Sampling Plan

Enel’s Federico II Power Plant

Brindisi, Italy

Sampling Episode 6576

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

March 21, 2011

EPA Contract No. 68-C-02-095

Work Assignment 8-29
i

TABLE OF CONTENTS

Page

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

1.1 Background..........................................................................................................1-1

1.2 Objectives and Scope...........................................................................................1-1

1.3 Plant Selection .....................................................................................................1-2

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

2.1 FGD Scrubber Systems........................................................................................2-1

2.1.1 Units 1 and 2 FGD Scrubber Systems .....................................................2-2

2.1.2 Units 3 and 4 FGD Scrubber Systems .....................................................2-3

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

3. SAMPLING PROCEDURES ...................................................................................................3-1

3.1 Sampling Point Selection.....................................................................................3-1

3.2 Analyte Selection.................................................................................................3-1

3.3 Sample Collection Procedures.............................................................................3-2

3.3.1 Influent to the FGD Wastewater Treatment System (SP-1) ....................3-3

3.3.2 Distillate from the Brine Concentrator (SP-2).........................................3-5

3.3.3 Condensate from the Crystallizer (SP-3)...............................................3-11

3.4 Sample Preservation, Shipping, and Analysis ...................................................3-17

3.5 Field Measurements and Engineering Data Collection .....................................3-18

3.6 Sample Labeling ................................................................................................3-18

3.7 Traffic Reports...................................................................................................3-19

3.8 Quality Assurance/Quality Control....................................................................3-19

4. SAMPLING ACTIVITIES ......................................................................................................4-1

4.1 Sampling Team Organization ..............................................................................4-1

4.2 Presampling Preparation ......................................................................................4-1

4.3 Field Sampling Activities ....................................................................................4-1

4.4 Logistics...............................................................................................................4-2

4.4.1 Federico II Power Plant ...........................................................................4-2

4.4.2 EPA Contacts...........................................................................................4-2

4.4.3 Analytical Laboratories............................................................................4-3

4.4.4 ERG Contacts...........................................................................................4-3

4.4.5 Freight Forwarders...................................................................................4-3

5. SAMPLE SHIPMENT ...........................................................................................................5-1

5.1 Sample Set Preparation........................................................................................5-1

5.2 Sample Packing....................................................................................................5-1

6. SITE-SPECIFIC HEALTH AND SAFETY PROCEDURES ..........................................................6-1

6.1 Emergency/Medical Procedures ..........................................................................6-1

6.1.1 First Aid ...................................................................................................6-1

6.1.2 Site Evacuation/Emergency Response Plan.............................................6-1

6.1.3 Emergency Showers and Eye Washes.....................................................6-1

6.1.4 Local Hospital..........................................................................................6-1
TABLE OF CONTENTS (Continued)

Page

ii

6.2 ERG Health and Safety Responsibilities and Authority......................................6-1

6.2.1 Work Assignment Manager.....................................................................6-1

6.2.2 Crew Chief...............................................................................................6-2

6.2.3 Sampling Team Members........................................................................6-2

6.3 Briefings...............................................................................................................6-2

6.3.1 Off-Site Briefings.....................................................................................6-2

6.3.2 On-Site Briefings.....................................................................................6-3

6.4 Safety Procedures.................................................................................................6-3

6.4.1 PPE...........................................................................................................6-3

6.4.2 Safety Practices........................................................................................6-3

6.4.3 Safe Work Practices.................................................................................6-4

6.5 Sampling-Point-Specific Safety Procedures........................................................6-4

6.5.1 Physical Hazards......................................................................................6-4

6.5.2 Thermal Hazards......................................................................................6-4

6.5.3 Chemical Hazards....................................................................................6-5

6.6 Temperature Extremes.........................................................................................6-5

6.6.1 Heat Stress ...............................................................................................6-5

6.6.2 Heat Stress Monitoring ............................................................................6-6

6.7 First Aid ...............................................................................................................6-7

6.8 Sample Preservation and Safety Considerations..................................................6-7

6.9 Training and Medical Monitoring Requirements ................................................6-8

6.10 Shift Work Protocol.............................................................................................6-8

7. REFERENCES .....................................................................................................................7-1
iii

LIST OF TABLES

Page

3-1. Sample Collection at Brindisi Power Plant ........................................................................ 3-21

3-2. Analytical Methods............................................................................................................. 3-22

3-3. Summary of Sample Containers and Planned Preservation ............................................... 3-23

3-4. Sampling Point Field Measurements.................................................................................. 3-24

6-1. Sample-Point-Specific PPE and Potential Hazards............................................................ 6-10

LIST OF FIGURES

Page

2-1. Diagram of the Chemical Precipitation and Softening Portion of the FGD Wastewater 

Treatment System, Brindisi Power Plant......................................................................... 2-7

2-3. Diagram of the Crystallization Portion of the FGD Wastewater Treatment System, 

Brindisi Power Plant ........................................................................................................ 2-9

3-1. Sample Preservation Log Sheet.......................................................................................... 3-25

3-2. Field Sampling Log Sheet .................................................................................................. 3-26

3-3. Engineering Data Collection Sheet (Page 1 of 3)............................................................... 3-27

3-4. Engineering Data Collection Sheet (Page 2 of 3)............................................................... 3-28

3-5. Engineering Data Collection Sheet (Page 3 of 3)............................................................... 3-29

3-6. Example Traffic Report...................................................................................................... 3-30
1-1

1. INTRODUCTION

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

Agency (EPA) is currently conducting a sampling program at steam electric power plants. The 

sampling program will characterize raw wastewaters generated by coal-fired steam electric 

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

reduce pollutant discharges. This sampling plan, developed for the Enel Federico II Power Plant

(Brindisi), located in Brindisi, Italy, provides plant-specific sampling procedures and methods

EPA and its contractors will follow when conducting sampling activities. Sampling will be 

performed by EPA’s technical contractor, Eastern Research Group, Inc. (ERG), under Contract 

No. 68-C-02-095. This document, in combination with the Generic Sampling and Analysis Plan 

for Coal-Fired Steam Electric Power Plants [1], is intended to serve as a guide to the ERG field 

sampling crew, a review mechanism for EPA personnel, and a source of procedural information 

for plant personnel. 

1.1

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

identified metals and certain other constituents present in the wastewater discharges from steam 

electric power plants in the United States that are contributing the majority of the toxic loadings 

for the industry. Additionally, EPA determined that one of the waste streams contributing most

of these toxic loadings are associated with wet flue gas desulfurization (FGD) systems present at 

coal-fired power plants.

Background

This sampling plan will focus on characterizing wastewaters and treatment system 

discharges at Brindisi. For a general description of the steam electric process and the 

wastewaters generated during the operation of a coal-fired steam electric power plant, see 

Chapters 3 and 4 of the Steam Electric Power Generating Point Source Category: Final Detailed 

Study Report [2].

1.2

EPA and ERG are preparing to collect and analyze samples to characterize wastewater 

streams generated at coal-fired steam electric power plants. This sampling plan describes the 

approach EPA and ERG will use to collect and analyze samples to characterize untreated FGD 

scrubber purge and treated FGD wastewater from an FGD wastewater treatment system 

consisting of chemical precipitation followed by mechanical vapor-compression evaporation. A 

chemical precipitation system utilizes physical and chemical treatment to remove heavy metals 

using hydroxide, or a combination of hydroxide and sulfide precipitation. A mechanical vaporcompression evaporation system uses a falling-film evaporator to produce a concentrated 

wastewater stream and a reusable distillate stream. The concentrated wastewater stream may be 

further processed in a crystallizer, in which a solid product is generated along with a reusable 

condensate stream. 

Objectives and Scope

Generally, the analytical results collected during this sampling program will support EPA 

in answering the following key questions:

• What are the characteristics (i.e., pollutants present, pollutant concentrations, flow 

rate/volume) of untreated FGD scrubber purge wastewater?
1-2

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

wastewater?

• What are the pollutant loadings associated with discharges of FGD wastewater 

following treatment?

ERG conducted a one-day presampling site visit at Brindisi on February 14, 2011, and 

collected the following information:

• Information about the plant’s operations, including existing sampling data and 

results;

• Process-specific information;

• Information on pollution prevention and wastewater treatment operations;

• Plant-specific information to tailor sampling plans; and

• Information on potential sampling points.

The sampling program will consist of three- or four-day sampling episodes at selected 

plants. The sampling will characterize the wastewater generated by the wet FGD scrubbers and

the treatment performance of the systems used to treat the FGD scrubber purge wastewater. EPA

and ERG will also collect field quality control (QC) samples consisting of bottle blanks, field

blanks, equipment blanks, field duplicate samples, and laboratory QC aliquots used for matrix 

spike/matrix spike duplicate analyses.

EPA’s sampling program will provide data to perform an engineering assessment of the 

design, operation, and performance of treatment systems at steam electric power plants. In 

addition to sampling the wastewater, EPA and ERG will collect information regarding system 

design and day-to-day operation. 

1.3

EPA expects to select up to eight coal-fired steam electric plants for FGD wastewater 

sampling, basing the plant selection on the process configurations and characteristics of the 

plants.

Plant Selection

Brindisi was selected by EPA for sampling based on the following site characteristics:

• The plant is a coal-fired power plant;

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

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

includes the following steps:

— Settling;

— Equalization,

— Lime, sodium sulfide, and caustic soda addition (pH adjustment/metal 

hydroxide precipitation),
1-3

— Ferric chloride addition,

— Polyelectrolyte addition,

— Clarification, 

— Ferrous chloride and soda ash addition (softening),

— Clarification,

— Evaporation (brine concentrator), and

— Crystallization; and

• The plant operates selective catalytic reduction (SCR) systems on all four units.
2-1

2. FACILITY OVERVIEW

Brindisi operates four steam electric units and each has a coal-fired boiler. All four units 

have a capacity of 660 megawatts (MW). Each unit burns a coal with 0.6% sulfur content. The 

Brindisi plant is located in Cerano-Tuturano (Brindisi), Italy.

Brindisi retrofitted all four units with wet FGD scrubber systems in the early 1990s to 

control the sulfur dioxide (SO2) releases from the plant. With the addition of the FGD scrubber 

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

the wastewater generated during the operation of the FGD scrubbers. In 2008, Brindisi upgraded

the FGD wastewater treatment system to include a vapor-compression evaporation system which 

allows the plant to operate as a zero liquid discharge plant. The FGD scrubber systems are 

discussed further in Section 2.1 and the FGD wastewater treatment system is discussed further in 

Section 2.2.

At the time the FGD scrubber systems were installed, Brindisi also installed selective 

catalytic reduction (SCR) systems on all four units to control nitrogen oxide (NOx) releases from 

the plant. 

Brindisi operates electrostatic precipitators (ESPs) on three of the four units to control 

particulate releases from the plant. The plant operates a baghouse on the other unit. According 

to plant personnel, Brindisi is in the process of converting the remaining three ESPs into 

baghouses. The plant almost exclusively handles the fly ash dry and trucks the ash to mines for 

use as structural fill; however, the plant does have the capability to sluice the fly ash to ships if 

the ash will be transported by barge.

Brindisi operates a wet bottom ash handling system which sluices the bottom ash to a 

segregated wastewater treatment basin. The overflow from the bottom ash basin is mixed with 

the FGD wastewater and treated by the vapor-compression evaporation system.

2.1

Brindisi operates eight forced oxidation wet FGD scrubber systems (two per unit) to 

control the emission of SO2 from the units. Each FGD system consists of both a prescrubber and 

a main scrubber. Brindisi has two different types of FGD scrubber systems for the four units. 

The Unit 1 and 2 FGD systems were manufactured by Bishoff and the Unit 3 and 4 FGD systems 

were manufactured by MHI (Mitsubishi). According to plant personnel, each of the scrubbers 

was designed to have the same SO2 removal efficiency; however, the Bishoff scrubbers are 

bigger than the Mitsubishi scrubbers and have achieved greater removal efficiencies.

FGD Scrubber Systems

The prescrubbers for each FGD system operate similarly, using a water scrubber to help 

remove the additional particulates from the flue gas (i.e., carry-over fly ash from the ESPs) prior 

to the FGD system. Additionally, the prescrubbers remove chlorides from the flue gas prior to 

the main scrubber. Each prescrubber has a continuous blowdown that is fed to the FGD 

wastewater treatment system. The Unit 1 and 2 prescrubber blowdown is approximately 60 

m3

/hr (264 gal/min) for the two units combined. The Unit 3 and 4 prescrubber blowdown is 

approximately 80 m3/hr (352 gal/min) for the two units combined.
2-2

The main scrubbers for each unit have some similarities, including the following:

• The systems are limestone forced oxidation scrubbers;

• The solids concentration in the scrubbers ranges from 18 to 24% solids; and

• The chlorides concentration in the scrubbers is approximately 5,000 ppm.

However, due to the differences between the Bishoff and Mitsubishi designs, Section 

2.1.1 describes the operation of the Bishoff scrubbers (i.e., Units 1 and 2) and Section 2.1.2 

describes the operation of the Mitsubishi scrubbers (i.e., Units 3 and 4).

2.1.1 Units 1 and 2 FGD Scrubber Systems

The Units 1 and 2 FGD scrubber systems were both manufactured by Bishoff and have 

an identical design. Each unit is equipped with two FGD scrubber systems, with each system 

receiving approximately 50 percent of the flue gas. The FGD systems use limestone as the 

sorbent in the system. The limestone slurry is pressurized and sprayed into the scrubber; the 

spray droplets absorb the SO2, which reacts with the limestone particles and produces calcium 

sulfite. The spray droplets fall to the reaction tank at the bottom of the scrubber where air is 

injected and the slurry is mixed to oxidize the calcium sulfite to calcium sulfate (i.e., gypsum).

Brindisi intermittently blows down the gypsum slurry from each FGD system to control 

the solids concentration in the scrubbers. The plant initiates a blow down once the solids reach 

24% within the scrubber. The plant continues to blowdown until the solids concentration is 

reduced to 18% within the scrubber.

The blowdown from each of the Units 1 and 2 FGD scrubbers is transferred to the 

primary hydrocyclones. There is one set of hydrocyclones for each FGD system; therefore, there 

are two sets of hydrocyclones for each unit. The underflow from each of the primary 

hydrocyclones is transferred to vacuum belt filters for dewatering. Brindisi washes the gypsum 

as it is applied to the vacuum belt filters. The vacuum belt filters dry the gypsum byproduct to a 

moisture content of less than 10 percent. Brindisi sells the gypsum for use in wallboard 

manufacturing. The filtrate from the vacuum belt filters is transferred to the Units 1 and 2 FGD 

sump.

The overflow from the two primary hyrdrocyclones for each unit is combined in a storage 

tank and then transferred to the secondary hydrocyclones (one set for each unit). The overflow 

from the secondary hydrocyclones is transferred to a thickener for settling (each unit has its own 

thickener). The overflow from the thickener is recycled back to the FGD scrubber systems. The

underflow from the thickeners is transferred to the Units 1 and 2 FGD sump. 

The Units 1 and 2 FGD sump also receives rainfall, stormwater runoff from the 

surrounding area, and other wash waters from the FGD process area. The wastewater that 

collects in the Units 1 and 2 FGD sump is periodically transferred to the FGD wastewater 

treatment system based on sump level control. Wastewater from the Units 1 and 2 FGD sump is 

typically transferred to the FGD wastewater treatment system at a flow rate of 20 m3

/hr (88 

gal/min) for 15 to 20 minutes every two hours.
2-3

2.1.2 Units 3 and 4 FGD Scrubber Systems

The Units 3 and 4 FGD scrubber systems were both manufactured by Mitsubishi and 

have an identical design. Each unit is equipped with two FGD scrubber systems, with each 

system receiving approximately 50 percent of the flue gas. The FGD systems use limestone as 

the sorbent in the system. The limestone slurry is pressurized and sprayed into the scrubber; the 

spray droplets absorb the SO2, which reacts with the limestone particles and produces calcium 

sulfite. The spray droplets fall to the reaction tank at the bottom of the scrubber where air is 

injected and the slurry is mixed to oxidize the calcium sulfite to calcium sulfate (i.e., gypsum).

Brindisi intermittently blows down the gypsum slurry from each FGD system to control 

the solids concentration in the scrubbers. The plant initiates a blow down once the solids reach 

24% within the scrubber. The plant continues to blowdown until the solids concentration is 

reduced to 18% within the scrubber.

The blowdown from each of the Units 3 and 4 FGD scrubbers is transferred to the 

primary hydrocyclones. There is one set of hydrocyclones for each FGD system; therefore, there 

are two sets of hydrocyclones for each unit. The underflow from the primary hydrocyclones is 

transferred to vacuum belt filters for dewatering. Brindisi washes the gypsum as it is applied to 

the vacuum belt filters. The vacuum belt filters dry the gypsum byproduct to a moisture content 

of less than 10 percent. Brindisi sells the gypsum for use in wallboard manufacturing. The 

filtrate from the vacuum belt filters is transferred to the Units 3 and 4 FGD sump. 

The overflow from each primary hydrocyclone is transferred to an intermediate storage 

tank and then to a clarifier. Both the overflow and the underflow from the clarifier for each FGD 

system are transferred to the Units 3 and 4 FGD sump, which means that the clarifier is not really 

acting as a clarifier but like a holding tank. According to plant personnel, the Units 3 and 4 FGD 

scrubber systems were initially designed with centrifuges, which are a solids separation process 

that is not as efficient as hyrdrocyclones; therefore, the clarifiers were needed to achieve 

additional solids settling. However, when the plant started using the hydrocyclones, the clarifiers 

were no longer needed.

The Units 3 and 4 FGD sump also receives rainfall, stormwater runoff from the 

surrounding area, and other wash waters from the FGD process area. The Units 3 and 4 FGD 

sump is periodically transferred to the FGD wastewater treatment system based on sump level 

control. Wastewater from the Units 3 and 4 FGD sump is typically transferred to the FGD 

wastewater treatment system at a flow rate of 100 m3

/hr (440 gal/min) for 10 to 15 minutes every 

30 minutes.

2.2

The FGD wastewater treatment system at Brindisi is designed to receive continuous 

blowdown flow from the eight prescrubber units and intermittent transfers from the Units 1 and 2 

FGD sump and the Units 3 and 4 FGD sump.

FGD Wastewater Treatment System

The FGD wastewater treatment system was originally installed to treat the FGD scrubber 

purge wastewater to meet the plant’s permit limits prior to discharge. However, in 2008, the 

plant upgraded the FGD wastewater treatment system to include a softening, evaporation, and 
2-4

crystallization system which allows the entire plant to achieve zero liquid discharge. The 

Brindisi FGD wastewater treatment system contains the following treatment operations:

• Settling;

• Equalization,

• Lime, sodium sulfide, and caustic soda addition (pH adjustment/metal hydroxide 

precipitation),

• Ferric chloride addition,

• Polyelectrolyte addition,

• Clarification, 

• Ferrous chloride and soda ash addition (softening (added in 2008)),

• Clarification,

• Evaporation (brine concentrator) (added in 2008), and

• Crystallization (added in 2008).

Figures 2-1, 2-2, and 2-3, located at the end of this section, present process flow diagrams 

of the FGD wastewater treatment system, as well as the planned sampling locations for EPA’s 

sampling episode. Figure 2-1 presents a diagram of the pretreatment system, which includes the 

chemical precipitation portion of the system. Figure 2-2 presents a diagram of the evaporation 

portion of the wastewater treatment system. Figure 2-3 presents a diagram of the crystallization 

portion of the wastewater treatment system.

The prescrubber blowdown, the Units 1 and 2 FGD sump transfers, and the Units 3 and 4 

FGD sump transfers are first treated in the settling basin. Brindisi has two settling basins, each 

with a capacity of 600 m3 (158,500 gallons). The plant only operates one settling basin at a time 

because while one is operating, the other is being dredged and cleaned out.

The overflow from the settling basins is transferred to the FGD wastewater treatment 

tanks, which consist of two 2,000 m3 (528,000 gallons) tanks used for equalization of the 

wastewater. Brindisi also transfers the overflow from the bottom ash treatment basins to the 

FGD wastewater treatment tanks.

The FGD wastewater treatment tanks feed the 1st stage of the neutralization basin, which 

is a large concrete basin that has three divided compartments/basins. In the 1st basin, the plant 

adds lime, sodium sulfide, and caustic soda. Overflow from the 1st basin feeds the 2nd basin 

where ferric chloride is added. The wastewater then flows to the 3rd basin where a 

polyelectrolyte is added.

The overflow from the third basin is transferred to the clarifier. The underflow from the 

clarifier is transferred to filter presses for dewatering. The dewatered solids are sent to a landfill 

for disposal. The overflow from the clarifier is sent to the 2nd stage of the neutralization basin, 

which has two divided compartments. In the first compartment, the plant adds ferrous chloride 

and sodium carbonate (soda ash) to the wastewater for softening. The overflow from the first 

compartment is transferred to the second compartment, which is a lamella type clarifier. The 

solids that settle at the bottom of the lamella clarifier consist of calcium carbonate (limestone); 

these solids are pumped back to the FGD process as make-up to the FGD limestone preparation. 

The overflow from the lamella clarifier is transferred to the clearwell.
2-5

From the clearwell, the FGD wastewater is either recycled back to the FGD system as 

make-up or sent to the softening tank for further treatment. The original design for the system 

was for the pretreatment system (i.e., neutralization basins) to treat 280 m3

/hr and 140 m3/hr 

would be recycled and 140 m3/hr would be sent to the softening tank. However, the plant 

attempts to maximize the amount of recycle because the lower the flow to the evaporation 

system, the less expensive it is to operate the system. Therefore, the plant currently operates the 

system by recycling 230 m3

/hr and transferring 50 m3/hr to the softening tank.

The wastewater sent to the softening tank is treated with additional sodium carbonate to 

complete the softening process. The overflow from the softening tanks is then transferred to the 

evaporation and crystallization system. As described above, the original design for the system 

was for the softening tank to receive 140 m3/hr of wastewater, but only 70 m3/hr was supposed to 

be transferred to the evaporation system, while 70 m3/hr was supposed to be recycled back to the 

FGD system. Because of the reduced flow to the softening tanks, the entire 50 m3

/hr entering the 

softening tanks is transferred to the evaporation system with no recycle back to the FGD system.

The wastewater from the softening tank is transferred to the evaporator feed tank, where 

the wastewater is equalized prior to being fed to the evaporation system. Additionally, the plant 

adds hydrochloric acid and an anti-scalant to the wastewater prior to the evaporation system. 

From the evaporator feed tank, the wastewater is split into two streams and both are sent to heat 

exchangers to bring the wastewater to its boiling point. The distillate stream from the brine 

concentrator and the condensate stream from the crystallizer are the streams used to transfer heat 

to the wastewater. From the heat exchangers, the wastewaters are recombined and sent to the 

deaerator, where the noncondensable materials such as carbon dioxide and oxygen are vented to 

the atmosphere.

From the deaerator, the wastewater enters the sump of the brine concentrator. Brine from 

the sump is pumped to the top of the brine concentrator and enters the heat transfer tubes. While 

falling down the heat transfer tubes, part of the solution is vaporized and then compressed and 

introduced to the shell side of the brine concentrator (i.e., the outside of the tubes), along with 

additional make-up steam. The temperature difference between the compressed vapor and the 

brine solution causes the compressed vapor to transfer heat to the brine solution, which flashes to 

a vapor. As heat is transferred to the brine, the compressed vapor cools and condenses as distilled 

water. 

The condensed vapor from the brine concentrator is collected and transferred to a 

distillate tank. The distillate is then pumped through one of the feed heat exchangers where it 

transfers its heat to the incoming wastewater and at the same time cooling the distillate stream. 

From the heat exchanger, the distillate continues to the second distillate tank where it is 

combined with the condensate from the crystallizer. 

The concentrated brine slurry from the brine concentrator tubes falls into the sump and is 

recycled with the feed (i.e., FGD wastewater) back to the top of the brine concentrator, while a 

small amount is continuously withdrawn from the sump and transferred to a set of 

hydrocyclones. To prevent scaling within the brine concentrator as a result of the gypsum 

present in the FGD wastewater, the brine concentrator is seeded with calcium sulfate. The 

calcium salts preferentially precipitate onto the seed crystals instead of the tube surfaces of the 

brine concentrator. The hydrocyclones recover the calcium sulfate seed crystals in the underflow

and recycle the seed to the recirculation stream entering the top of the brine concentrator. The 
2-6

overflow from the hydrocyclones is the concentrate that is transferred to the crystallizer feed 

tank.

The crystallizer feed tank also receives the filtrate from the filter presses that dewater the 

solids generated in the crystallizer. From the crystallizer feed tank, the wastewater is combined 

with the some of the slurry recirculation from the bottom of the crystallizer and then combined 

with the reheated slurry recycle and fed into the crystallizer. The crystallizer is operated with a 

certain level of slurry in the bottom of the system. Within the system, the water is evaporated 

and exits the top of the crystallizer as steam. Some of the steam is diverted to a 

thermocompressor where the low-pressure steam is converted to high pressure steam. This highpressure steam is transferred to the forced circulation heat exchanger where it transfers its heat to 

the slurry that is recirculated in the crystallizer, which provides the heat for the water to vaporize 

in the system. The condensed steam is transferred to one of the feed heat exchangers to heat the 

FGD wastewater entering the deaerator. The condensate is then combined with the brine 

concentrator distillate in the distillate tank. The rest of the steam that exits the top of the 

crystallizer is diverted to a condenser where it is cooled with cooling water and transferred to a 

condensate tank.

Some of the slurry from the bottom of the crystallizer is transferred through the forced 

circulation heat exchanger where it is heated by the high-pressure steam and fed back to the 

crystallizer. The heat transferred to the slurry allows the water present in the slurry to evaporate 

and exit the crystallizer as steam. The evaporation of the water also concentrates the solids 

present and allows the solids to crystallize. There is a continuous bleed of the slurry from the 

crystallizer that is fed to the filter presses where the crystallized solids are dewatered. The 

filtrate from the filter presses is recycled back to the crystallizer feed tank and the solids are 

transferred to a mine as fill.
2-7

Secondary Hydrocyclone 

Overflow

FGD 

Wastewater 

Treatment 

Tank A

Filter Press

SP-1

Indicates a Sampling Point

Clarifier

Solids to Landfill

Prescrubber Blowdown Unit 1

Prescrubber Blowdown Unit 2

Prescrubber Blowdown Unit 3

Prescrubber Blowdown Unit 4

Unit 1&2 FGD Sump Transfer

Unit 3&4 FGD Sump Transfer

Settling Basin A

Settling Basin B

FGD 

Wastewater 

Treatment 

Tank B

Bottom Ash Treatment 

Basin Overflow

1st Basin 2nd Basin 3rd Basin

1st Stage Neutralization Basin

Lime

NaOH

Sodium 

Sulfide

Ferric Chloride

Polyelectrolyte

1st Basin Lamella 

Clarifier

2nd Stage Neutralization 

Basin

Ferrous 

Chloride Soda 

Ash

Clearwell

To Softening/

Evaporation/

Crystallization

FGD System 

Make Up

Figure 2-1. Diagram of the Chemical Precipitation and Softening Portion of the FGD Wastewater Treatment System, Brindisi

Power Plant
2-8

Hydrochloric 

Acid

Feed/Crystallizer 

Heat Exchanger

Distillate 

Tank

Deaerator

Brine Concentrator Compressor

Vent to 

Atmosphere

Brine 

Solution

Brine 

Recycle

Distillate

Liquid Stream

Legend

Gas Stream

Softening 

Tank

From 

Pretreatment 

Clearwell

Soda Ash

To Limestone 

Preparation

Evaporator 

Feed Tank

Anti-Scalant

Feed/Distillate 

Heat Exchanger

Condensate from 

Crystallizer

Make-up 

Steam

Concentrate to 

Crystallizer Feed Tank

Distillate 

Tank

To Plant for 

Reuse

Indicates a sampling point

SP-2

Figure 2-2. Diagram of the Evaporation Portion of the FGD Wastewater Treatment System, Brindisi Power Plant
2-9

Concentrate from 

Brine Concentrator

Liquid Stream

Legend

Gas Stream

Crystallizer 

Feed Tank

Feed/Distillate 

Heat Exchanger

Crystallizer Forced 

Circulation Heat 

Exchanger

E-29

Crystallizer

Thermocompressor

Make-up Steam

Cooling Water

Condenser

Condensate 

Tank

Solid Stream

Solids to Disposal

Filter Press

Indicates a sampling point

Condensate to 

Distillate Tank

SP-3

Condensate to 

Distillate Tank

Figure 2-3. Diagram of the Crystallization Portion of the FGD Wastewater Treatment System, Brindisi Power Plant
3-1

3. SAMPLING PROCEDURES

This section discusses the planned sampling procedures to be followed during the 

sampling episode at Brindisi. This section also provides the necessary information to plan for the 

logistics of this sampling episode. All tables and figures in this section are presented at the end of 

the section.

3.1

EPA and ERG selected the following six sampling points for Brindisi (the three proposed 

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

Quality Assurance/Quality Control (QA/QC) samples):

Sampling Point Selection

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

• SP-2 Distillate from the Brine Concentrator;

• SP-3 Condensate from the Crystallizer;

• SP-4 Field Blank for the Influent to the FGD Wastewater Treatment System 

(same location as SP-1);

• SP-5 Field Blank for Distillate from the Brine Concentrator (same location as SP2); and

• SP-6 Field Blank for Condensate from the Crystallizer (same location as SP-3).

3.2

Analytes that will be included in EPA’s Brindisi sampling episode include those in the 

following classes of pollutants:

Analyte Selection

• Classicals:

— Chemical oxygen demand (COD),

— Total suspended solids (TSS),

— Total dissolved solids (TDS),

— Sulfate,

— Chloride,

— Total Kjeldahl nitrogen (TKN),

— Ammonia as nitrogen,

— Nitrate/nitrite as nitrogen, and

— Total phosphorus;
3-2

• Total 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, and zinc.

The analytes selected for analysis reflect the current understanding of coal-fired power 

plant FGD wastewaters, including contributions from coal, scrubber sorbents, treatment 

chemicals, and other sources. Table 3-1 lists the potential analytes for each sampling point, Table 

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

volume and planned on-site preservation for each parameter or parameter group. 

3.3

To characterize the influent to the FGD wastewater treatment system (SP-1), the distillate 

from the brine concentrator (SP-2), and the condensate from the crystallizer (SP-3) at Brindisi, 

the sampling team will use varying methods to collect the samples depending on the sampling 

point and pollutant parameters. This subsection describes in detail the sample collection 

techniques. 

Sample Collection Procedures

Samples will be collected as a series of “fractions,” or bottles designated for particular 

analyses requiring the same preservation. The comprehensive sample set will consist of sample

fractions for all pollutant classes listed in Section 3.2. Note that some sample fractions will be 

collected in the same sample bottle, such as Group I analytes (TSS, TDS, sulfate, and chloride) 

and Group II analytes (ammonia as nitrogen, COD, nitrate/nitrite as nitrogen, TKN, and total 

phosphorus). 

In general, samplers will work in teams of two to ensure that proper sampling techniques 

are followed and adequate notes are taken at each sampling location. Samplers will wear 

disposable gloves, Tyvek® suits, masks (when sampling for mercury by EPA Method 1631E), 

steel-toed boots, hard hats, and safety eyewear, and will observe precautions while collecting 

samples, remaining aware of their surroundings. Note that the use of masks is to prevent 

contamination of the mercury samples and not for respiratory protection.

Sample containers and bottles will be purchased precleaned and certified and will not 

require rinsing with sample. The sample bottles for the metals analyses will be cleaned according 

to EPA Method 1669. For this sampling episode, ERG will collect six-hour composite samples at 

the distillate from the brine concentrator and condensate from the crystallizer sampling points for 

most analytes; however, mercury will be collected as four grab samples. ERG will collect

individual grab samples at the influent to the FGD wastewater treatment system sampling point

for all analytes. ERG will collect one sample at the influent to the FGD wastewater treatment 

system sampling point for two consecutive days. ERG will collect one sample at the distillate 

from the brine concentrator and condensate from the crystallizer sampling points for three

consecutive days (mercury will be collected as four grab samples over a six-hour period each day 

for both the distillate from the brine concentrator and condensate from the crystallizer sampling 

points). ERG will follow protocols described in EPA Method 1669 to collect metal sample 

fractions. All sampling equipment (e.g., tubing) and sample bottles will be cleaned according to 
3-3

the procedures described in EPA Method 1669. Samplers will use “clean hands / dirty hands” 

sample collection techniques when collecting metal sample fractions, as described in EPA 

Method 1669. 

Samplers will take care not to touch the insides of bottles or lids/caps during sampling. 

Samples that require cooling to ≤6°C for preservation will be cooled immediately in an ice-water 

bath and then placed into coolers containing bagged ice throughout sample storage, shipment, 

and receipt at the analytical laboratories. The Crew Chief will confirm that samples are actually 

≤6°C before being packed for shipment to the laboratory and the temperature reading will be 

documented in the traffic report for the samples. Samples that require cooling to ≤6°C shall not 

be shipped until that temperature is reached. In addition, the length of time required for the 

samples to reach ≤6°C shall be documented in the field log sheet.

3.3.1 Influent to the FGD Wastewater Treatment System (SP-1)

The influent to the FGD wastewater treatment system (SP-1) will be collected directly 

from the settling basin at the point where the Units 1&2 and Units 3&4 sump transfer lines and 

the prescrubber blowdown lines enter the settling basin. Because the transfers from the sumps 

are not continuous, ERG will need to coordinate closely with Brindisi personnel during the 

sampling episode to determine when grab samples can be collected (i.e., when wastewater from 

both sumps is being transferred to the FGD wastewater treatment system). ERG will follow 

protocols described in EPA Method 1669 to collect metal sample fractions from SP-1.

For all analytes, the samplers will pump the samples directly from the settling basin into 

the specified containers using a peristaltic pump and tubing. The sampling equipment will 

consist of the following:

• Colorless, electronic-grade, non-nitrile gloves;

• Teflon® tubing;

• Silicone tubing;

• PVC piping;

• Peristaltic pump;

• Small table;

• Cleanbox;

• Tyvek® suits (for metals samples); 

• Masks (for mercury samples); and

• Sample containers.

ERG will follow all procedures and protocols described in EPA Method 1669 to clean all 

metals sampling equipment and to collect metal sample fractions. Two or more ERG samplers 

(one designated as “clean hands” and the other as “dirty hands”) will follow the protocols 

described in the steps below to set up the sampling point, collect the field blank samples, and 

collect wastewater samples. In addition to the specific instances noted in the steps below, the 

samplers will change gloves any time that the sampler has reason to believe his/her gloves have 

become contaminated. This section describes the set-up of the sample point and collection of the 

EPA samples.
3-4

1) Samplers remove the bags containing the gloves and HDPE plastic wrap from the 

coolers or storage containers in which they are packed. Samplers identify which 

coolers or boxes contain the double-bagged sample bottles, pre-cleaned tubing, 

and cleanbox.

2) Both samplers put on Tyvek® suits, gloves, and masks. “Dirty hands” covers 

work surfaces (tables and platform) with HDPE plastic wrap and places the 

double-bagged sample bottles and Teflon® tubing within easy access on the 

covered surface.

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

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

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

located inside the box.

4) “Dirty hands” opens the opening on the peristaltic pump head so the tubing can be 

placed in the pump head. “Dirty hands” opens the outer bag containing a length 

of pre-cleaned Teflon® tubing attached to a 10-foot length of pre-cleaned silicone 

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

the cleanbox. “Clean hands” opens the inner bag and removes the tubing. “Clean 

hands” places a clean plastic bag over the Teflon® and silicone ends of the tubing 

set. 

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

6) Both samplers change gloves.

7) “Dirty hands” opens the outer bags of the blank water and total mercury field 

blank sample bottles. “Clean hands” opens the inner bag for the field blank water, 

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

Teflon® end of the tubing into the blank water. “Clean hands” removes the total 

mercury field blank sample bottle and places it in the cleanbox. Working inside 

the cleanbox, “clean hands” opens in the inner bag and unscrews the lid of the 

total mercury field blank sample bottle. “Clean hands” holds the end of the 

silicone tubing outside the cleanbox over a bucket, with the plastic bag still 

covering the end of the tubing. “Dirty hands” operates the pump to pump blank 

water through the tubing. After the tubing has been purged with sufficient 

volume, “clean hands” places the silicone tubing back in the cleanbox and fills the 

total mercury field blank sample bottle. “Dirty hands” stops the pump. “Clean 

hands” places the plastic bag over the end of the silicone tubing, replaces the lid 

on the sample bottle, and closes the inner bag. “Clean hands” removes the bottle 

from the cleanbox and places it in the outer bag. “Dirty hands” closes the outer 

bag. The samplers repeat this procedure for the total metals field blank samples.

8) After collecting all of the total metals field blank samples, “clean hands” and 

“dirty hands” work together to place the Teflon® end of the tubing into the 

settling basin, taking care that the end of the tubing does not touch anything other 
3-5

than the sample water. The samplers will secure the Teflon® tubing to a piece of 

PVC piping so the samplers can easily control the position of the tubing in the 

basin.

9) Both samplers change gloves.

10) “Clean hands” holds the end of the silicone tubing outside the cleanbox over a 

bucket, with the plastic bag still covering the end of the tubing and “dirty hands” 

operates the pump to purge the tubing for a minimum of 2 minutes. After the 

tubing is purged, “Dirty hands” turns off the pump. “Clean hands” places the end 

of the silicone tubing back in the cleanbox.

11) “Dirty hands” opens the outer bag for the total mercury sample bottles. “Clean 

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

hands” opens the inner bag and bottle lid. “Dirty hands” operates the pump and 

“Clean hands” fills the sample bottle. “Dirty hands” stops the pump. “Clean 

hands” replaces the lid on the sample bottle and closes the inner bag. “Clean 

hands” removes the sample bottle from the cleanbox and places it in the outer 

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

the total metals samples.

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

13) “Clean hands” holds the tubing outside the cleanbox over a bucket and removes 

the plastic bag covering the end of the tubing. “Dirty hands” opens the lid of a 1-

L plastic container for field measurements and holds the bottle above the bucket 

while “clean hands” fills the bottle with sample from the tubing. The samplers 

will give the container to another sampling team member to measure the 

temperature and pH. 

14) “Dirty hands” opens the lid of the Group I sample container and holds the bottle 

above the bucket while “clean hands” fills the bottle with sample from the tubing. 

The samplers repeat this procedure for the Group II samples.

15) Immediately after all samples have been collected, the samplers preserve the 

samples according to the preservation protocols outlined in Sections 3.4 and 3.5. 

EPA and ERG plan to collect samples at the influent to the FGD wastewater treatment 

system (SP-1) on two consecutive days. The sample collection setup and sampling technique for 

each day of sampling will be the same.

3.3.2 Distillate from the Brine Concentrator (SP-2)

The distillate from the brine concentrator (SP-2) will be collected from the sample tap 

located on the discharge side of the pump that transfers the wastewater from the distillate tank 

through the heat exchanger and to the other distillate tank. For the sample collection, the plant 

will need to install a two-way splitter with 3/8 inch hose barbs on each splitter. Brindisi has 
3-6

agreed to install a two-way splitter on the sample tap that will have two separate taps to collect 

samples from the sampling point. ERG will follow protocols described in EPA Method 1669 to 

collect metal sample fractions from SP-2.

ERG will collect the distillate from the brine concentrator as manual composite samples 

collected into a large container (e.g., a 20-liter HPDE carboy). ERG will collect a total of 20

liters of sample volume, which will provide sufficient sample volume to collect all EPA samples, 

as well as volume for purging tubing and contingencies. ERG will collect five liters of sample 

every two hours for a six-hour period to collect the 20 liters of sample. Following the composite 

period, ERG will pump off the specific sample volumes into the individual sample containers.

ERG will use one 20-liter carboy to collect sample volume for the metals analyses 

(excluding mercury) and all classical analytes (i.e., Group I and Group II). In addition to 

collecting manual composite samples for the analytes listed above, ERG will collect total 

mercury grab samples every two hours during the compositing period. 

ERG will collect the total mercury grab samples by shrouding one of the two taps on the 

two-way splitter (the other tap is used for the compositor) and collecting the samples directly 

from the tap.

For all analytes, ERG will collect laboratory QC aliquots at the distillate from the brine 

concentrator (SP-2) on Day 2 of the sampling episode. 

The sample of the distillate from the brine concentrator (SP-2) will be collected from a 

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

• Colorless, electronic-grade, non-nitrile gloves;

• Large composite container (i.e., 20-liter carboy);

• Peristaltic pump;

• “T” splitter;

• Teflon® tubing;

• Silicone tubing;

• Cleanbox;

• Tyvek® suits (for metals samples); 

• Masks (for mercury samples); and

• Sample containers.

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

described in EPA Method 1669. The supplier of the cleaned bottles, tubing, and composite 

containers will prepare and analyze bottle blanks and equipment blanks to evaluate possible 

contamination. ERG will follow protocols described in EPA Method 1669 to collect metal 

sample fractions. Two or more ERG samplers (“clean hands” and “dirty hands”) will follow the 

protocols described in the steps below to set up the sampling point, collect the field blank 

samples, and collect wastewater samples. In addition to the specific instances noted in the steps 

below, the samplers will change gloves any time that the sampler has reason to believe his/her 

gloves have become contaminated. This section describes the set up of the sample point and 

collection of the EPA samples.
3-7

1) Samplers remove the bags containing the gloves and HDPE plastic wrap from the 

coolers or storage containers in which they are packed. Samplers identify which 

coolers or boxes contain the double-bagged composite containers, precleaned

tubing, blank water, and cleanbox.

2) Both samplers put on Tyvek® suits, masks, and gloves. “Dirty hands” covers 

work surfaces (ground or table) with HDPE plastic wrap and places the doublebagged composite container within easy access on the covered surface.

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

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

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

located inside the box.

4) “Dirty hands” opens up the peristaltic pump portion of an automatic compositor 

so the tubing can be added. “Dirty hands” opens the outer bag containing a length 

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

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

the cleanbox. “Clean hands” opens the inner bag and removes the tubing. “Clean 

hands” places a clean plastic bag over each end of the silicone tubing. The tubing 

configuration will be set up such that one end will be connected to the sample tap, 

one end will be connected to the large composite container, and one end will be 

placed next to a sump/drain near the sampling point. To collect the manual 

composite samples, the samplers will pinch the piece of tubing leading to the 

large composite container by folding a length of tubing over itself and holding it. 

The samplers will then open the sample tap, which will allow the sample to flow 

to the drain. The samplers will let the tap purge with sample for two minutes and 

will then pinch the piece of tubing leading to the drain and at the same time 

unpinch the tubing leading to the compositor. The samplers will allow the 

compositor to fill with five liters of sample and will then repinch the tubing 

leading to the compositor.

5) “Dirty hands” threads one portion of the silicone tubing through the peristaltic 

pump portion of the automatic compositor.

6) Both samplers change gloves.

7) “Dirty hands” opens the outer bag of the metals field blank water and the field 

blank composite container. “Clean hands” opens the inner bag for the field blank 

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

one end of the silicone tubing into the blank water. “Clean hands” also opens the 

inner bag for the field blank composite container and loosens the lid. “Clean 

hands” holds the silicone tubing with the plastic bag covering the end out of the 

cleanbox and over a bucket and “dirty hands” operates the pump to pump blank 

water through the tubing. After the tubing has been purged with sufficient 

volume, “clean hands” holds the silicone tubing at the mouth of the field blank 

composite container and fills the composite container with sufficient volume to 
3-8

collect the total metals field blank samples at the pump-off location. “Dirty 

hands” stops the pump. During the purging of the tubing and collection of the 

field blank sample volume, “dirty hands” pinches the silicone tubing that will be 

placed by the sump/drain to prevent this portion of the tubing configuration from 

filling with blank water during the pumping process. “Clean hands” places the 

plastic bag over the end of the silicone tubing, replaces the lid on the field blank 

composite container, places the silicone tubing back in the cleanbox, and closes 

the inner bag of the field blank composite container. “Dirty hands” closes the 

outer bag of the field blank composite container1

.

8) “Dirty hands” removed the silicone tubing from the peristaltic pump.

9) Both samplers work together to move the sampling tubing, automatic compositor, 

and composite container into position for the sample collection. Samplers will 

ensure that the tubing will stay in place during the six-hour sample collection 

period.

10) “Dirty hands” changes gloves.

11) “Clean hands” holds the end of the silicone tubing outside the cleanbox over a 

bucket, with the plastic bag still covering the end of the tubing. “Dirty hands”

places the end of the silicone tubing near the sump/drain and opens the sample tap 

valve to allow the wastewater to flow through the tubing. “Dirty hands” pinches 

the tubing leading to the drain which allows the sample to flow through the tubing 

that will be connected to the compositor. The samplers purge this portion of the 

tubing for a minimum of 2 minutes.

12) “Dirty hands” opens the outer bag of the large composite container. “Clean 

hands” opens the inner bag and connects the silicone tubing to the port on the 

composite container, securing the connection with a cable tie. “Clean hands” 

closes the inner bag around the composite bottle, and “dirty hands” closes the 

outer bag. The samplers put ice around the composite container to keep the 

samples cold during the compositing time period.

13) “Dirty hands” pinches the tubing leading to the composite container and opens the 

sample tap to allow the wastewater to flow to the drain for two minutes. “Dirty 

hands” then unpinches the tubing leading to the composite container as another 

“dirty hands” sampler then pinches the tubing leading to the drain. The samplers 

allow the composite container to fill with approximately five liters of sample and 

then “Dirty hand” pinches the tubing leading to the composite container while the 

other “dirty hands” sampler unpinches the tubing leading to the drain.

 1 ERG will collect field blank samples for all metals samples at the distillate from the brine concentrator on Day 1 of 

the sampling episode. Additionally, ERG will collect a total mercury field blank sample during one of the grab 

samples for each day of sample collection at the distillate from the brine concentrator.
3-9

14) “Dirty hands” zipties the tubing leading to the composite container such that it 

remains pinched until the next manual composite sample collection.

15) “Dirty hands” closes the sample tap and allows the wastewater to drain out of the 

sample tubing. “Dirty hands” pinches the tubing leading to the drain.

16) “Dirty hands” and “clean hands” then work to collect the total mercury field blank 

sample. “Dirty hands” shrouds the sample tap with a clear plastic bag that covers 

the end of the sample tap and provides enough room for samplers to work in with 

their hands. “Dirty hands” then opens the outer bag of the mercury field blank 

water and the total mercury field blank sample bottle. “Clean hands” opens the 

inner bag for the field blank water and the total mercury field blank sample bottle, 

unscrews the lids, and places each in its inner bag. “Clean hands” pours the field 

blank water into the field blank sample bottle, closes the lids, and closes the inner 

bags. “Clean hands” places the total mercury field blank sample bottle in the outer 

bag and “dirty hands” closes the outer bag.

17) “Dirty hands” positions a bucket under the sample tap, opens the valve and purges 

the valve for at least two minutes. “Dirty hands” then opens the outer bag of the 

total mercury sample bottle. “Clean hands” takes the bottles and positions 

himself/herself at the tap with the bottle under the shrouding and opens the inner 

bag. “Clean hands” opens the lid of the total mercury sample bottle and places the 

bottle under the flowing stream to fill the bottle. “Clean hands” then closes the lid 

on the bottle and closes the inner bag. “Dirty hands” closes the sample tap. “Clean 

hands” places the bottle in the outer bag and “dirty hands” closes the outer bag.

18) Samplers fill a 1-L jar for the field measurements. The samplers will give the jar 

to another sampling team member to measure the temperature and pH.

19) The samplers will collect five liters into the large composite container, total 

mercury grab samples, and a field test jar every two hours during the six-hour 

compositing time period.

20) After the fourth manual composite sample is collected, “dirty hands” opens the 

outer bag of the composite container. “Clean hands” opens the inner bag and 

detaches the used tubing from the composite container and covers the port with a 

closed lid. The samplers transport the composite containers, including the field 

blank composite container, to the pump-off area to pump off the samples into the 

specified containers.

After collecting the composite samples, the sampling team then needs to transfer the 

sample into the individual sample containers at the pump-off area. For this sampling point, ERG 

will use a sample pump-off approach to transfer the composite samples to the individual sample 

bottles.
3-10

Sample Pump-Off Procedures

21) Samplers remove the bags containing the gloves and HDPE plastic wrap from the 

coolers or storage containers in which they are packed. Samplers identify which 

coolers or boxes contain the double-bagged sample bottles, precleaned tubing, and 

cleanbox.

22) Both samplers put on Tyvek® suits and gloves. “Dirty hands” covers work 

surfaces with HDPE plastic wrap and places the double-bagged sample bottles 

and precleaned tubing within easy access on the covered surface.

23) “Dirty hands” opens the outer bag of the cleanbox and “clean hands” opens the 

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

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

located inside the box. 

24) “Dirty hands” opens the peristaltic pump head so the tubing can be placed in the 

pump head. “Dirty hands” opens the outer bag containing a length of precleaned

Teflon® tubing connected to a length of precleaned silicone tubing. “Clean 

hands” moves the tubing into the cleanbox and opens the inner bag and removes 

the tubing. “Clean hands” places a clean plastic bag over the end of the Teflon® 

and silicone tubing.

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

26) Both samplers change gloves.

27) “Dirty hands” opens the outer bag of the field blank composite container and total

metals field blank sample bottle. “Clean hands” removes the total metals field 

blank sample bottle and places it in the cleanbox. “Clean hands” opens the inner 

bag of the field blank composite container. “Clean hands” removes the lid from 

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

the blank water. “Clean hands” holds the end of the silicone tubing outside the 

cleanbox over a bucket, with the plastic bag still covering the end of the tubing 

and “dirty hands” operates the pump to pump about 750 mL of blank water from 

the field blank composite container. “Clean hands” places the end of the silicone 

tubing in the cleanbox, opens the inner bag of the total metals field blank sample 

bottle, and removes the lid. “Dirty hands” operates the pump to collect the total 

metals field blank sample and then stops the pump. “Clean hands” closes the lid 

on the sample bottle and closes the inner bag. “Clean hands” places the inner bag 

and bottle in the outer bag and “dirty hands” closes the outer bag.

28) “Dirty hands” shakes the large composite container to mix the sample. “Dirty 

hands” opens the outer bag for the composite container and “clean hands” opens 

the inner bag. “Clean hands” transfers the Teflon® tubing from the field blank 

composite container to the metals sample composite container. “Clean hands” 
3-11

holds the end of the silicone tubing outside the cleanbox over a bucket, with the 

plastic bag still covering the end of the tubing and “dirty hands” operates the 

pump to pump about one liter of sample through the tubing and then stops the 

pump.

29) “Dirty hands” opens the outer bag of the total metals sample bottle. “Clean hands” 

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

opens the inner bag and removes the lid. “Dirty hands” operates the pump to 

collect the total metals sample and then stops the pump. “Clean hands” closes the 

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

bag and bottle in the outer bag and “dirty hands” closes the outer bag. During Day 

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

the laboratory QC analyses.

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

31) “Clean hands” holds the silicone tubing outside the cleanbox over a bucket, with 

the plastic bag covering the end of the tubing. “Dirty hands” opens the lid of a 1-L 

plastic container for field measurements and holds the bottle above the bucket 

while “clean hands” fills the bottle with sample from the tubing. The samplers 

will give the container to another sampling team member to measure the 

temperature.

32) “Dirty hands” opens the lid of the Group I sample container and holds the bottle 

above the bucket while “clean hands” fills the bottle with sample from the tubing. 

The samplers repeat this procedure for the Group II samples. During Day 2 of the 

sampling episode, the samplers will collect additional sample volume for the 

laboratory QC analyses.

33) Immediately after all samples have been collected, the samplers preserve the 

samples according to the preservation protocols outlined in Section 3.4.

34) EPA and ERG plan to collect samples at the distillate from the brine concentrator

(SP-2) on three consecutive days. The sample collection setup and sampling 

technique for each day of sampling will be the same.

3.3.3 Condensate from the Crystallizer (SP-3)

The condensate from the crystallizer (SP-3) will be collected from the sample tap located 

on the discharge side of the pump that transfers the wastewater to the distillate tank. For the 

sample collection, the plant will need to install a two-way splitter with 3/8 inch hose barbs on 

each splitter. Brindisi has agreed to install a two-way splitter on the sample tap that will have two 

separate taps to collect samples from the sampling point. ERG will follow protocols described in 

EPA Method 1669 to collect metal sample fractions from SP-3.

ERG will collect the condensate from the crystallizer as manual composite samples 

collected into a large container (e.g., a 20-liter HPDE carboy). ERG will collect a total of 20 
3-12

liters of sample volume, which will provide sufficient sample volume to collect all EPA samples, 

as well as volume for purging tubing and contingencies. ERG will collect five liters of sample 

every two hours for a six-hour period to collect the 20 liters of sample. Following the composite 

period, ERG will pump off the specific sample volumes into the individual sample containers.

ERG will use one 20-liter carboy to collect sample volume for the metals analyses 

(excluding mercury) and all classical analytes (i.e., Group I and Group II). In addition to 

collecting manual composite samples for the analytes listed above, ERG will collect total 

mercury grab samples every two hours during the compositing period. 

ERG will collect the total mercury grab samples by shrouding one of the two taps on the 

two-way splitter (the other tap is used for the compositor) and collecting the samples directly 

from the tap.

For all analytes, ERG will collect laboratory QC aliquots at the condensate from the 

crystallizer (SP-3) on Day 3 of the sampling episode. 

The sample of the condensate from the crystallizer (SP-3) will be collected from a sample 

tap. The sampling equipment will consist of the following:

• Colorless, electronic-grade, non-nitrile gloves;

• Large composite container (i.e., 20-liter carboy);

• Peristaltic pump;

• “T” splitter;

• Teflon® tubing;

• Silicone tubing;

• Cleanbox;

• Tyvek® suits (for metals samples); 

• Masks (for mercury samples); and

• Sample containers.

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

described in EPA Method 1669. The supplier of the cleaned bottles, tubing, and composite 

containers will prepare and analyze bottle blanks and equipment blanks to evaluate possible 

contamination. ERG will follow protocols described in EPA Method 1669 to collect metal 

sample fractions. Two or more ERG samplers (“clean hands” and “dirty hands”) will follow the 

protocols described in the steps below to set up the sampling point, collect the field blank 

samples, and collect wastewater samples. In addition to the specific instances noted in the steps 

below, the samplers will change gloves any time that the sampler has reason to believe his/her 

gloves have become contaminated. This section describes the set up of the sample point and 

collection of the EPA samples.

1) Samplers remove the bags containing the gloves and HDPE plastic wrap from the 

coolers or storage containers in which they are packed. Samplers identify which 

coolers or boxes contain the double-bagged composite containers, precleaned 

tubing, blank water, and cleanbox.
3-13

2) Both samplers put on Tyvek® suits, masks, and gloves. “Dirty hands” covers 

work surfaces (ground or table) with HDPE plastic wrap and places the doublebagged composite container within easy access on the covered surface.

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

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

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

located inside the box.

4) “Dirty hands” opens up the peristaltic pump portion of an automatic compositor 

so the tubing can be added. “Dirty hands” opens the outer bag containing a length 

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

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

the cleanbox. “Clean hands” opens the inner bag and removes the tubing. “Clean 

hands” places a clean plastic bag over each end of the silicone tubing. The tubing 

configuration will be set up such that one end will be connected to the sample tap, 

one end will be connected to the large composite container, and one end will be 

placed next to a sump/drain near the sampling point. To collect the manual 

composite samples, the samplers will pinch the piece of tubing leading to the 

large composite container and open the sample tap, which will allow the sample 

to flow to the drain. The samplers will let the tap purge with sample for two 

minutes and will then pinch the piece of tubing leading to the drain and at the 

same time unpinch the tubing leading to the compositor. The samplers will allow 

the compositor to fill with five liters of sample and will then repinch the tubing 

leading to the compositor.

5) “Dirty hands” threads one portion of the silicone tubing through the peristaltic 

pump portion of the automatic compositor.

6) Both samplers change gloves.

7) “Dirty hands” opens the outer bag of the metals field blank water and the field 

blank composite container. “Clean hands” opens the inner bag for the field blank 

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

one end of the silicone tubing into the blank water. “Clean hands” also opens the 

inner bag for the field blank composite container and loosens the lid. “Clean 

hands” holds the silicone tubing with the plastic bag covering the end out of the 

cleanbox and over a bucket and “dirty hands” operates the pump to pump blank 

water through the tubing. After the tubing has been purged with sufficient 

volume, “clean hands” holds the silicone tubing at the mouth of the field blank 

composite container and fills the composite container with sufficient volume to 

collect the total metals field blank samples at the pump-off location. “Dirty 

hands” stops the pump. During the purging of the tubing and collection of the 

field blank sample volume, “dirty hands” pinches the silicone tubing that will be 

placed by the sump/drain to prevent this portion of the tubing configuration from 

filling with blank water during the pumping process. “Clean hands” places the 

plastic bag over the end of the silicone tubing, replaces the lid on the field blank 
3-14

composite container, places the silicone tubing back in the cleanbox, and closes 

the inner bag of the field blank composite container. “Dirty hands” closes the 

outer bag of the field blank composite container2

.

8) “Dirty hands” removed the silicone tubing from the peristaltic pump. 

9) Both samplers work together to move the sampling tubing, automatic compositor, 

and composite container into position for the sample collection. Samplers will 

ensure that the tubing will stay in place during the six-hour sample collection 

period. 

10) “Dirty hands” changes gloves.

11) “Clean hands” holds the end of the silicone tubing outside the cleanbox over a 

bucket, with the plastic bag still covering the end of the tubing. “Dirty hands”

places the end of the silicone tubing near the sump/drain and opens the sample tap 

valve to allow the wastewater to flow through the tubing. “Dirty hands” pinches 

the tubing leading to the drain which allows the sample to flow through the tubing 

that will be connected to the compositor. The samplers purge this portion of the 

tubing for a minimum of 2 minutes.

12) “Dirty hands” opens the outer bag of the large composite container. “Clean 

hands” opens the inner bag and connects the silicone tubing to the port on the 

composite container, securing the connection with a cable tie. “Clean hands” 

closes the inner bag around the composite bottle, and “dirty hands” closes the 

outer bag. The samplers put ice around the composite container to keep the 

samples cold during the compositing time period.

13) “Dirty hands” pinches the tubing leading to the composite container and opens the 

sample tap to allow the wastewater to flow to the drain for two minutes. “Dirty 

hands” then unpinches the tubing leading to the composite container as another 

“dirty hands” sampler then pinches the tubing leading to the drain. The samplers 

allow the composite container to fill with approximately five liters of sample and 

then “Dirty hand” pinches the tubing leading to the composite container while the 

other “dirty hands” sampler unpinches the tubing leading to the drain.

14) “Dirty hands” zipties the tubing leading to the composite container such that it 

remains pinched until the next manual composite sample collection.

15) “Dirty hands” closes the sample tap and allows the wastewater to drain out of the 

sample tubing. “Dirty hands” pinches the tubing leading to the drain.

 2 ERG will collect field blank samples for all metals samples at the condensate from the crystallizer on Day 1 of the 

sampling episode. Additionally, ERG will collect a total mercury field blank sample during one of the grab samples 

for each day of sample collection at the condensate from the crystallizer.
3-15

16) “Dirty hands” and “clean hands” then work to collect the total mercury field blank 

sample. “Dirty hands” shrouds the sample tap with a clear plastic bag that covers 

the end of the sample tap and provides enough room for samplers to work in with 

their hands. “Dirty hands” then opens the outer bag of the mercury field blank 

water and the total mercury field blank sample bottle. “Clean hands” opens the 

inner bag for the field blank water and the total mercury field blank sample bottle, 

unscrews the lids, and places each in its inner bag. “Clean hands” pours the field 

blank water into the field blank sample bottle, closes the lids, and closes the inner 

bags. “Clean hands” places the total mercury field blank sample bottle in the outer 

bag and “dirty hands” closes the outer bag.

17) “Dirty hands” positions a bucket under the sample tap, opens the valve and purges 

the valve for at least two minutes. “Dirty hands” then opens the outer bag of the 

total mercury sample bottle. “Clean hands” takes the bottles and positions 

himself/herself at the tap with the bottle under the shrouding and opens the inner 

bag. “Clean hands” opens the lid of the total mercury sample bottle and places the 

bottle under the flowing stream to fill the bottle. “Clean hands” then closes the lid 

on the bottle and closes the inner bag. “Dirty hands” closes the sample tap. “Clean 

hands” places the bottle in the outer bag and “dirty hands” closes the outer bag.

18) Samplers fill a 1-L jar for the field measurements. The samplers will give the jar 

to another sampling team member to measure the temperature and pH.

19) The samplers will collect a manual composite sample (i.e., five liters into the 

large composite container), a total mercury grab sample, and a field test sample

every two hours during the six-hour compositing time period.

20) After the fourth manual composite sample is collected, “dirty hands” opens the 

outer bag of the composite container. “Clean hands” opens the inner bag and 

detaches the used tubing from the composite container and covers the port with a 

closed lid. The samplers transport the composite containers, including the field 

blank composite container, to the pump-off area to pump off the samples into the 

specified containers.

After collecting the composite samples, the sampling team then needs to transfer the 

sample into the individual sample containers at the pump-off area. For this sampling point, ERG 

will use a sample pump-off approach to transfer the composite samples to the individual sample 

bottles. 

Sample Pump-Off Procedures

21) Samplers remove the bags containing the gloves and HDPE plastic wrap from the 

coolers or storage containers in which they are packed. Samplers identify which 

coolers or boxes contain the double-bagged sample bottles, precleaned tubing, and 

cleanbox.
3-16

22) Both samplers put on Tyvek® suits and gloves. “Dirty hands” covers work 

surfaces with HDPE plastic wrap and places the double-bagged sample bottles 

and precleaned tubing within easy access on the covered surface.

23) “Dirty hands” opens the outer bag of the cleanbox and “clean hands” opens the 

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

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

located inside the box. 

24) “Dirty hands” opens the peristaltic pump head so the tubing can be placed in the 

pump head. “Dirty hands” opens the outer bag containing a length of precleaned

Teflon® tubing connected to a length of precleaned silicone tubing. “Clean 

hands” moves the tubing into the cleanbox and opens the inner bag and removes 

the tubing. “Clean hands” places a clean plastic bag over the end of the Teflon® 

and silicone tubing.

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

26) Both samplers change gloves.

27) “Dirty hands” opens the outer bag of the field blank composite container and total

metals field blank sample bottle. “Clean hands” removes the total metals field 

blank sample bottle and places it in the cleanbox. “Clean hands” opens the inner 

bag of the field blank composite container. “Clean hands” removes the lid from 

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

the blank water. “Clean hands” holds the end of the silicone tubing outside the 

cleanbox over a bucket, with the plastic bag still covering the end of the tubing 

and “dirty hands” operates the pump to pump about 750 mL of blank water from 

the field blank composite container. “Clean hands” places the end of the silicone 

tubing in the cleanbox, opens the inner bag of the total metals field blank sample 

bottle, and removes the lid. “Dirty hands” operates the pump to collect the total 

metals field blank sample and then stops the pump. “Clean hands” closes the lid 

on the sample bottle and closes the inner bag. “Clean hands” places the inner bag 

and bottle in the outer bag and “dirty hands” closes the outer bag.

28) “Dirty hands” shakes the large composite container to mix the sample. “Dirty 

hands” opens the outer bag for the composite container and “clean hands” opens 

the inner bag. “Clean hands” transfers the Teflon® tubing from the field blank 

composite container to the metals sample composite container. “Clean hands” 

holds the end of the silicone tubing outside the cleanbox over a bucket, with the 

plastic bag still covering the end of the tubing and “dirty hands” operates the 

pump to pump about one liter of sample through the tubing and then stops the 

pump.

29) “Dirty hands” opens the outer bag of the total metals sample bottle. “Clean hands” 

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

opens the inner bag and removes the lid. “Dirty hands” operates the pump to 
3-17

collect the total metals sample and then stops the pump. “Clean hands” closes the 

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

bag and bottle in the outer bag and “dirty hands” closes the outer bag. During Day 

3 of the sampling episode, the samplers will collect additional sample volume for 

the laboratory QC analyses.

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

31) “Clean hands” holds the silicone tubing outside the cleanbox over a bucket, with 

the plastic bag covering the end of the tubing. “Dirty hands” opens the lid of a 1-L 

plastic container for field measurements and holds the bottle above the bucket 

while “clean hands” fills the bottle with sample from the tubing. The samplers 

will give the container to another sampling team member to measure the 

temperature.

32) “Dirty hands” opens the lid of the Group I sample container and holds the bottle 

above the bucket while “clean hands” fills the bottle with sample from the tubing. 

The samplers repeat this procedure for the Group II samples. During Day 3 of the 

sampling episode, the samplers will collect additional sample volume for the 

laboratory QC analyses.

33) Immediately after all samples have been collected, the samplers preserve the 

samples according to the preservation protocols outlined in Section 3.4.

EPA and ERG plan to collect samples at the condensate from the crystallizer (SP-3) on 

three consecutive days. The sample collection setup and sampling technique for each day of 

sampling will be the same.

3.4

All samples will be maintained on ice immediately upon collection (except metals 

samples that do not require cooling). Because the classical samples are required to be cooled, all 

composite containers will be maintained on ice. After pumping off the composite samples into 

the individual sample containers, the classical samples will be put in an ice-water bath; however, 

the metals samples, which do not require cooling, will 

Sample Preservation, Shipping, and Analysis 

not

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

requirements for each type of analysis. The type and amount of preservation used will be 

recorded on sample preservation log sheets (

be placed on ice. The classical grab 

samples collected at the FGD influent sampling point will also be placed on ice immediately 

after collection. All metals samples will be acid-preserved prior to extraction at the laboratory. 

Figure 3-1). If 10 percent of the sample volume is 

added and the required pH is not achieved, ERG will discontinue preservation to prevent the 

sample from being diluted any further and the final pH will be noted on the traffic report. The 

wastewater samples, except metals samples that do not require cooling, will be packed in ice 

chests with a sufficient quantity of ice to maintain a temperature of ≤6°C. All samples will be 

prepared for overnight shipment via Federal Express to laboratories.
3-18

3.5

Temperature and pH will be measured and recorded by the sampling crew at each 

sampling point (SP-1, SP-2, and SP-3). For SP-1, the samplers will measure the temperature and 

pH at the time the samples are collected. For SP-2 and SP-3, the samplers will measure 

temperature and pH each time a mercury grab sample is collected, which is every two hours 

during the compositing period. The samplers will fill a 1-liter plastic bottle with sample and test 

the wastewater for temperature and pH immediately after collecting the aliquot.

Field Measurements and Engineering Data Collection

Samplers will follow applicable test kit calibration procedures specified by the 

manufacturer. Table 3-4 summarizes the field measurements, the method to be used for the 

measurement, and the detection range of each field test instrument. In addition, EPA and ERG

will collect flow rate data for each sampled waste stream. The flow rates for all the sampling 

points will be collected from the plant’s existing flow recorders. 

Field sampling log sheets (Figure 3-2) will be completed at each sampling point. This 

sheet will record the sampling methodology, names of the samplers, sample collection time, field 

measurements, and any notes and observations.

Samplers will also collect engineering information with regard to design and operation of 

the plant. For example, they will collect information such as coal usage, plant capacity, 

wastewater flow rates, sludge generation rates (if applicable), and retention times in wastewater 

treatment process stages. Engineering data collection sheets (Figures 3-3, 3-4, and 3-5) will be 

completed for the plant. This information will be used to determine if the specific design or 

operational criteria of the steam electric operations affect the wastewater characteristics.

3.6

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

collection. Typically, labels are printed prior to arrival in the field, although they may also be 

completed by hand. Each self-adhesive label will be completed in indelible ink and contain the 

following information:

Sample Labeling

• Sample number;

• Sampling episode number;

• Sampling point/description;

• Date of sample collection;

• Analysis to be performed;

• Sample bottle type; and

• Required preservation.

If any of the preprinted information is incorrect, it will be revised using indelible ink. In 

particular, if a required preservation is not used, it will be marked out (additional preservation 

details will be noted on the traffic report). Once applied to the sample container, labels are 

covered with clear tape to prevent tampering, abrasion, smearing, or loss during transit. For 

metal samples, the samplers will not label the sample bottles, but will label the outer plastic bag 

of the sample bottle.
3-19

3.7

To maintain a record of sample collection, transfer between personnel, shipment, and 

receipt by the laboratory, samplers will complete a traffic report for each sample set at each 

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

the laboratory. Traffic report forms will be completed for all samples sent to all laboratories. 

Traffic Reports

Figure 3-6 includes an example of a traffic report. At the time of sample shipment, a copy of the 

traffic report will be sent to ERG, another copy will be kept by sampling personnel, and two 

copies will be transmitted with the samples to the analytical laboratory.

In addition to the transfer of custody, the traffic report provides information to the 

analytical laboratory on the sample number, type of water sample (in-line process, untreated 

wastewater, treated effluent), sample description, whether the sample is preserved, pH of the 

sample after preservation, type of sample (grab, composite), sample collection date and time, and 

the analyses requested. Samplers will use the comment section to provide special notes or 

instructions to the laboratory, such as whether samples have been filtered on site or how to 

composite separate samples prior to analysis. The sampling team will also comment if sample 

bottles are not completely filled (i.e., less than 75 percent full). In addition, the comments section 

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

not be acid-preserved because of excessive buffering).

3.8

The QA/QC program for sample collection at Brindisi will include the following:

Quality Assurance/Quality Control

• Documentation for samples through laboratory traffic reports;

• Collection of bottle blank(s) for metals;

• Collection of field blank(s) for metals;

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

• Collection of laboratory QC aliquots for matrix spike/matrix spike duplicate and 

laboratory duplicate analyses.

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

The bottle blank will consist of an analyte-free matrix (Ultra Pure Blank Water DI+TM) poured 

into the appropriate sample bottles (e.g., 250-mL plastic bottle for metals) and stored for several 

days prior to shipment to the laboratory. The supplier of the cleaned metals bottles will prepare 

and analyze the bottle blanks prior to shipping the equipment to the sampling episode.

Field blanks will be used to evaluate possible contamination caused by sampling 

equipment or by sampling equipment decontamination procedures. Field blanks will be prepared 

in the field prior to sample collection and analyzed for all sampling equipment, other than sample 

bottles, that come into direct contact with samples (e.g., tubing or filters). 
3-20

ERG will prepare field blanks for each of the total metals analyses at each of the three

sampling points during Day 1 of the sampling episode. Additionally, ERG will collect total 

mercury field blanks at the distillate from the brine concentrator and condensate from the 

crystallizer sampling points during the collection of one of the grab samples each day of the 

sampling episode. ERG samplers will use “clean hands / dirty hands” sampling techniques to 

prepare the metals field blanks, as discussed in more detail in Section 3.3. The total metals field 

blanks (including mercury) at the influent to the FGD wastewater treatment system will be 

prepared by pumping ASTM Type 1 water through the Teflon® and silicone tubing into the 

sample bottles. The total metals field blanks (excluding mercury) at the distillate from the brine 

concentrator and condensate from the crystallizer sampling points will be prepared by pumping 

ASTM Type 1 water through the composite tubing set into a large composite container where it 

will be held for the six-hour compositing period, then pumping the ASTM Type 1 water from the 

large composite container through the Teflon® and silicone tubing and into the sample bottles. 

The total mercury field blanks at the distillate from the brine concentrator and condensate from 

the crystallizer sampling points will be prepared by pouring ASTM Type 1 water directly into 

the sample bottles. The field blanks will determine if there is any contamination from the 

sampling equipment, atmospheric contamination, or other contamination from the surroundings.

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

metals to evaluate possible contamination of metals caused by the sampling equipment. The 

supplier of the tubing and composite containers will prepare and analyze these equipment blanks 

and provide a report certifying the equipment as clean. 

As part of standard laboratory quality control, matrix effects on analytical performance 

are assessed through the analysis of matrix spikes and laboratory duplicates. Consequently, 

additional sample volume must be collected for these laboratory QC analyses. The sampling 

team will collect, label, and ship the necessary laboratory QC volumes. Laboratory QC volumes 

(e.g., matrix spike (MS)/matrix spike duplicate (MSD) sample) will be collected for every 10

samples collected at a sampling event, excluding field blank samples. For all analytes requiring 

laboratory QC volumes, the sampling team will collect laboratory QC aliquots from the distillate 

from the brine concentrator (SP-2) during Day 2 of the sampling episode. The sampling team 

will also collect laboratory QC aliquots from the condensate from the crystallizer (SP-3) during 

Day 3 of the sampling episode.
3-21

Table 3-1. Sample Collection at Brindisi Power Plant

Sampling Point 

Number Sampling Point Name

Total Metals(EPA Method 200.8 with collision cell)Total Metals(EPA Method 200.7)Total Mercury Group I aGroup II b

SP-1 Influent to the FGD Wastewater Treatment System 2 2 2 2 2

SP-2 Distillate from the Brine Concentrator 3+1QC 3+1QC 3+1QC 3+1QC 3+1QC

SP-3 Condensate from the Crystallizer 3+1QC 3+1QC 3+1QC 3+1QC 3+1QC

SP-4 Influent to the FGD Wastewater Treatment System Field Blank 1 1 1

SP-5 Distillate from the Brine Concentrator Field Blank 1 1 3

SP-6 Condensate from the Crystallizer Field Blank 1 1 3

Total Number of Samples 11+2QC 11+2QC 15+2QC 8+2QC 8+2QC

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), chemical oxygen demand (COD), and total phosphorus.
3-22

Table 3-2. Analytical Methods 

Parameter Method Number

Maximum Holding 

Time a

Classicals

Chemical oxygen demand (COD) EPA 410.4 28 days

Total suspended solids (TSS) SM 2540 D 7 days

Total dissolved solids (TDS) SM 2540 C 7 days

Sulfate EPA 300.0 28 days

Chloride EPA 300.0 28 days

Ammonia as nitrogen EPA 350.1 28 days

Nitrate/nitrate as nitrogen EPA 353.2 28 days

Total Kjeldahl nitrogen (TKN) EPA 351.2 28 days

Total phosphorus EPA 365.1 28 days

Total Metals

Mercury EPA 1631E 90 days b

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

nickel, selenium, silver, thallium, and vanadium

EPA 200.8 with 

collision cell 

6 months

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

iron, magnesium, manganese, molybdenum, sodium, 

tin, titanium, and zinc

EPA 200.7 6 months

a The holding times are based on the on-site field preservation identified in Table 3-3. b The mercury samples must be preserved by the laboratory within 48 hours after sample collection.
3-23

Table 3-3. Summary of Sample Containers and Planned Preservation

Parameter

Sample 

Container and 

Volume

Laboratory 

QC Sample 

Container and 

Volume On-Site Preservation

Classicals

Group I a One 1-L plastic 

bottle

One 1-L plastic 

bottle

≤6°C

Group II b Two 1-L plastic 

bottles

Two 1-L plastic 

bottles

H2SO4 to pH <2, ≤6°C

Metals

Total metals (EPA Method 200.8 with 

collision cell)

One 500-mL 

plastic bottle

No additional 

volume needed

None

(acid preserve at laboratory)

Total metals (EPA Method 200.7) One 500-mL 

plastic bottle

No additional 

volume needed

None

(acid preserve at laboratory)

Total mercury: None

Manual composite grab samples (acid preserve at laboratory) Four 125-mL 

glass bottle

No additional 

volume needed

Influent samples and field blank 

samples

Two 250-mL 

glass bottle

No additional 

volume needed

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

b – Group II includes ammonia as nitrogen, COD, nitrate/nitrite as nitrogen, TKN, and total phosphorus.
3-24

Table 3-4. Sampling Point Field Measurements

Field Measurements Method Detection Range (or Gradation of Scale)

Temperature Thermometer -20 to 150 ± 1oC

pH (Standard Units) Four-color indicator strip

pH meter

0 to 12 ± 1 pH S.U.

-1.0 to 15.0 ± 0.1 pH S.U.
3-25

Sampling Episode ____________

Preservation Chemicals – List Strength of Solution from Bottle and Lot Number 

H2SO4 _____________________NH4SO4 ________________________

NaOH _____________________

Sample

Number

Analysis Date Time Name Chemical Initial 

pH

Final pH Number of 

Drops

Figure 3-1. Sample Preservation Log Sheet
3-26

Sampling Episode: _________________________________

Sampling Point: ___________________________________

Sample Numbers: __________________________________

Date: 

Manual Composite □ Grab □ 

Automatic Composite □ 

Time of Grab Sample Collection:

Start Time □ AM □ PM

End Time □ AM □ PM

Time of Automatic Sample Collection:

Start Time □ AM □ PM

End Time □ AM □ PM

Equipment Used: _________________________________________________

Samplers’ Names: ________________________________________________

Grab Sample Time

Temp

°C

pH 

(S.U.) 

meter / strips

Waste Stream Flow Rate 

(MGD)

1

2

3

4

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

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

Figure 3-2. Field Sampling Log Sheet
3-27

Plant Name: _______________________________________________________________________________

Plant Contact: ______________________________________________________________________________

Dates of Sample Collection: ___________________________________________________________________

Data Collected by: __________________________________________________________________________

Instructions: In the tables below, fill out information on the generating units and FGD systems operating at the plant based on all four days of the sampling 

episode. Note any changes in operation that occur during the four-day period. Provide actual data if possible. If actual data are not available, provide estimates 

for the specific information. Some of the data requested may not be susceptible to estimation. Enter “URE” for “unable to reasonably estimate.” Otherwise, 

specify whether data provided are actual or estimated by writing in “ACT” or EST” wherever appropriate.

Generating Unit Operating Characteristics During Sample Collection

Unit 

ID Boiler Type

Capacity 

(MW)

Electricity 

Production

(MW)

(or Percent 

Capacity %)

a

SCR

(No, On, 

Off)

Particulate 

Control System 

(HS/CS ESP, or 

BH)

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

midnight of the last day of sample collection.

FGD System Operating Characteristics During Sample Collection

Unit 

ID

Wet FGD 

System 

(Yes/No)

Type of 

Scrubber

Forced 

Oxidation 

(Yes/No) Sorbent

Additives 

(DBA, formic 

acid, etc.)

Prescrubber 

Water Source

FGD Makeup Water 

Source

SO2

Removal 

Percentage

Type of 

Solids 

Separation

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

Figure 3-3. Engineering Data Collection Sheet (Page 1 of 3)
3-28

Plant Name: _______________________________________________________________________________

Plant Contact: ______________________________________________________________________________

Dates of Sample Collection: ___________________________________________________________________

Data Collected by: __________________________________________________________________________

Instructions: In the tables below, provide information on the coal burned and FGD scrubber slurry at the plant for 

each day of the sampling episode. Provide actual data if possible. If actual data are not available, provide estimates 

for the specific information. Some of the data requested may not be susceptible to estimation. Enter “URE” for 

“unable to reasonably estimate.” Otherwise, specify whether data provided are actual or estimated by writing in 

“ACT” or EST” wherever appropriate.

Coal Information

Day of 

Sampling Unit ID Coal Type

Amount of 

Coal Used 

During 

Day of 

Sampling

Source of 

Coal (Coal 

Region 

and/or 

State)

Percent 

Sulfur in 

Coal

Chlorine 

Content of 

Coal

1

2

3

Note changes in operation over the past month (e.g., turned off SCRs on October 1 or burned 5% petroleum coke 

previous week) as well as conditions and changes during the sampling episode:

Scrubber Slurry Information

Day of 

Sampling

FGD 

System ID

Associated 

Unit IDs

Scrubber Slurry Blowdown 

Flow Rate

Scrubber 

Slurry 

Percent 

Solids 

Time of 

Dewatering 

During 

Sampling Day 

Flow Rate 

(gpm) Duration 

1

2

3

4

Figure 3-4. Engineering Data Collection Sheet (Page 2 of 3)
3-29

Plant Name: ________________________________________________________________________________

Plant Contact: ______________________________________________________________________________

Dates of Sample Collection: ___________________________________________________________________

Data Collected by: ___________________________________________________________________________

Instructions: In the table below, provide information on the FGD wastewater treatment system for each day of the sampling episode and the volumes of the FGD 

wastewater treatment system tanks and reactors. If possible, provide the name of the acid and polymer used during the sampling episode. Provide actual data if 

possible. If actual data are not available, provide estimates for the specific information. Some of the data requested may not be susceptible to estimation. Enter 

“URE” for “unable to reasonably estimate.” Otherwise, specify whether data provided are actual or estimated by writing in “ACT” or EST” wherever 

appropriate.

FGD Wastewater Treatment System Operation Information

Day of 

Sampling

Chemical Usage

(Quantity added - specify units)

Lime Caustic Soda

Sodium 

Sulfide

Ferric 

Chloride Polyelectrolyte

Ferrous 

Chloride Soda Ash

Hydrochloric 

Acid Anti-Scalant

1

2

3

Volume of equalization tank: 1)________________ 2) ________________

Volume of neutralization basins: 1) ________________ 2) ________________ 3) ________________ 4

Volume of clarifiers: 1) ________________ 2) ________________

) ________________ 

Volume of softening tanks: 1) ________________ 2) ________________ 

Figure 3-5. Engineering Data Collection Sheet (Page 3 of 3)
3-30

Figure 3-6. Example Traffic Report

EPISODE NO:

RANGE OF SAMPLE NOS:

Return completed form to:

FOR LAB USE ONLY

NAME: SHIP TO: DATE REC'D:

CITY: ATTN: REC'D BY:

STATE: CARRIER: SAMPLE CONDITION ON RECEIPT:

INDUSTRIAL CATEGORY: AIRBILL:

DATE SHIPPED:

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

SAMPLE 

NUMBER

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

ADDITIONAL 

SAMPLE 

DESCRIPTION

PH LEVELPRESERVED (Y/N)G=GRAB / C=COMPOSITESAMPLE COLLECTION TIME / DATE

Comments:

United States

EPA Environmental Protection Agency

Washington, DC 20460

TRAFFIC REPORT P.O. BOX 1407

USEPA ENGINEERING AND ANALYSIS DIVISION ALEXANDRIA, VA 22313

SAMPLE CONTROL CENTER (703) 519-1140

INDUSTRIAL FIRM SAMPLED SHIPPING & INFORMATION

SAMPLE POINT DESCRIPTION SAMPLE ANALYSES

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151
4-1

4. SAMPLING ACTIVITIES

This section discusses the sampling team organization, sampling preparation, and 

sampling activities.

4.1

The sampling crew will consist of a crew chief and one crew member from ERG and one

EPA representative. The crew chief will be responsible for all health and safety, sample 

collection, preservation, and shipping activities while at Brindisi. Following the sampling 

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

this information in a trip report to EPA. After EPA review, the report will be forwarded to 

Brindisi for review.

Sampling Team Organization

4.2

On February 14, 2011, ERG conducted a site visit at Brindisi. The site visit and 

subsequent follow-up telephone calls to Brindisi representatives provided ERG and EPA the 

necessary information to prepare for the sampling episode and to create this sampling plan. 

Presampling Preparation

As part of preparing the team for the sampling episode at Brindisi, the ERG crew chief 

will distribute this sampling plan to each team member and ensure they are completely familiar 

with the sampling plan and the health and safety requirements specific to Brindisi. 

The ERG crew chief will also coordinate the procurement and shipment of all necessary 

sampling and health and safety equipment. 

4.3

Upon arrival at Brindisi, the ERG crew chief, in conjunction with the EPA representative,

will meet with Brindisi personnel to determine whether samples can be collected as planned at 

each of the planned sampling points. Upon confirming the methods to collect samples, the ERG 

crew chief will update the descriptions of the proposed sampling points, if necessary, in 

consultation with EPA and Brindisi personnel. The changes to the sampling point collection 

techniques will be described in the trip report prepared by ERG after the sampling episode, 

described in Section 4.1. If necessary, the crew chief will obtain additional equipment. The 

revised sampling description will include:

Field Sampling Activities

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

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

• A list of potential physical hazards (e.g., pH, temperature, and potentially 

hazardous equipment);

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

• A list of proposed health and safety procedures. 

Prior to sampling, the ERG crew chief will notify the ERG Health and Safety 

Coordinator (HSC) of any revised sampling activity descriptions along with recommended 

revisions to the proposed health and safety procedures. Together, the crew chief and HSC will 

review the proposed health and safety procedures. The crew chief will incorporate any plant-
4-2

specific changes indicated by the HSC and receive approval for sampling from the HSC before 

proceeding with sampling activities.

All sample bottles will be labeled, collected, and preserved, according to method 

protocols. Sample fractions requiring ≤6oC preservation will be placed on ice. Sample fractions 

will then be sealed, and placed in coolers for shipment to the laboratory. The Traffic Report 

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

picked up by FedEx and shipped to the analytical laboratories. At the conclusion of the sampling 

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

4.4

This subsection summarizes Brindisi contacts, analytical laboratory contacts and 

addresses, and sampling team personnel and support functions.

Logistics

4.4.1 Federico II Power Plant

Claudio Mosti

Enel Produzione SpA

Via Carlo Bini 2

Florence, Italy 50134

+39 0555234086

Adolfo De Leo

Enel Produzione SpA

Centrale termoelettrica Federico II

Cerano (Brindisi), Italy, 72100

+39 0831254007

4.4.2 EPA Contacts

Ron Jordan

Engineering and Analysis Division

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (4303T)

Washington, D.C. 20460

(202) 566-1003

Jezebele Alicea

Engineering and Analysis Division

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (4303T)

Washington, D.C. 20460

(202) 566-1755
4-3

4.4.3 Analytical Laboratories

Classicals and Metals by 200.7 and 200.8 with Collision Cell

TestAmerica, Inc.

:

4955 Yarrow Street

Arvada, CO 80002

Phone: (303) 736-0138

Contact: Elizabeth Eichelberger

Frontier GeoSciences, Inc.

Mercury:

414 Pontius Ave. North

Seattle, WA 98109

Phone: (206) 957-1428

Contact: Patrick Garcia-Strickland

4.4.4 ERG Contacts

TJ Finseth (Crew Chief)

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633-1698

Deborah Bartram (Work Assignment Manager)

Eastern Research Group, Inc.

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633-1669

4.4.5 Freight Forwarders

Federal Express (FedEx)

General Information (800) 463-3339

Customer Service (Italy): 199-151-119
5-1

5. SAMPLE SHIPMENT

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

will be tracked using Traffic Report forms. Custody will be maintained by the sampling crew 

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

All samples will be packaged and shipped in accordance with U.S. Department of 

Transportation (DOT) or International Air Transport Association (IATA) regulations. The 

general IATA packaging requirements for air shipment are as follows:

• “Inner packaging must be so packed, secured or cushioned as to prevent their 

breakage or leakage and so as to control their movement within the outer 

packaging during normal conditions of transport. Cushioning material must not 

react dangerously with the contents of the inner packaging. Any leakage of the 

contents must not substantially impair the protective properties of the cushioning 

material. Unless otherwise provided in this paragraph or in the Packing 

Instructions, liquids in Classes, 3, 4, 5, 6, or 8 of Packing Groups I or II in glass or 

earthenware inner packaging, must be packaged using material capable of 

absorbing the liquid. Absorbent material must not react dangerously with the 

liquid. Absorbent material is not required...” (IATA Dangerous Goods 

Regulations, 5.0.16).

• “When filling receptacles for liquids, sufficient ullage (outage) must be left to 

ensure that neither leakage nor permanent distortion of the receptacle will occur 

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

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

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

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

nonhazardous samples. Hazardous samples will be identified based on consultation with the 

hazardous shipments contact, Steve Strackbein (ERG), and appropriate hazardous shipping 

procedures will be followed. Based on process considerations, samples collected at Brindisi will 

not be classified as IATA dangerous goods.

5.1

Samples will be collected as a series of “fractions,” or bottles designated for particular 

analyses requiring the same preservation. The comprehensive water sample set will consist of 

sample fractions for all pollutants listed in Section 3.2, collected as grab samples directly into the 

individual sample containers or composite samples that are transferred to individual sample 

containers using a pump-off approach.

Sample Set Preparation

5.2

All dilute samples from the plant will be packed according to the following guidelines 

(there is no limit on the amount of liquid each sample container may contain):

Sample Packing
5-2

1) Label each sample bottle. If a required preservation is not used, cross it off with 

indelible ink. Cover the label with clear tape to protect this information. Do not 

label metal sample bottles, but the outer plastic bag for each bottle instead.

2) Tighten the lid on each filled sample bottle, being careful not to overtighten the 

lid. If bottle threads are dirty to where the lid is impeded from closing, clean the 

threads on the bottle being careful to not introduce contamination into the sample. 

Clean the sample bottle with a cloth rag or paper towel. Do not clean the bottle 

threads for the metals sample bottles.

3) Prior to packaging, place each sample bottle requiring ≤6°C preservation into an 

ice chest with wet ice to cool.

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

temperature, wrap each glass sample bottle with two layers of “bubble wrap” (or 

place bottle in two “bubble bags”). The bubble wrap must fit snugly and 

completely cover the sample bottle. Enclose each “bubble-wrapped” container 

and plastic container in an individual sealable plastic freezer bag. 

5) Place two garbage bags inside each other in the cooler.

6) Place sample bottles in garbage bags in the cooler with proper end up, close the 

interior garbage bag by tying or with a twist-tie.

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

sealed plastic freezer bags filled with wet ice on top of the sample bottles (if 

samples require ≤6°C preservation). If using wet ice, place the ice inside two onegallon sealable freezer bags. Put at least 4 × 1⁄2 gallons of ice (4 × 2.5 pounds of 

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

small cooler. Use more ice when ambient temperatures are very high. Place the 

ice inside the second garbage bag and close the second garbage bag with a twisttie.

8) Fill in around the bottles and any free space with additional cushioning material. 

Use sufficient packing material so that the sample containers will not shift during 

shipment. 

9) Seal the Traffic Report form in a plastic zip-lock bag and tape it securely to the 

inside of the cooler lid.

10) Place a "Return to ..." label on the inside of the cooler lid.

11) Close cooler.

12) Make several wraps with tape around the cooler perpendicular to the seal to 

ensure that the lid will remain closed if the latch is accidentally released or 

damaged.
5-3

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

14) Place a completed address label on the lid of the cooler including name, address, 

and telephone number of the receiving laboratory and the return address and 

telephone number of the shipper.

15) Attach customs forms to the package, including commercial invoices and packing 

lists.
6-1

6. SITE-SPECIFIC HEALTH AND SAFETY PROCEDURES

This section specifies the health and safety procedures and practices to be used by the 

sampling team during sampling at Brindisi. This section provides general health and safety 

information for this sampling episode. The sampling team is obligated to follow all safety

procedures specified in this section.

6.1

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

situation. 

Emergency/Medical Procedures

6.1.1 First Aid

Brindisi has first aid kits available throughout the plant. In addition, ERG will also bring 

a first aid kit. In case of an emergency, EPA/ERG will immediately call the control room for 

safety response. Brindisi has first aid responders that are trained in CPR and emergency 

response and will respond to an emergency. 

6.1.2 Site Evacuation/Emergency Response Plan

The sampling team will be informed of the Brindisi evacuation procedures and routes by 

plant personnel. 

6.1.3 Emergency Showers and Eye Washes

Emergency showers and eye wash stations are located throughout the plant. Before 

collecting samples at any point, sampling team members will locate the nearest operating safety 

shower and eye wash station.

6.1.4 Local Hospital

The nearest hospital is Medicasa Italia, located in Brindisi, Italy, and is approximately 12 

miles from Federico II Power Plant. The hospital address is:

Medicasa Italia

Corso Giuseppe Garibaldi, 53

72100 Brindisi, Italy

0831 529920

6.2

The ERG Work Assignment Manager (WAM), crew chief, and sampling team members 

have different responsibilities to maintain a safe sampling environment. These responsibilities 

are described below.

ERG Health and Safety Responsibilities and Authority

6.2.1 Work Assignment Manager

The ERG WAM, Deborah Bartram, has the overall responsibility to ensure that these 

health and safety procedures are developed and implemented in accordance with regulations and 
6-2

corporate guidelines, that proper health and safety procedures have been initiated, and that all 

ERG activities are conducted in accordance with the health and safety plan. The ERG WAM will 

also ensure that proper resources are allocated so that the project is conducted in a safe manner, 

and that the crew chief is competent in his ability to oversee health and safety during the 

sampling episode.

6.2.2 Crew Chief

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

members adhere to this plan. The ERG crew chief is responsible for overseeing all activities. The 

crew chief must report any accident, near miss, or injury to any sampling team member to the 

ERG Chantilly Office Health and Safety Coordinator (HSC), Kevin Sikora, verbally within eight

hours, or sooner. The HSC will investigate the incident to identify the cause of the accident, near 

miss, or injury. If sufficient cause exists, ERG’s general health and safety plan and in-house 

training program will be modified to avoid similar accidents in the future.

At the start of the sampling visit, the crew chief will inspect all sampling points and 

review sample collection procedures with the Brindisi personnel to ensure that all potential 

hazards have been identified.

The crew chief has the authority to enforce ERG’s health and safety requirements 

contained in this plan, and any facility-specific requirements. Changes to this plan or the 

sampling plan can be made if the crew chief, the Chantilly HSC, and EPA representative agree 

that the changes are appropriate.

6.2.3 Sampling Team Members

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

to plant-specific health and safety procedures, and donning required/recommended personal 

protective equipment (PPE). They are also responsible for bringing health and safety issues to 

the attention of the crew chiefs.

6.3

ERG sampling team personnel will attend on- and off-site health and safety briefings.

Briefings

6.3.1 Off-Site Briefings

Prior to arriving on site, all members of the sampling team will receive a copy of this 

sampling plan and attend a presampling meeting to review the sampling plan and the proposed 

sample collection activities. All ERG employees will be required to sign a health and safety signoff sheet stating that they have read, understood, and agree with this health and safety plan prior 

to participating in field sampling activities.
6-3

6.3.2 On-Site Briefings

ERG sampling team personnel must attend a half-hour safety course given by Brindisi

personnel prior to conducting sampling activities at Brindisi. This safety course will review 

plant-specific health and safety procedures, including:

• Locations of on-site first aid/descriptions of emergency medical procedures;

• Required PPE;

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

• Emergency alarms and evacuation procedures; and 

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

6.4

ERG personnel will follow general safety procedures, which include wearing PPE and 

engaging in safe work practices.

Safety Procedures

6.4.1 PPE

The PPE listed below will be worn by ERG personnel at all times while inside the 

premises of Hatfield’s Ferry:

• Steel-toed safety shoes;

• Long sleeves (when collecting samples) and pants;

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

• Hearing protection, where needed;

• Nitrile or noncolored, electronic grade gloves, when collecting or preserving

samples; and

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

preserving samples.

For all phases of sample collection, disposable PPE will be used, so decontamination of 

the PPE may not be necessary. If gloves become torn or degraded, they will be thrown away and 

replaced with a new pair. Disposable PPE, including gloves, will be removed, bagged, and left at 

the site in a controlled manner.

6.4.2 Safety Practices

ERG personnel will conduct themselves at all times in a manner judged to be safe by site 

supervisors. 

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

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

system will ensure against an employee becoming injured or contaminated with chemicals 

without a coworker being aware of his or her condition. Workers should “watch out” for each 

other while working close to potential chemical and physical hazards. A Brindisi or EPA 

employee may be used as a buddy by ERG personnel. This arrangement will be agreed to and 

acknowledged by the employee. 
6-4

ERG employees will not enter any permit-required confined space areas. 

6.4.3 Safe Work Practices

ERG samplers will obey the following safety rules while working in the facility:

• Wearing PPE, where required;

• Staying within designated areas;

• Not wearing loose clothing or jewelry; 

• Keeping long hair in hard hat or tied back; 

• Not eating in the sampling or staging areas; and

• Not smoking in the sampling or staging areas.

6.5

All sampling team members will be advised of any sampling-point-specific safety 

protocols during the on-site health and safety briefing. 

Sampling-Point-Specific Safety Procedures

Table 6-1 summarizes all potential 

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

sampling team health and safety officer (HSO) for this sampling episode is the crew chief, TJ 

Finseth (ERG). The HSO and the sampling team will inspect each sampling point area to identify 

unique or additional hazards not already covered in this plan or during the formal health and 

safety briefing. If additional hazards are found, the sampling team will be informed of each 

hazard and required control measures prior to the start of work. Where identified hazards may 

affect the plant’s personnel, the HSO will notify the appropriate Brindisi personnel.

6.5.1 Physical Hazards

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

hazards may arise from using catwalks, hitting low-hanging overhead piping, and working 

around moving equipment or vehicles. ERG personnel will be aware of the potential splash 

hazards at SP-2 and SP-3 due to the location of the sample taps. To prevent splashing, ERG

personnel will ensure that the sample tubing is connected securely to the sample tap and will 

open the sample valve slowly when collecting samples. Other potential hazards may include 

falling hazards during sample collection, tripping on metal grates, or operation of large trucks 

and machinery in the vicinity of the sample collection area. See Table 6-1 for potential hazards 

that may be associated with specific sampling points.

Noise may be a hazard in certain areas of the facility. The sampling team will use hearing 

protection where required by the plant, when they are having trouble hearing or being heard 

when standing three feet or less away from another person, or when deemed necessary by the 

Brindisi personnel or ERG crew chief. 

6.5.2 Thermal Hazards

Heat stress may be a concern during the sampling episode. Samplers may be suited in 

Tyvek® and temperatures could reach extremes. 
6-5

The wastewater at SP-2 and SP-3 sampling points is expected to be extremely hot; 

therefore, during collection of the mercury grab samples at these locations, samplers will wear 

heat-resistant gloves. 

6.5.3 Chemical Hazards

The only chemical hazards expected are chemicals used to preserve samples. All 

sampling team members will be advised of any potential chemical hazards at each sampling 

point as well as any special PPE recommendations during the formal health and safety briefing. 

If the sample tap (i.e., the point from which the wastewater flows) is above waist height, a face 

shield or goggles must be worn during sample collection. To avoid ingesting chemicals, 

sampling team members will be required to wash hands thoroughly before eating or drinking. 

ERG personnel will not be permitted to enter areas where the facility has determined that 

respiratory protection equipment is necessary to protect against inhalation hazards. 

6.6

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

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

Temperature Extremes

6.6.1 Heat Stress

Heat stress is not only a concern in hot/humid outdoor environments, it is a concern due 

to the thermal or radiant heat generated by equipment and/or processes. Sampling team personnel 

will monitor each other for the following symptoms:

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

Treatment: Wear cotton clothing under coveralls or Tyvek®.

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

replacement. Many times, cramps may not occur until after work or until the 

worker is sleeping. Signs and symptoms include muscle spasms and pain in the 

hands, feet, and abdomen. 

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

rest in a cool shaded area.

• Heat exhaustion that occurs from increased stress on various body organs 

including inadequate blood circulation due to cardiovascular insufficiency or 

dehydration. Signs and symptoms include:

— Pale, cool, moist, clammy skin

— Heavy sweating

— Headache and dizziness

— Nausea

— Fainting or fatigue

— Elevated pulse rate (above 150)
6-6

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

Place worker in cool air and seek medical care.

• Heat stroke is the most serious form of heat stress. Temperature regulation fails 

and the body temperature rises to critical levels. Immediate action must be taken 

to cool the body before serious injury and death occur. Competent medical help 

must be obtained. Signs and symptoms are:

— Red, hot, usually dry skin, body core temperature 108°F (oral)

— Lack of or reduced perspiration

— Nausea

— Headache, dizziness, and confusion

— Strong, rapid pulse

— Coma

• Treatment: Remove worker to cool area, saturate clothes with cold water, wrap 

worker in wet cold sheets (if possible), monitor ABC (airway, breathing, 

circulation), treat for shock, and call emergency services for basic life support 

(BLS) or advanced life support (ALS).

6.6.2 Heat Stress Monitoring

A worker who exhibits any of the above symptoms will be immediately relieved of 

responsibilities and requested to consume electrolyte fluid or cool water while resting in a shaded 

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

symptoms appear critical, persist, or get worse, the crew chief will seek immediate medical 

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

increase in heart rate for the remainder of his/her shift. In addition, the worker will be requested 

to consume electrolyte fluid or cool water every hour.

• The crew chief will visually monitor workers hourly when:

• Symptoms of heat stress are reported or observed;

• Ambient temperatures exceed 70°F and workers are dressed in impervious 

clothing; or

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

For sampling on this project, work periods will be considered to be approximately two 

hours in length.

At ambient temperatures of 87°F and above, workers will be monitored for heat stress 

conditions by measuring the heart rate (HR) by radial (wrist) pulse for 30 seconds after one 

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

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

period remains the same. If the pulse rate is still higher than 110 beats per minute after one 
6-7

minute of rest in the next rest period, the following work cycle will be shortened by another 33 

percent. This shortening of the work period must continue until the worker's HR is no greater 

than 110 beats per minute.

6.7

First aid procedures in response to chemical exposures will be conducted in accordance 

with the appropriate Material Safety Data Sheets (MSDS) for the chemical involved. If an 

incident occurs and MSDSs are not available for a particular hazardous chemical (e.g., 

wastewater), the following general first aid procedures will be performed:

First Aid

• Skin Contact – Rinse the affected area thoroughly and copiously with clean water. 

Seek medical attention if irritation is experienced after cleaning.

• Eye Contact – Flush the eyes thoroughly at the nearest eyewash station for 15 

minutes. Follow up with medical attention.

• Ingestion – Notify the hospital and carry out any procedures recommended. 

The first aid kit will be maintained on each site in the equipment staging area. The 

contents of the first aid kit will include at a minimum:

• Adhesive bandages;

• Antiseptic wipes;

• A compress;

• An eyewash solution;

• Gauze pads;

• A cold pack; and 

• A triangular bandage.

The injuries most likely to be encountered at Hatfield’s Ferry are cuts and bruises; the 

first aid kit will be maintained and stocked accordingly.

6.8

Water samples to be analyzed for various contaminants may be preserved with sulfuric 

acid (H2SO4) before shipment to the analytical laboratory. Nitrile gloves and splash goggles must 

be worn when handling these corrosive chemicals to prevent chemical burns. Sample 

preservation must be performed in a well-ventilated area (preferably an operational lab hood) to 

avoid potential accumulation and inhalation of any toxic vapors. When pouring samples, skin 

protection must also be worn (long-sleeved cotton coveralls or uncoated Tyvek®, safety glasses 

with side shields or splash goggles, and nitrile gloves). Sodium arsenite is a known carcinogen 

and toxic so extra care should be taken when handling any solutions containing sodium arsenite.

Sample Preservation and Safety Considerations

In some instances, the use of these preservation chemicals could create a chemical 

reaction (i.e., generation of heat or release of toxic vapors). For instance, if acids are added to a 

wastewater sample containing cyanide or sulfides, dangerous and toxic vapors will be emitted. If 

the sample reacts violently, notify the crew chief and stop preserving the sample immediately.
6-8

In the case of a chemical spill, the following procedures must be followed:

• Don protective clothing (nitrile gloves as a minimum).

• Ventilate area (open doors, windows, or turn on ventilation).

• Use spill control pillows or prepared neutralizers to contain/clean up spill. Do not 

add water to acid.

• Place spilled material in a heavy plastic container, label the container, and contact 

site for disposal information.

• Notify the crew chief of the spill and the procedures used.

At any time, if personnel do not feel comfortable about cleaning up the spilled material or 

if a large quantity has been spilled, notify site personnel. The site may have an emergency 

response team who will respond to the chemical spill. 

In the case of fire, notify the site contact. If the fire can be easily extinguished using a 

portable fire extinguisher, and personnel have received fire extinguisher training, extinguish the 

fire using the portable extinguisher.

6.9

All ERG sampling crew personnel have participated in ERG's annual eight-hour health 

and safety training program as specified by ERG's Corporate Health and Safety Policy. 

Training and Medical Monitoring Requirements

This training includes:

• Toxicology;

• Exposure limits;

• Chemical, biological, and physical hazards;

• Heat and cold stress;

• Confined spaces;

• PPE;

• Decontamination; and

• Emergency plans and procedures.

All ERG personnel involved with sample collection and preservation are active 

participants in the Medical Monitoring Program. Field sampling personnel have received a 

baseline medical information review.

6.10

This subsection provides guidance for field personnel project schedules and field work, 

particularly overtime. It is important to remember extended work schedules will contribute to 

poor production and motivation. All field teams will rotate to ensure that sampling team 

members receive sufficient rest to avoid injuries resulting from fatigue or inattention.

Shift Work Protocol
6-9

It is common practice to perform 12-hour work days under project management direction. 

If this work schedule is exceeded, the following guidelines will be recognized:

1) A maximum work day will be 15 hours, provided that it does not occur on 

consecutive days, or more than three times in ANY SEVEN-DAY PERIOD.

2) Each shift will be followed by nine hours off per 24-hour period, excluding 

driving time to and from the hotel.

3) No more than seven consecutive days of work will be allowed without a 

minimum of 24 hours off.

4) Each work day will be reviewed as a 24-hour cycle to assure all field workers 

receive adequate time off.
6-10

Table 6-1. Sample-Point-Specific PPE and Potential Hazards

Sampling 

Point Number Sampling Point Description PPE Required a Potential Physical Hazards b

SP-1 Influent to the FGD 

Wastewater Treatment System

Steel-toed boots, hard hats, 

gloves, and safety glasses.

Fall and trip hazard: Potential 

for falling and tripping because 

one sampler will need to stand 

on a catwalk holding the tubing 

in the settling basin during 

sample collection.

SP-2 Distillate from the Brine 

Concentrator

Steel-toed boots, hard hats, 

gloves, safety glasses, and heatresistant gloves while collecting 

the mercury grab samples.

Thermal hazard: Potential for 

burns from the extremely hot 

temperatures of the samples.

SP-3 Condensate from the 

Crystallizer

Steel-toed boots, hard hats, 

gloves, safety glasses, and heatresistant gloves while collecting 

the mercury grab samples.

Thermal hazard: Potential for 

burns from the extremely hot 

temperatures of the samples.

a – Splash protection (face shield) required if sampling port is waist high or above. Hearing protection (ear plugs) 

will be worn if needed.

b – Additional physical hazards, if any, will be identified during the formal on-site health and safety briefing. 

Updates to this table will be made as needed.
7-1

7. REFERENCES

1. Eastern Research Group, Inc. 2010. Generic Sampling and Analysis Plan for Coal-Fired 

Steam Electric Power Plants. (February).

2. U.S. EPA. 2009. Steam Electric Power Generating Point Source Category: Final 

Detailed Study Report. EPA 821-R-09-008. Washington, DC. (October). Available online 

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