 5-2. Field Duplicate Results, Mitchell

Analyte

Original FGD Effluent 

Concentration (SP-3) 

Duplicate FGD Effluent 

Concentration (SP-5) Average Result 

Relat

Diffe

Beryllium NQ (5.00) NQ (5.00) ND (5.00) Boron 198,000 200,000 199,000 Cadmium NQ (5.00) NQ (5.00) ND (5.00) Calcium 2,250,000 2,290,000 2,270,000 Chromium ND (10.0) ND (10.0) ND (10.0) Hexavalent Chromium 10.0 12.0 11.0 Cobalt NQ (50.0) NQ (50.0) ND (50.0) Copper 13.9 14.3 14.1 Iron NQ (100) NQ (100) ND (100) Lead ND (50.0) ND (50.0) ND (50.0) Magnesium 1,220,000 1,220,000 1,220,000 Manganese 4,350 3,880 4,120 Mercury ND (10.0) ND (10.0) ND (10.0) Molybdenum 21.1 21.6 21.4 Nickel NQ (50.0) NQ (50.0) ND (50.0) Selenium 71.2 72.2 71.7 Sodium 302,000 298,000 300,000 Thallium ND (10.0) ND (10.0) ND (10.0) Titanium ND (10.0) ND (10.0) ND (10.0) Vanadium ND (20.0) ND (20.0) ND (20.0) Yttrium NQ (5.00) NQ (5.00) ND (5.00) Zinc ND (10.0) ND (10.0) ND (10.0) 
5-9 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not analyzed.

NC – Not calculated. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Thpresented in Appendix A with a J flag designation. 

Table 5-2. Field Duplicate Results, Mitchell

Analyte

Original FGD Effluent 

Concentration (SP-3) 

Duplicate FGD Effluent 

Concentration (SP-5) Average Result 

Relat

Diffe

Low-Level Total Metals Antimony ND (1.00) 1.73 < 1.37 Arsenic NQ (30.0) 20.4 < 25.2 Cadmium NQ (5.00) NQ (1.00) ND (3.00) Chromium NQ (160) NQ (80.0) ND (120) Copper NQ (40.0) NQ (20.0) ND (30.0) Lead NQ (2.50) NQ (0.500) ND (1.50) Mercury 0.809 0.766 0.788 Nickel NQ (200) 109 < 155 Selenium 417 T 444 431 Thallium 4.01 3.91 3.96 Zinc ND (100) 67.0 < 83.5 Low-Level Dissolved Metals Antimony 1.60 1.68 1.64 Arsenic 19.5 T 22.3 20.9 Cadmium NQ (1.00) NQ (1.00) ND (1.00) Chromium NQ (80.0) NQ (80.0) ND (80.0) Hexavalent Chromium NQ (2.50) ND (2.50) ND (2.50) Copper NQ (20.0) NQ (20.0) ND (20.0) Lead NQ (0.500) NQ (0.500) ND (0.500) Mercury 0.166 0.152 0.159 Nickel 103 100 102 
5-10 

< – Average result includes at least one non-detect value. (Calculation uses detection limit for non-detected results). 

R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not analyzed.

NC – Not calculated. ND – Not detected (number in parenthesis is the report limit). NQ – Analyte was measured above the method detection limit, but below the report limit (number in parenthesis is the report limit). Thpresented in Appendix A with a J flag designation. 

Table 5-2. Field Duplicate Results, Mitchell

Analyte

Original FGD Effluent 

Concentration (SP-3) 

Duplicate FGD Effluent 

Concentration (SP-5) Average Result 

Relat

Diffe

Selenium 413 400 407 Thallium 3.96 4.01 3.99 Zinc ND (50.0) NQ (50.0) ND (50.0) 
6-1

6. REFERENCES

1. Eastern Research Group, Inc., 2007. Sampling Plan, Ohio Power Company’s Mitchell 

Plant. October 9. DCN 05912A1. 

2. Eastern Research Group, Inc., 2007. Quality Assurance Project Plan for the Steam 

Electric Detailed Study. September 25. DCN 05079. EPA-HQ-OW-2006-0071-0724. 

3. U.S. EPA. 2001. Method 200.7: Trace Elements in Water, Solids, and Biosolids, by 

Inductively Coupled Plasma-Atomic Emission Spectrometry. Revision 5.0. EPA-821-R01-010. January. 
Appendix A 

ANALYTICAL RESULTS 
A-1 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). NA – Not applicable. Calculated value. ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-1. FGD Influent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Classical Pollutants – Total Ammonia As Nitrogen (NH3-N) 4500-NH3F MG/L 1 NP NP Nitrate/Nitrite (NO3-N + NO2-N) 4500NO3H MG/L 100 NP NP Total Kjeldahl Nitrogen (TKN) 4500-N,C MG/L 1 NP NP Biochemical Oxygen Demand (BOD) SM 5210B MG/L 4 NP NP Chloride 4500-CL-C MG/L 10 NP NP Hexane Extractable Material (HEM) 1664A MG/L 1 NP NP Silica Gel Treated HEM (SGT-HEM) 1664A MG/L 1 NP NP Sulfate D516-90 MG/L 50 NP NP Total Dissolved Solids (TDS) 2540 C MG/L 1 NP NP Total Phosphorus 365.3 MG/L 10 NP NP Total Suspended Solids (TSS) 2540 D MG/L 1 NP NP Routine Metals – Total Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 100 270 10,000 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 Cobalt 200.7 UG/L 1 0.600 50.0 
A-2 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). NA – Not applicable. Calculated value. ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-1. FGD Influent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 100 20.0 1,500 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Routine Metals – Dissolved Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 
A-3 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). NA – Not applicable. Calculated value. ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-1. FGD Influent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Boron 200.7 UG/L 100 270 10,000 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 Hexavalent Chromium D1687-92 UG/L 1 1.00 2.00 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 100 20.0 1,500 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 
A-4 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). NA – Not applicable. Calculated value. ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-1. FGD Influent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Low-Level Metals – Total Antimony 1638 UG/L 50 0.350 1.00 Arsenic 1638 UG/L 200 3.04 30.0 Cadmium 1638 UG/L 50 0.0500 5.00 Chromium 1638 UG/L 200 16.6 160 Copper 1638 UG/L 200 0.800 40.0 Lead 1638 UG/L 50 0.0500 2.50 Mercury 1631E UG/L 200 0.0376 0.100 Nickel 1638 UG/L 200 2.60 200 Selenium 1638 UG/L 200 3.20 200 Silver 1638 UG/L 50 0.100 5.00 Thallium 1638 UG/L 50 0.0200 1.00 Zinc 1638 UG/L 200 41.8 100 Low-Level Metals - Dissolved Antimony 1638 UG/L 10 0.0700 0.200 Arsenic 1638 UG/L 100 1.52 15.0 Cadmium 1638 UG/L 10 0.0100 1.00 Chromium 1638 UG/L 100 8.30 80.0 Copper 1638 UG/L 100 0.400 20.0 Lead 1638 UG/L 10 0.0100 0.500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 100 1.30 100 Selenium 1638 UG/L 100 1.60 100 
A-5 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). NA – Not applicable. Calculated value. ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-1. FGD Influent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Silver 1638 UG/L 10 0.0200 1.00 Thallium 1638 UG/L 10 0.00400 0.200 Zinc 1638 UG/L 100 20.9 50.0 Low-Level Metals – Solid (dry weight) Antimony 1638 MG/KG NA 0.0490 0.140 Arsenic 1638 MG/KG NA 0.425 4.20 Cadmium 1638 MG/KG NA 0.00770 0.699 Chromium 1638 MG/KG NA 2.32 22.4 Copper 1638 MG/KG NA 0.112 5.59 Lead 1638 MG/KG NA 0.00700 0.350 Mercury 1631E MG/KG NA 0.00530 0.0140 Nickel 1638 MG/KG NA 0.364 28.0 Selenium 1638 MG/KG NA 0.448 28.0 Silver 1638 MG/KG NA 0.0140 0.699 Thallium 1638 MG/KG NA 0.00280 0.140 Zinc 1638 MG/KG NA 5.85 14.0 
A-6 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL (number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-2. FGD Primary Clarifier Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Classical Pollutants Ammonia As Nitrogen (NH3-N) 4500-NH3F MG/L 1 NP NP Nitrate/Nitrite (NO3-N + NO2-N) 4500NO3H MG/L 100 NP NP Total Kjeldahl Nitrogen (TKN) 4500-N,C MG/L 1 NP NP Biochemical Oxygen Demand (BOD) SM 5210B MG/L 6 NP NP Chloride 4500-CL-C MG/L 10 NP NP Hexane Extractable Material (HEM) 1664A MG/L 1 NP NP Silica Gel Treated HEM (SGT-HEM) 1664A MG/L 1 NP NP Sulfate D516-90 MG/L 50 NP NP Total Dissolved Solids (TDS) 2540 C MG/L 1 NP NP Total Phosphorus 365.3 MG/L 1 NP NP Total Suspended Solids (TSS) 2540 D MG/L 1 NP NP Routine Metals – Total Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 100 270 10,000 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 Cobalt 200.7 UG/L 1 0.600 50.0 
A-7 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL (number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-2. FGD Primary Clarifier Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 10 2.00 150 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Routine Metals – Dissolved Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 100 270 10,000 
A-8 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL (number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-2. FGD Primary Clarifier Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 Hexavalent Chromium D1687-92 UG/L 1 1.00 2.00 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 10 2.00 150 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Low-Level Metals – Total Antimony 1638 UG/L 10 0.0700 0.200 
A-9 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL (number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-2. FGD Primary Clarifier Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Arsenic 1638 UG/L 100 1.52 15.0 Cadmium 1638 UG/L 10 0.0100 1.00 Chromium 1638 UG/L 100 8.30 80.0 Copper 1638 UG/L 100 0.400 20.0 Lead 1638 UG/L 10 0.0100 0.500 Mercury 1631E UG/L 10 0.00188 0.00500 Nickel 1638 UG/L 100 1.30 100 Selenium 1638 UG/L 100 1.60 100 Silver 1638 UG/L 10 0.0200 1.00 Thallium 1638 UG/L 10 0.00400 0.200 Zinc 1638 UG/L 100 20.9 50.0 Low-Level Metals - Dissolved Antimony 1638 UG/L 10 0.0700 0.200 Arsenic 1638 UG/L 100 1.52 15.0 Cadmium 1638 UG/L 10 0.0100 1.00 Chromium 1638 UG/L 100 8.30 80.0 Hexavalent Chromium 1636 UG/L 5 1.75 2.50 Copper 1638 UG/L 100 0.400 20.0 Lead 1638 UG/L 10 0.0100 0.500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 100 1.30 100 Selenium 1638 UG/L 100 1.60 100 Silver 1638 UG/L 10 0.0200 1.00 
A-10 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL (number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-2. FGD Primary Clarifier Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Thallium 1638 UG/L 10 0.00400 0.200 Zinc 1638 UG/L 100 20.9 50.0 
A-11 

J – Result measured above the MDL, but less than the reporting limit. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-3. FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Classical Pollutants Ammonia As Nitrogen (NH3-N) 4500-NH3F MG/L 1 NP NP Nitrate/Nitrite (NO3-N + NO2-N) 4500NO3H MG/L 100 NP NP Total Kjeldahl Nitrogen (TKN) 4500-N,C MG/L 1 NP NP Biochemical Oxygen Demand (BOD) SM 5210B MG/L 1 NP NP Chloride 4500-CL-C MG/L 10 NP NP Hexane Extractable Material (HEM) 1664A MG/L 1 NP NP Silica Gel Treated HEM (SGT-HEM) 1664A MG/L 1 NP NP Sulfate D516-90 MG/L 50 NP NP Total Dissolved Solids (TDS) 2540 C MG/L 1 NP NP Total Phosphorus 365.3 MG/L 1 NP NP Total Suspended Solids (TSS) 2540 D MG/L 1 NP NP Routine Metals – Total Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 100 270 10,000 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 Cobalt 200.7 UG/L 1 0.600 50.0 
A-12 

J – Result measured above the MDL, but less than the reporting limit. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-3. FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 10 2.00 150 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Routine Metals – Dissolved Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 
A-13 

J – Result measured above the MDL, but less than the reporting limit. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-3. FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Boron 200.7 UG/L 100 270 10,000 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 Hexavalent Chromium D1687-92 UG/L 1 1.00 2.00 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 10 2.00 150 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 
A-14 

J – Result measured above the MDL, but less than the reporting limit. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-3. FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Low-Level Metals – Total Antimony 1638 UG/L 50 0.350 1.00 Arsenic 1638 UG/L 200 3.04 30.0 Cadmium 1638 UG/L 50 0.0500 5.00 Chromium 1638 UG/L 200 16.6 160 Copper 1638 UG/L 200 0.800 40.0 Lead 1638 UG/L 50 0.0500 2.50 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 200 2.60 200 Selenium 1638 UG/L 200 3.20 200 Silver 1638 UG/L 50 0.100 5.00 Thallium 1638 UG/L 50 0.0200 1.00 Zinc 1638 UG/L 200 41.8 100 Low-Level Metals - Dissolved Antimony 1638 UG/L 10 0.0700 0.200 Arsenic 1638 UG/L 100 1.52 15.0 Cadmium 1638 UG/L 10 0.0100 1.00 Chromium 1638 UG/L 100 8.30 80.0 Hexavalent Chromium 1636 UG/L 5 1.75 2.50 Copper 1638 UG/L 100 0.400 20.0 Lead 1638 UG/L 10 0.0100 0.500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 100 1.30 100 
A-15 

J – Result measured above the MDL, but less than the reporting limit. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-3. FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Selenium 1638 UG/L 100 1.60 100 Silver 1638 UG/L 10 0.0200 1.00 Thallium 1638 UG/L 10 0.00400 0.200 Zinc 1638 UG/L 100 20.9 50.0 
A-16 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-4. Duplicate of FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Classical Pollutants Ammonia As Nitrogen (NH3-N) 4500-NH3F MG/L 1 NP NP Nitrate/Nitrite (NO3-N + NO2-N) 4500NO3H MG/L 100 NP NP Total Kjeldahl Nitrogen (TKN) 4500-N,C MG/L 1 NP NP Biochemical Oxygen Demand (BOD) SM 5210B MG/L 4 NP NP Chloride 4500-CL-C MG/L 10 NP NP Sulfate D516-90 MG/L 50 NP NP Total Dissolved Solids (TDS) 2540 C MG/L 1 NP NP Total Phosphorus 365.3 MG/L 1 NP NP Total Suspended Solids (TSS) 2540 D MG/L 1 NP NP Routine Metals – Total Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 100 270 10,000 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 
A-17 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-4. Duplicate of FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 10 2.00 150 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Routine Metals – Dissolved Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 100 270 10,000 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 100 510 5,000 Chromium 200.7 UG/L 1 0.200 10.0 
A-18 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-4. Duplicate of FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Hexavalent Chromium D1687-92 UG/L 1 1.00 2.00 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 100 890 20,000 Manganese 200.7 UG/L 10 2.00 150 Mercury 245.1 UG/L 50 2.50 10.0 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Low-Level Metals – Total Antimony 1638 UG/L 10 0.0700 0.200 Arsenic 1638 UG/L 100 1.52 15.0 Cadmium 1638 UG/L 10 0.0100 1.00 Chromium 1638 UG/L 100 8.30 80.0 
A-19 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-4. Duplicate of FGD Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Copper 1638 UG/L 100 0.400 20.0 Lead 1638 UG/L 10 0.0100 0.500 Mercury 1631E UG/L 50 0.00940 0.0250 Nickel 1638 UG/L 100 1.30 100 Selenium 1638 UG/L 100 1.60 100 Silver 1638 UG/L 10 0.0200 1.00 Thallium 1638 UG/L 10 0.00400 0.200 Zinc 1638 UG/L 100 20.9 50.0 Low-Level Metals - Dissolved Antimony 1638 UG/L 10 0.0700 0.200 Arsenic 1638 UG/L 100 1.52 15.0 Cadmium 1638 UG/L 10 0.0100 1.00 Chromium 1638 UG/L 100 8.30 80.0 Hexavalent Chromium 1636 UG/L 5 1.75 2.50 Copper 1638 UG/L 100 0.400 20.0 Lead 1638 UG/L 10 0.0100 0.500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 100 1.30 100 Selenium 1638 UG/L 100 1.60 100 Silver 1638 UG/L 10 0.0200 1.00 Thallium 1638 UG/L 10 0.00400 0.200 Zinc 1638 UG/L 100 20.9 50.0 
A-20 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-5. Fly Ash Pond Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific 

Classical Pollutants Ammonia As Nitrogen (NH3-N) 4500-NH3F MG/L 1 NP NP Nitrate/Nitrite (NO3-N + NO2-N) 4500NO3H MG/L 20 NP NP Total Kjeldahl Nitrogen (TKN) 4500-N,C MG/L 1 NP NP Biochemical Oxygen Demand (BOD) SM 5210B MG/L 1 NP NP Chloride 4500-CL-C MG/L 1 NP NP Hexane Extractable Material (HEM) 1664A MG/L 1 NP NP Sulfate D516-90 MG/L 50 NP NP Total Dissolved Solids (TDS) 2540 C MG/L 1 NP NP Total Phosphorus 365.3 MG/L 1 NP NP Total Suspended Solids (TSS) 2540 D MG/L 1 NP NP Routine Metals – Total Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 1 2.70 100 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 1 5.10 50.0 Chromium 200.7 UG/L 1 0.200 10.0 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 
A-21 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-5. Fly Ash Pond Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific 

Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 1 8.90 200 Manganese 200.7 UG/L 1 0.200 15.0 Mercury 245.1 UG/L 1 0.0500 0.200 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Routine Metals – Dissolved Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 1 2.70 100 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 1 5.10 50.0 
A-22 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-5. Fly Ash Pond Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific 

Chromium 200.7 UG/L 1 0.200 10.0 Hexavalent Chromium D1687-92 UG/L 1 1.00 2.00 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 1 8.90 200 Manganese 200.7 UG/L 1 0.200 15.0 Mercury 245.1 UG/L 1 0.0500 0.200 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 10 405 5,000 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Low-Level Metals – Total Antimony 1638 UG/L 5 0.0350 0.100 Arsenic 1638 UG/L 5 0.0760 0.750 Cadmium 1638 UG/L 5 0.00500 0.500 
A-23 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). NP – Not provided. The sample-specific MDL and sample-specific RL are only provided for the metal analytes because EPA is present

metals that are quantified below the report limit. For this analyte, only values above the report limit are presented. If the analyte was nolimit, the report limit is presented in parentheses in the concentration column. 

Table A-5. Fly Ash Pond Effluent Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific 

Chromium 1638 UG/L 5 0.415 4.00 Copper 1638 UG/L 5 0.0200 1.00 Lead 1638 UG/L 5 0.00500 0.250 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 5 0.0650 5.00 Selenium 1638 UG/L 5 0.0800 5.00 Silver 1638 UG/L 5 0.0100 0.500 Thallium 1638 UG/L 5 0.00200 0.100 Zinc 1638 UG/L 5 1.05 2.50 Low-Level Metals - Dissolved Antimony 1638 UG/L 5 0.0350 0.100 Arsenic 1638 UG/L 5 0.0760 0.750 Cadmium 1638 UG/L 5 0.00500 0.500 Chromium 1638 UG/L 5 0.415 4.00 Hexavalent Chromium 1636 UG/L 5 1.75 2.50 Copper 1638 UG/L 5 0.0200 1.00 Lead 1638 UG/L 5 0.00500 0.250 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 5 0.0650 5.00 Selenium 1638 UG/L 5 0.0800 5.00 Silver 1638 UG/L 5 0.0100 0.500 Thallium 1638 UG/L 5 0.00200 0.100 Zinc 1638 UG/L 5 1.05 2.50 
a – Barium was detected in two equipment blanks for #73 silicone tubing at 0.490 ug/L and 0.476 ug/L. Because #73 

silicone tubing was used in this fabricated tubing set, the barium concentration is assumed to be 0.490 ug/L. 

ND – Not detected (number in parenthesis is the report limit). 

A-24 

Table A-6. Bottle Blank and Equipment Blank Analytical Data, Mitchell 

Analyte Method Process Units Concentration 

LDPE 250 ml Plastic Bottles – Bottle Blank (for low-level metals and low-level hexavalent chromium 

samples) 

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium EPA 1638 Dissolved UG/L ND (0.10) 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

Flint 125 ml Amber Glass Bottles – Bottle Blank (for speciation samples) 

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium EPA 1638 Dissolved UG/L ND (0.10) 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 
a – Barium was detected in two equipment blanks for #73 silicone tubing at 0.490 ug/L and 0.476 ug/L. Because #73 

silicone tubing was used in this fabricated tubing set, the barium concentration is assumed to be 0.490 ug/L. 

ND – Not detected (number in parenthesis is the report limit). 

A-25 

Table A-6. Bottle Blank and Equipment Blank Analytical Data, Mitchell 

Analyte Method Process Units Concentration 

Flint 250 ml Glass Bottles – Bottle Blank (for low-level mercury samples)

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

Capsule Filter – Equipment Blank (for dissolved low-level metals sample collection)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium EPA 1638 Dissolved UG/L ND (0.10) 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Mercury EPA 1631E Dissolved UG/L ND (0.00020) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

LDPE 2000 ml Plastic Bottles – Bottle Blank (for low-level metals field blank water)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium EPA 1638 Dissolved UG/L ND (0.10) 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 
a – Barium was detected in two equipment blanks for #73 silicone tubing at 0.490 ug/L and 0.476 ug/L. Because #73 

silicone tubing was used in this fabricated tubing set, the barium concentration is assumed to be 0.490 ug/L. 

ND – Not detected (number in parenthesis is the report limit). 

A-26 

Table A-6. Bottle Blank and Equipment Blank Analytical Data, Mitchell 

Analyte Method Process Units Concentration 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

LDPE 4000 ml Plastic Bottles – Bottle Blank (for low-level metals field blank water)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium EPA 1638 Dissolved UG/L ND (0.10) 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

Borosilicate 1000 ml Glass Bottles – Bottle Blank (for low-level mercury field blank water)

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

LDPE 10 L Composite Bottles – Bottle Blank (sample composite bottle for dissolved/filtration pump-off)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium EPA 1638 Dissolved UG/L ND (0.10) 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 
a – Barium was detected in two equipment blanks for #73 silicone tubing at 0.490 ug/L and 0.476 ug/L. Because #73 

silicone tubing was used in this fabricated tubing set, the barium concentration is assumed to be 0.490 ug/L. 

ND – Not detected (number in parenthesis is the report limit). 

A-27 

Table A-6. Bottle Blank and Equipment Blank Analytical Data, Mitchell 

Analyte Method Process Units Concentration 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

Pump-Off Tubing Set – Equipment Blank (Three feet of Teflon® tubing, 10 feet of #73 silicone tubing, Ysplitter, and two pieces of five feet of #24 silicone tubing for dissolved sample collection for low-level metals)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium a EPA 1638 Dissolved UG/L ND (0.10) 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

C-Flex Tubing Set – Equipment Blank (five feet of #73 silicone tubing, Y-splitter, and two pieces of five feet 

of #24 silicone tubing for sample collection for low-level mercury and low-level metals from sample taps)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium a EPA 1638 Dissolved UG/L 0.490 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 
a – Barium was detected in two equipment blanks for #73 silicone tubing at 0.490 ug/L and 0.476 ug/L. Because #73 

silicone tubing was used in this fabricated tubing set, the barium concentration is assumed to be 0.490 ug/L. 

ND – Not detected (number in parenthesis is the report limit). 

A-28 

Table A-6. Bottle Blank and Equipment Blank Analytical Data, Mitchell 

Analyte Method Process Units Concentration 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

C-Flex Tubing Set (alternate) – Equipment Blank (five feet of #73 silicone tubing attached to five feet of #24 

silicone tubing for alternative sample collection for low-level mercury and low-level metals from sample 

taps)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium a EPA 1638 Dissolved UG/L 0.490 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

Tubing Set – Equipment Blank (25 feet of Teflon® tubing, 10 feet of #73 silicone tubing, Y-splitter, two 

pieces of five feet of #24 silicone tubing for sample collection for low-level mercury and low-level metals 

from fly ash pond effluent)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium a EPA 1638 Dissolved UG/L 0.490 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 
a – Barium was detected in two equipment blanks for #73 silicone tubing at 0.490 ug/L and 0.476 ug/L. Because #73 

silicone tubing was used in this fabricated tubing set, the barium concentration is assumed to be 0.490 ug/L. 

ND – Not detected (number in parenthesis is the report limit). 

A-29 

Table A-6. Bottle Blank and Equipment Blank Analytical Data, Mitchell 

Analyte Method Process Units Concentration 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 

Funnel Assembly Set – Equipment Blank (Plastic funnel attached to two feet of #73 silicone tubing, Ysplitter, and two pieces of five feet of #24 silicone tubing for field blank sample collection for low-level total 

mercury and low-level total metals at the FGD influent, FGD primary clarifier overflow, and FGD effluent)

Aluminum EPA 1638 Dissolved UG/L ND (2.0) 

Antimony EPA 1638 Dissolved UG/L ND (0.50) 

Arsenic EPA 1638 Dissolved UG/L ND (0.50) 

Barium a EPA 1638 Dissolved UG/L 0.490 

Beryllium EPA 1638 Dissolved UG/L ND (0.10) 

Cadmium EPA 1638 Dissolved UG/L ND (0.10) 

Chromium EPA 1638 Dissolved UG/L ND (1.0) 

Cobalt EPA 1638 Dissolved UG/L ND (0.10) 

Copper EPA 1638 Dissolved UG/L ND (0.30) 

Lead EPA 1638 Dissolved UG/L ND (0.050) 

Manganese EPA 1638 Dissolved UG/L ND (0.50) 

Mercury EPA 1631E Total Recoverable UG/L ND (0.00020) 

Molybdenum EPA 1638 Dissolved UG/L ND (0.50) 

Nickel EPA 1638 Dissolved UG/L ND (0.50) 

Selenium EPA 1638 Dissolved UG/L ND (2.0) 

Silver EPA 1638 Dissolved UG/L ND (0.10) 

Thallium EPA 1638 Dissolved UG/L ND (0.050) 

Vanadium EPA 1638 Dissolved UG/L ND (1.0) 

Zinc EPA 1638 Dissolved UG/L ND (0.50) 
A-30 

Table A-7. FGD Influent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Low-Level Metals – Total Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 Low-Level Metals - Dissolved Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 
A-31 

Table A-8. FGD Primary Clarifier Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific R

Low-Level Metals – Total Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 Low-Level Metals – Dissolved Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Hexavalent Chromium 1636 UG/L 5 1.75 2.50 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 
A-32 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-9. FGD Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Routine Metals – Total Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 1 2.70 100 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 1 5.10 50.0 Chromium 200.7 UG/L 1 0.200 10.0 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 1 8.90 200 Manganese 200.7 UG/L 1 0.200 15.0 Mercury 245.1 UG/L 1 0.0500 0.200 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 1 40.5 500 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 
A-33 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-9. FGD Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Routine Metals – Dissolved Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 1 2.70 100 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 1 5.10 50.0 Chromium 200.7 UG/L 1 0.200 10.0 Hexavalent Chromium D1687-92 UG/L 1 1.00 2.00 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 1 8.90 200 Manganese 200.7 UG/L 1 0.200 15.0 Mercury 245.1 UG/L 1 0.0500 0.200 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 1 40.5 500 Thallium 200.7 UG/L 1 0.500 10.0 
A-34 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-9. FGD Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Low-Level Metals – Total Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 Low-Level Metals - Dissolved Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Hexavalent Chromium 1636 UG/L 5 1.75 2.50 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 
A-35 

J – Result measured above the MDL, but less than the reporting limit. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-9. FGD Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 
A-36 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-10. Fly Ash Pond Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Routine Metals – Total Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 1 2.70 100 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 1 5.10 50.0 Chromium 200.7 UG/L 1 0.200 10.0 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 1 8.90 200 Manganese 200.7 UG/L 1 0.200 15.0 Mercury 245.1 UG/L 1 0.0500 0.200 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 1 40.5 500 Thallium 200.7 UG/L 1 0.500 10.0 Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 
A-37 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-10. Fly Ash Pond Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Routine Metals – Dissolved Aluminum 200.7 UG/L 1 10.6 50.0 Antimony 200.7 UG/L 1 0.700 20.0 Arsenic 200.7 UG/L 1 0.500 10.0 Barium 200.7 UG/L 1 0.100 2.00 Beryllium 200.7 UG/L 1 0.500 5.00 Boron 200.7 UG/L 1 2.70 100 Cadmium 200.7 UG/L 1 0.100 5.00 Calcium 200.7 UG/L 1 5.10 50.0 Chromium 200.7 UG/L 1 0.200 10.0 Hexavalent Chromium D1687-92 UG/L 1 1.00 2.00 Cobalt 200.7 UG/L 1 0.600 50.0 Copper 200.7 UG/L 1 0.200 10.0 Iron 200.7 UG/L 1 5.40 100 Lead 200.7 UG/L 1 0.700 50.0 Magnesium 200.7 UG/L 1 8.90 200 Manganese 200.7 UG/L 1 0.200 15.0 Mercury 245.1 UG/L 1 0.0500 0.200 Molybdenum 200.7 UG/L 1 0.200 10.0 Nickel 200.7 UG/L 1 1.10 50.0 Selenium 200.7 UG/L 1 0.600 5.00 Silver 200.7 UG/L 1 0.400 20.0 Sodium 200.7 UG/L 1 40.5 500 Thallium 200.7 UG/L 1 0.500 10.0 
A-38 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-10. Fly Ash Pond Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Tin 200.7 UG/L 1 0.400 30.0 Titanium 200.7 UG/L 1 0.200 10.0 Vanadium 200.7 UG/L 1 0.600 20.0 Yttrium 200.7 UG/L 1 0.200 5.00 Zinc 200.7 UG/L 1 0.200 10.0 Low-Level Metals – Total Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 Mercury 1631E UG/L 1 0.000188 0.000500 Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 Low-Level Metals - Dissolved Antimony 1638 UG/L 1 0.00700 0.0200 Arsenic 1638 UG/L 1 0.0152 0.150 Cadmium 1638 UG/L 1 0.00100 0.100 Chromium 1638 UG/L 1 0.0830 0.800 Hexavalent Chromium 1636 UG/L 5 1.75 2.50 Copper 1638 UG/L 1 0.00400 0.200 Lead 1638 UG/L 1 0.00100 0.0500 
A-39 

J – Result measured above the MDL, but less than the reporting limit. L – Sample result between 5x and 10x blank result. U – Result below the MDL. Number shown in parentheses is the reporting limit). ND – Not detected (number in parenthesis is the report limit). 

Table A-10. Fly Ash Pond Effluent Field Blank Analytical Data, Mitchell 

Analyte Method Unit Dilution Factor Sample-Specific MDL Sample-Specific RL 

Nickel 1638 UG/L 1 0.0130 1.00 Selenium 1638 UG/L 1 0.0160 1.00 Silver 1638 UG/L 1 0.00200 0.100 Thallium 1638 UG/L 1 0.000400 0.0200 Zinc 1638 UG/L 1 0.209 0.500 
Appendix B 

ANALYTICAL DATA FOR METALS, FGD WASTEWATER AND ASH POND 
B-1 

J - Result measured above the MDL, but less than the reporting limit. L - Sample result between 5x and 10x blank result. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. U - Result below the MDL. Number shown in parentheses is the reporting limit). NA – Not analyzed. ND – Not detected (number in parenthesis is the report limit). Note: Results shown are not paired samples. See Section 4.2. 

Table B-1. Analytical Results for Metals in the FGD Wastewater Treatment System, Mitc

FGD Influent (SP-1) 

FGD Primary Clarifier 

Effluent (SP-2) Original FGD Effluent (SP-3) 

D

Analyte Method Unit Total Dissolved Total Dissolved Total Dissolved 

Routine Metals Aluminum 200.7 UG/L 17,900 ND (50.0) U ND (50.0) U ND (50.0) U ND (50.0) U ND (50.0) U ND Antimony 200.7 UG/L 28.7 15.8 J 12.0 J 10.2 J 14.1 J 13.3 J Arsenic 200.7 UG/L 72.5 6.79 J 10.0 3.25 J 10.6 3.15 J 8Barium 200.7 UG/L 588 488 457 401 434 390 Beryllium 200.7 UG/L 8.04 6.02 4.73 J 4.31 J 4.48 J 4.29 J 4Boron 200.7 UG/L 229,000 232,000 244,000 217,000 210,000 198,000 20Cadmium 200.7 UG/L 19.7 1.89 J 1.51 J 1.18 J 1.20 J 1.09 J ND Calcium 200.7 UG/L 3,030,000 2,350,000 2,650,000 2,450,000 2,390,000 2,250,000 2,3Chromium 200.7 UG/L 70.7 ND (10.0) U 0.418 J ND (10.0) U ND (10.0) U ND (10.0) U ND Hexavalent Chromium 

D1687-92 UG/L NA 5.00 NA 15.0 NA 10.0 

Cobalt 200.7 UG/L 68.0 41.7 J 7.07 J 5.89 J 5.75 J 5.30 J 5Copper 200.7 UG/L 164 7.31 J 16.6 12.0 16.8 13.9 Iron 200.7 UG/L 60,600 ND (100) U 971 57.4 J 331 82.0 J Lead 200.7 UG/L 103 ND (50.0) U 3.86 J ND (50.0) U 4.92 J ND (50.0) U 3Magnesium 200.7 UG/L 1,470,000 1,370,000 1,480,000 1,300,000 1,290,000 1,220,000 1,2Manganese 200.7 UG/L 28,800 27,900 7,380 7,000 4,510 4,350 4Mercury 245.1 UG/L 67.5 ND (10.0) U ND (10.0) U ND (10.0) U ND (10.0) U ND (10.0) U ND Molybdenum 200.7 UG/L 65.0 22.2 24.5 21.9 23.3 21.1 2Nickel 200.7 UG/L 554 355 55.5 46.6 J 35.1 J 31.1 J 3Selenium 200.7 UG/L 2,130 46.9 121 82.3 85.1 R 71.2 8Silver 200.7 UG/L ND (20.0) U ND (20.0) U ND (20.0) U ND (20.0) U ND (20.0) U ND (20.0) U ND 
B-2 

J - Result measured above the MDL, but less than the reporting limit. L - Sample result between 5x and 10x blank result. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. U - Result below the MDL. Number shown in parentheses is the reporting limit). NA – Not analyzed. ND – Not detected (number in parenthesis is the report limit). Note: Results shown are not paired samples. See Section 4.2. 

Table B-1. Analytical Results for Metals in the FGD Wastewater Treatment System, Mitc

FGD Influent (SP-1) 

FGD Primary Clarifier 

Effluent (SP-2) Original FGD Effluent (SP-3) 

D

Analyte Method Unit Total Dissolved Total Dissolved Total Dissolved 

Sodium 200.7 UG/L 314,000 324,000 315,000 305,000 312,000 302,000 29Thallium 200.7 UG/L ND (10.0) U ND (10.0) U ND (10.0) U ND (10.0) U ND (10.0) U ND (10.0) U ND Tin 200.7 UG/L 4.34 J ND (30.0) U 0.694 J ND (30.0) U 0.947 J ND (30.0) U Titanium 200.7 UG/L 377 ND (10.0) U 10.5 ND (10.0) U 10.2 ND (10.0) U 6Vanadium 200.7 UG/L 203 ND (20.0) U 5.65 J ND (20.0) U ND (20.0) U ND (20.0) U ND Yttrium 200.7 UG/L 64.9 2.34 J 2.73 J 1.48 J 1.62 J 1.48 J Zinc 200.7 UG/L 885 87.8 46.4 ND (10.0) U 15.4 ND (10.0) U 3Low-Level Metals Antimony 1638 UG/L 9.23 1.97 2.00 1.75 ND (1.00) U 1.60 Arsenic 1638 UG/L 59.9 20.2 12.0 J 20.9 24.3 J 19.5 T 2Cadmium 1638 UG/L 5.28 0.446 J 0.404 J 0.374 J 0.903 J 0.334 J 0Chromium 1638 UG/L 176 L ND (80.0) U 32.8 J 35.3 J 69.7 J 35.8 J 3Hexavalent Chromium 

1636 UG/L NA NA NA 1.78 J NA 2.21 J 

Copper 1638 UG/L 139 2.86 J 6.22 J 8.54 J 10.1 J 10.2 J Lead 1638 UG/L 68.1 ND (0.500) U 2.01 0.0276 J 0.791 J 0.0287 J 0Mercury 1631E UG/L 138 0.0111 2.38 0.0190 0.809 0.166 0Nickel 1638 UG/L 650 433 63.4 J 123 102 J 103 Selenium 1638 UG/L 1,990 443 234 472 417 T 413 Silver 1638 UG/L 0.730 J ND (1.00) U ND (1.00) U ND (1.00) U ND (5.00) U ND (1.00) U 0Thallium 1638 UG/L 6.33 4.47 4.08 4.11 4.01 3.96 3Zinc 1638 UG/L 730 160 71.0 34.9 J ND (100) U ND (50.0) U 6
J – Result measured above the MDL, but less than the reporting limit. 

L – Sample result between 5x and 10x blank result. 

ND – Not detected (number in parenthesis is the report limit). 

U – Result below the MDL. (Number shown in parentheses is the reporting limit). 

B-3 

Table B-2. Analytical Results for Metals in the Fly Ash Pond Effluent, Mitchell 

Fly Ash Pond Effluent (SP-4) 

Analyte Method Unit Total Dissolved 

Routine Metals 

Aluminum 200.7 UG/L 404 241 

Antimony 200.7 UG/L 24.6 23.9 

Arsenic 200.7 UG/L 150 138 

Barium 200.7 UG/L 133 128 

Beryllium 200.7 UG/L ND (5.00) U ND (5.00) U 

Boron 200.7 UG/L 2,350 2,290 

Cadmium 200.7 UG/L ND (5.00) U ND (5.00) U 

Calcium 200.7 UG/L 115,000 113,000 

Chromium 200.7 UG/L 15.9 14.1 

Hexavalent Chromium D1687-92 UG/L NA 7.00 

Cobalt 200.7 UG/L 1.36 J 1.12 J 

Copper 200.7 UG/L 4.60 J 3.19 J 

Iron 200.7 UG/L 85.0 J ND (100) U 

Lead 200.7 UG/L ND (50.0) U ND (50.0) U 

Magnesium 200.7 UG/L 21,000 20,300 

Manganese 200.7 UG/L 13.9 J 2.94 J 

Mercury 245.1 UG/L ND (0.200) U ND (0.200) U 

Molybdenum 200.7 UG/L 359 330 

Nickel 200.7 UG/L 7.41 J 6.37 J 

Selenium 200.7 UG/L 177 162 

Silver 200.7 UG/L ND (20.0) U ND (20.0) U 

Sodium 200.7 UG/L 526,000 514,000 

Thallium 200.7 UG/L ND (10.0) U ND (10.0) U 

Tin 200.7 UG/L ND (30.0) U ND (30.0) U 

Titanium 200.7 UG/L 6.61 J ND (10.0) U 

Vanadium 200.7 UG/L 110 108 

Yttrium 200.7 UG/L ND (5.00) U ND (5.00) U 

Zinc 200.7 UG/L ND (10.0) U ND (10.0) U 

Low-Level Metals – Total 

Antimony 1638 UG/L 25.8 22.5 

Arsenic 1638 UG/L 142 131 

Cadmium 1638 UG/L 1.32 1.17 

Chromium 1638 UG/L 20.4 16.0 

Hexavalent Chromium 1636 UG/L NA 17.4 

Copper 1638 UG/L 5.47 4.54 

Lead 1638 UG/L 0.580 0.218 J 
J – Result measured above the MDL, but less than the reporting limit. 

L – Sample result between 5x and 10x blank result. 

ND – Not detected (number in parenthesis is the report limit). 

U – Result below the MDL. (Number shown in parentheses is the reporting limit). 

B-4 

Table B-2. Analytical Results for Metals in the Fly Ash Pond Effluent, Mitchell 

Fly Ash Pond Effluent (SP-4) 

Analyte Method Unit Total Dissolved 

Mercury 1631E UG/L 0.00212 0.000388 J 

Nickel 1638 UG/L 11.0 9.57 

Selenium 1638 UG/L 191 161 

Silver 1638 UG/L 0.0468 J 0.0161 J 

Thallium 1638 UG/L 1.72 1.42 

Zinc 1638 UG/L 10.1 9.51 
Appendix C 

DATA REVIEW NARRATIVES 
Computer Sciences Corporation 

www.csc.com 

6101 Stevenson Avenue 

Alexandria, Virginia 22304 

703.461.2000 Fax 703.461.2020 

MEMORANDUM

DATE: January 4, 2007 

TO: Ron Jordan, Project Officer 

 EPA EAD 

FROM: Sara Clark, Quality Assurance Chemist 

Computer Sciences Corporation 

SUBJECT: Data Review Narrative for Classical Analyses for the Steam Electric Power Study, 

Episode 6550 

OVERVIEW

Under EPA Contract Number 68-C-03-058, ProChem Analytical, Inc. submitted classical wet chemistry 

data for seven samples in Episode 6550. Sample 70620, identified as the FGD influent, was expected to 

contain a significant and variable particulate concentration. EPA and industry representatives were 

concerned that the variable nature of the sample would 1) complicate the collection of a representative 

sample for both EPA and industry analyses and 2) lead to analytical interferences. Therefore, for some 

classical analyses, the laboratory was directed by EPA to separate the FGD influent sample into an 

aqueous-phase and a solid-phase and analyze each if the total solids of the original sample was greater or 

equal to 1%. However, because the total solids for the FGD influent sample was < 1%, the sample was 

not phase separated. 

Table 1 provides a complete listing of samples, matrices, descriptions, sampling dates, and the required 

analytes. 

Table 1 - Sample Identifiers, Descriptions, Sampling Dates and Analytes 

EPA Sample # Matrix Sample Description Sampling 

Date Analytes

70620 Aqueous SP-1 FGD Influent 10/17/07 

BOD (SM 5210B), HEM (1664A), 

SGT-HEM (1664A), Hexavalent 

Chromium (ASTM D1687-92), 

TSS (SM 2540D), TDS (SM 

2540C), Chloride (SM 4500-Cl-

 C), 

Sulfate (ASTM D516-90), TKN 

(SM 4500-N C), Ammonia (SM 

4500-NH3 F), Total Phosphorus 

(365.3), and Nitrate/Nitrite (SM 

4500-NO3 H) 

70621 Aqueous SP-2 FGD Primary 

Clarifier 10/17/07 

BOD (SM 5210B), HEM (1664A), 

SGT-HEM (1664A), Hexavalent 

Chromium (ASTM D1687-92), 

TSS (SM 2540D), TDS (SM 

2540C), Chloride (SM 4500-Cl-

 C), 

Sulfate (ASTM D516-90), TKN 

(SM 4500-N C), Ammonia (SM 

4500-NH3 F), Total Phosphorus 

(365.3), and Nitrate/Nitrite (SM 

4500-NO3 H) 
2

Table 1 - Sample Identifiers, Descriptions, Sampling Dates and Analytes 

EPA Sample # Matrix Sample Description Sampling 

Date Analytes

70622 Aqueous SP-3 FGD Effluent 10/17/07 

BOD (SM 5210B), HEM (1664A), 

SGT-HEM (1664A), Hexavalent 

Chromium (ASTM D1687-92), 

TSS (SM 2540D), TDS (SM 

2540C), Chloride (SM 4500-Cl- C), 

Sulfate (ASTM D516-90), TKN 

(SM 4500-N C), Ammonia (SM 

4500-NH3 F), Total Phosphorus 

(365.3), and Nitrate/Nitrite (SM 

4500-NO3 H) 

70623 Aqueous SP-4 Fly Ash Pond 

Effluent 10/18/07 

BOD (SM 5210B), HEM (1664A), 

SGT-HEM (1664A), Hexavalent 

Chromium (ASTM D1687-92), 

TSS (SM 2540D), TDS (SM 

2540C), Chloride (SM 4500-Cl-

 C), 

Sulfate (ASTM D516-90), TKN 

(SM 4500-N C), Ammonia (SM 

4500-NH3 F), Total Phosphorus 

(365.3), and Nitrate/Nitrite (SM 

4500-NO3 H) 

70624 Aqueous SP-5 FGD Effluent 

Duplicate 10/17/07 

BOD (SM 5210B), Hexavalent 

Chromium (ASTM D1687-92), 

TSS (SM 2540D), TDS (SM 

2540C), Chloride (SM 4500-Cl-

 C), 

Sulfate (ASTM D516-90), TKN 

(SM 4500-N C), Ammonia (SM 

4500-NH3 F), Total Phosphorus 

(365.3), and Nitrate/Nitrite (SM 

4500-NO3 H) 

70627 Aqueous SP-8 FGD Effluent 

Field Blank 10/17/07 Hexavalent Chromium (ASTM 

D1687-92) 

70628 Aqueous SP-9 Fly Ash Pond 

Effluent Field Blank 10/18/07 Hexavalent Chromium (ASTM 

D1687-92) 

These data have been reviewed in accordance with CSC’s Data Review Guidelines for Classical Wet 

Chemistry Analyses (DR-02 Revision 2, September 1, 2007) and with the specifications listed in the 

contract. All data are of acceptable quality with the qualifiers described below and detailed in the data 

review summary table (Table 2). 

SUMMARY

All samples were analyzed within the contract-specified holding times for all classical wet chemistry 

parameters specified in the sampling and analysis plan. The calibration and continuing calibration 

standards were successfully analyzed. Laboratory blanks were performed for each analysis, and there was 

no contamination detected above the laboratory reporting limits, with the exceptions described below. An 

effluent and influent field blank were analyzed for hexavalent chromium and the analyte was not detected 

above the minimum level (ML) in either blank. The QC samples, including the ongoing precision and 

recovery sample (OPR) and matrix spike/matrix spike duplicate (MS/MSD) samples, demonstrated that 

laboratory performance for these analyses was acceptable, with the exceptions described below. The 

MS/MSDs analyses were performed on sample 70622. 
3

DATA ISSUES 

Nitrate and Nitrite 

Nitrate/Nitrite was detected in the laboratory calibration blank at a concentration of 0.023 mg/L, which is 

greater than the ML of 0.01 mg/L. The Nitrate/Nitrite results for the associated samples are greater than 

ten times the blank result. Because the presence of the analyte in the blank does not adversely affect the 

data when the result is greater than ten times the associated blank, the Nitrate/Nitrite data are acceptable 

without qualification for all associated samples. 

SGT-HEM 

The MS/MSD relative percent difference (RPD) for sample 70622 was 75%, which is above the methodspecified acceptance criteria of 34%. The MSD recovery (129%) was acceptable, but the MS recovery 

(59%) was below method-specified acceptance criteria (64-132%). However, because SGT-HEM was 

not detected in sample 70622, CSC recommends that the result be included in the database without 

qualification. 

TKN

TKN was detected in the laboratory preparation blank at a concentration of 0.24 mg/L, which is greater 

than the ML of 0.1 mg/L. The TKN results for the associated samples 70620, 70621, 70622, and 70624 

are greater than ten times the blank result. Because the presence of the analyte in the blank does not 

adversely affect the data when the result is greater than ten times the associated blank, these TKN sample 

results are acceptable without qualification. The TKN result for sample 70623 is less than five times the 

blank result. When the sample result is less than five times the blank result, there are no means by which 

to ascertain whether or not the presence of the analyte may be attributed to contamination. Therefore, 

CSC recommends that the TKN result for sample 70623 be reported in the database as a not detected at 

the ML, adjusted for sample size, dilution, and matrices. 

BOD 

Three of the four GGA standard recoveries (83%, 75%, and 81%) were below method-specified 

acceptance criteria of 84-116%. CSC considers the BOD results for the associated samples (70620, 

70621, 70622, 70623, and 70624) to be of acceptable quality, but may be minimum values. 

Field Duplicate 

The RPD for field duplicates 70622 and 70624 (FGD Effluent and FGD Effluent Field Duplicate) total 

suspended solids results is 29%. CSC does not routinely qualify results based on field duplicate RPD 

failure. 

TECHNICAL NOTES: 

Although HEM/SGT-HEM analyses were requested for sample 70623, SGT-HEM analysis was not 

performed because HEM was not detected in this sample. 
4

If you have any questions regarding the analyses of these samples or the review of these data, please 

contact Barbara Beard by telephone at (703) 461-2154, by facsimile at (703) 461-8056, or by email at 

bbeard2@csc.com. 

cc: Brian D’Amico, EPA Beverly Randolph, EPA 

Marla Smith, EPA Nelson Andrews, EPA 

Brian Englert, EPA Deb Bartram, ERG 

TJ Finseth, ERG Lynn Walters, CSC 

Barbara Beard, CSC 

Table 2

Data Review Summary Table 

Episode: 6550 Analysis: Classicals 

Industry: Steam Electric Power Study Reviewer: Sara Clark 

Sample Analyte Action Reason CSC Qual Level

70623 TKN 

Report in 

database as 

non-detect 

Sample result <5x 

blank result NA 

70620 

70621 

70622 

70623 

70624 

BOD Minimum value 

GGA standard 

recovery below 

method-specified 

criteria 

NA 

See Database 

NA= Not Applicable 
Computer Sciences Corporation 

www.csc.com

MEMORANDUM 

DATE: January 09, 2008 

TO: Ron Jordan, Work Assignment Manager 

 EPA EAD 

FROM: Lisa White, Quality Assurance Chemist 

Computer Sciences Corporation 

SUBJECT: Data Review Narrative for Total and Dissolved Metals Analyses for the Steam Electric 

Study, Episode 6550 

Under EPA contract number 68-C-03-044, ProChem Analytical submitted data for the analysis of metals 

by EPA Method 200.7 and mercury by Method 245.1. Seven aqueous samples in this episode were 

analyzed for total and dissolved metals. Because influent samples for this study were expected to be 

highly variable in solids content, the laboratory was directed to obtain results for the solid phase if the 

total solids of the original sample were greater or equal to 1%. However, because the total solids for the 

FGD influent sample were < 1%, the sample was not phase separated. 

Table 1 provides a list of samples, matrices, descriptions, sampling dates, phases, and the required 

analytical methods. 

Table 1 - Sample Identifiers, Descriptions, Sampling Dates, and Analysis Methods 

EPA 

Sample # Matrix Sample Description Sampling

Date Phase Method

Total 

70620 Aqueous 

SP-1 

FGD Influent

10/17/07 

Dissolved 

200.7, 245.1

Total 

70621 Aqueous 

SP-2 

FGD Clarifier 

Effluent

10/17/07 Dissolved 200.7, 245.1

Total 

70622 Aqueous 

SP-3 

FGD Effluent 

10/17/07 

Dissolved 

200.7, 245.1

Total 

70623 Aqueous 

SP-4 

Fly Ash Pond

Effluent

10/18/07 Dissolved 200.7, 245.1

Total 

70624 Aqueous 

SP-5 

FGD Effluent 

Duplicate 

10/17/07 Dissolved 200.7, 245.1

Total 

70627 Aqueous 

SP-8 

FGD Effluent Field 

Blank 

10/17/07 Dissolved 200.7, 245.1

Total 

70628 Aqueous 

SP-9 

Fly Ash Pond

Effluent Field Blank 

10/18/07 Dissolved 200.7, 245.1

NA = Not Applicable 

6101 Stevenson Avenue 

Alexandria, Virginia 22304 

703.461.2000 Fax 703.461.2020
These data have been reviewed in accordance with CSC's Data Review Guidelines for Metals Analyses 

(November 2004); the EAD contract; and with the specifications listed in EPA Methods 200.7 (Rev. 5.0). 

All data are of acceptable quality with the qualifiers described below and detailed in the data review 

summary table (Table 2). 

 

SUMMARY 

All samples were successfully analyzed within the method-specified holding times. The method detection

limit (MDL) studies and initial precision and recovery (IPR) analyses were performed and met the 

contract-specified criteria. Calibration curves, calibration standards, and calibration blanks were 

successfully analyzed. Preparation blanks performed for each analysis detected no contamination above 

the laboratory’s reporting limits. QC samples, including ongoing precision and recovery (OPR) samples, 

matrix spike (MS) samples, matrix spike duplicate (MSD) samples, and laboratory serial dilution samples 

demonstrated that laboratory performance for these analyses was acceptable, with the exception of the 

issues described below and summarized in Table 2. The MS/MSD analyses were performed on samples 

70622 and 70623. 

DATA ISSUES

Method and Analytical Blanks

Several analytes were detected in the preparation blanks (PBs), initial calibration blanks (ICBs), and 

continuing calibration blanks (CCBs) associated with the samples in this episode at concentrations greater 

than the respective MDLs, but less than the method-specified MLs. The data quality is affected as 

follows: 

 • Sample Results Greater than Five Times but Less than Ten Times Blank Results: CSC considers 

these results to be of acceptable quality, but they may be maximum values. The result for total 

calcium in sample 70628 falls under this category. This instance is detailed in Table 2. 

• Sample Results Greater than Ten Times Blank Results or Analyte Not Detected in Sample: CSC 

does not consider the presence of the analyte in the blank to adversely affect the data in cases 

where the sample results are greater than ten times the associated blank results or where the 

analyte is not detected in associated samples. Several samples fall into this category, but because 

CSC considers such data to be acceptable without qualification, these cases do not merit further 

detail. 

Matrix Performance 

MS/MSD and Serial Dilution analyses were performed on samples 70622 and 70623. 

The percent recovery for total selenium (138%) in the MSD for sample 70622 was above the contractspecified criteria of 125%. CSC recommends that the result for total selenium in sample 70622 be 

considered of acceptable quality, but may be a maximum value. 

 

The serial dilution percent differences for several analytes were above the contract-specified criteria of 

10%. These instances are as follows: total titanium (13%) and zinc (100%) in sample 70622; dissolved 

antimony (15%) in sample 70623; and total aluminum (28%) in sample 70623. In these cases, MS/MSD 

percent recoveries were within acceptable criteria. CSC recommends that the results for these analytes be 

included in the database without qualification. 

2 
3

Field Duplicates 

The relative percent difference (RPD) between the total zinc results for samples 70622 (FGD Effluent) 

and 70624 (FGD Effluent Duplicate) was 79%. CSC does not routinely qualify results based on field 

duplicate RPD. 

Field Blanks 

Several analytes were detected at concentrations above the contract-specified minimum levels. These 

instances are summarized as follows: 

• Boron and magnesium were detected in the dissolved FGD Effluent Field Blank sample 70627; 

• Calcium was detected in the total FGD Effluent Field Blank sample 70627; 

• Calcium was detected in the total Fly Ash Pond Effluent Field Blank sample 70628. 

Per EPA request, CSC does not qualify sample results based on field blank results. 

TECHNICAL NOTES 

Minimum Levels 

Due to severe matrix interferences, the laboratory analyzed several samples at 50-fold dilutions for 

mercury. Total and dissolved mercury results for samples 70620, 70621, 70622, and 70624 were affected 

by this dilution. Reporting limits for these results have been adjusted accordingly. 

If you have any questions regarding the analyses of these samples or the review of these data, please 

contact Barbara Beard by telephone at (703) 461-2154, by facsimile at (703) 461-8056, or by email at 

bbeard2@csc.com.

cc: Brian D’Amico, EPA Deb Bartram, ERG 

Beverly Randolph, EPA TJ Finseth, ERG 

Marla Smith, EPA Lynn Watlers, CSC 

Nelson Andrews, EPA Barbara Beard, CSC 

Brian Englert, EPA 

 
4

Table 2 

Data Review Summary Table

Episode: 6550 Analysis: Metals

Industry: Steam Electric Study Reviewer: Lisa White 

Sample Analyte Action Reason CSC Qual Level

70628 Total Ca Maximum Value Sample result >5x but 

<10x blank result NA See Database 

70622 Total Se Maximum Value MSD %R above contractspecified criteria NA See Database 

NA= Not applicable 

 
Computer Sciences Corporation 

www.csc.com 

6101 Stevenson Avenue 

Alexandria, Virginia 22304 

703.461.2000 Fax 703.461.2020 

MEMORANDUM 

DATE: December 20, 2007 

TO: Ron Jordan, Work Assignment Manager 

 EPA EAD 

FROM: Cris Robinson, Quality Assurance Chemist 

Computer Sciences Corporation 

SUBJECT: Data Review Narrative for Trace Metals Analyses for the Steam Electric Study, Episode 

6550 

Under EPA contract number 68-C-03-046, Battelle Marine Sciences submitted data for the analyses of 

trace metals. All nine aqueous samples in this episode were analyzed for total mercury (Hg) by Method 

1631E and total metals including antimony (Sb), arsenic (As), cadmium (Cd), copper (Cu), chromium 

(Cr), lead (Pb), nickel (Ni), selenium (Se), silver (Ag), thallium (Tl), and zinc (Zn) by Method 1638 (ICPMS). Seven of the nine (FGD and Fly Ash Pond Effluents; FGD Clarifier Effluent; FGD Effluent 

Duplicate; FGD Effluent, Fly Ash Pond Effluent, and FGD Clarifier Field Blanks) were analyzed for 

hexavalent chromium by Method 1636. Several samples were analyzed for dissolved metals as well as 

total. Because FGD influent samples for this study were expected to be highly variable in solids content, 

EPA chose to obtain results for this phase as well. The solid-phase results for sample 70620 were not 

directly analyzed, but rather calculated from total, dissolved, and TSS results.

Table 1 - Sample Identifiers, Descriptions, Sampling Dates, and Analysis Methods 

EPA Sample 

# Matrix Sample Description Sampling Date Phase Methods

Total 1631E, 

1638 

10/17/07 

Dissolved 1631E, 

1638 70620 Aqueous SP-1 FGD Influent 

NA Calculated 

Solid 

1631E, 

1638 

Total 1631E, 

1638 

Dissolved 1631E, 

1638 

70621 Aqueous SP-2 FGD Clarifier Effluent 10/17/07 

NA 1636 

Total 1631E, 

1638 

Dissolved 1631E, 

1638 

70622 Aqueous SP-3 FGD Effluent 10/17/07 

NA 1636 

 

 
2 

Table 1 - Sample Identifiers, Descriptions, Sampling Dates, and Analysis Methods 

EPA Sample 

# Matrix Sample Description Sampling Date Phase Methods

Total 1631E, 

1638 

Dissolved 1631E, 

1638 

70623 Aqueous SP-4 Fly Ash Pond Effluent 10/18/07 

NA 1636 

Total 1631E, 

1638 

Dissolved 1631E, 

1638 

70624 Aqueous SP-5 FGD Effluent Duplicate 10/17/07 

NA 1636 

Total 1631E, 

1638 70625 Aqueous SP-6 FGD Influent Field Blank 10/17/07 

Dissolved 1638 

Total 1631E, 

1638 

Dissolved 1638 70626 Aqueous SP-7 FGD Clarifier Effluent Field 

Blank 10/17/07 

NA 1636 

Total 1631E, 

1638 

Dissolved 1638 70627 Aqueous SP-8 FGD Effluent Field Blank 10/17/07 

NA 1636 

Total 1631E, 

1638 

Dissolved 1638 70628 Aqueous SP-9 Fly Ash Pond Effluent Field 

Blank 10/18/07 

NA 1636 

NA = Not applicable

These data have been reviewed in accordance with CSC's Data Review Guidelines for Metals Analyses 

(November 2004), with the EAD contract, and with the specifications listed in EPA Methods 1631E (Aug 

2002), 1636 (Jan 1996), and 1638 (Jan 1996). All data are of acceptable quality with the qualifiers 

described below and detailed in the data review summary table (Table 2). 

SUMMARY

All nine samples were successfully analyzed within the method-specified holding times, and initial 

precision and recovery (IPR) analyses and method detection limit (MDL) studies were acceptably 

performed. All QC samples, including ongoing precision and recovery samples (OPR), matrix spike and 

matrix spike duplicate (MS/MSD) samples, and quality control samples (QCS) were within method 

specified criteria, with the exceptions described below. The MS/MSD analyses were performed on total 

and dissolved samples 70622 and 70623. Calibration curves and calibration verification standards were 

successfully analyzed, with the exceptions described below. 
3 

All calibration and preparation blanks were free of contamination above the report limit (minimum level 

or ML), with the exceptions described below. No analytes were detected at levels above the reporting 

limit in the field blanks, with the exceptions described below. 

 

DATA ISSUES

Method and Analytical Blanks

Several analytes were detected in the preparation blanks (PB), initial calibration blanks (ICBs), and 

continuing calibration blanks (CCBs) associated with the samples in this episode at concentrations greater 

than the respective MDLs, but less than the method-specified MLs. Antimony was detected in one ICB 

and zinc was detected in one CCB at levels marginally above their respective MLs. The data quality is 

affected as follows: 

• Sample Results Less than Five Times Blank Results: When the sample result is less than five 

times the blank result, there are no means by which to ascertain whether or not the presence of the 

analyte may be attributed to contamination. Therefore, CSC recommends that the data be 

reported in the database as a not detected at the ML, adjusted for sample size, dilution, and 

matrices. The affected samples and analytes are as follows: 70622 total Sb. 

• Sample Results Greater than Five Times but Less than Ten Times Blank Results: CSC considers 

these results to be of acceptable quality, but they may be maximum values. The affected samples 

and analytes are as follows: 70620 total Cr. 

• Sample Results Greater than Ten Times Blank Results or Analyte Not Detected in Sample: CSC 

does not consider the presence of the analyte in the blank to adversely affect the data in cases 

where the sample results are greater than ten times the associated blank results or where the 

analyte is not detected in associated samples. Because CSC considers such data to be acceptable 

without qualification, these cases do not merit further detail. 

CCV 

The recoveries of silver (108% and 109%) in two continuing calibration verification samples (CCV) were 

slightly above the method-specified upper limit of 107%. The affected results are as follows: total silver 

for samples 70620, 70621, 70622, and 70624; dissolved silver for samples 70621, 70622, and 70624. 

However, because silver was not detected in any of these associated samples, CSC recommends that the 

results be included in the database without qualification. 

Field Blanks 

CSC reviewed results from four field blanks. All field blanks exhibited no results above the ML with the 

following exception: hexavalent chromium in sample 70626. Per EPA request, CSC does not qualify 

results based on field blank contamination. 

MS/MSD 

The relative percent difference (RPD) for dissolved arsenic (22%) for the MS/MSD set performed on 

sample 70622 was marginally above the laboratory limit (20%). Recoveries for both the MS and MSD 

were acceptable. CSC recommends that the dissolved arsenic result for the unspiked sample 70622 be 

considered of acceptable quality, but may be an estimated value. 
4 

The RPD for total selenium (31%) for the MS/MSD set performed on sample 70622 was above the 

contract-specified limit (20%). Recoveries for both the MS and MSD were acceptable. CSC 

recommends that the total selenium result for the unspiked sample 70622 be considered of acceptable 

quality, but may be an estimated value. 

TECHNICAL NOTES 

Sample Temperature 

Trace metals samples were not chilled during shipment for this study. 

Additional Analytes 

Two additional analytes, arsenic and chromium, were included for evaluation by Method 1638. Because 

they are not specified in the method, the MLs for these (0.15 μg/L and 0.80 μg/L, respectively) were set 

well above the laboratory-determined MDL. 

Minimum Levels 

In order to alleviate interference caused by high levels of dissolved solids, the laboratory performed 

various dilutions on several samples on which Method 1636 and 1638 were performed. MLs are adjusted 

appropriately. 

Solid-Phase Calculations 

CSC calculated the solid-phase results using the following formula: 

The results for the various phases will be labeled in the PROCEDUR field of the EPA database as 

“DISSOLVED”, “TOTAL”, and “CALCULATED SOLID (DRY WEIGHT)”. 

When two results are mathematically combined to obtain a Calculated Solid result, CSC will report the 

larger of the two MLs associated with each result as the Calculated Solid ML. 

In the generation of the Calculated Solid result, at EPA's request, CSC included Total and Dissolved 

concentrations that were greater than the MDL but less than the ML. However, if any concentration was 

affected by contamination in an associated blank at less than 5 times the associated blank result, it was 

changed to a zero before going through the calculation, per CSC's data review protocols. Negative values 

submitted by the laboratory were not used in the calculations. 

The TSS result for the sample 70620 bottle analyzed for mercury is 7164 mg/L. The TSS result for the 

sample 70620 bottle analyzed for Method 1638 metals is 7150 mg/L. 

original sample

Total Dissolved

TSS mg L

Conc ng L Conc ng L

/

( . / . / ) Solid phase concentration (ng/mg or μg/g) − =
5 

If you have any questions regarding the analyses of these samples or the review of these data, please 

contact Barbara Beard by telephone at (703) 461-2154, facsimile at (703) 461-8056, or via email at 

bbeard2@csc.com. 

cc: Brian Damico, EPA Deb Bartram, ERG 

Beverly Randolph, EPA TJ Finseth, ERG 

Marla Smith, EPA Lynn Walters, CSC 

Nelson Andrews, EPA Barbara Beard, CSC 

Brian Englert, EPA 

Table 2 

Data Review Summary Table

Episode: 6550 Analysis: Trace Metals

Industry: STELEC Study Reviewer: Cris Robinson 

Sample Analyte Action Reason SCC Qual Level

70622 Total Sb Report in database 

as non-detect 

Sample result <5x blank 

result NA 

70620 Total Cr Maximum value Sample result >5x and 

<10x blank result NA 

70622 Dissolved As 

70622 Total Se 

Estimated value MS/MSD RPD above 

contract -specified criteria NA 

70620 Calculated 

Solid Cr Maximum value Associated total result is a 

maximum NA 

See Database 

NA = Not applicable
Appendix D 

PICTURES FROM THE SAMPLING EPISODE 
D-1 

Figure D-1. Sampler Working Inside a “Cleanbox” 
D-2 

Figure D-2. Sample Collection Set-Up at the Influent to FGD Wastewater Treatment 

System 
D-3 

Figure D-3. Sample Tap and Tubing at the FGD Clarifier Effluent 
D-4 

Figure D-4. Sample Collection Set-Up at the FGD Clarifier Effluent 
D-5 

Figure D-5. Sample Collection Set-Up at the Effluent from FGD Wastewater Treatment 

System 
D-6 

Figure D-6. Sample Collection Set-Up at the Effluent from the Fly Ash Pond