## Appendix B

We Energies’ Pleasant Prairie Power Plant

### Section 1

CWA 308 Monitoring Letter and InstructionsEnclosure 1

Instructions for Sample Collection, Packaging, and Shipment

EPA Sampling Program

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

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

guidelines and standards for the Steam Electric Power Gen erating Industry.

These instructions are being provided to We Energies’ Pleasa nt Prairie Power Plant to aid

in collecting, packaging, and shipping samples for this sampl ing program.

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

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

and cyanide at the effluent from the FGD wastewater tre atment sampling point. At the

FGD wastewater treatment effluent, the plant must co llect cyanide as a single grab

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

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

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

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

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

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

Equipment Needed

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

samples to the laboratories:

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

according to EPA Method 1669);

• Automatic compositor;

• Powder-free gloves;

• Tyvek® coveralls or suitable alternative;

• Dust masks (for use while collecting mercury samples)

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

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

• Coolers;

• Garbage bags;

• Packing material;

• Strapping tape; and

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

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

specified in the letter. Samples are to be collected fr om each of the two sampling points

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

for this sampling program. The following is a description o f the two sampling points:

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

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

transferred to the FGD wastewater treatment system pri or to any commingling

with other wastewaters or treatment system recycle s treams. This sample should

be collected from the sample tap located on the seconda ry hydroclone.

• FGD wastewater treatment effluent (SP-2) : This sampling point shall represent

the effluent from the FGD wastewater treatment syste m, prior to mixing with

dilution water or other streams. This sampling point shou ld be collected from the

sample tap that is located on the wastewater piping dow nstream of the effluent

storage tanks; where the plant collects its samples a ssociated with its NPDES

internal monitoring point.

Analytes

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

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

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

program, as well as the analytical methods that will be used to analyze the samples.

Table 1. Analytes and Analytical Methods Included in the Moni toring Program

Parameter Method Number

Classicals

Biochemical oxygen demand (BOD 5 ) SM 5210 B

Chemical oxygen demand (COD) EPA 410.4

Total suspended solids (TSS) SM 2540 D

Total dissolved solids (TDS) SM 2540 C

Sulfate EPA 300.0

Chloride EPA 300.0

Ammonia as nitrogen EPA 350.1

Nitrate/nitrate as nitrogen EPA 353.2

Total Kjeldahl nitrogen (TKN) EPA 351.2

Total phosphorus EPA 365.1

Total cyanide SM 4500 CN E

Total Metals

Total mercury EPA 1631E

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

selenium, silver, thallium, vanadium, and zinc EPA 200.8 with collision

cell

Aluminum, barium, beryllium, boron, calcium, cobalt, ir on, magnesium, manganese, molybdenum, sodium, tin, and titani um EPA 200.7SecondaryHydrocycloneOverflowLimeOrganosulfideFerricChloridePolymerHydrochloricAcidTreatedEffluent toDischargeTo Sludge DisposalEqualizationTankReaction Tank 1Primary ClarifierReactionTank 2ReactionTank 3FlashMix TankFlocculationTankSecondaryClarifierTreatedWastewaterStorageTanksSludge HoldingTankFilter PressFiltrateSumpSP-1SP-2Indicates a Sampling PointTreatedEffluentRecyclePolymerHydrochloricAcidFigure 1. Pleasant Prairie FGD Wastewater Treatment System Monitoring Program Sampling PointsSample Bottles and Preservation

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

cyanide.

Table 2. Summary of Sample Container and Planned Preservation

Parameter Sample Container

and Volume On-Site Preservation

BOD 5 One 1-L HDPE

bottle ≤ 6 ° C

Group I a One 1-L HDPE

bottle ≤ 6 ° C

Group II b Two 1-L HDPE

bottles H 2 SO 4 to pH <2, ≤ 6 ° C

Total cyanide One 1-L HDPE

bottle Dilution until sulfide is not detected,

NaAsO 2 until total chlorine is not

present, NaOH to pH >10, ≤ 6 ° C

Total metals (EPA Method 200.8 with

collision cell) One 500-mL HDPE

bottle None

(acid preserve at laboratory)

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

bottle None

(acid preserve at laboratory)

Total mercury:

Laboratory composite grab samples at FGD

wastewater treatment effluent Four 125-mL glass

bottles

Influent samples and field blank samples Two 250-mL glass

bottles None

(acid preserve at laboratory)

(a) Group I includes TSS, TDS, sulfate, and chloride.

(b) Group II includes ammonia as nitrogen, COD, nitrate/ni trite as nitrogen, TKN, and total phosphorus.

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

the four sets of samples.Sample Labeling

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

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

following information:

• Sample number (see Table 3);

• Sampling episode number (see Table 3);

• Sampling point/description (see Table 3);

• Date of sample collection;

• Analysis to be performed;

• Sample bottle type; and

• Required on-site preservation.

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

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

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

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

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

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

Table 3 provides the sampling point descriptions, sample numbe rs, and sampling episode

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

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

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

analysis:

• BOD;

• Group I;

• Group II;

• Total Cyanide;

• Total Metals – 200.8 w/ CC;

• Total Metals – 200.7;

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

• Total Mercury – Grab 1 (for FGD wastewater treatment ef fluent

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

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

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

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

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

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

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

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

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

Program

Sampling Point Description Sample Number Sampling Episode Number

FGD Wastewater Treatment Influent – Set 1 72041 6566

FGD Wastewater Treatment Influent – Set 2 72042 6566

FGD Wastewater Treatment Influent – Set 3 72043 6566

FGD Wastewater Treatment Influent – Set 4 72044 6566

FGD Wastewater Treatment Effluent – Set 1 72045 6566

FGD Wastewater Treatment Effluent – Set 2 72046 6566

FGD Wastewater Treatment Effluent – Set 3 72047 6566

FGD Wastewater Treatment Effluent – Set 4 72048 6566

FGD Wastewater Treatment Influent Field Blank 72049 6566

FGD Wastewater Treatment Effluent Field Blank – Set 1 72050 6566

FGD Wastewater Treatment Effluent Field Blank – Set 2 72051 6566

FGD Wastewater Treatment Effluent Field Blank – Set 3 72052 6566

FGD Wastewater Treatment Effluent Field Blank – Set 4 72053 6566

QC Samples

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

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

Table 4. Field Blank Collection Frequency

Sampling Point Total Mercury Total Metals (200.8

and 200.7) Classicals 1

FGD Wastewater

Treatment Influent Collected during one

of the four sets Collected during one

of the four sets No field blanks

required

FGD Wastewater

Treatment Effluent Collected during all

four sets Collected during all

four sets No field blanks

required

1 Classicals includes the analyses for BOD, Group I, Group II, and total cyanide.

The laboratory will perform MS/MSD analyses on the total metals and total mercury

analyses; however, no additional sample volume is requi red.

Sample Collection

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

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

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

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

airborne particles, dirt, and corrosion particulates fr om piping, railing, etc.The plant must collect grab samples for all analytes a t the influent to the FGD wastewater

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

except cyanide and mercury at the FGD wastewater treatme nt effluent sampling point.

The 24-hour composites must be set up to collect equal sam ple aliquots every hour over

the 24-hour period. For mercury at the FGD wastewater tr eatment effluent sampling

point, the plant must collect four individual grab samples over the 24-hour period (i.e., one

mercury grab collected every six hours). For cyanide at th e FGD wastewater treatment

effluent sampling point, the plant must collect a singl e grab sample after the one of the

mercury grab samples.

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

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

sampling plan drafted for the EPA sampling episode to colle ct the field blank samples, set

up the composite containers, and perform the composite pum p-off procedures for the FGD

wastewater treatment effluent sampling point. The foll owing instructions can be used to

collect the grab samples at the influent to the FGD wa stewater treatment system sampling

point and for the mercury and cyanide grab samples at the FGD wastewater treatment

effluent sampling point: (NOTE: If a sample tap or valv e is not available to collect these

samples or if the FGD wastewater treatment effluent sampling point has intermittent flows

which may interfere with the automatic composite colle ction, please contact TJ Finseth,

(703) 633-1698 to discuss possible alternatives.)

1. Arrive at the sampling point location and prepare supplies and bottles for

the sample collection.

2. Clean hands and dirty hands put on Tyvek® suits, masks, and powder-free

gloves.

3. Dirty hands gets a clear plastic bag and opens it slightl y (touching only the

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

open the bag completely.

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

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

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

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

collection.

5. Dirty hands opens the outer bags of the field blank wat er and total mercury

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

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

the inner bag of the total mercury and total metals field bl ank sample

bottles. Clean hands pours the blank water into the fi eld blank sample

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

Clean hands then places the total mercury and total met als bottles in the

outer bags and dirty hands closes the outer bag.

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

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

collected.7. Dirty hands opens the outer bag for the total mercury s ample bottle. Clean

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

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

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

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

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

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

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

composite samples.

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

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

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

plastic bag shrouding and collect directly from the tap.

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

shipment to the laboratories. Use the information provide d in the “Sample

Bottle and Preservation” section of these instruction f or the preservation

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

should be placed on ice immediately after sample coll ection/preservation.

Sample Packing and Shipment

The following steps should be used when packing and shipping the s amples to the

laboratories.

1. Make sure that each sample bottle has a label, and tha t the label correctly

specifies the sample point.

2. Tighten the lid on each filled sample bottle, being car eful not to

overtighten the lid. If bottle threads are dirty to w here the lid is impeded

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

contamination into the sample. Clean the sample bottl e with a cloth rag or

paper towel.

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

into an ice chest with wet ice to cool.

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

temperature, wrap each glass sample bottle with two layers of “bubble

wrap” (or place bottle in two “bubble bags”). The bubble wr ap must fit

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

freezer bag.

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

ship samples to the laboratories.

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

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

7. Add ice to the cooler to keep samples cold during shipment. Ar range 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 theice inside two one-gallon sealable freezer bags. Put at l east 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 sec ond garbage bag.

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

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

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

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

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

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

be shipped with the classicals, but the metals samples w ould need to be

chilled prior to packing them in the cooler with the clas sicals and ice

would need to be added to the cooler between the interior a nd outer

garbage bags to keep the samples cold.

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

coolers with additional cushioning material. Sufficient pac king material

should be used so that the sample containers will not shi ft during

shipment.

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

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

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

cooler(s). NOTE: the top page of the traffic report mus t be sent to ERG at

the following address:

Eastern Research Group

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

Attn: TJ Finseth

(703) 633-1698

12. Close the cooler(s).

13. Place a completed laboratory address label on the lid o f the cooler(s). The

classicals and metals samples should be shipped to TestAme rica as

follows:

TestAmerica

4955 Yarrow Street

Arvada, CO 80002

Attn: Elizabeth Eichelberger

(303) 736-0100

14. Make several wraps with strapping tape around the cooler pe rpendicular to

the seal to ensure that the lid will remain closed if t he latch is accidentally

released or damaged.

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

proper end up, close the interior garbage bag by tying, or with a twist-tie.16. Do not add ice to the mercury cooler, simply close the second garbage bag

by tying, or with a twist-tie.

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

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

containers will not shift during shipment.

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

electronically by ERG). Seal the last two pages of the traffic report form

in a plastic envelope secured to the inside of the top o f the cooler. NOTE:

the top page of the traffic report must be sent to ERG a t the same address

provided in step 11:

19. Close the cooler.

20. Place a completed laboratory address label on the lid o f the cooler. The

mercury samples should be shipped to Frontier as follows:

Frontier GeoSciences

414 Pontius Ave. North

Seattle, WA 98109

Attn: Patrick Garcia-Strickland

(206) 957-1428

21. Make several wraps with strapping tape around the cooler pe rpendicular to

the seal to ensure that the lid will remain closed if t he latch is accidentally

released or damaged.

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

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

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

the coolers to the laboratories.

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

Finseth at (703) 633-1698, to notify him that the samples have b een shipped to the laboratories.

Traffic Reports

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

collection event. The plant will need to make changes t o the traffic report electronically

for the other three sample collection events. Some information, such as the date and

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

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

After the traffic report is completed by the plant, th e plant must print the four pages in the

file. The last two pages in the file must be placed in t he cooler for shipment to the

laboratories and the first page must be sent to ERG. The plant can keep the second page

of the traffic report.Engineering Data

The plant must provide engineering data regarding the operatio n of the plant and FGD

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

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

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

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

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

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

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

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

.

Certification Statement

The individual responsible for directing and supervising the s ample collection and the

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

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

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

the same time the engineering data is submitted.Complete the following tables for each sampling pointPlant NameSampleCollectionNumberDate of SampleCollectionSample CollectionTime Temperature (°C)pH(S.U.)Set 1Set 2Set 3Set 4Plant NameSampleCollectionNumberUnit OverflowSampled atInfluent(7 or 8)Influent SamplesCollected as Grabs(Yes or No)Mercury and CyanideSamples Collected asGrabs(Yes or No)Effluent SamplesCollected as 24-Hour Composites(Yes or No)Tyvek Suitsused(Yes or No)Dust MasksUsed forMercury(Yes or No)Clean Hands/DirtyHands SamplingTechniques Used(Yes or No)Description of SampleCollection Technique (ifdifferent thaninstructions)Description of AbnormalConditions in FGD Systemor FGD WastewaterTreatment System that MayImpact ConcentrationsSet 1Set 2Set 3Set 4Complete the following tables based on the plant operating characteristics during each set of samplescollectedUnits OperatingDuring SamplingDayUnits Off-lineEntireSampling DaySCRs/SNCRsOperating onUnitsSet 1Set 2Set 3Set 4Flow Rate (gpm)DurationSet 1Set 2Set 3Set 4Lime Usage(tons)Ferric ChlorideUsage(Liters/day)Organosulfide Usage(Liters/day)Polymer Usage(Liters/day)Acid Usage(Liters/day)ChemicalPrecipitationSystem EffluentFlow Rate (gpd)Set 1Set 2Set 3Set 4Plant NameSampleCollectionNumberDate of SampleCollectionPlant Operation During Sample CollectionPlant NameSampleCollectionNumberDate of SampleCollectionPlant Operation During Sample CollectionScrubber Slurry Blowdown FlowRateScrubber SlurryPercent SolidsPercent HydrocloneOverflow RecycledBack to ScrubberFGD Wastewater Treatment Operation During Sample CollectionPlant NameSampleCollectionNumberDate of SampleCollectionScrubber PurgeFlow Rate DuringInfluent SampleCollection(gpm)Unit 1 Unit 2 Daily Power Generation (MW-hrs)

Plant Name Date Provide the daily power generation for each scrubbe d unit starting two weeks prior to the first

set of samples through the last set of samplesFGD Wastewater Treatment System Flow

Rates

(gpd)

Chemical Precipitation Effluent Plant Name Date Provide the average flow rate in the FGD wastewater treatment system for each stream included in the

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

Authority

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

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

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

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

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

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

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

he may reasonably require."

Confidentiality

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

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

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

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

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

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

procedures, set forth in Subpart B.

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

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

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

without further notice to you.

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

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

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

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

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

satisfy the criteria for confidentiality.

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

Notice of Intent to Transfer Confidential Information to Sel ected EPA Contractors

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

selected EPA contractors.

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

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

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

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

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

limitations guidelines and standards for the Steam Electri c Power Generating industry.

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

development of these regulations are listed below:

EPA Office

Receiving

Support Contractor Name EPA Contract

No. Type of Support

Eastern Research Group, Inc. 68-C-02-095 Engineering analysi s Office of Water/

Office of

Science &

Technology/

Engineering &

Analysis

Division Westat EP-C-10-023 Statistical analysis

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

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

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

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

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

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

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

Ronald Jordan

USEPA Headquarters

Ariel Rios Building

1200 Pennsylvania Ave., N.W.

Mail Code: 4303T

Washington, DC 20460

jordan.ronald@epa.govEnclosure 4

Certification Statement

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

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

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

representative.

Certification Statement

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

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

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

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

data required, and that the sampling and engineering data provided are complete and ref lect

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

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

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

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

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

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

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

in Section 308 of the Clean Water Act.

Signature of Certifying Official Date

( )

Printed Name of Certifying Official Telephone Numbe r of Certifying Official

Title of Certifying Official

Company Name

### Section 2

On

- Site Audit Memorandum

### MEMORANDUM

TO: Ron Jordan, EPA

Jezebele Alicea, EPA

FROM: TJ Finseth, ERG

DATE: 12 November 2010

SUBJECT: Notes from On-Site Review of Industry Self-Monitoring Sampl ing at We

Energies’ Pleasant Prairie Power Plant on November 2-3, 2010

ERG conducted an on-site review of the self-monitoring sampling conducted at the We

Energies’ Pleasant Prairie Power Plant (Pleasant Pr airie) located in Pleasant Prairie, WI. ERG

was on site for all sample collection activities tha t Pleasant Prairie conducted for the second set

of the industry self-monitoring sampling on November 2 and 3, 2010. These notes summarize

the sample collection techniques used by Pleasant Prairie at each of the sampling points and

EPA’s observations/findings from the on-site review. An overall process water diagram for the

Pleasant Prairie plant is provided as Attachment 1. The checklists that EPA completed as part of

the on-site review are provided as Attachment 2.

During this set of the industry self-monitoring, Unit 1 wa s shut down to replace a layer of

catalyst in its selective catalytic reduction system. The unit was shut down on October 8, 2010,

and was expected to commence operation on Friday, November 5, 2010. Therefore, for this set

of samples, only Unit 2 was operating.

The following sections describe the sample collection at each of the sampling points and

the observations/findings from each sampling point.

FGD Wastewater Treatment Influent (SP-1)

The FGD wastewater treatment influent consists of th e secondary hydrocyclone overflow

that is transferred to the equalization tank at the beg inning of the FGD wastewater treatment

system; therefore, the samples from this sampling point were collected as grab samples. For this

sampling point, Pleasant Prairie used a sample tap off of the drain of the secondary hydrocyclone

overflow piping that transfers the secondary hydrocyclon e overflow to the equalization tank.

This is the same sampling point that EPA used during its samp le collection.

Sample Collection

To collect the samples of the FGD wastewater treatm ent influent, Pleasant Prairie

personnel followed EPA Method 1669 protocols and the EPA-provi ded instructions. PleasantMemorandum

November 9, 2010

Page 2

Prairie personnel shrouded the tap with a clean plastic b ag and let the sample flow from the tap

for two minutes prior to collecting any samples. The samp lers then collected the samples

underneath the shroud. At this sampling point, Pleasant Pr airie only collected samples for the

EPA program and did not collect their own split sample s. All samples were filled from the tap

while the samplers held the bottles under the shrouding.

Preservation

Pleasant Prairie personnel followed all method specific ations when preserving the

classical samples. The Group II samples were preserve d using H 2 SO 4 and the pH was confirmed

to be below 2 S.U. The cyanide samples were checked for sulfides and chlorine using lead

acetate paper and potassium iodide starch paper, respectiv ely. The samplers did not detect

sulfides or chlorine in the samples. The cyanide samp les were then preserved using NaOH and

the pH was confirmed to be above 10 S.U. The BOD, Group I, Group II, and cyanide samples

were all placed on ice after collection or preservati on.

Field Measurements

Pleasant Prairie personnel used a pH probe and a temperatur e probe to measure the pH

and temperature of the FGD wastewater influent samples. Pleasant Prairie personnel filled a

small bottle with sample after collecting the metals samples and prior to collecting the classicals

samples. After completing the classicals sample col lection, Pleasant Prairie personnel

transported the field test bottle to the laboratory ar ea, poured some of the sample into a small

beaker, and inserted temperature and pH probes into the bea ker with sample. Pleasant Prairie

personnel stated that they had already calibrated the te mperature and pH probes; however, ERG

did not observe the calibration of the probes. Pleasan t Prairie personnel allowed the temperature

and pH stabilize and then recorded the values.

Observations/Findings

ERG observed the Pleasant Prairie personnel collectin g the Set 2 samples of the FGD

wastewater treatment influent stream. Pleasant Prair ie did not collect the field blanks during the

sample collection activities because they were colle cted during Set 1. Pleasant Prairie personnel

followed all applicable procedures during the sample collect ion. Pleasant Prairie personnel used

the correct techniques to preserve the classicals samples . The Group II samples were preserved

18 minutes after collection.

FGD Wastewater Treatment Effluent (SP-2)

The FGD wastewater treatment effluent stream is the effluent from a chemical

precipitation system used to treat the Pleasant Prairie FGD wastewater; therefore, the samples for

this sampling point were collected as composite samples, except for the mercury and cyanide

samples. For the composite samples at this sampling po int, Pleasant Prairie collected the

samples using the plant’s existing compliance monitoring poi nt and the existing ISCO auto

sampler, which is not the same sampling point that EPA used during its sample collection;Memorandum

November 9, 2010

Page 3

however, the two sampling points are both on the same wa stewater piping and there are no

chemical additions or process operations that occur bet ween the two sampling points. The

Pleasant Prairie auto sampler is configured with a piece of tubing that connects a tap on the

wastewater piping to a three-way control valve. The va lve is controlled by the ISCO auto

sampler to either pull sample to the compositor or purge s ample to the drain. When the ISCO

sampler is preparing to collect a sample, the valve opens the line to the drain to let fresh sample

enter the tubing and once the line is flushed, the valve s witches to allow the sample to be pulled

to the compositor. For the mercury and cyanide grab sampl es at this sampling point, Pleasant

Prairie collected the samples from one of the efflue nt samples taps, which are the same taps that

were used by EPA during its sample collection.

Sample Collection

To collect the samples of the FGD wastewater treatm ent effluent, Pleasant Prairie

personnel followed EPA Method 1669 protocols and the EPA-provi ded instructions. To collect

the composite samples, Pleasant Prairie personnel repl aced the tubing that connects the threeway control valve to the ISCO auto sampler with specia lly-cleaned silicone tubing. Pleasant

Prairie personnel attached one end of the specially-clea ned silicone tubing to the outlet from the

three-way control valve and the other end was threaded thr ough the ISCO 6712 auto sampler and

attached to a vented cap on a 20-liter carboy. The sampl ers programmed the compositor to

collect 830 mL of sample every hour for a 24-hour period. After the 24-hour period, the

samplers removed the composite tubing from the ISCO auto s ampler and replaced it with a short

piece of Teflon® tubing connected to a length of silicone tubing to transfer the samples to

individual sample bottles. The samplers first shook the 20-liter container to homogenize the

sample and then they attached a pump-off cap onto the car boy. The Teflon® end of the tubing

was then inserted into the carboy and the tubing was purged w ith two liters of sample. Pleasant

Prairie personnel then collected the metals samples usi ng a cleanbox. Additionally, the plant

collected multi-fill splits in the cleanbox. After a ll the metals samples were collected, the

samplers filled the classical samples outside the cl eanbox. Pleasant Prairie collected multi-fill

split samples for the Group I and Group II samples; howe ver, for the BOD and cyanide samples,

the samplers only collected samples for the EPA progra m.

Pleasant Prairie personnel also collected grab samples for mercury every six hours during

the sampling. The samplers collected the mercury sampl es at this sampling point by shrouding

one of their effluent sample taps with a clean plasti c bag and letting sample flow through the

sample tap for two minutes prior to collecting any sample s. Pleasant Prairie personnel filled the

mercury bottles directly from the tap, underneath the s hroud. The samplers collected the

mercury samples as multi-fill splits. Pleasant Prai rie personnel also collected the cyanide

samples as a grab sample immediately after the first of the four mercury grab samples at the

sampling point. Pleasant Prairie personnel did not colle ct a cyanide split sample.

Preservation

Pleasant Prairie personnel followed all method specific ations when preserving the

classicals samples, which are the same as those descr ibed in the Preservation section for the FGDMemorandum

November 9, 2010

Page 4

wastewater treatment influent stream. Additionally, t he plant kept the composite container on

ice during the sample collection time period.

Field Measurements

Pleasant Prairie personnel did not collect a field tes t sample to test for the temperature

and pH. Instead, the samplers calibrated the inline temp erature and pH probes at the effluent

sampling location prior to the sampling episode and recorded th e temperature and pH at the time

each mercury grab was collected, which was every six hour s. ERG was not present at the time

the temperature and pH probes were calibrated.

Observations/Findings

ERG/EPA observed the Pleasant Prairie personnel collec ting the composite set up, composite

breakdown, and composite pump off for the Set 2 samples. Pleasant Prairie personnel collected

field blank samples for the total metals samples during thi s set. ERG also observed the Grab 1

and 2 mercury grab samples and the cyanide grab sample. Pl easant Prairie personnel collected

the mercury field blank sample during the Grab 1 sample. P leasant Prairie personnel followed

all applicable procedures during the sample collection and pr eservation, except the samplers did

not test the temperature of the composite carboy after the completion of the compositing period.

ERG communicated this issue to the samplers to allow the m to fix this for the remaining

samples.

ERG noted that the Pleasant Prairie personnel replaced the tubing that connected the

three-way control valve to the ISCO auto sampler; howe ver, the Pleasant Prairie personnel did

not replace the tubing that connected the wastewater pipi ng to the three-way control valve.

Therefore, ERG cannot be certain that there was not c ontamination from that tubing. ERG

communicated this issue to the samplers to allow them t o fix this for the remaining samples.

ERG also noted that the ISCO 6712 auto sampler required t he samplers to thread the

tubing (including the end of the tubing) through the pump to set up the composite tubing;

however, when the samplers were threading the tubing th rough the ISCO, the end of the tubing

was covered with a Ziploc bag to prevent potential conta mination.

## Attachment 1

Overall Process Water Diagram

## Attachment 2

Checklists

### Section 3

Signed Certification StatementEnclosure 4

Certification Statement

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

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

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

representative.

Certification Statement

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

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

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

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

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

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

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

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

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

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

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

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

in Section 308 of the Clean Water Act.

Signature of Certifying Official Date

( )

Printed Name of Certifying Official Telephone Number of Certifying Official

Title of Certifying Official

Company Name David M. Lee March 3, 2011

Manager - Water Quality

Wisconsin Electric Power Company 414 221-2158

, d/b/a We Energies Digitally signed by David M. Lee

DN: cn=David M. Lee, o=We Energies, ou=Environmental Department, email=David.

Lee@we-energies.com, c=US

Date: 2011.03.03 10:11:57 -06'00'

### Section 4

Engineering DataTable B 4

- 1. Field Measurement s for Sample Collection at the Influent to FGD Wastewater Treatment System, Pleasant Prairie

Episode Number Sample Collection

Number Date of Sample

Collection Sample Collection

Time Temperature

(°C) pH

(S.U.)

6566 Set 1

- Grab 1 09/30/10 0 808 53.0 6.40

6566 Set 2

- Grab 1 11/03/10 0 757 46.1 6.89

6566 Set 3

- Grab 1 12/08/10 0 8 06 50.5 6.70

6566 Set 4

- Grab 1 01/26/11 0 756 51.0 6.27Table B 4

- 2. Field Measurement s for Sample Collection at the Ef fluent from the FGD Wastewater Treatment System

, Pleasant

Prairie

Episode Number Sample Collection

Number Date of Sample

Collection Sample Collection

Time Temperature

(°C) pH

(S.U.)

6566 Set 1

- Grab 1 09/29/ 20 10 10 19 40.1 6.78

6566 Set 1

- Grab 2 09/29/ 20 10 16 17 40.6 6.89

6566 Set 1

- Grab 3 09/29/ 20 10 22 10 40.5 6.97

6566 Set 1

- Grab 4 09/30/ 20 10 04 10 40.1 6.89

6566 Set 2

- Grab 1 11/02/ 20 10 1034 33.9 7.10

6566 Set 2

- Grab 2 11/02/ 20 10 16 30 34.9 7.09

6566 Set 2

- Grab 3 11/02/ 20 10 22 28 35.1 7.05

6566 Set 2

- Grab 4 11/03/ 20 10 04 23 35.2 7.07

6566 Set 3

- Grab 1 12/07/ 20 10 1010 34.9 7.02

6566 Set 3

- Grab 2 12/07/ 20 10 16 04 34.6 6.97

6566 Set 3

- Grab 3 12/07/ 20 10 22 06 35.0 7.03

6566 Set 3

- Grab 4 12/08/ 20 10 04 02 35.2 7.03

6566 Set 4

- Grab 1 01/25/ 20 11 1008 36.8 7.07

6566 Set 4

- Grab 2 01/25/ 20 11 15 58 36.9 7.05

6566 Set 4

- Grab 3 01/25/ 20 11 21 55 37.9 6.99

6566 Set 4

- Grab 4 01/26/ 20 11 03 57 38.2 7.70Table B 4

- 3 . Sample Collection Procedures Used during the Sampling Episode

Episode

Number Sample

Collection

Number Influent

Samples

Collected as

Grabs

(Yes or No) Mercury

and Cyanide

Samples

Collected as

Grabs

(Yes or No) Bioreactor Influent

and Bioreactor

Effluent Samples

Collected as 24

- Hour Composites

(Yes or No) Clean

Hands/D irty

Hands Sampling

Techniques Used

(Yes or No) * Description of

Sample

Collection

Technique (if

different than

instructions) Description of Abnormal

Conditions in FGD

System or FGD

Wastewater Treatment

System that May Impact

Concentrations

6566 Set 1 Yes Yes Yes Yes None None

6566 Set 2 Yes Yes Yes Yes None None

6566 Set 3 Yes Yes Yes Yes None None

6566 Set 4 Yes Yes Yes Yes None None

* Includes the use of tyveks suits during all sampling events and dust masks during the collection of mercury samples.Table B 4

- 4

. Generating Unit Operation at Time of Sampling, Pleasant Prairie

Episode Number Sample Collection

Number Date of Sample

Collection Plant Operation During Sample Collection

Units Operating

During Sampling

Day Units Off

- line Entire

Sampling Day SCRs/SNCRs

Operating on

Units

6566 Set 1 09/30/10 Unit 1/2 None SCR

6566 Set 2 11/03/10 Unit 1/2 * None SCR

6566 Set 3 12/08/10 Unit 1/2 None SCR

6566 Set 4 01/26/11 Unit 1/2 None SCR

* Unit 1 was in start up mode on November 3, 2010. The FGD system was in service, but the unit had not yet reached high enough steam pressure

to generate power.Table B 4

- 5. FGD Scrubber Slurry Information at Time of Sampling, Pleasant Prairie

Episode

Number Sample

Collection

Number Date of Sample

Collection Plant Operation During Sample Collection

Scrubber Slurry Blowdown

Flow Rate Scrubber

Slurry

Percent

Solids Percent Hydroclone

Overflow Recycled

Back to Scrubber ** Flow Rate

(gpm) Duration *

6566 Set 1 09/30/10 500 continuous 20% 75%

6566 Set 2 11/03/10 500 continuous 20% 75%

6566 Set 3 12/08/10 500 continuous 20% 75%

6566 Set 4 01/26/11 530 continuous 20% 75%

* Primary hydroclone flow on both scrubbers was 24 hr/day on sampling days, with minor flow rate variation.

** Based on system design.Table B 4

- 6 . FGD Wastewater Treatment System Operation Information, Pleasant Prairie

Episode

Number Sample

Collection

Number Date of Sample

Collection Scrubber Purge

Flow Rate During

Influent Sample

Collection

(gpm) FGD Wastewater Treatment Operation During Sample Collection

Lime

Usage

(tons) * Ferric

Chloride

Usage

(Liters/day) Organosulfide

Usage

(Liters/day) Polymer Usage

(Liters/day) * Acid Usage

(Liters/day)

6566 Set 1 09/30/10 46 0.26 40 12 4 20

6566 Set 2 11/03/10 50 0.26 40 7 4 20

6566 Set 3 12/08/10 40 0.26 37 7 4 10

6566 Set 4 01/26/11 46 0.26 36 9 4 20

* Based on longer

- term averages.Table B 4

- 7 . Daily Power Generation During Sampling Period, Pleasant Prairie

Episode Number Date Daily Pow er Generation

(MW

- hrs)

Unit 1 Unit 2

6566 09/15/10 12,936 13,098

6566 09/16/10 12,706 11,819

6566 09/17/10 13,104 12,332

6566 09/18/10 8,875 9,315

6566 09/19/10 7,944 7,969

6566 09/20/10 12,097 12,013

6566 09/21/10 12,205 12,653

6566 09/22/10 12,716 11,551

6566 09/23/10 12,679 12,378

6566 09/24/10 11,106 11,870

6566 09/25/10 9,575 10,867

6566 09/26/10 9,743 9,506

6566 09/27/10 11,049 11,837

6566 09/28/10 10,076 12,660

6566 09/29/10 9,907 12,814

6566 09/30/10 7,573 11,345

6566 10/01/10 13,324 13,968

6566 10/02/10 11,830 10,509

6566 10/03/10 10,912 11,253

6566 10/04/10 13,808 12,960

6566 10/05/10 12,882 13,331

6566 10/06/10 13,443 13,067

6566 10/07/10 12,649 12,761

6566 10/08/10 13,325 13,146

6566 10/09/10 12,823 13,034

6566 10/10/10 12,624 12,533

6566 10/11/10 13,043 13,177

6566 10/12/10 13,517 13,862

6566 10/13/10 12,949 13,179

6566 10/14/10 12,316 12,052

6566 10/15/10 11,037 12,810

6566 10/16/10 337 12,714

6566 10/17/10 0 11,630

6566 10/18/10 0 13,871

6566 10/19/10 0 13,541

6566 10/20/10 0 13,256

6566 10/21/10 0 13,706

6566 10/22/10 0 13,250

6566 10/23/10 0 13,518

6566 10/24/10 0 12,306

6566 10/25/10 0 13,349Table B 4

- 7 . Daily Power Generation During Sampling Period, Pleasant Prairie

Episode Number Date Daily Pow er Generation

(MW

- hrs)

Unit 1 Unit 2

6566 10/26/10 0 12,446

6566 10/27/10 0 12,984

6566 10/28/10 0 13,035

6566 10/29/10 0 13,477

6566 10/30/10 0 14,693

6566 10/31/10 0 13,936

6566 11/01/10 0 14,105

6566 11/02/10 0 14,039

6566 11/03/10 0 13,711

6566 11/04/10 14 14,341

6566 11/05/10 9,017 14,539

6566 11/06/10 11,168 11,655

6566 11/07/10 9,547 10,492

6566 11/08/10 12,537 10,077

6566 11/09/10 12,624 10,891

6566 11/10/10 11,942 12,044

6566 11/11/10 11,077 11,165

6566 11/12/10 12,094 12,165

6566 11/13/10 11,534 12,032

6566 11/14/10 11,107 11,110

6566 11/15/10 13,562 13,311

6566 11/16/10 13,228 12,871

6566 11/17/10 13,472 11,778

6566 11/18/10 14,827 327

6566 11/19/10 13,532 0

6566 11/20/10 12,397 0

6566 11/21/10 12,213 0

6566 11/22/10 12,762 0

6566 11/23/10 13,129 0

6566 11/24/10 12,924 0

6566 11/25/10 9,641 0

6566 11/26/10 10,874 0

6566 11/27/10 13,309 0

6566 11/28/10 8,695 981

6566 11/29/10 10,675 10,424

6566 11/30/10 10,997 10,902

6566 12/01/10 12,729 12,752

6566 12/02/10 12,519 12,366

6566 12/03/10 13,429 12,869

6566 12/04/10 9,903 10,388

6566 12/05/10 10,614 10,656

6566 12/06/10 12,564 12,433

6566 12/07/10 12,583 12,910Table B 4

- 7 . Daily Power Generation During Sampling Period, Pleasant Prairie

Episode Number Date Daily Pow er Generation

(MW

- hrs)

Unit 1 Unit 2

6566 12/08/10 12,023 12,472

6566 12/09/10 11,050 11,248

6566 12/10/10 12,274 12,137

6566 12/11/10 9,536 9,610

6566 12/12/10 10,193 10,036

6566 12/13/10 13,350 13,785

6566 12/14/10 12,281 11,699

6566 12/15/10 10,525 10,476

6566 12/16/10 10,944 12,950

6566 12/17/10 12,545 12,750

6566 12/18/10 13,306 11,192

6566 12/19/10 14,780 11,925

6566 12/20/10 13,528 11,878

6566 12/21/10 13,883 11,090

6566 12/22/10 13,652 11,642

6566 12/23/10 12,953 10,966

6566 12/24/10 11,680 9,750

6566 12/25/10 8,506 8,428

6566 12/26/10 8,773 8,600

6566 12/27/10 11,568 10,752

6566 12/28/10 11,927 12,074

6566 12/29/10 8,687 9,463

6566 12/30/10 9,077 8,153

6566 12/31/10 9,461 9,259

6566 01/01/11 8,179 8,674

6566 01/02/11 10,569 9,834

6566 01/03/11 12,519 11,894

6566 01/04/11 12,510 12,174

6566 01/05/11 13,534 12,950

6566 01/06/11 12,605 12,643

6566 01/07/11 10,131 9,895

6566 01/08/11 12,158 11,522

6566 01/09/11 10,544 12,371

6566 01/10/11 12,844 12,669

6566 01/11/11 12,309 12,034

6566 01/12/11 9,949 9,759

6566 01/13/11 11,856 11,852

6566 01/14/11 12,389 10,630

6566 01/15/11 11,932 10,122

6566 01/16/11 9,617 9,585

6566 01/17/11 10,131 9,583

6566 01/18/11 10,627 11,009

6566 01/19/11 11,297 10,893Table B 4

- 7 . Daily Power Generation During Sampling Period, Pleasant Prairie

Episode Number Date Daily Pow er Generation

(MW

- hrs)

Unit 1 Unit 2

6566 01/20/11 11,869 10,645

6566 01/21/11 11,624 10,516

6566 01/22/11 12,454 10,686

6566 01/23/11 8,778 9,953

6566 01/24/11 12,357 12,182

6566 01/25/11 13,042 13,041

6566 01/26/11 13,381 12,695

Note : Unit 1 was shut down from October 17

– November 4, 2010 to replace SCR catalyst. Unit 2 was

shut down from November 19

– 28, 2010 to repair a superheater tube leak. The plant does not expect that

these shut downs had any major impact on the wastewater samples collected during or near these outages.Table B 4

- 8. FGD Wastewater Treatment System Flow Rate during Sampling Period,

Pleasant Prairie

Episode Number Date FGD Wastewater Treatment System Flow Rates

(gpd)

Chemical Precipitation Effluent

6566 09/15/10 66,519

6566 09/16/10 46,657

6566 09/17/10 65,405

6566 09/18/10 49,088

6566 09/19/10 7,462

6566 09/20/10 27,287

6566 09/21/10 55,058

6566 09/22/10 51,324

6566 09/23/10 68,913

6566 09/24/10 57,490

6566 09/25/10 59,318

6566 09/26/10 11,389

6566 09/27/10 28,910

6566 09/28/10 50,103

6566 09/29/10 57,805

6566 09/30/10 57,705

6566 10/01/10 64,702

6566 10/02/10 58,417

6566 10/03/10 0

6566 10/04/10 26,776

6566 10/05/10 57,176

6566 10/06/10 62,193

6566 10/07/10 52,653

6566 10/08/10 65,033

6566 10/09/10 53,279

6566 10/10/10 0

6566 10/11/10 28,732

6566 10/12/10 41,366

6566 10/13/10 15,276

6566 10/14/10 57,590

6566 10/15/10 48,246

6566 10/16/10 38,595

6566 10/17/10 42,249

6566 10/18/10 67,006

6566 10/19/10 47,189

6566 10/20/10 52,341

6566 10/21/10 66,490

6566 10/22/10 58,215

6566 10/23/10 41,733Table B 4

- 8. FGD Wastewater Treatment System Flow Rate during Sampling Period,

Pleasant Prairie

Episode Number Date FGD Wastewater Treatment System Flow Rates

(gpd)

Chemical Precipitation Effluent

6566 10/24/10 0

6566 10/25/10 33,651

6566 10/26/10 11,023

6566 10/27/10 39,026

6566 10/28/10 65,718

6566 10/29/10 38,183

6566 10/30/10 42,073

6566 10/31/10 12,071

6566 11/01/10 25,020

6566 11/02/10 54,967

6566 11/03/10 57,603

6566 11/04/10 66,572

6566 11/05/10 25,674

6566 11/06/10 0

6566 11/07/10 0

6566 11/08/10 153

6566 11/09/10 22,710

6566 11/10/10 59,203

6566 11/11/10 36,795

6566 11/12/10 64,266

6566 11/13/10 57,444

6566 11/14/10 0

6566 11/15/10 21,620

6566 11/16/10 48,053

6566 11/17/10 57,285

6566 11/18/10 63,463

6566 11/19/10 47,348

6566 11/20/10 54,652

6566 11/21/10 15,375

6566 11/22/10 32,175

6566 11/23/10 49,798

6566 11/24/10 57,785

6566 11/25/10 55,649

6566 11/26/10 56,615

6566 11/27/10 52,735

6566 11/28/10 15,436

6566 11/29/10 25,575

6566 11/30/10 58,290

6566 12/01/10 58,104

6566 12/02/10 38,057

6566 12/03/10 59,997Table B 4

- 8. FGD Wastewater Treatment System Flow Rate during Sampling Period,

Pleasant Prairie

Episode Number Date FGD Wastewater Treatment System Flow Rates

(gpd)

Chemical Precipitation Effluent

6566 12/04/10 56,449

6566 12/05/10 8,148

6566 12/06/10 21,975

6566 12/07/10 60,070

6566 12/08/10 55,510

6566 12/09/10 47,693

6566 12/10/10 62,496

6566 12/11/10 59,826

6566 12/12/10 2,430

6566 12/13/10 24,737

6566 12/14/10 42,010

6566 12/15/10 69,009

6566 12/16/10 49,713

6566 12/17/10 60,752

6566 12/18/10 58,909

6566 12/19/10 0

6566 12/20/10 0

6566 12/21/10 34,848

6566 12/22/10 51,044

6566 12/23/10 62,279

6566 12/24/10 53,463

6566 12/25/10 60,912

6566 12/26/10 306

6566 12/27/10 29,573

6566 12/28/10 63,829

6566 12/29/10 52,017

6566 12/30/10 63,769

6566 12/31/10 59,315

6566 01/01/11 53,767

6566 01/02/11 0

6566 01/03/11 27,029

6566 01/04/11 45,561

6566 01/05/11 63,453

6566 01/06/11 63,374

6566 01/07/11 60,008

6566 01/08/11 55,355

6566 01/09/11 0

6566 01/10/11 0

6566 01/11/11 0

6566 01/12/11 0

6566 01/13/11 0Table B 4

- 8. FGD Wastewater Treatment System Flow Rate during Sampling Period,

Pleasant Prairie

Episode Number Date FGD Wastewater Treatment System Flow Rates

(gpd)

Chemical Precipitation Effluent

6566 01/14/11 0

6566 01/15/11 0

6566 01/16/11 0

6566 01/17/11 0

6566 01/18/11 27,094

6566 01/19/11 56,829

6566 01/20/11 43,440

6566 01/21/11 14,766

6566 01/22/11 4,858

6566 01/23/11 11,504

6566 01/24/11 14,662

6566 01/25/11 53,096

6566 01/26/11 43,622

NOTE 1 : The FGD wastewater secondary clarifier (a lamella type clarifier) is typically removed from service

every Saturday to clean scale from the incline section and baffles. Without weekly cleaning, the secondary clarifier

performance deteriorates to unaccepta ble levels. Sometimes the system is not returned to service during a 24

- hour

period, so a zero flow for the day will be indicated. Since this is a routine practice, there would be no impact to the

wastewater samples from one week compared to another.

NOTE 2: The January flow data had zero flow for a number of consecutive days due to Lake intake warming with

the wastewater discharge line. (Some or all of the cooling tower blowdown and other wastewaters flowing through

the common discharge line can be recir culated to the intake structure in Lake Michigan to keep it free from icing.)

During intake warming, the plant do es not discharge FGD wastewater effluent to avoid potential cooling tower

chemistry problems that could arise from mixing the treated FGD wast ewater with the cooling tower makeup

water from the lake. The plant expect s t hat higher concentrations of various constituents could be present in samples

taken after this period compared to periods of more continuous effluent discharge.

### Section 5

Analytical DataND – Not detected (number in parentheses is the quantitation limit).NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit). The analytical result ispresented in Tables B5-6 through B5-18 with a J flag designation. A “NQ” for the 4-set average result indicates that all results were below the quantitation limit, but at least oneresult is a J-value.^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.B – Analyte was found in the blank and sample.Est – Estimated value.F – MS and/or MSD not within laboratory control limits.Min – Minimum value.Table B5-1. Influent to FGD Wastewater Treatment System, Pleasant PrairieAnalyteUnitsMethodInfluent to FGD Wastewater Treatment System (SP-1)Set 1Set 2Set 3Set 44-SetAverageClassicalsAmmonia mg/L350.1 1.90 2.10 2.30 3.20 2.38Nitrate Nitrite as N mg/L353.2 190 160 160 230 185Nitrogen, TotalKjeldahlmg/L351.2 64.0 B, Min 34.0 73.0 29.0 50.0BiochemicalOxygen Demandmg/L5210B ND (2.00) ND (2.00) ND (2.00) ND (2.00) ND (2.00)Chemical OxygenDemandmg/L410.4 480 450 F 420 520 468Chloridemg/L300.0 2,300 1,800 2,000 3,100 2,300Sulfatemg/L300.0 14,000 14,000 11,000 13,000 13,000Cyanide, Total mg/L4500 CN E 0.290 Est 0.160 0.290 0.370 0.278Total DissolvedSolidsmg/L2540C 27,000 19,000 23,000 21,000 22,500Total SuspendedSolidsmg/L2540D 4,200 4,900 4,700 6,400 5,050Phosphorus, Total mg/L365.1 5.00 8.00 B 0.0560 B8.80 B5.46Total MetalsAluminum ug/L 200.7 140,000 170,000 B 87,000 95,000 123,000Antimony ug/L 200.8 56.0 57.0 42.0 25.0 45.0Arsenicug/L 200.8 150 170 110 72.0 126ND – Not detected (number in parentheses is the quantitation limit).NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit). The analytical result ispresented in Tables B5-6 through B5-18 with a J flag designation. A “NQ” for the 4-set average result indicates that all results were below the quantitation limit, but at least oneresult is a J-value.^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.B – Analyte was found in the blank and sample.Est – Estimated value.F – MS and/or MSD not within laboratory control limits.Min – Minimum value.Table B5-1. Influent to FGD Wastewater Treatment System, Pleasant PrairieAnalyteUnitsMethodInfluent to FGD Wastewater Treatment System (SP-1)Set 1Set 2Set 3Set 44-SetAverageBariumug/L 200.7 840 1,000 B 790 670 825Beryllium ug/L 200.7 4.60 4.70 3.70 3.30 4.08Boronug/L 200.7 18,000 B 17,000 B 17,000 B19,000 B17,800Cadmium ug/L 200.8 12.0 11.0 7.70 8.80 9.88Calciumug/L 200.7 660,000 710,000 B 780,000 610,000 690,000Chromium ug/L 200.8 1,100 1,100 ^ 690 370 815Cobaltug/L 200.7 140 140 130 160 143Copperug/L 200.8 900 1,000 680 400 745Ironug/L 200.7 390,000 410,000 B 250,000 180,000 308,000Leadug/L 200.8 210 270 170 110 190Magnesium ug/L 200.7 4,600,000 B 4,100,000 B 3,500,000 B4,300,000 4,130,000Manganese ug/L 200.7 96,000 B 90,000 B 75,000 86,000 B86,800Mercuryng/L 1631E 1,320,000 973,000 1,420,000 1,830,000 1,390,000Molybdenum ug/L 200.7 250 220 190 140 200Nickelug/L 200.8 1,400 1,400 1,500 1,200 1,380Selenium ug/L 200.8 16,000 18,000 11,000 9,100 13,500Silverug/L 200.8 NQ (2.00) NQ (2.00) NQ (2.00) NQ (2.00) NQ (2.00)Sodiumug/L 200.7 490,000 B 390,000 B 360,000 540,000 445,000Thalliumug/L 200.8 10.0 12.0 10.0 8.90 10.2Tinug/L 200.7 NQ (200) NQ (200) NQ (200) NQ (200) NQ (200)Titaniumug/L 200.7 3,300 3,600 B 2,400 2,600 2,980ND – Not detected (number in parentheses is the quantitation limit).NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit). The analytical result ispresented in Tables B5-6 through B5-18 with a J flag designation. A “NQ” for the 4-set average result indicates that all results were below the quantitation limit, but at least oneresult is a J-value.^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.B – Analyte was found in the blank and sample.Est – Estimated value.F – MS and/or MSD not within laboratory control limits.Min – Minimum value.Table B5-1. Influent to FGD Wastewater Treatment System, Pleasant PrairieAnalyteUnitsMethodInfluent to FGD Wastewater Treatment System (SP-1)Set 1Set 2Set 3Set 44-SetAverageVanadium ug/L 200.8 930 1,000 620 400 738Zincug/L 200.7 1,500 1,600 ^ 1,100 930 1,280[QUESTION FOR PLEASANT PRAIRIE: Please provide the split sampling mercury results associated with Sets 1, 2, 3, and 4 of theInfluent to FGD Wastewater Treatment System.]ND – Not detected (number in parentheses is the quantitation limit).NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit). The analytical result ispresented in Tables B5-6 through B5-18 with a J flag designation. A “NQ” for the 4-set average result indicates that all results were below the quantitation limit, but at least oneresult is a J-value.^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.B – Analyte was found in the blank and sample.Est – Estimated value.F – MS and/or MSD not within laboratory control limits.Min – Minimum value.Table B5-2. Effluent from FGD Wastewater Treatment System, Pleasant PrairieAnalyteUnitsMethodEffluent from FGD Wastewater Treatment System (SP-2)Set 1Set 2Set 3Set 44-SetAverageClassicalsAmmonia mg/L350.1 2.40 2.00 1.10 2.80 2.08Nitrate Nitrite as N mg/L353.2 210 170 150 220 188Nitrogen, TotalKjeldahlmg/L351.2 46.0 B,4, Min 31.0 25.0 36.0 34.5BiochemicalOxygen Demandmg/L5210B NQ (2.50) ND (2.00) NQ (2.50) ND (2.00) NQ (2.25)Chemical OxygenDemandmg/L410.4 330 F 290 B,*, F 320 460 350Chloridemg/L300.0 2,400 2,000 1,900 3,300 2,400Sulfatemg/L300.0 13,000 12,000 9,600 13,000 11,900Cyanide, Total mg/L4500 CN E 0.170 F, Est 0.240 0.230 0.360 0.250Total DissolvedSolidsmg/L2540C 25,000 21,000 14,000 20,000 20,000Total SuspendedSolidsmg/L2540D NQ (4.00) NQ (4.00) ND (4.00) NQ (4.00) NQ (4.00)Phosphorus, Totalmg/L365.1 0.0570 F, Min 0.130 B NQ(0.0500)B0.0910 B< 0.0758Total MetalsAluminum ug/L 200.7 ND (200) ND (200) ND (200) ND (200) ND (200)ND – Not detected (number in parentheses is the quantitation limit).NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit). The analytical result ispresented in Tables B5-6 through B5-18 with a J flag designation. A “NQ” for the 4-set average result indicates that all results were below the quantitation limit, but at least oneresult is a J-value.^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.B – Analyte was found in the blank and sample.Est – Estimated value.F – MS and/or MSD not within laboratory control limits.Min – Minimum value.Table B5-2. Effluent from FGD Wastewater Treatment System, Pleasant PrairieAnalyteUnitsMethodEffluent from FGD Wastewater Treatment System (SP-2)Set 1Set 2Set 3Set 44-SetAverageAntimony ug/L 200.8 2.70 2.80 2.40 3.70 2.90Arsenicug/L 200.8 8.00 6.20 6.10 7.50 6.95Bariumug/L 200.7 76.0 51.0 B 63.0 69.0 64.8Beryllium ug/L 200.7 ND (2.00) ND (2.00) ND (2.00) ND (2.00) ND (2.00)Boronug/L 200.7 14,000 B,4 14,000 B 11,000 B16,000 B13,800Cadmium ug/L 200.8 ND (4.00) ND (4.00) ND (4.00) ND (4.00) ND (4.00)Calciumug/L 200.7 670,000 4 650,000 B 720,000 740,000 695,000Chromium ug/L 200.8 ND (8.00) ND (8.00) ^ ND (8.00) ND (8.00) ND (8.00)Cobaltug/L 200.7 ND (20.0) ND (20.0) ND (20.0) ND (20.0) ND (20.0)Copperug/L 200.8 12.0 NQ (4.00) NQ (4.00) NQ (4.00) < 4.50Ironug/L 200.7 NQ (200) NQ (200) B NQ (200) NQ (200) NQ (200)Leadug/L 200.8 ND (2.00) ND (2.00) ND (2.00) ND (2.00) ND (2.00)Magnesium ug/L 200.7 4,200,000 B,4 3,400,000 B 2,600,000 B3,900,000 3,530,000Manganese ug/L 200.7 15,000 B,4 12,000 B 5,200 13,000 B11,300Mercuryng/L 1631E 175 108 34.2 132 112Molybdenum ug/L 200.7 47.0 44.0 52.0 72.0 53.8Nickelug/L 200.8 NQ (4.00) 5.50 NQ (4.00) 5.40 < 3.73Seleniumug/L 200.8 2,900 4 2,800 1,800 3,400 2,730Silverug/L 200.8 ND (2.00) F ND (2.00) ND (2.00) ND (2.00) ND (2.00)Sodiumug/L 200.7 600,000 B,4 450,000 B 380,000 590,000 505,000Thalliumug/L 200.8 2.10 NQ (2.00) ND (2.00) NQ (2.00) < 1.28ND – Not detected (number in parentheses is the quantitation limit).NQ – Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitation limit). The analytical result ispresented in Tables B5-6 through B5-18 with a J flag designation. A “NQ” for the 4-set average result indicates that all results were below the quantitation limit, but at least oneresult is a J-value.^ - ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.B – Analyte was found in the blank and sample.Est – Estimated value.F – MS and/or MSD not within laboratory control limits.Min – Minimum value.Table B5-2. Effluent from FGD Wastewater Treatment System, Pleasant PrairieAnalyteUnitsMethodEffluent from FGD Wastewater Treatment System (SP-2)Set 1Set 2Set 3Set 44-SetAverageTinug/L 200.7 ND (200) ND (200) ND (200) ND (200) ND (200)Titaniumug/L 200.7 ND (20.0) ND (20.0) ND (20.0) ND (20.0) ND (20.0)Vanadium ug/L 200.8 ND (10.0) NQ (10.0) ND (10.0) NQ (10.0) NQ (10.0)Zincug/L 200.7 NQ (40.0) NQ (40.0) ^ NQ (40.0) NQ (40.0) NQ (40.0)[QUESTION FOR PLEASANT PRAIRIE: Please provide the split sampling mercury results associated with Sets 1, 2, 3, and 4 of theEffluent from FGD Wastewater Treatment System.]<

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

ND

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

NQ

– Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the quantitat ion limit). The analytical result is

presented in Tables B 5

- 6 through B 5

- 18 with a J flag designation. A “NQ” for the 4

- set avera ge result indicates that all results were below the quantitation limit, but at least one

result is a J

- value. Table B 5

- 3

. Classical Pollutants 4

- Set Average Data Summary for FGD Wastewater Treatment System

, Pleasant Prairie

Analyte Unit Method Influent to FGD

Wastewater Treatment

System (SP

- 1)

4

- Set Average Effluent from FGD

Wastewater Treatment

System (SP

- 2)

4

- Set Average

Classicals

Ammonia mg/L 350.1 2.38 2.08

Nitrate Nitrite as N mg/L 353.2 185 188

Nitrogen, Total Kjeldahl mg/L 351.2 50.0 34.5

Biochemical Oxygen Demand mg/L 5210B ND (2.00) NQ (2.25)

Chemical Oxygen Demand mg/L 410.4 468 350

Chloride mg/L 300.0 2,300 2,400

Sulfate mg/L 300.0 13,000 11,900

Cyanide, Total mg/L 4500 CN E 0.278 0.250

Total Dissolved Solids mg/L 2540C 22,500 20,000

Total Suspended Solids mg/L 2540D 5,050 NQ (4.00)

Phosphorus, Total mg/L 365.1 5.46 < 0.0758<

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

ND

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

NQ

– Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the q uantitation limit). The analytical result is

presented in Tables B 5

- 6 through B 5

- 18 with a J flag designation. A “NQ” for the 4

- set average result indicates that all results were below the quantitation limit, but at least one

result is a J

- value. Table B 5

- 4

. Metals Pollutants 4

- Set Average Data Summary for FGD Wastewater Treatment System,

Pleasant Prairie

Analyte Units Method Influent to FGD

Wastewater Treatment

System (SP

- 1)

4

- Set Average Effluent from FGD

Wastewater Treatment

System (SP

- 2)

4

- Set Average

Total Metals

Aluminum ug/L 200.7 123,000 ND (200)

Antimony ug/L 200.8 45.0 2.90

Arsenic ug/L 200.8 126 6.95

Barium ug/L 200.7 825 64.8

Beryllium ug/L 200.7 4.08 ND (2.00)

Boron ug/L 200.7 17,800 13,800

Cadmium ug/L 200.8 9.88 ND (4.00)

Calcium ug/L 200.7 690,000 695,000

Chromium ug/L 200.8 815 ND (8.00)

Cobalt ug/L 200.7 143 ND (20.0)

Copper ug/L 200.8 745 < 4.50

Iron ug/L 200.7 308,000 NQ (200)

Lead ug/L 200.8 190 ND (2.00)

Magnesium ug/L 200.7 4,130,000 3,530,000

Manganese ug/L 200.7 86,800 11,300

Mercury ng/L 1631E 1,390,000 112

Molybdenum ug/L 200.7 200 53.8

Nickel ug/L 200.8 1,380 < 3.73

Selenium ug/L 200.8 13,500 2,730<

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

ND

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

NQ

– Analyte was measured above the method detection limit, but below the quantitation limit (number shown in parentheses is the q uantitation limit). The analytical result is

presented in Tables B 5

- 6 through B 5

- 18 with a J flag designation. A “NQ” for the 4

- set average result indicates that all results were below the quantitation limit, but at least one

result is a J

- value. Table B 5

- 4

. Metals Pollutants 4

- Set Average Data Summary for FGD Wastewater Treatment System,

Pleasant Prairie

Analyte Units Method Influent to FGD

Wastewater Treatment

System (SP

- 1)

4

- Set Average Effluent from FGD

Wastewater Treatment

System (SP

- 2)

4

- Set Average

Silver ug/L 200.8 NQ (2.00) ND (2.00)

Sodium ug/L 200.7 445,000 505,000

Thallium ug/L 200.8 10.2 < 1.28

Tin ug/L 200.7 NQ (200) ND (200)

Titanium ug/L 200.7 2,980 ND (20.0)

Vanadium ug/L 200.8 738 NQ (10.0)

Zinc ug/L 200.7 1,280 NQ (40.0)Table B 5

- 5

. Field Blank Analytical Results, Pleasant Prairie

Analyte Sample Point Met hod Unit Concentration

Total Metals

Mercury Effluent from FGD Wastewater Treatment System Field

Blank

- Day 2 1631E ng/L 1.20ND

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

B

– Analyte was found in the blank and sample.

Est

– Estimated value.

J

– Result measured above the MDL, but less than the quantitation limit.

Min

– Minimum value.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 6

. Influent to FGD Wastewater Treatment System, Set 1 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 1.9

Nitrate Nitrite as N 353.2 mg/L 50 0.95 5 190

Nitrogen, Total Kjeldahl 351.2 mg/L 2 0.77 10 64 B , Min

Biochemical Oxygen Demand 5210B mg/L 1 0.24 2 ND (2) U

Chemical Oxygen Demand 410.4 mg/L 5 20 100 480

Chloride 300.0 mg/L 50 13 150 2,300

Sulfate 300.0 mg/L 500 120 2,500 14,000

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.29 Est

Total Dissolved Solids 2540C mg/L 1 47 100 27,000

Total Suspended Solids 2540D mg/L 1 55 200 4,200

Phosphorus, Total 365.1 mg/L 10 0.05 0.5 5

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 140,000

Antimony 200.8 ug/L 2 0.72 2 56

Arsenic 200.8 ug/L 2 1.2 4 150

Barium 200.7 ug/L 2 2.5 20 840

Beryllium 200.7 ug/L 2 0.71 2 4.6

Boron 200.7 ug/L 50 170 5,000 18,000 B

Cadmium 200.8 ug/L 5 2.9 10 12

Calcium 200.7 ug/L 2 69 400 660,000

Chromium 200.8 ug/L 2 3.3 8 1,100ND

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

B

– Analyte was found in the blank and sample.

Est

– Estimated value.

J

– Result measured above the MDL, but less than the quantitation limit.

Min

– Minimum value.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 6

. Influent to FGD Wastewater Treatment System, Set 1 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Cobalt 200.7 ug/L 2 1.1 20 140

Copper 200.8 ug/L 5 2.4 10 900

Iron 200.7 ug/L 2 32 200 390,000

Lead 200.8 ug/L 2 0.73 2 210

Magnesium 200.7 ug/L 50 540 10,000 4,600,000 B

Manganese 200.7 ug/L 50 13 500 96,000 B

Mercury 1631E ng/L 400,000 104,000 218,000 1,320,000

Molybdenum 200.7 ug/L 2 1.6 40 250

Nickel 200.8 ug/L 5 2.2 10 1,400

Selenium 200.8 ug/L 50 16 100 16,000

Silver 200.8 ug/L 2 0.59 2 0.8 J

Sodium 200.7 ug/L 2 180 10,000 490,000 B

Thallium 200.8 ug/L 2 0.47 2 10

Tin 200.7 ug/L 2 4.8 200 24 J

Titanium 200.7 ug/L 2 1.6 20 3,300

Vanadium 200.8 ug/L 2 1.7 10 930

Zinc 200.7 ug/L 2 9.1 40 1,500ND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

F

– MS and/or MSD not within laboratory control limits.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Nu mber shown in parentheses is the quantitation limit). Table B 5

- 7

. Influent to FGD Wastewater Treatment System, Set 2 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 2.1

Nitrate Nitrite as N 353.2 mg/L 20 0.38 2 160

Nitrogen, Total Kjeldahl 351.2 mg/L 5 0.38 5 34

Biochemical Oxygen Demand 5210B mg/L 1 0.24 2 ND (2) U

Chemical Oxygen Demand 410.4 mg/L 5 20 100 450 F

Chloride 300.0 mg/L 100 25 300 1,800

Sulfate 300.0 mg/L 500 120 2,500 14,000

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.16

Total Dissolved Solids 2540C mg/L 1 94 200 19,000

Total Suspended Solids 2540D mg/L 1 46 170 4,900

Phosphorus, Total 365.1 mg/L 10 0.05 0.5 8 B

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 170,000 B

Antimony 200.8 ug/L 2 0.72 2 57

Arsenic 200.8 ug/L 2 1.2 4 170

Barium 200.7 ug/L 2 2.5 20 1,000 B

Beryllium 200.7 ug/L 2 0.71 2 4.7

Boron 200.7 ug/L 50 170 5,000 17,000 B

Cadmium 200.8 ug/L 2 1.2 4 11

Calcium 200.7 ug/L 2 69 400 710,000 BND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

F

– MS and/or MSD not within laboratory control limits.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Nu mber shown in parentheses is the quantitation limit). Table B 5

- 7

. Influent to FGD Wastewater Treatment System, Set 2 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Chromium 200.8 ug/L 2 3.3 8 1,100 ^

Cobalt 200.7 ug/L 2 1.1 20 140

Copper 200.8 ug/L 2 0.96 4 1,000

Iron 200.7 ug/L 2 32 200 410,000 B

Lead 200.8 ug/L 2 0.73 2 270

Magnesium 200.7 ug/L 50 540 10,000 4,100,000 B

Manganese 200.7 ug/L 50 13 500 90,000 B

Mercury 1631E ng/L 50,000 12,400 26,000 973,000

Molybdenum 200.7 ug/L 2 1.6 40 220

Nickel 200.8 ug/L 2 0.89 4 1,400

Selenium 200.8 ug/L 50 16 100 18,000

Silver 200.8 ug/L 2 0.59 2 1.1 J

Sodium 200.7 ug/L 2 180 10,000 390,000 B

Thallium 200.8 ug/L 2 0.47 2 12

Tin 200.7 ug/L 2 4.8 200 24 J

Titanium 200.7 ug/L 2 1.6 20 3,600 B

Vanadium 200.8 ug/L 2 1.7 10 1,000

Zinc 200.7 ug/L 2 9.1 40 1,600 ^ND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 8

. Influent to FGD Wastewater Treatment System, Set 3 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 2.3

Nitrate Nitrite as N 353.2 mg/L 20 0.38 2 160

Nitrogen, Total Kjeldahl 351.2 mg/L 2 0.77 10 73

Biochemical Oxygen Demand 5210B mg/L 1 0.24 2 ND (2) U

Chemical Oxygen Demand 410.4 mg/L 5 20 100 420

Chloride 300.0 mg/L 100 25 300 2,000

Sulfate 300.0 mg/L 500 120 2,500 11,000

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.29

Total Dissolved Solids 2540C mg/L 1 240 500 23,000

Total Suspended Solids 2540D mg/L 1 55 200 4,700

Phosphorus, Total 365.1 mg/L 1 0.005 0.05 0.056 B

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 87,000

Antimony 200.8 ug/L 2 0.72 2 42

Arsenic 200.8 ug/L 2 1.2 4 110

Barium 200.7 ug/L 2 2.5 20 790

Beryllium 200.7 ug/L 2 0.71 2 3.7

Boron 200.7 ug/L 50 170 5,000 17,000 B

Cadmium 200.8 ug/L 2 1.2 4 7.7

Calcium 200.7 ug/L 50 1,700 10,000 780,000

Chromium 200.8 ug/L 2 3.3 8 690

Cobalt 200.7 ug/L 2 1.1 20 130

Copper 200.8 ug/L 2 0.96 4 680ND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 8

. Influent to FGD Wastewater Treatment System, Set 3 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Iron 200.7 ug/L 2 32 200 250,000

Lead 200.8 ug/L 2 0.73 2 170

Magnesium 200.7 ug/L 50 540 10,000 3,500,000 B

Manganese 200.7 ug/L 50 13 500 75,000

Mercury 1631E ng/L 400,000 99,400 208,000 1,420,000

Molybdenum 200.7 ug/L 2 1.6 40 190

Nickel 200.8 ug/L 2 0.89 4 1,500

Selenium 200.8 ug/L 10 3.1 20 11,000

Silver 200.8 ug/L 2 0.59 2 0.94 J

Sodium 200.7 ug/L 2 180 10,000 360,000

Thallium 200.8 ug/L 2 0.47 2 10

Tin 200.7 ug/L 2 4.8 200 8.2 J

Titanium 200.7 ug/L 2 1.6 20 2,400

Vanadium 200.8 ug/L 2 1.7 10 620

Zinc 200.7 ug/L 2 9.1 40 1,100ND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 9

. Influent to FGD Wastewater Treatment System, Set 4 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 3.2

Nitrate Nitrite as N 353.2 mg/L 50 0.95 5 230

Nitrogen, Total Kjeldahl 351.2 mg/L 5 0.38 5 29

Biochemical Oxygen Demand 5210B mg/L 1 0.24 2 ND (2) U

Chemical Oxygen Demand 410.4 mg/L 5 20 100 520

Chloride 300.0 mg/L 100 25 300 3,100

Sulfate 300.0 mg/L 500 120 2,500 13,000

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.37

Total Dissolved Solids 2540C mg/L 1 94 200 21,000

Total Suspended Solids 2540D mg/L 1 140 500 6,400

Phosphorus, Total 365.1 mg/L 10 0.05 0.5 8.8 B

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 95,000

Antimony 200.8 ug/L 2 0.72 2 25

Arsenic 200.8 ug/L 2 1.2 4 72

Barium 200.7 ug/L 2 2.5 20 670

Beryllium 200.7 ug/L 2 0.71 2 3.3

Boron 200.7 ug/L 50 170 5,000 19,000 B

Cadmium 200.8 ug/L 2 1.2 4 8.8

Calcium 200.7 ug/L 2 69 400 610,000

Chromium 200.8 ug/L 2 3.3 8 370

Cobalt 200.7 ug/L 2 1.1 20 160

Copper 200.8 ug/L 2 0.96 4 400ND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 9

. Influent to FGD Wastewater Treatment System, Set 4 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Iron 200.7 ug/L 2 32 200 180,000

Lead 200.8 ug/L 2 0.73 2 110

Magnesium 200.7 ug/L 50 540 10,000 4,300,000

Manganese 200.7 ug/L 50 13 500 86,000 B

Mercury 1631E ng/L 400,000 99,400 208,000 1,830,000

Molybdenum 200.7 ug/L 2 1.6 40 140

Nickel 200.8 ug/L 5 2.2 10 1,200

Selenium 200.8 ug/L 10 3.1 20 9,100

Silver 200.8 ug/L 2 0.59 2 0.84 J

Sodium 200.7 ug/L 2 180 10,000 540,000

Thallium 200.8 ug/L 2 0.47 2 8.9

Tin 200.7 ug/L 2 4.8 200 7.4 J

Titanium 200.7 ug/L 2 1.6 20 2,600

Vanadium 200.8 ug/L 2 1.7 10 400

Zinc 200.7 ug/L 2 9.1 40 930ND

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

4

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

B

– Analyte was found in the blank and sample.

Est

– Estimated value.

F

– MS and/or MSD not wi thin laboratory control limits.

J

– Result measured above the MDL, but less than the quantitat ion limit.

Min

– Minimum value.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 10

. Effluent from FGD Wastewater Treatment System, Set 1 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 2.4

Nitrate Nitrite as N 353.2 mg/L 50 0.95 5 210

Nitrogen, Total Kjeldahl 351.2 mg/L 10 0.77 10 46 B,4 , Min

Biochemical Oxygen Demand 5210B mg/L 1 0.3 2.5 1.7 J

Chemical Oxygen Demand 410.4 mg/L 5 20 100 330 F

Chloride 300.0 mg/L 50 13 150 2,400

Sulfate 300.0 mg/L 500 120 2,500 13,000

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.17 F , Est

Total Dissolved Solids 2540C mg/L 1 47 100 25,000

Total Suspended Solids 2540D mg/L 1 1.1 4 2.8 J

Phosphorus, Total 365.1 mg/L 1 0.005 0.05 0.057 F , Min

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U

Antimony 200.8 ug/L 2 0.72 2 2.7

Arsenic 200.8 ug/L 2 1.2 4 8

Barium 200.7 ug/L 2 2.5 20 76

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 50 170 5,000 14,000 B,4

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 670,000 4

Chromium 200.8 ug/L 2 3.3 8 ND (8) UND

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

4

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

B

– Analyte was found in the blank and sample.

Est

– Estimated value.

F

– MS and/or MSD not wi thin laboratory control limits.

J

– Result measured above the MDL, but less than the quantitat ion limit.

Min

– Minimum value.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 10

. Effluent from FGD Wastewater Treatment System, Set 1 Analytical Results, Pleasant Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Cobalt 200.7 ug/L 2 1.1 20 ND (20) U

Copper 200.8 ug/L 2 0.96 4 12

Iron 200.7 ug/L 2 32 200 150 J

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 50 540 10,000 4,200,000 B,4

Manganese 200.7 ug/L 2 0.51 20 15,000 B,4

Mercury 1631E ng/L 10 2.48 5.2 175

Molybdenum 200.7 ug/L 2 1.6 40 47

Nickel 200.8 ug/L 2 0.89 4 2.4 J

Selenium 200.8 ug/L 5 1.6 10 2,900 4

Silver 200.8 ug/L 2 0.59 2 ND (2) U,F

Sodium 200.7 ug/L 2 180 10,000 600,000 B,4

Thallium 200.8 ug/L 2 0.47 2 2.1

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 ND (10) U

Zinc 200.7 ug/L 2 9.1 40 22 JND

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

*

- LCS or LCSD is outside the laboratory control limits.

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

F

– MS and/or MSD not within laboratory control limits.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 11

. Effluent from FGD Wastewater Treatment System, Set 2 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 2

Nitrate Nitrite as N 353.2 mg/L 20 0.38 2 170

Nitrogen, Total Kjeldahl 351.2 mg/L 5 0.38 5 31

Biochemical Oxygen Demand 5210B mg/L 1 0.24 2 ND (2) U

Chemical Oxygen Demand 410.4 mg/L 2 8.1 40 290 B,* , F

Chloride 300.0 mg/L 100 25 300 2,000

Sulfate 300.0 mg/L 500 120 2,500 12,000

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.24

Total Dissolved Solids 2540C mg/L 1 47 100 21,000

Total Suspended Solids 2540D mg/L 1 1.1 4 2 J

Phosphorus, Total 365.1 mg/L 1 0.005 0.05 0.13 B

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U

Antimony 200.8 ug/L 2 0.72 2 2.8

Arsenic 200.8 ug/L 2 1.2 4 6.2

Barium 200.7 ug/L 2 2.5 20 51 B

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 50 170 5,000 14,000 B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 650,000 BND

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

*

- LCS or LCSD is outside the laboratory control limits.

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

F

– MS and/or MSD not within laboratory control limits.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 11

. Effluent from FGD Wastewater Treatment System, Set 2 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Chromium 200.8 ug/L 2 3.3 8 ND (8) U,^

Cobalt 200.7 ug/L 2 1.1 20 ND (20) U

Copper 200.8 ug/L 2 0.96 4 3.8 J

Iron 200.7 ug/L 2 32 200 110 J,B

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 50 540 10,000 3,400,000 B

Manganese 200.7 ug/L 2 0.51 20 12,000 B

Mercury 1631E ng/L 20 4.87 10.2 108

Molybdenum 200.7 ug/L 2 1.6 40 44

Nickel 200.8 ug/L 2 0.89 4 5.5

Selenium 200.8 ug/L 2 0.62 4 2,800

Silver 200.8 ug/L 2 0.59 2 ND (2) U

Sodium 200.7 ug/L 2 180 10,000 450,000 B

Thallium 200.8 ug/L 2 0.47 2 0.49 J

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 2.1 J

Zinc 200.7 ug/L 2 9.1 40 20 J,^ND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 12

. Effluent from FGD Wastewater Treatment System, Set 3 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 1.1

Nitrate Nitrite as N 353.2 mg/L 20 0.38 2 150

Nitrogen, Total Kjeldahl 351.2 mg/L 5 0.38 5 25

Biochemical Oxygen Demand 5210B mg/L 1 0.3 2.5 1.7 J

Chemical Oxygen Demand 410.4 mg/L 5 20 100 320

Chloride 300.0 mg/L 100 25 300 1,900

Sulfate 300.0 mg/L 500 120 2,500 9,600

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.23

Total Dissolved Solids 2540C mg/L 1 47 100 14,000

Total Suspended Solids 2540D mg/L 1 1.1 4 ND (4) U

Phosphorus, Total 365.1 mg/L 1 0.005 0.05 0.025 J,B

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U

Antimony 200.8 ug/L 2 0.72 2 2.4

Arsenic 200.8 ug/L 2 1.2 4 6.1

Barium 200.7 ug/L 2 2.5 20 63

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 50 170 5,000 11,000 B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 50 1,700 10,000 720,000

Chromium 200.8 ug/L 2 3.3 8 ND (8) U

Cobalt 200.7 ug/L 2 1.1 20 ND (20) UND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 12

. Effluent from FGD Wastewater Treatment System, Set 3 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Copper 200.8 ug/L 2 0.96 4 3.2 J

Iron 200.7 ug/L 2 32 200 51 J

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 50 540 10,000 2,600,000 B

Manganese 200.7 ug/L 2 0.51 20 5,200

Mercury 1631E ng/L 20 4.97 10.4 34.2

Molybdenum 200.7 ug/L 2 1.6 40 52

Nickel 200.8 ug/L 2 0.89 4 3.4 J

Selenium 200.8 ug/L 10 3.1 20 1,800

Silver 200.8 ug/L 2 0.59 2 ND (2) U

Sodium 200.7 ug/L 2 180 10,000 380,000

Thallium 200.8 ug/L 2 0.47 2 ND (2) U

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 ND (10) U

Zinc 200.7 ug/L 2 9.1 40 15 JND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 13

. Effluent from FGD Wastewater Treatment System, Set 4 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Classicals

Ammonia 350.1 mg/L 1 0.055 1 2.8

Nitrate Nitrite as N 353.2 mg/L 50 0.95 5 220

Nitrogen, Total Kjeldahl 351.2 mg/L 5 0.38 5 36

Biochemical Oxygen Demand 5210B mg/L 1 0.24 2 ND (2) U

Chemical Oxygen Demand 410.4 mg/L 5 20 100 460

Chloride 300.0 mg/L 100 25 300 3,300

Sulfate 300.0 mg/L 500 120 2,500 13,000

Cyanide, Total 4500 CN E mg/L 1 0.02 0.1 0.36

Total Dissolved Solids 2540C mg/L 1 94 200 20,000

Total Suspended Solids 2540D mg/L 1 1.1 4 1.2 J

Phosphorus, Total 365.1 mg/L 1 0.005 0.05 0.091 B

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U

Antimony 200.8 ug/L 2 0.72 2 3.7

Arsenic 200.8 ug/L 2 1.2 4 7.5

Barium 200.7 ug/L 2 2.5 20 69

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 50 170 5,000 16,000 B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 740,000

Chromium 200.8 ug/L 2 3.3 8 ND (8) U

Cobalt 200.7 ug/L 2 1.1 20 ND (20) UND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 13

. Effluent from FGD Wastewater Treatment System, Set 4 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

Specific

MDL Sample

Specific

QL Concentration

Copper 200.8 ug/L 2 0.96 4 1.6 J

Iron 200.7 ug/L 2 32 200 57 J

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 50 540 10,000 3,900,000

Manganese 200.7 ug/L 2 0.51 20 13,000 B

Mercury 1631E ng/L 100 24.8 52 132

Molybdenum 200.7 ug/L 2 1.6 40 72

Nickel 200.8 ug/L 2 0.89 4 5.4

Selenium 200.8 ug/L 2 0.62 4 3,400

Silver 200.8 ug/L 2 0.59 2 ND (2) U

Sodium 200.7 ug/L 2 180 10,000 590,000

Thallium 200.8 ug/L 2 0.47 2 1.3 J

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 2 J

Zinc 200.7 ug/L 2 9.1 40 14 JND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 14

. Influent to FGD Wastewater Treatment System Field Blank, Set 1 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U,^

Antimony 200.8 ug/L 2 0.72 2 ND (2) U

Arsenic 200.8 ug/L 2 1.2 4 ND (4) U

Barium 200.7 ug/L 2 2.5 20 ND (20) U

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 2 6.7 200 14 J,B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 ND (400) U

Chromium 200.8 ug/L 2 3.3 8 ND (8) U

Cobalt 200.7 ug/L 2 1.1 20 ND (20) U

Copper 200.8 ug/L 2 0.96 4 ND (4) U

Iron 200.7 ug /L 2 32 200 ND (200) U

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 2 21 400 60 J,B

Manganese 200.7 ug/L 2 0.51 20 ND (20) U

Mercury 1631E ng/L 1 0.24 0.5 ND (0.5) U

Molybdenum 200.7 ug/L 2 1.6 40 ND (40) U

Nickel 200.8 ug/L 2 0.89 4 ND (4) U

Selenium 200.8 ug/L 2 0.62 4 0.78 J

Silver 200.8 ug/L 2 0.59 2 ND (2) U

Sodium 200.7 ug/L 2 180 10,000 180 J,B

Thallium 200.8 ug/L 2 0.47 2 ND (2) UND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 14

. Influent to FGD Wastewater Treatment System Field Blank, Set 1 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 1.8 J

Zinc 200.7 ug/L 2 9.1 40 ND (40) UND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 5

. Effluent from FGD Wastewater Treatment System Field Blank, Set 1 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U,^

Antimony 200.8 ug/L 2 0.72 2 ND (2) U

Arsenic 200.8 ug/L 2 1.2 4 ND (4) U

Barium 200.7 ug/L 2 2.5 20 ND (20) U

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 2 6.7 200 14 J,B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 ND (400) U

Chromium 200.8 ug/L 2 3.3 8 ND (8) U

Cobalt 200.7 ug/L 2 1.1 20 ND (20) U

Copper 200.8 ug/L 2 0.96 4 ND (4) U

Iron 200.7 ug/L 2 32 200 ND (200) U

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 2 21 400 23 J,B

Manganese 200.7 ug/L 2 0.51 20 2.4 J,B

Mercury 1631E ng/L 1 0.24 0.5 ND (0.5) U

Molybdenum 200.7 ug/L 2 1.6 40 2 J

Nickel 200.8 ug/L 2 0.89 4 ND (4) U

Selenium 200.8 ug/L 2 0.62 4 1.1 J

Silver 200.8 ug/L 2 0.59 2 1 J

Sodium 200.7 ug/L 2 180 10,000 320 J,B

Thallium 200.8 ug/L 2 0.47 2 ND (2) UND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 5

. Effluent from FGD Wastewater Treatment System Field Blank, Set 1 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 2.1 J

Zinc 200.7 ug/L 2 9.1 40 ND (40) UND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 6

. Effluent from FGD Wastewater Treatment System Field Blank, Set 2 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U

Antimony 200.8 ug/L 2 0.72 2 ND (2) U

Arsenic 200.8 ug/L 2 1.2 4 ND (4) U

Barium 200.7 ug/L 2 2.5 20 4.4 J,B

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 2 6.7 200 17 J,B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 ND (400) U

Chromium 200.8 ug/L 2 3.3 8 ND (8) U,^

Cobalt 200.7 ug/L 2 1.1 20 ND (20) U

Copper 200.8 ug/L 2 0.96 4 ND (4) U

Iron 200.7 ug/L 2 32 200 ND (200) U

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 2 21 400 24 J,B

Manganese 200.7 ug/L 2 0.51 20 ND (20) U

Mercury 1631E ng/L 1 0.24 0.5 1.2

Molybdenum 200.7 ug/L 2 1.6 40 ND (40) U

Nickel 200.8 ug/L 2 0.89 4 ND (4) U

Selenium 200.8 ug/L 2 0.62 4 1.2 J

Silver 200.8 ug/L 2 0.59 2 ND (2) U

Sodium 200.7 ug/L 2 180 10,000 ND (10,000) U

Thallium 200.8 ug/L 2 0.47 2 ND (2) UND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 6

. Effluent from FGD Wastewater Treatment System Field Blank, Set 2 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 2.6 J

Zinc 200.7 ug/L 2 9.1 40 25 J,^ND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 7

. Effluent from FGD Wastewater Treatment System Field Blank, Set 3 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U

Antimony 200.8 ug/L 2 0.72 2 ND (2) U

Arsenic 200.8 ug/L 2 1.2 4 ND (4) U

Barium 200.7 ug/L 2 2.5 20 ND (20) U

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 2 6.7 200 75 J,B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 96 J

Chromium 200.8 ug/L 2 3.3 8 ND (8) U

Cobalt 200.7 ug/L 2 1.1 20 ND (20) U

Copper 200.8 ug/L 2 0.96 4 ND (4) U

Iron 200.7 ug/L 2 32 200 ND (200) U

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 2 21 400 98 J,B

Manganese 200.7 ug/L 2 0.51 20 ND (20) U

Mercury 1631E ng/L 1 0.24 0.5 ND (0.5) U

Molybdenum 200.7 ug/L 2 1.6 40 ND (40) U

Nickel 200.8 ug/L 2 0.89 4 ND (4) U

Selenium 200.8 ug/L 2 0.62 4 0.83 J,^

Silver 200.8 ug/L 2 0.59 2 ND (2) U

Sodium 200.7 ug/L 2 180 10,000 370 J

Thallium 200.8 ug/L 2 0.47 2 ND (2) UND

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

^

- ICV, CCV, ICB, CCB, ISA, ISB, CRI, or MRL standard: Instrument related QC exceeds the control limits.

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 7

. Effluent from FGD Wastewater Treatment System Field Blank, Set 3 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Tin 200.7 ug/L 2 4.8 200 ND (200) U

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 1.9 J

Zinc 200.7 ug/L 2 9.1 40 ND (40) UND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 8

. Effluent from FGD Wastewater Treatment System Field Blank, Set 4 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Total Metals

Aluminum 200.7 ug/L 2 9.4 200 ND (200) U

Antimony 200.8 ug/L 2 0.72 2 ND (2) U

Arsenic 200.8 ug/L 2 1.2 4 ND (4) U

Barium 200.7 ug/L 2 2.5 20 ND (20) U

Beryllium 200.7 ug/L 2 0.71 2 ND (2) U

Boron 200.7 ug/L 2 6.7 200 19 J,B

Cadmium 200.8 ug/L 2 1.2 4 ND (4) U

Calcium 200.7 ug/L 2 69 400 ND (400) U

Chromium 200.8 ug/L 2 3.3 8 ND (8) U

Cobalt 200.7 ug/L 2 1.1 20 ND (20) U

Copper 200.8 ug/L 2 0.96 4 ND (4) U

Iron 200.7 ug/L 2 32 200 ND (200) U

Lead 200.8 ug/L 2 0.73 2 ND (2) U

Magnesium 200.7 ug/L 2 21 400 34 J

Manganese 200.7 ug/L 2 0.51 20 ND (20) U

Mercury 1631E ng/L 1 0.24 0.5 ND (0.5) U

Molybdenum 200.7 ug/L 2 1.6 40 ND (40) U

Nickel 200.8 ug/L 2 0.89 4 ND (4) U

Selenium 200.8 ug/L 2 0.62 4 1.2 J

Silver 200.8 ug/L 2 0.59 2 ND (2) U

Sodium 200.7 ug/L 2 180 10,000 180 J

Thallium 200.8 ug/L 2 0.47 2 ND (2) U

Tin 200.7 ug/L 2 4.8 200 ND (200) UND

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

B

– Analyte was found in the blank and sample.

J

– Result measured above the MDL, but less than the quantitation limit.

U

– Result below the MDL. (Number shown in parentheses is the quantitation limit). Table B 5

- 1 8

. Effluent from FGD Wastewater Treatment System Field Blank, Set 4 Analytical Results, Pleasant

Prairie

Analyte Method Unit Dilution

Factor Sample

- Specific

MDL Sample

Specific QL Concentration

Titanium 200.7 ug/L 2 1.6 20 ND (20) U

Vanadium 200.8 ug/L 2 1.7 10 2 J

Zinc 200.7 ug/L 2 9.1 40 ND (40) U

### Section 6

Data Review Narratives

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

removed.]1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

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

Deb Bartram, ERG

TJ Finseth, ERG

From: Donna Tedder, ERG

Date: 2/9/2012

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

Month 1 (Part 1)

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

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

Atomic Fluorescence Spectrometry (CVAFS) analysis.

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

and analyzed for total mercury.

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

EPA

Sample # Lab Sample

ID # Sample

Matrix Sample Description Sampling

Date

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUMMARY

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

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

dataset.

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES

There were no sample receipt issues in this data package.

INITIAL CALIBRATION

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

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

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

criteria.

BLANKS

All the preparation blanks or laboratory reagent blanks (L RBs) and the continuing

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

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

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

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

results.

DUPLICATES

No field duplicate samples were collected with these sa mpling episodes. Two samples

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

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

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

LABORATORY CONTROL SAMPLES

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

and 24% RPD.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES

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

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

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

DETECTION LIMITS

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

were reported as not detected (ND).1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

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

Monitoring: Month 1 (Part 1)

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

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

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

EPA Method 200.8.

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

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

72041 FGD Influent, Set 1 280

- 7918

- 1 Aqueous 9/30/2010 10/1/2010

72045 FGD Effluent, Set 1 280

- 7918

- 2 Aqueous 9/30/2010 10/1/2010

72049 FGD Influent Field Blank 280

- 7918

- 4 Aqueous 9/30/2010 10/1/2010

72050 FGD Effluent Field Blank, Set 1 280

- 7918

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

72091 FGD Influent, Set 1 280

- 7817

- 1 Aqueous 9/28/2010 9/29/2010

72095 FGD Effluent, Set 1 280

- 7817

- 2 Aqueous 9/28/2010 9/29/2010

72099 FGD Influent Field Blank, Set 1 280

- 7817

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

72100 FGD Effluent Field Blank, Set 1 280

- 7817

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

72191 FGD Influent, Set 1 280

- 7870

- 1 Aqueous 9/29/2010 9/30/2010

72195 FGD SBR Influent, Set 1 280

- 7870

- 2 Aqueous 9/29/2010 9/30/2010

72199 FGD SBR Effluent, Set 1 280

- 7870

- 3 Aqueous 9/29/2010 9/30/2010

72203 FGD Influent Field Blank 280

- 7870

- 6 Aqueous 9/29/2010 9/30/2010

72204 FGD SBR Influent Field Blank,

Set 1 280

- 7870

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

72208 FGD SBR Effluent Field Blank,

Set 2 280

- 7870

- 5 Aqueous 9/29/2010 9/30/20102

SUMMARY

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

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

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

EPA Method 200.8, by ICP/MS analysis.

Any significant findings are summarized below. No addition al data qualifiers were

required.

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

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

70–130%.

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

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

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

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

and vanadium.

INTERNAL STANDARDIZATION

All internal standards used by TestAmerica were within th e method criteria.

INITIAL CALIBRATION

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATION (IC V/CCV)

The initial calibration verifications (ICV) and continu ing calibration verifications (CCV)

performed by TestAmerica all had recoveries within the m ethod criteria.

METHOD/INSTRUMENT BLANKS

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

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

required for method blanks.

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

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

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

REPORTING LIMIT VERIFICATION STANDARD (CRI)

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

LABORATORY CONTROL SAMPLES (LCS)

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

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION

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

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

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

ICS.

All interference check sample B (ICSAB) synthetic sp ikes recovered within

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

SERIAL DILUTION

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

difference.

FIELD DUPLICATES

No field duplicate samples were collected with these sa mpling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES

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

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

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

indicating concentrations in the parent samples were grea ter than four times the spike

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

control limits.

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

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

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

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

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

insoluble silver sulfide and/or silver sulfate.4

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

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

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

POST DIGESTION SPIKES

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

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

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

for PDS samples.

DETECTION LIMITS

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

of reagent water.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

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

Monitoring: Month 1 (Part 1)

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

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

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

according to EPA Method 200.7.

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

EPA Method 200.7.

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

Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

72041 FGD Influent, Set 1 280

- 7918

- 1 Aqueous 9/30/2010 10/1/2010

72045 FGD Effluent, Set 1 280

- 7918

- 2 Aqueous 9/30/2010 10/1/2010

72049 FGD Influent Field Blank 280

- 7918

- 4 Aqueous 9/30/2010 10/1/2010

72050 FGD Effluent Field Blank,

Set 1 280

- 7918

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

72091 FGD Influent, Set 1 280

- 7817

- 1 Aqueous 9/28 /2010 9/29 /2010

7 2095 FGD Effluent, Set 1 280

- 7817

- 2 Aqueous 9/28 /2010 9/29 /2010

7 2099 FGD Influent Field Blank,

Set 1 280

- 7817

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

7 2100 FGD Ef

fluent Field Blank

, Set 1 280

- 7817

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

72191 FGD Influent, Set 1 280

- 7870

- 1 Aqueous 9/29/2010 9/30/2010

72195 FGD SBR Influent, Set 1 280

- 7870

- 2 Aqueous 9/29/2010 9/30/2010

72199 FGD SBR Effluent, Set 1 280

- 7870

- 3 Aqueous 9/29/2010 9/30/2010

72203 FGD Influent Field Blank 280

- 7870

- 6 Aqueous 9/29/2010 9/30/2010

72204 FGD SBR Influent Field

Blank, Set 1 280

- 7870

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

72208 FGD SBR Effluent Field

Blank, Set 2 280

- 7870

- 5 Aqueous 9/29/2010 9/30/20102

SUMMARY

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

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

summarized below. No additional data qualifiers were requir ed.

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

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

130%.

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

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

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

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

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES

There were no sample receipt issues in this data package.

INTERNAL STANDARDIZATION

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

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

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

INITIAL CALIBRATION

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

The initial calibration verifications (ICV) and continu ing calibration verifications (CCV)

performed by TestAmerica all had recoveries within the m ethod criteria.

METHOD/INSTRUMENT BLANKS

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

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

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

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

flagged with the “J” qualifier.3

REPORTING LIMIT VERIFICATION STANDARD (CRI)

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

LABORATORY CONTROL SAMPLES (LCS)

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

INTERFERENCE CHECK SOLUTIONS

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

data quality objectives met TestAmerica’s SOP criteria.

SERIAL DILUTION (SRD)

Serial dilutions were performed for each batch of total samples. All serial dilution percent

differences were less than 10% as required by TestAmerica ’s SOP.

FIELD DUPLICATES

No field duplicate samples were collected with these sa mpling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

MS and MSDs were performed on the total samples of 72095 and 72045. Some elements

with high concentrations failed the EPA 200.7 Method spike recovery control limits of

70–130% but were flagged with a “4” qualifier indicating that the c oncentration in the

parent sample was greater than 4 times the spike and co uld not be reliably calculated.

These data were considered acceptable based on the LCS pas sing the method control

limits. Otherwise, all MS/MSD spike recoveries were within the method control criteria

of 70-130%, except for barium for sample 72095, which had a reco very of 65% and was

qualified with an “F”. The RPD for all MS/MSDs were wi thin TestAmerica’s ± 20%

requirement, except for magnesium for sample 72095. No add itional data qualifiers were

needed.

POST DIGESTION SPIKE (PDS)

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

recovery for all analytes except titanium, which was qual ified with a “W”. No additional

data qualifiers were required.

DETECTION LIMITS

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

of reagent water.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Donna Tedder, ERG

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Classicals Ana lyses – Long-Term

Monitoring: Month 1 (Part 1)

TestAmerica Denver Laboratory generated analytical data for classical wet chemistry

analyses for these long-term monitoring samples. All s amples were tested for the

following analytes:

• Ammonia by EPA method 350.1,

• Biochemical Oxygen Demand – 5 day (BOD 5 ) by SM 5210B,

• Chloride and Sulfate by EPA method 300.0,

• Chemical Oxygen Demand (COD) by EPA method 410.4,

• Cyanide (total) by SM 4500 CN

- E,

• Nitrate/Nitrite by EPA method 353.2,

• Phosphorus (total) by EPA method 365.1,

• Total Dissolved Solids (TDS) by SM 2540C,

• Total Kjeldahl Nitrogen (TKN) by EPA method 351.2, and

• Total Suspended Solids (TSS) by SM 2540D.

Table 1 summarizes the seven samples that TestAmerica analyzed for the above analytes.

Table 1. Long-Term Monitoring Month 1 (Part 1) Classical Analytes – Sample

Identification

EPA

Sample # Sample

Matrix Sample Description Sampling

Date

72041 Water FGD Influent, Set 1 9/30/10

72045 Water FGD Effluent, Set 1 9/30/10

72091 Water FGD Influent, Set 1 9/28/10

72095 Water FGD Effluent, Set 1 9/28/10

72191 Water FGD Influent, Set 1 9/29/10

72195 Water FGD SBR Influent, Set 1 9/29/10

72199 Water FGD SBR Effluent, Set 1 9/29/102

SUMMARY

All samples were analyzed within the holding time specif ied in 40 CFR 136 Table II. All

samples were preserved appropriately unless otherwise speci fied below.

Field duplicate samples were not collected for these ep isodes. Depending on the method,

a laboratory duplicate was analyzed, instead. The Relati ve Percent Difference (RPD)

between the sample and its duplicate was less than 20% unl ess otherwise noted below.

If applicable, the appropriate number of standards was used to create a calibration curve.

If sample results were above the highest standard used t o create the curve, the sample was

diluted and reanalyzed. All sample results were between the lowest and highest standards

unless noted below. Additionally, unless otherwise noted, a ll calibration blanks and

calibration verification samples met the criteria sp ecified in the method.

If required by the method, the quality control sample (QC S), a secondary source standard

used to verify calibration, was always within the cont rol limits specified by the method.

As described below, the analyte of interest was detecte d above the method detection limit

(MDL) in some laboratory reagent blanks (LRB). However , the analyte of interest was

never detected above the reporting limit (RL) in the LRBs . If required by the method, all

laboratory fortified blanks (LFB) met the criteria spec ified in the method unless specified

below.

If required by the method, a matrix spike (MS) sample wa s analyzed on sample 72045 for

each analyte to check for matrix interferences. For so me analytes, TestAmerica spiked

more samples than required. All MS samples analyzed met the criteria specified in the

method unless described below.

DATA NOTES/ISSUES

Ammonia

No issues were identified by the data reviewer.

BOD 5

TestAmerica analyzed five dilutions, but no dilutions had a dissolved oxygen (DO)

depletion greater than 2.0 mg/L for sample 72041 and 72091. Theref ore, BOD 5 was reported as not detected for these samples. The rest of the samples had at least one

dilution with a DO depletion greater than 2.0 mg/L. As requ ired in the method, the final

result was calculated by taking the average of the resul ts for all dilutions with a DO

depletion greater than 2.0 mg/L and a final DO greater than 1.0 mg/L.

BOD was not detected above the RL in any method blanks. Ho wever, for one batch, the

results for the three water/unseeded blanks were 0.22 mg/L , 0.14 mg/L, and 0.16 mg/L.3

One of these water blanks was above the method contro l criteria of 0.20 mg/L. However,

all samples contained in this batch (samples 72041 and 72045) we re either qualified with

a “J” meaning that the sample result was an estimated v alue because it was below the RL

or BOD was not detected in the sample, so no further qual ification was necessary.

One of the three batches had a seed correction factor lower than 0.6 mg/L. The seed

correction factors were 0.6267 mg/L, 0.5776 mg/L, and 0.6384 mg/L for b atches 33523,

33769, and 33938, respectively. Unlike previous episodes, TestAmeric a did not flag

samples in batch 33769 with an “s” indicating the seed corre ction blank (SCB) recovery

was low. This low seed correction factor suggests that s amples 72191, 72195, and 72199

may be biased low. Therefore, these samples were also flagged with an “s”. Sample

72191 was already flagged by TestAmerica with a “J” meaning tha t the sample result was

an estimated value because it was below the RL, so no fur ther qualification was

necessary. However, samples 72195 and 72199 were flagged as minim um values. Due to

the short holding time for the analysis, the samples could not be reanalyzed.

All glucose-glutamic acid standards and laboratory duplicat es were analyzed

appropriately and met the criteria specified in SM 5210B.

Chloride and Sulfate

The MS and matrix spike duplicate (MSD) results for sam ple 72045 for sulfate and

chloride were above the calibration curve. TestAmerica did not reanalyze the samples

with a higher dilution factor because the percent recov eries were within EPA method

300.0 control limits. If reported, these MS/MSD results w ill be qualified as estimated

values. The LFB associated with this sample met the me thod criteria. The analyzed result

for sample 72045 was within the calibration curve, so there was no need to qualify this

sample.

COD

The percent recovery for the MSD analyses for sample 72045 was below the control

limits of 90-110% required by EPA method 410.4. The percent recov eries for the MS and

MSD analyses for this sample were 109% and 87%, respective ly. Because the MS

percent recovery met the method criteria and an MSD is not required by the method,

sample 72045 was not qualified. The LFB percent recoveries a ssociated with sample

72045 met the method criteria.

Cyanide

Samples 72041 and 72045 were received by the laboratory at neutra l pH. The lab added

more NaOH to increase the pH to greater than 10 S.U. These samples are qualified as

estimated values.

Results for the following samples were less than the l owest calibration standard (0.01

mg/L): 72095, 72195, and 72199. Because all of these samples were a lready flagged by4

TestAmerica with a “J”, meaning the sample result was an estimated value because it was

below the RL, no further qualification was necessary.

The percent recoveries for the MS and MSD analyses o f sample 72045 were both 85%,

which is outside of the laboratory control criteria of 90-110%. However, because there

are no criteria for MS/MSD analyses specified in SM 4500 CN

- E, no further

qualification was necessary.

Nitrate/Nitrite

No issues were identified by the data reviewer.

Phosphorus

The percent recoveries for the MS/MSD analysis of sam ple 72045 were not within the

control limits of 90-110% specified in EPA Method 365.1 or within the laboratory

control limits of 71-128%. The percent recoveries of the MS and MSD samples were

19% and 21%, respectively. The result for sample 72045 was only slightly above the RL.

This low sample result could have caused the low percen t recovery. Nevertheless, sample

72045 was qualified as a minimum value. The LFB percent recov ery met the method

criteria.

TDS

Constant weight was not achieved after 3 drying cycles fo r all samples. It should be noted

that the weight increased from the first weighing to the second weighing for all samples.

Method 2540C warns that samples which contain high levels o f calcium, magnesium,

chloride, and sulfate may be hygroscopic meaning they abso rb moisture from the air.

FGD wastewater contains high concentrations of all o f these species. This was likely the

cause for the inconsistent weight calculations. The sam ples were not qualified, but results

may be biased high.

The RPDs for laboratory duplicates from samples 72045 and 72191 w ere less than 10%

as required by SM 2540C. However, the RPD for sample 72091 was 14%. Because the

RPD was greater than the method control limits, sampl e 72091 was qualified as an

estimated value.

TDS was detected at 6.0 mg/L in the method blank associa ted with samples 72191,

72195, and 72199. The method blank result was greater than the MDL (4.7 mg/L), but

less than the RL (10 mg/L). No qualification was necessar y because the blank result was

less than the RL.

TKN

The percent recovery for the LFB associated with sampl es 72041, 72045, 72091, 72095,

72191, 72195, and 72199 was not within the method control limits of 90-11 0%, but was5

within the laboratory control limits of 77-115%. The percen t recoveries for the LFB and

LFBD were 84% and 86%, respectively. Because the percent r ecovery of the LFB was

below the method criteria, samples 72041, 72045, 72091, 72095, 72191, 72195, and

72199 were qualified as minimum values.

TestAmerica performed MS/MSD analysis on sample 72045. The percent recoveries for

the MS and MSD samples were 77% and 93%, respectively. The MS sample did not meet

the method control limits of 90-110%, but did meet the labo ratory control limits of 54-

131%. The LFB associated with this batch was also not wit hin the laboratory control

limits, so this may have caused the low MS percent reco very. Also, the sample

concentration was greater than 4 times the spike amoun t in the MS and MSD samples, so

TestAmerica stated that the percent recoveries and RP Ds could not be reliably calculated.

Therefore, sample 72045 was not additionally qualified based on the MS failure because

it is not possible to determine if the MS failure was a result of matrix interferences or the

low spiking level.

TKN was detected at 0.133 mg/L in the LRB associated with samples 72041, 72045,

72091, 72095, 72191, 72195, and 72199. The blank result was greater than the MD L

(0.077 mg/L), but less than the RL (1.0 mg/L). Because the bla nk result was less than the

RL, no samples were qualified based on the LRB result.

TSS

The RPD for the laboratory duplicate of sample 72045 was 13%. This RPD was greater

than the method control criteria of 10%. Sample 72045 and its duplicate were already

qualified by TestAmerica with a “J” meaning that the resul t is an estimated value because

the result is below the RL, so no further qualificatio n was necessary.

Table 2. Data Review Summary Table

Sample Analyte Qualifier/Ac

tion Reason Level Detected

72191 BOD s SCB Recovery Low XXX mg/L

72195 BOD s, Minimum

Value SCB Recovery Low XXX mg/L

72199 BOD s, Minimum

Value SCB Recovery Low XXX mg/L

72041 Cyanide Estimated

Value Sample pH < 10 S.U.

at receipt 0.29 mg/L

72045 Cyanide Estimated

Value Sample pH < 10 S.U.

at receipt 0.17 mg/L

72045 Phosphorus Minimum

Value MS % recovery <

method-specified

criteria 0.057 mg/L6 Table 2. Data Review Summary Table

Sample Analyte Qualifier/Ac

tion Reason Level Detected

72091 TDS Estimated

Value Lab duplicate RPD >

method-specified

criteria XXX mg/L

72041 TKN Minimum

Value LFB% recovery <

method-specified

criteria 64 mg/L

72045 TKN Minimum

Value LFB% recovery <

method-specified

criteria 46 mg/L

72091 TKN Minimum

Value LFB% recovery <

method-specified

criteria XXX mg/L

72095 TKN Minimum

Value LFB% recovery <

method-specified

criteria XXX mg/L

72191 TKN Minimum

Value LFB% recovery <

method-specified

criteria XXX mg/L

72195 TKN Minimum

Value LFB% recovery <

method-specified

criteria XXX mg/L

72199 TKN Minimum

Value LFB% recovery <

method-specified

criteria XXX mg/L1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

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

Deb Bartram, ERG

TJ Finseth, ERG

From: Donna Tedder, ERG

Date: 2/9/2012

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

Month 2 (Part 1)

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

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

Atomic Fluorescence Spectrometry (CVAFS) analysis.

Table 1 summarizes the 19 samples (excluding laboratory pre p blanks) FGS extracted

and analyzed for total mercury.

Table 1. Long-Term Monitoring Month 2 (Part 1) Mercury – Sample Identification

EPA

Sample # Lab Sample

ID # Sample

Matrix Sample Description Sampling

Date

71992 1011064-01 Aqueous FGD Influent, Set 2 11/3/2010

71996 1011064-06 Aqueous FGD Bioreactor Influent, Set 2 11/3/2010

72000 1011064-11 Aqueous FGD Bioreactor Effluent, Set 2 11/3/2010

72005 1011064-12 Aqueous FGD Bioreactor Influent Field Blank, Set 2 11/ 3/2010

72009 1011064-13 Aqueous FGD Bioreactor Effluent Field Blank, Set 2 11/3 /2010

72042 1011043-01 Aqueous FGD Influent, Set 2 11/3/2010

72046 1011043-02 Aqueous FGD Effluent, Set 2 11/2/2010

72051 1011043-03 Aqueous FGD Effluent Field Blank, Set 2 11/2/2010

72092 1011031-01 Aqueous FGD Influent, Set 2 11/2/2010

72096 1011031-02 Aqueous FGD Effluent, Set 2 11/2/2010

72101 1011031-03 Aqueous FGD Effluent, Field Blank, Set 2 11/1/2010

72142 1011032-01 Aqueous FGD Influent, Set 2 11/1/2010

72146 1011032-02 Aqueous FGD Bioreactor Influent, Set 2 11/1/2010

72150 1011032-03 Aqueous FGD Bioreactor Effluent, Set 2 11/1/2010

72155 1011032-04 Aqueous FGD Bioreactor Influent Field Blank, Set 2 11/ 1/2010

72159 1011032-05 Aqueous FGD Bioreactor Effluent Field Blank, Set 2 11/1 /2010

72242 1011061-01 Aqueous FGD Influent, Set 2 11/4/2010

72246 1011061-06 Aqueous FGD Effluent, Set 2 11/4/2010

72251 1011061-07 Aqueous FGD Effluent Field Blank, Set 2 11/3/20102

SUMMARY

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

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

dataset. The following summarizes the findings from the data review:

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES

There were no sample receipt issues in this data package.

INITIAL CALIBRATION

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

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

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

criteria.

BLANKS

All the preparation blanks or laboratory reagent blanks (L RBs) and the continuing

calibration blanks (CCBs) met the method-specified crite ria. Because all of the blank

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

results.

DUPLICATES

No field duplicate samples were collected with these sa mpling episodes. Two samples

were analyzed in duplicate at the laboratory, samples 72046 a nd 72246. The relative

percent difference (RPD) for samples 72046 and 72246 were 4.25% an d 0.84%,

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

LABORATORY CONTROL SAMPLES

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

and 24% RPD.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES

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

71996, 72046, 72150, and 72246. All aqueous MS/MSD recoveries were within th e3

method specifications of 71-125%, except for the MS samples for 72046 and 72150,

which had recoveries of 20.1% and 54.5%, respectively. All RPD s met method-specified

criteria of less than or equal to 24%, except for samples 72046 and 72150, which had

RPDs of 72.2% and 24.5%, respectively. Because the MSDs an d the associated LCSs

were within the method specifications, no data qualificati on is required for these samples.

DETECTION LIMITS

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

were reported as not detected (ND).1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

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

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

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

Monitoring: Month 2 (Part 1)

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

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

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

EPA Method 200.8.

Table 1. Long-Term Monitoring Month 2 (Part 1) Total Metals – Sample

Identification

EPA

Sample # EPA Sample

Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

71992 FGD Influent, Set 2 280

- 9327

- 1 Aqueous 11/03/2010 11/04/2010

71996 FGD Bioreactor Influent,

Set 2 280

- 9389

- 1 Aqueous 11/04/2010 11/05/2010

72000 FGD Bioreactor Effluent,

Set 2 280

- 9389

- 2 Aqueous 11/04/2010 11/05/2010

72005 FGD Bioreactor Influent

Field Blank, Set 2 280

- 9389

- 3 Aqueous 11/04/2010 11/05/2010

72009 FGD Bioreactor Effluent

Field Blank, Set 2 280

- 9389

- 4 Aqueous 11/04/2010 11/05/2010

72042 FGD Influent, Set 2 280

- 9326

- 1 Aqueous 11/03/2010 11/04/2010

72046 FGD Effluent, Set 2 280

- 9326

- 2 Aqueous 11/03/2010 11/04/2010

72051 FGD Bioreactor Effluent

Field Blank, Set 2 280

- 9326

- 3 Aqueous 11/03/2010 11/04/2010

72092 FGD Influent, Set 2 280

- 9249

- 1 Aqueous 11/02/2010 11/03/2010

72096 FGD Effluent, Set 2 280

- 9249

- 2 Aqueous 11/02/2010 11/03/2010

72101 FGD Effluent Field

Blank, Set 2 280

- 9249

- 3 Aqueous 11/02/2010 11/03/2010

72142 FGD Influent, Set 2 280

- 9202

- 1 Aqueous 11/01/2010 11/02/2010

72146 FGD Bioreactor Influent,

Set 2 280

- 9250

- 1 Aqueous 11/02/2010 11/03/20102 Table 1. Long-Term Monitoring Month 2 (Part 1) Total Metals – Sample

Identification

EPA

Sample # EPA Sample

Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

72150 FGD Bioreactor Effluent,

Set 2 280

- 9250

- 2 Aqueous 11/02/2010 11/03/2010

72155 FGD Bioreactor Influent

Field Blank, Set 2 280

- 9250

- 3 Aqueous 11/02/2010 11/03/2010

72159 FGD Bioreactor Effluent

Field Blank, Set 2 280

- 9250

- 4 Aqueous 11/02/2010 11/03/2010

72242 FGD Influent, Set 2 280

- 9388

- 1 Aqueous 11/04/2010 11/05/2010

72246 FGD Effluent, Set 2 280

- 9388

- 2 Aqueous 11/04/2010 11/05/2010

72251 FGD Bioreactor Effluent

Field Blank, Set 2 280

- 9388

- 3 Aqueous 11/04/2010 11/05/2010

SUMMARY

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

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

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

EPA Method 200.8, by ICP/MS analysis.

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

required.

• The serial dilution for selenium for sample 72096 failed TestAmerica’s criteria of

±10% difference.

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

sample 72096 failed the EPA Method 200.8 control limits of 70–130%.

• The MS and MSD recoveries for selenium and silver for sample 72246 failed the

EPA Method 200.8 control limits of 70–130%.

• The MS/MSD relative percent difference (RPD) for silver for sample 72246 failed

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

• The post digestion spike (PDS) recoveries for silver failed TestAmerica’s control

limits of 85–115%.

INTERNAL STANDARDIZATION

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

INITIAL CALIBRATION3

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATION (ICV/CCV)

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

performed by TestAmerica all had recoveries within the method criteria.

METHOD/INSTRUMENT BLANKS

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

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

required for method blanks.

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

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

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

REPORTING LIMIT VERIFICATION STANDARD (CRI)

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

LABORATORY CONTROL SAMPLES (LCS)

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

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION

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

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

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

ICS.

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

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

The ICSA solution for the method 200.8 analysis exceeded the acceptance limits for

Chromium in analytical batch 280-40682. The lab has confirmed with the vendor that

Chromium is a trace impurity in the ICSA solution. Therefore, corrective action was

deemed unnecessary; the associated data have been flagged “^”.4

SERIAL DILUTION

The serial dilution performed on sample 72096 passed TestAmerica’s criteria of ±10%

difference for all analytes except selenium, which was flagged “V.” No further data

qualifiers were needed for the serial dilution.

FIELD DUPLICATES

No field duplicate samples were collected with these sampling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

MS and MSD were performed on samples 72096 and 72246. The MS/MSD for sample

72096 failed the method control limits of 70–130% recovery for selenium and silver.

Selenium was flagged for the MS/MSD with a “4” qualifier indicating that the

concentration in the parent sample was greater than 4 times the spike and could not be

reliably calculated. This result was considered acceptable based on the LCS passing the

method control limits. Silver was flagged for the MS/MSD with an “F” qualifier and it is

likely that silver failed due to matrix interference from the high concentration of sulfates,

which can form insoluble silver sulfide and/or silver sulfate. The silver recoveries in the

associated LCS/LCSD were acceptable.

The MS/MSD for sample 72246 failed the method control limits of 70–130% recovery

for selenium and silver, which were flagged with an “F” qualifier. The RPD failed the

FGD ICP/MS SOP control limits of ±20% for silver for sample 72246. No additional data

qualifiers were required for MS/MSD samples.

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

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

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

POST DIGESTION SPIKES (PDS)

The PDS performed on sample 72096 passed TestAmerica’s control limits of 85–115%

recovery for all analytes, except for silver, which was flagged with a “W” qualifier. It is

likely that silver failed due to matrix interference from the high concentration of sulfates,

which can form insoluble silver sulfide and/or silver sulfate. The silver recoveries in the

associated LCS/LCSD were acceptable. No additional data qualifiers were required.

DETECTION LIMITS

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

of reagent water.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

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

Monitoring: Month 2 (Part 1)

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

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

titanium and zinc). The samples were analyzed according t o EPA Method 200.7.

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

EPA Method 200.7.

Table 1. Long-Term Monitoring Month 2 (Part 1) Total Metals – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

7199 2 FGD Influent, Set 2 280

- 9327

- 1 Aqueous 11/03 /2010 11/04 /2010

71996 FGD Bioreactor Influent, Set 2 280

- 9389

- 1 Aqueous 11/04 /2010 11/05 /2010

72000 FGD Bioreactor Effluent, Set 2 280

- 9389

- 2 Aqueous 11/04 /2010 11/05 /2010

72005 FGD Bioreactor Influent Field

Blank, Set 2 280

- 9389

- 3 Aqueous 11/04 /2010 11/05 /2010

72009 FGD Bioreactor Effluent Field

Blank, Set 2 280

- 9389

- 4 Aqueous 11/04 /2010 11/05 /2010

7 2042 FGD Influent, Set 2 280

- 9326

- 1 Aqueous 11/03 /2010 11/04 /2010

7 2046 FGD Effluent, Set 2 280

- 9326

- 2 Aqueous 11/03 /2010 11/04 /2010

72051 FGD Bioreactor Effluent Field

Blank, Set 2 280

- 9326

- 3 Aqueous 11/03 /2010 11/04 /2010

7 2092 FGD Influent, Set 2 280

- 9249

- 1 Aqueous 11/02 /2010 11/03 /2010

72 101 FGD Ef

fluent Field Blank , Set 2 280

- 9249

- 3 Aqueous 11/02 /2010 11/03 /2010

72142 FGD Influent, Set 2 280

- 9202

- 1 Aqueous 11/01 /2010 11/02 /2010

7 2146 FGD Bioreactor Influent, Set 2 280

- 9250

- 1 Aqueous 11/02 /2010 11/03 /2010

7 2150 FGD Bioreactor Effluent, Set 2 280

- 9250

- 2 Aqueous 11/02 /2010 11/03 /2010

7 2155 FGD Bioreactor In fluent Field

Blank, Set 2 280

- 9250

- 3 Aqueous 11/02 /2010 11/03 /2010

7 2159 FGD Bioreactor Ef fluent Field

Blank, Set 2 2 80

- 9250

- 4 Aqueous 11/02 /2010 11/03 /2010

72242 FGD Influent, Set 2 280

- 9388

- 1 Aqueous 11/04 /2010 11/05 /20102

Table 1. Long-Term Monitoring Month 2 (Part 1) Total Metals – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

72251 FGD Bioreactor Effluent Field

Blank, Set 2 280

- 9388

- 3 Aqueous 11/04 /2010 11/05 /2010

SUMMARY

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

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

summarized below. No additional data qualifiers were requir ed for this data set.

• Aluminum, calcium, iron, magnesium, and manganese wer e measured above the

reporting limit (RL) in a method blank; however, the conc entration of these

elements in the samples associated with this method blank were at least 10 times

the blank result or below the RL.

• The matrix spike (MS)/matrix spike duplicate (MSD) rel ative percent difference

(RPD) for boron, calcium, and magnesium for sample 72096 failed TestAmerica’s

± 20% requirement.

• The post digestion spike (PDS) for calcium, manganese, t itanium, and zinc for

sample 72096 failed TestAmerica’s control limits of 85-115% re covery.

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES

There were no sample receipt issues in this data package.

INTERNAL STANDARDIZATION

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

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

the SOP were seen. All ISTD were within TestAmerica’ s SOP control limits.

INITIAL CALIBRATION

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

The initial calibration verifications (ICV) and continu ing calibration verifications (CCV)

performed by TestAmerica all had recoveries within the m ethod criteria.3

METHOD/INSTRUMENT BLANKS

All the method blanks were less than the RL, except for MB 280-40683/1-A. Aluminum,

calcium, iron, magnesium, and manganese were measured ab ove the RL in this method

blank; however, the concentration of these elements in the samples associated with this

method blank were at least 10 times the blank result or b elow the RL. Therefore, no data

needed qualification regarding the method blank result. In the other method blanks, some

elements were above the method detection limit (MDL), but less than the RL; therefore,

these blanks and were flagged with the “J” qualifier.

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

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

flagged with the “J” qualifier.

REPORTING LIMIT VERIFICATION STANDARD (CRI)

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

LABORATORY CONTROL SAMPLES (LCS)

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

INTERFERENCE CHECK SOLUTIONS

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

data quality objectives met TestAmerica’s SOP criteria.

SERIAL DILUTION (SRD)

All serial dilution percent differences were less tha n 10% as required by TestAmerica’s

SOP.

FIELD DUPLICATES

No field duplicate samples were collected with these sa mpling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

Matrix spikes (MS) and matrix spike duplicates (MSD) w ere performed on the total

samples of 72096 and 72246. Some elements with high concentrat ions failed the EPA

200.7 Method spike recovery control limits of 70–130% but were f lagged with a “4”

qualifier indicating that the concentration in the paren t sample was greater than 4 times

the spike and could not be reliably calculated. These da ta were considered acceptable

based on the LCS passing the method criteria. Otherwi se, all MS/MSD spike recoveries

were within the method control criteria of 70-130%. The RPD for all MS/MSDs were4

within TestAmerica’s ± 20% requirement, except for boron, calcium, and magnesium for

sample 72096. These elements were flagged with an “F” qualif ier.

POST DIGESTION SPIKE (PDS)

The PDS performed on sample 72096 passed TestAmerica’s contr ol limits of 85-115%

recovery for all analytes except boron, calcium, man ganese, sodium, titanium, and zinc.

Calcium, manganese, titanium, and zinc were qualified wit h a “W;” however, Because

the spike level in the MS/MSD analyses for these ele ments was less than 4 times the

sample concentration, there is no evidence of matrix in terferences. Additionally, these

elements passed TestAmerica’s requirement of percent d ifferences less than 10% for the

serial dilution for sample 72096. Boron and sodium failed t he PDS; however, the percent

recoveries were not calculated by the laboratory becaus e their concentrations were

greater than 4 times the PDS spike level. Boron and sodiu m also passed the serial dilution

for sample 72096 demonstrating no significant matrix interfe rences.

DETECTION LIMITS

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

of reagent water.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Ariel Atkinson, ERG

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Classicals Ana lyses – Long Term

Monitoring: Month 2 (Part 1)

TestAmerica Denver Laboratory generated analytical data for classical wet chemistry

analyses for these long-term monitoring samples. All s amples were tested for the

following analytes:

• Ammonia by EPA method 350.1,

• Biochemical Oxygen Demand – 5 day (BOD 5 ) by SM 5210B,

• Chloride and Sulfate by EPA method 300.0,

• Chemical Oxygen Demand (COD) by EPA method 410.4,

• Cyanide (total) by SM 4500 CN

- E,

• Nitrate/Nitrite by EPA method 353.2,

• Phosphorus (total) by EPA method 365.1,

• Total Dissolved Solids (TDS) by SM 2540C,

• Total Kjeldahl Nitrogen (TKN) by EPA method 351.2, and

• Total Suspended Solids (TSS) by SM 2540D.

Table 1 summarizes the 12 samples that TestAmerica anal yzed for the above analytes.

Table 1. Long-Term Monitoring Month 2 (Part 1) Classical Analytes – Sample

Identification

EPA

Sample # Sample

Matrix Sample Description Sampling

Date

71992 Water FGD Influent, Set 2 11/3/10

71996 Water FGD Bioreactor Influent, Set 2 11/3/10(CN)

11/4/10(All other

analytes)

72000 Water FGD Bioreactor Effluent, Set 2 11/3/10(CN)

11/4/10(All other

analytes)

72042 Water FGD Influent, Set 2 11/3/2010

72046 Water FGD Effluent, Set 2 11/3/20102

Table 1. Long-Term Monitoring Month 2 (Part 1) Classical Analytes – Sample

Identification

EPA

Sample # Sample

Matrix Sample Description Sampling

Date

72092 Water FGD Influent, Set 2 11/2/2010

72096 Water FGD Effluent, Set 2 11/2/2010

72142 Water FGD Influent, Set 2 11/1/2010

72146 Water FGD Bioreactor Influent, Set 2 11/2/2010

72150 Water FGD Bioreactor Effluent, Set 2 11/1/10(CN)

11/2/10(All other

analytes)

72242 Water FGD Influent, Set 2 11/4/10

72246 Water FGD Effluent, Set 2 11/4/10

SUMMARY

All samples were analyzed within the holding time specif ied in 40 CFR 136 Table II. All

samples were preserved appropriately unless otherwise speci fied below.

Field duplicate samples were not collected for these ep isodes. Depending on the method,

a laboratory duplicate was analyzed, instead. The Relati ve Percent Difference (RPD)

between the sample and its duplicate was less than 20% unl ess otherwise noted below.

If applicable, the appropriate number of standards was used to create a calibration curve.

If sample results were above the highest standard used t o create the curve, the sample was

diluted and reanalyzed unless otherwise specified below. Al l sample results were between

the lowest and highest standards unless noted below. Additi onally, unless otherwise

noted, all calibration blanks and calibration verificat ion samples met the criteria specified

in the method.

If required by the method, the quality control sample (QC S), a secondary source standard

used to verify calibration, was always within the cont rol limits specified by the method

unless otherwise noted below.

As described below, the analyte of interest was detecte d above the method detection limit

(MDL) in some laboratory reagent blanks (LRB). However , the analyte of interest was

never detected above the reporting limit (RL) in the LRBs . If required by the method, all

laboratory fortified blanks (LFB) met the criteria spec ified in the method unless specified

below.

If required by the method, a matrix spike (MS) sample wa s analyzed on samples 72042,

72096, and/or 72246 for each analyte to check for matrix interf erences. For some

analytes, TestAmerica spiked more samples than require d. MS samples analyzed met the

criteria specified in the method unless described below.3

DATA NOTES/ISSUES

Ammonia

The MS result failed criteria at 111% recovery and was qualified with an “F” flag. The

MSD and LCS recoveries demonstrate that the analysis was under control. No additional

qualifiers were required.

BOD 5

TestAmerica analyzed five dilutions, but no dilutions had a dissolved oxygen (DO)

depletion greater than 2.0 mg/L for samples 72092, 72146, 72150 72042, 72046, 71992,

71996, and 72246. Therefore, BOD 5 was reported as not detected for these samples. The

rest of the samples had at least one dilution with a DO depletion greater than 2.0 mg/L.

As required in the method, the final result was calculat ed by taking the average of the

results for all dilutions with a DO depletion greater t han 2.0 mg/L and a final DO greater

than 1.0 mg/L.

One of the three batches had a seed correction factor lower than 0.6 mg/L. The seed

correction factors were 0.632 mg/L, 0.5533 mg/L, and 0.6267 mg/L for batches 38776,

39101, and 39326 respectively. The samples in batch 39101 should be flagg ed with an

“s” indicating the seed correction blank (SCB) recovery was low. This low seed

correction factor suggests that samples 72042, 72046, and 71992 may be biased low;

however all these samples had a result of ND and ther efore do not require qualification.

All glucose-glutamic acid standards and laboratory duplicat es were analyzed

appropriately and met the criteria specified in SM 5210B.

Chloride and Sulfate

The MS/MSD results of samples 72246 for sulfate and chlori de were above the

calibration curve. TestAmerica did not reanalyze the s amples with a higher dilution factor

because the percent recoveries were within EPA method 300. 0 control limits. If reported,

these MS/MSD results will be qualified as estimated val ues. The LFB associated with

this sample met the method criteria. The analyzed resu lt for sample 72246 was within the

calibration curve, so there was no need to qualify this s ample.

COD

Several LRB and Calibration Blanks (CB) had results gr eater than the MDL; however, all

the LRB and CB results less than the RL and were flagge d with a “J” qualifier. No further

qualifications are necessary.

One LFB, LCSD from batch 41304, had a percent recovery grea ter that the 90-110%

criteria. The LFB was flagged with a “*” qualifier indic ating the LCS or LCSD exceeds4

the control limits. The sample 72046, which is associated with this LFB, was also flagged

with “*” qualifier.

The percent recovery for the MS/MSD analyses for sam ples 72096 and 72246 were above the control limits of 90-110% required by EPA method 410.4. The percent

recoveries for the MS and MSD analyses for sample 72096 were 115% and 118%,

respectively and the recoveries for sample 72246 were 131% and 132%, respectively.

These results were flagged with an “F” qualifier because t hey exceed control limits. The

LFB percent recoveries associated with samples 72096 and 72246 m et the method

criteria.

MS/MSDs were not performed in batches 41739 and 41304. The sampl es associated with

these batches include 72042 and 72046. These sample results were qualified with an “F”

qualifier because there were no MS/MSD results.

Cyanide

The calibration was performed using standards ranging from 0.00 ppb to 400.0 ppb. The

method states that the appropriate calibration range of s tandard concentrations for this

method are between 5 ppb and 20 ppb. Samples 72142, 72092, 72096, 72046, 72242, a ll

had results ≥ 20 ug/L; but were not diluted because they were within the ca libration range

performed by the laboratory.

The MS/MSD results for sample 72246 passed the recovery cr iteria; however, the

MS/MSD results for sample 72096 failed recovery criteria. The MS/MSD results for

72096 were qualified with an “F” flag. The associated LCS/LC SD recoveries were

within control limits.

Nitrate/Nitrite

The RPD between the LFB and a duplicate LFB from batch 280-40320 is 10.7%. This

does not meet the control limits, and therefore the LF B, LFB duplicate, and associated

samples are flagged with a “*” qualifier meaning RPD of the LCS and LCSD exceeds the

control limit. The RPD for the MS/MSD in this batch was 1 percent; therefore the system

appears to be in control. No further qualifiers were nee ded.

The MS/MSD results for samples 72042, 72096, and 72246 were above t he calibration

curve. TestAmerica did not reanalyze these MS/MSDs with a higher dilution factor, but

the MS/MSD results for samples 72246 and 72042 were flagged with an “E” qualifier

because the results exceeded calibration range. The MS/MSD results for sample 72096

were not flagged with “E” qualifier because the percent re coveries for the MS/MSD

analysis of sample 72096 were not within the method control limits of 90-110 percent;

therefore, these MS/MSD results were flagged with an “ F” qualifier. The percent

recoveries for the MS/MSD of 72096 were 118% and 121%, respectiv ely. Additionally,

the MS of sample 72042, and the MSD of sample 72246 were not wi thin the method

control limits of 90-110%. The percent recovery of the MS D for sample 72246 was 89%5

and the percent recovery of the MS of sample 72042 was 88 pe rcent; however neither

MS/MSDs were flagged with an “F’ qualifier because they d id meet the laboratory

control limits. If reported, the 72042 MS should be flagged w ith an “F” qualifier, the

72096 MS/MSD should be qualified as estimated, and the 72246 MS sho uld be flagged

with an “F” qualifier.

Phosphorus

The LRB was greater than the MDL at 0.0141 mg/L, however th e result was less than the

RL. The LRB results were flagged with a “J” qualifier b ecause the result was less than

the RL but greater than the MDL. No further qualifiers are needed. All samples that

contained the analyte were also flagged with a “B” qualif ier because the compound was

found in the blank and the sample. All calibration blank r esults were also above the MDL

but less than the RL, and therefore are also flagged wi th a “J” qualifier.

The percent recoveries for the MS/MSD analysis of sa mples 72096 and 72246 were not

within the control limits of 90-110% specified in EPA Method 365. 1. However the

MS/MSD of sample 72096 were within the laboratory control limits of 71-128%. The

percent recoveries of the MS and MSD for sample 72096 were 87% and 84%,

respectively, and the MS and MSD recoveries for sample 72246 were 26% and 31%,

respectively. Because the MS/MSD of sample 72096 met labo ratory control limits it was

not flagged by the laboratory, but if the MS/MSD results for sample 72096 are reported,

they should be flagged with an “F” qualifier.

Samples 72146, 72150, 72046, 72242, 71996, 72000, and the LRB had results that were

lower than the lowest calibration standard. Each of th ese results was flagged with a “J”

qualifier because each result was less than the RL but greater than or equal to the MDL,

and therefore the concentrations are approximate values. N o further qualifiers are needed.

TDS

Constant weight was not achieved after 3 drying cycles fo r all samples. It should be noted

that the weight increased from the first weighing to th e second weighing for all samples

except 72042, 72046, 71992, 72242, 72246, 71996, and 72000. Method 2540C warns that

samples which contain high levels of calcium, magnesiu m, chloride, and sulfate may be

hygroscopic meaning they absorb moisture from the air. FGD wastewater contains high

concentrations of all of these species. This was likely the cause for the inconsistent

weight calculations. Samples 72142, 72092, 72096, 72146, and 72150 were not qua lified,

but results may be biased high.

The RPD for the laboratory duplicate from sample 72096 was 12%, which is not less than

10% as required by SM 2540C. The laboratory control limits a re 20%; therefore, the

laboratory did not qualify the sample. The sample resu lt will be qualified as an estimated

value as shown in Table 2. Laboratory duplicates were n ot performed in the other

batches.6

TKN

TestAmerica performed MS/MSD analysis on samples 72096 and 72246. The percent

recoveries for the MS and MSD for sample 72096 were 161% an d 147%, respectively,

and 145% and 149% for the MS and MSD for sample 72246. These samp les did not meet

the method control limits of 90-110%, nor the laboratory co ntrol limits of 54-131%. The

sample concentration was greater than 4 times the spike amount in the MS and MSD

samples, so TestAmerica stated that the percent recove ries and RPDs could not be

reliably calculated. The associated LCS/LCSD were also acceptable, therefore, no

additional data qualifiers are required.

TKN was detected in the calibration blanks. The results were greater than the MDL

(0.077 mg/L), but less than the RL (1.0 mg/L). Because the re sults were less than the RL,

no samples were qualified, but the CBs were flagged with a “J” qualifier.

TSS

The RPDs for the laboratory duplicates performed on sam ples 72142, 72096, 72046, and

72246 were greater than the method control criteria of 10%, at 11%, 18%, 22%, and 18%,

respectively. The laboratory control criterion is 20 perc ent; therefore, samples 72142,

72096, and 72246 were not qualified by the laboratory. Sample 72046 and its duplicate

were already qualified by TestAmerica with a “J” meaning t hat the result is an estimated

value because the result is below the RL, so no further qualification was necessary for

this sample. Because the RPD was greater than the meth od control limits, sample 72142,

72096, and 72246 were qualified as estimated values.

Table 2. Data Review Summary Table

Sample Analyte Qualifier/Ac

tion Reason Level Detected

72042 COD F MS/MSD not

performed in batch 450 mg/L

72046 COD F MS/MSD not

performed in batch 290 mg/L

72096 TDS Estimated

Value Lab duplicate RPD >

method-specified

criteria Sample: XXX

mg/L

Dup: XXX

mg/L,12%RPD

72142 TSS Estimated

Value Lab duplicate RPD >

method-specified

criteria Sample: XXX

mg/L Dup: XXX

mg/L; 11%RPD

72096 TSS Estimated

Value Lab duplicate RPD >

method-specified

criteria Sample: XXX

mg/L

Dup: XXX

mg/L; 18% RPD7 Table 2. Data Review Summary Table

Sample Analyte Qualifier/Ac

tion Reason Level Detected

72246 TSS Estimated

Value Lab duplicate RPD >

method-specified

criteria Sample: XXX

mg/L

Dup: XXX

mg/L; 18% RPD1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

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

Deb Bartram, ERG

TJ Finseth, ERG

From: Donna Tedder, ERG

Date: 2/9/2012

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

Month 3

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

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

Atomic Fluorescence Spectrometry (CVAFS) analysis.

Table 1 summarizes the 24 samples (excluding laboratory pre p blanks) FGS extracted

and analyzed for total mercury.

Table 1. Long-Term Monitoring Month 3 Mercury – Sample Identification

EPA

Sample # Lab Sample

ID # Sample

Matrix Sample Description Sampling

Date

71993 1012119-01 Aqueous FGD Influent, Set 3 12/8/2010

71997 1012119-06 Aqueous FGD Bioreactor Influent, Set 3 12/8/2010

72001 1012119-11 Aqueous FGD Bioreactor Effluent, Set 3 12/8/2010

72006 1012119-12 Aqueous FGD Bioreactor Influent Field Blank, Set 3 12/ 8/2010

72010 1012119-13 Aqueous FGD Bioreactor Effluent Field Blank, Set 3 12/8 /2010

72043 1012094-01 Aqueous FGD Influent, Set 3 12/8/2010

72047 1012094-02 Aqueous FGD Effluent, Set 3 12/7/2010

72052 1012094-03 Aqueous FGD Effluent Field Blank, Set 3 12/7/2010

72093 1012077-01 Aqueous FGD Influent Set 3 12/7/2010

72097 1012077-02 Aqueous FGD Effluent, Set 3 12/7/2010

72102 1012077-03 Aqueous FGD Effluent Field Blank, Set 3 12/7/2010

72143 1012080-01 Aqueous FGD Influent, Set 3 12/6/2010

72147 1012080-06 Aqueous FGD Bioreactor Influent, Set 3 12/6/2010

72151 1012080-11 Aqueous FGD Bioreactor Effluent, Set 3 12/6/2010

72156 1012080-12 Aqueous FGD Bioreactor Influent Field Blank, Set 3 12/ 6/2010

72160 1012080-13 Aqueous FGD Bioreactor Effluent Field Blank, Set 3 12/6/2010

72192 1012105-01 Aqueous FGD Influent, Set 1 12/8/2010

72196 1012105-02 Aqueous FGD SBR Influent, Set 1 12/8/2010

72200 1012105-03 Aqueous FGD SBR Effluent, Set 1 12/8/20102 Table 1. Long-Term Monitoring Month 3 Mercury – Sample Identification

EPA

Sample # Lab Sample

ID # Sample

Matrix Sample Description Sampling

Date

72205 1012105-04 Aqueous FGD SBR Influent Field Blank, Set 1 12/8/2010

72209 1012105-05 Aqueous FGD SBR Effluent Field Blank, Set 1 12/8/2010

72243 1012117-01 Aqueous FGD Influent, Set 3 12/9/2010

72247 1012117-06 Aqueous FGD Effluent, Set 3 12/9/2010

72252 1012117-07 Aqueous FGD Effluent Field Blank, Set 3 12/8/2010

SUMMARY

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

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

dataset.

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES

There were no sample receipt issues in this data package.

INITIAL CALIBRATION

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

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

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

criteria.

BLANKS

All the preparation blanks or laboratory reagent blanks (L RBs) and the continuing

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

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

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

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

results.

DUPLICATES

No field duplicate samples were collected with these sa mpling episodes. Three samples

were analyzed in duplicate at the laboratory, Bioreacto r Influent sample 72147, SBR

Influent sample 72196, and Effluent sample 72247. The relative pe rcent difference (RPD)3

for samples 72147, 72196, and 72247 were 9.74%, 4.36%, and 9.10%, respectiv ely. A

sample from another work order was analyzed in duplica te with these batches that

resulted in an RPD of 79.7%, which is outside of the laborat ory’s criteria. The

laboratory’s RPD criteria between analytical duplicates is 24%. No sample qualifications

were needed based on these analytical duplicate results.

LABORATORY CONTROL SAMPLES

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

and 24% RPD.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

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

72097, 72147, and 72196. Additionally, an MS/MSD was performed on samp le 72296,

which was a rerun from the long-term monitoring, month 2 set of samples. All aqueous

MS/MSD recoveries were within method specifications of 71-125%. All RPDs met

method-specified criteria.

DETECTION LIMITS

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

were reported as not detected (ND).1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

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

Monitoring: Month 3

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

chromium, copper, lead, nickel, selenium, silver, thalliumand vanadium) for these longterm monitoring samples. The samples were analyzed accor ding to EPA Method 200.8.

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

EPA method 200.8.

Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

71993 FGD Influent, Set 3 280

- 10586

- 1 Aqueous 12/08/2010 12/09/2010

71997 FGD Bioreactor Influent, Set 3 280

- 10586

- 2 Aqueous 12/08/2010 12/09/2010

71997 FGD Bioreactor Influent, Set 3 280

- 10654

- 1 Aqueous 12/09/2010 12/10/2010

72001 FGD Bioreactor Effluent, Set 3 280

- 10654

- 2 Aqueous 12/09/2010 12/10/2010

72006 FGD Bioreactor Influent Field

Blank, Set 3 280

- 10654

- 3 Aqueous 12/09/2010 12/10/2010

72010 FGD Bioreactor Effluent Field

Blank, Set 3 280

- 10654

- 4 Aqueous 12/09/2010 12/10/2010

72043 FGD Influent, Set 3 280

- 10584

- 1 Aqueous 12/08/2010 12/09/2010

72047 FGD Effluent, Set 3 280

- 10584

- 2 Aqueous 12/08/2010 12/09/2010

72052 FGD Bioreactor Effluent Field

Blank, Set 3 280

- 10584

- 3 Aqueous 12/08/2010 12/09/2010

72093 FGD Influent, Set 3 280

- 10515

- 1 Aqueous 12/07/2010 12/08/2010

72097 FGD Effluent, Set 3 280

- 10515

- 2 Aqueous 12/07/2010 12/08/2010

72102 FGD Effluent Field Blank, Set 3 280

- 10515

- 3 Aqueous 12/07/2010 12/08/2010

72143 FGD Influent, Set 3 280

- 10455

- 1 Aqueous 12/06/2010 12/07/2010

72147 FGD Bioreactor Influent, Set 3 280

- 10517

- 1 Aqueous 12/07/2010 12/08/2010

72151 FGD Bioreactor Effluent, Set 3 280

- 10517

- 2 Aqueous 12/07/2010 12/08/2010

72156 FGD Bioreactor Influent Field

Blank, Set 3 280

- 10517

- 3 Aqueous 12/07/2010 12/08/2010

72160 FGD Bioreactor Effluent Field 280

- 10517

- 4 Aqueous 12/07/2010 12/08/20102

Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

Blank, Set 3

72192 FGD Influent, Set 1 280

- 10585

- 1 Aqueous 12/08/2010 12/09/2010

72196 FGD SBR Influent, Set 1 280

- 10585

- 2 Aqueous 12/08/2010 12/09/2010

72200 FGD SBR Effluent, Set 1 280

- 10585

- 3 Aqueous 12/08/2010 12/09/2010

72205 FGD SBR Influent Field Blank,

Set 1 280

- 10585

- 4 Aqueous 12/08/2010 12/09/2010

72209 FGD SBR Effluent Field Blank,

Set 1 280

- 10585

- 5 Aqueous 12/08/2010 12/09/2010

72243 FGD Influent, Set 3 280

- 10655

- 1 Aqueous 12/09/2010 12/10/2010

72247 FGD Effluent, Set 3 280

- 10655

- 2 Aqueous 12/09/2010 12/10/2010

72252 FGD Effluent Field Blank, Set 3 280

- 10655

- 3 Aqueous 12/09/2010 12/10/2010

SUMMARY

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

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

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

EPA Method 200.8, by ICP/MS analysis.

Any significant findings are summarized below. No addition al data qualifiers were

required.

• One of the continuing calibration verifications (CCV) per formed on 12/21/2010

failed the method criteria for selenium.

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

silver for sample 72196 failed the EPA Method 200.8 control lim its of 70-130%.

The MSD recovery for total silver for sample 72147 also fa iled the method

control limits.

• The MS/MSD relative percent difference (RPD) for tota l silver for samples 72147

and 72196 failed the FGD ICP/MS SOP control limits of ±20%.

• The post digestion spike (PDS) recoveries for copper, nic kel, and silver for

sample 72147 failed TestAmerica’s control limits of 85–115%. The PDS

recovery for silver for sample 71997 also failed TestAmeri ca’s control limits.

INTERNAL STANDARDIZATION

All internal standards used by TestAmerica were within th e method criteria.3

INITIAL CALIBRATION

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATION (IC V/CCV)

The initial calibration verifications (ICV) and CCV perf ormed by TestAmerica all had

recoveries within the method criteria, except for seleniu m for one CCV on 12/21/2010.

Samples associated with this CCV that had selenium value s less than the reporting limit

were reported. Any samples with selenium values above the reporting limit were

reanalyzed.

METHOD/INSTRUMENT BLANKS

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

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

required for method blanks.

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

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

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

REPORTING LIMIT VERIFICATION STANDARD (CRI)

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

LABORATORY CONTROL SAMPLES (LCS)

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

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION

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

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

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

ICS.

All interference check sample B (ICSAB) synthetic sp ikes recovered within

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

SERIAL DILUTION

The serial dilution performed on samples 72147 and 72196 passed Te stAmerica’s criteria

of ±10% difference.4

FIELD DUPLICATES

No field duplicate samples were collected with these sa mpling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

MS and MSD were performed on samples of 72147, 72196, and 71997. The M SD of

sample 72147 failed the method control limits of 70–130% recover y for silver at 69%,

which was flagged with an “F” qualifier. The MS/MSD of sam ple 72196 failed the

method control limits of 70–130% recovery for silver, which was flagged with an “F”

qualifier. These silver failures are likely due to matrix interference from the high

concentration of sulfates, which can form insoluble si lver sulfide and/or silver sulfate.

The silver recoveries in the associated LCS/LCSDs were acceptable. The RPD for the

MS/MSDs for samples 72147 and 72196 failed the FGD ICP/MS SOP ± 20% control

limits for silver.

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

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

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

POST DIGESTION SPIKES (PDS)

The PDS performed on samples 72147 and 71997 passed TestAmerica’s control limits of

85–115% recovery for all analytes, except for copper, nickel, and silver for PDS sample

72147 and silver for PDS sample 71997, which were flagged with a “W ” qualifier. No

additional data qualifiers were required.

DETECTION LIMITS

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

of reagent water.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

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

Monitoring: Month 3

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

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

titanium and zinc). The samples were analyzed according t o EPA Method 200.7.

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

EPA Method 200.7

Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

71993 FGD Influent , Set 3 280

- 10586

- 1 Aqueous 12/08 /2010 12/09 /2010

71997 FGD Bioreactor Influent , Set 3 280

- 10654

- 1 Aqueous 12/09 /2010 12/10 /2010

72001 FGD Bioreactor Effluent , Set 3 280

- 10654

- 2 Aqueous 12/09 /2010 12/10 /2010

72006 FGD Bioreactor Influent Field

Blank, Set 3 280

- 10654

- 3 Aqueous 12/09 /2010 12/10 /2010

72010 FGD Bioreactor Effluent Field

Blank, Set 3 280

- 10654

- 4 Aqueous 12/09 /2010 12/10 /2010

7 2043 FGD Influent, Set 3 280

- 10584

- 1 Aqueous 12/08 /2010 12/09 /2010

7 2047 FGD Effluent, Set 3 280

- 10584

- 2 Aqueous 12/08 /2010 12/09 /2010

72052 FGD Bioreactor Effluent Field

Blank, Set 3 280

- 10584

- 3 Aqueous 12/08 /2010 12/09 /2010

7 2093 FGD Influent, Set 3 280

- 10515

- 1 Aqueous 12/07 /2010 12/08 /2010

7 2097 FGD Ef fluent, Set 3 280

- 10515

- 2 Aqueous 12/07 /2010 12/08 /2010

72 102 FGD Ef

fluent Field Blank , Set 3 280

- 10515

- 3 Aqueous 12/07 /2010 12/08 /2010

72143 FGD Influent, Set 3 280

- 10455

- 1 Aqueous 12/06 /2010 12/07 /2010

7 2147 FGD Bioreactor Influent, Set 3 280

- 10517

- 1 Aqueous 12/07 /2010 12/08 /2010

7 2151 FGD Bioreactor Effluent, Set 3 280

- 10517

- 2 Aqueous 12/07 /2010 12/08 /2010

7 2156 FGD Bioreactor In fluent Field

Blank, Set 3 280

- 10517

- 3 Aqueous 12/07 /2010 12/08 /2010

7 2160 FGD Bioreactor Ef fluent Field

Blank, Set 3 2 80

- 10517

- 4 Aqueous 12/07 /2010 12/08 /2010

7 2192 FGD Influent, Set 1 280

- 10585

- 1 Aqueous 12/08 /2010 12/09 /20102 Table 1. Long-Term Monitoring Month 3 Total Metals – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

72196 FGD SBR Influent, Set 1 280

- 10585

- 2 Aqueous 12/08 /2010 12/09 /2010

72200 FGD SBR Effluent, Set 1 280

- 10585

- 3 Aqueous 12/08 /2010 12/09 /2010

72205 FGD SBR Influent Field Blank

, Set 1 280

- 10585

- 4 Aqueous 12/08 /2010 12/09 /2010

72209 FGD SBR Effluent Field Blank

, Set 1 280

- 10585

- 5 Aqueous 12/08 /2010 12/09 /2010

72243 FGD Influent, Set 3 280

- 10655

- 1 Aqueous 12/09 /2010 12/10 /2010

72247 FGD Effluent, Set 3 280

- 10655

- 2 Aqueous 12/09 /2010 12/10 /2010

72252 FGD Effluent Field Blank, Set 3 280

- 10655

- 3 Aqueous 12/09 /2010 12/10 /2010

SUMMARY

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

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

summarized below. Additional data qualifiers were require d (see Table 2).

• The serial dilution for cobalt, iron, and zinc for sa mple 72143 failed

TestAmerica’s SOP control limit of percent differenc es less than 10%.

• The post digestion spike (PDS) for calcium, iron, magn esium, and zinc for sample

72143 failed TestAmerica’s control limits of 85–115% recovery.

• The PDS for manganese for sample 72147 failed TestAmerica ’s control limits of

85–115% recovery.

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES

The samples associated with Episode 6569 (72192, 72196, 72200, 72205, and 72209) did

not have a sample date or time on the traffic report.

INTERNAL STANDARDIZATION

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

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

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

INITIAL CALIBRATION

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

calibration for the ICP analysis consisted of a blank an d one calibration standard.3

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

The initial calibration verifications (ICV) and continu ing calibration verifications (CCV)

performed by TestAmerica all had recoveries within the m ethod criteria.

METHOD/INSTRUMENT BLANKS

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

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

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

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

flagged with the “J” qualifier.

REPORTING LIMIT VERIFICATION STANDARD (CRI)

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

LABORATORY CONTROL SAMPLES (LCS)

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

INTERFERENCE CHECK SOLUTIONS

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

data quality objectives met TestAmerica’s SOP criteria.

SERIAL DILUTION (SRD)

Serial dilutions were performed for each batch of total samples. All serial dilution percent

differences were less than 10% as required by TestAmeric a’s SOP, except for cobalt,

iron, and zinc for sample 72143, which were flagged with a “ V” qualifier.

FIELD DUPLICATES

No field duplicate samples were collected with these sa mpling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

Matrix spikes (MS) and matrix spike duplicates (MSD) w ere performed on the total

samples of 72143, 72147, and 72196. Some elements with high concent rations failed the

EPA 200.7 Method spike recovery control limits of 70–130% but w ere flagged with a “4”

qualifier indicating that the concentration in the paren t sample was greater than 4 times

the spike and could not be reliably calculated. These data were considered acceptable

based on the LCS passing the method control limits. Othe rwise, all MS/MSD spike

recoveries were within the method control criteria of 70-130%. The RPD for all4

MS/MSDs were within TestAmerica’s ± 20% requirement. No additional data qualifiers

were needed.

POST DIGESTION SPIKE (PDS)

The PDS performed on sample 72143 passed TestAmerica’s cont rol limits of 85–115%

recovery for all analytes except aluminum, boron, calc ium, iron, magnesium, titanium,

and zinc. Calcium, magnesium, and zinc were qualified with a “W”. Calcium and

magnesium did pass in the matrix spike for this sample. Aluminum, boron, iron and

titanium failed the PDS; however, the percent recoveri es were not calculated by the

laboratory because their concentrations were greater than 4 times the PDS spike level.

Aluminum, boron, and titanium passed TestAmerica’s requir ement of percent differences

less than 10% for the serial dilution for this sample demo nstrating that there were no

significant matrix interference with these elements. Iron and zinc failed TestAmerica’s

requirements for the serial dilution; therefore, based on these cumulative results, iron and

zinc are being qualified as suspect due to matrix interfere nce. These additional qualifiers

appear in Table 2.

The PDS performed on sample 72147 passed TestAmerica’s cont rol limits of 85–115%

recovery for all analytes except boron and manganese. Manganese was qualified with a

“W”. Boron failed the PDS; however, the percent recov ery was not calculated by the

laboratory because its concentration was greater the 4 times the PDS spike level. Both

boron and manganese passed TestAmerica’s requirement of percent differences less than

10% for the serial dilution for sample 72147 demonstrating th at there were no significant

matrix interferences. No additional qualifier is requir ed due to this PDS.

The PDS performed on sample 72196 passed TestAmerica’s cont rol limits of 85–115%

recovery for all analytes except boron and manganese; however, the percent recoveries

were not calculated by the laboratory because their co ncentrations were greater than 4

times the PDS spike level. Both boron and manganese passed TestAmerica’s requirement

of percent differences less than 10% for the serial dil ution for sample 72196

demonstrating that there were no significant matrix int erferences. No additional qualifier

is required due to this PDS.

DETECTION LIMITS

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

of reagent water.

Table 2. Data Review Summary

Sample Analyte Qualifier/Action Reason Level Detected

72143 Iron (total) Matrix

Interference PDS and SD Failed XXX μ g/L

72143 Zinc (total) Matrix

Interference PDS and SD Failed XXX ug/L1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Deb Bartram, ERG

TJ Finseth, ERG

From: Jennifer Colby, ERG

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Classicals Ana lyses – Long-Term

Monitoring: Month 3

TestAmerica Denver Laboratory generated analytical data f or classical wet chemistry

analyses for these long-term monitoring samples. All s amples were tested for the

following analytes:

• Ammonia by EPA method 350.1,

• Biochemical Oxygen Demand – 5 day (BOD 5 ) by SM 5210B,

• Chloride and Sulfate by EPA method 300.0,

• Chemical Oxygen Demand (COD) by EPA method 410.4,

• Cyanide (total) by SM 4500 CN

- E,

• Nitrate/Nitrite by EPA method 353.2

• Phosphorus (total) by EPA method 365.1,

• Total Dissolved Solids (TDS) by SM 2540C,

• Total Kjeldakl Nitrogen (TKN) by EPA method 351.2, and

• Total Suspended Solids (TSS) by SM 2540D.

Table 1 summarizes the 15 samples that TestAmerica anal yzed for the above analytes.

Table 1. Long-Term Monitoring Month 3 Classical Analytes – Sample

Identification

EPA

Sample # Sample

Matrix Sample Description Sampling

Date

71993 Water FGD Influent, Set 3 12/08/2010

71997 Water FGD Bioreactor Influent, Set 3 12/09/2010

72001 Water FGD Bioreactor Effluent, Set 3 12/09/2010

72043 Water FGD Influent, Set 3 12/08/2010

72047 Water FGD Effluent, Set 3 12/08/2010

72093 Water FGD Influent, Set 3 12/07/2010

72097 Water FGD Effluent, Set 3 12/07/2010

72143 Water FGD Influent, Set 3 12/06/2010

72147 Water FGD Bioreactor Influent, Set 3 12/07/20102 Table 1. Long-Term Monitoring Month 3 Classical Analytes – Sample

Identification

EPA

Sample # Sample

Matrix Sample Description Sampling

Date

72151 Water FGD Bioreactor Effluent, Set 3 12/07/2010

72192 Water FGD Influent, Set 1 12/08/2010

72196 Water FGD SBR Influent, Set 1 12/08/2010

72200 Water FGD SBR Effluent, Set 1 12/08/2010

72243 Water FGD Influent, Set 3 12/09/2010

72247 Water FGD Effluent, Set 3 12/09/2010

SUMMARY

All samples were analyzed within the holding time specif ied in 40 CFR 136 Table II

unless otherwise noted below. All samples were preserve d appropriately unless

otherwise specified below. Samples 72192, 72196, and 72200 had no colle ction dates or

times listed on the traffic report, and were given the date of relinquishment. Many of the

traffic reports did not have receipt temperatures.

Field duplicate samples were not collected for this epis ode. Depending on the method, a

laboratory duplicate was analyzed instead. The Relative Percent Difference (RPD)

between the sample and its duplicate was less than 20% unl ess otherwise noted below.

If applicable, the appropriate number of standards was used to create a calibration curve.

If sample results were above the highest standard used t o create the curve, the sample was

diluted and reanalyzed. All sample results were between the lowest and highest standards

unless noted below. Additionally, unless otherwise noted, a ll calibration blanks and

calibration verification samples met the criteria sp ecified in the method.

If required by the method, the quality control sample (QC S), a secondary source standard

used to verify calibration, was always within the cont rol limits specified by the method.

As described below, the analyte of interest was detecte d above the method detection limit

(MDL) in some laboratory reagent blanks (LRB). However , the analyte of interest was

never detected above the reporting limit (RL) in the LRBs . If required by the method, all

laboratory fortified blanks (LFB) met the criteria spec ified in the method unless specified

below.

If required by the method, a matrix spike (MS) analysis was run on sample 72147 and

sample 72196 for each analyte to check for matrix interfe rences. All MS samples

analyzed met the criteria specified in the method unless described below.3

DATA NOTES/ISSUES

Ammonia

The result for the method blank associated with one of the batches was greater than the

MDL. All associated samples were flagged with a “B” qualif ier. This affects samples

72147, 72143, 72093, 72097, and 72151. No further action is required.

The percent recoveries for the MS and matrix spike dupli cate (MSD) for sample 72147

were 93% and 102%, respectively, which is within the method co ntrol criteria; however,

the results exceeded the calibration range. These MS a nd MSD and results were flagged

with an “E” qualifier.

BOD 5

TestAmerica analyzed five dilutions, but no dilutions had a dissolved oxygen (DO)

depletion greater than 2.0 mg/L for samples 72143, 72151, 72043, 71993, a nd 72247.

Therefore, BOD 5 was reported as not detected for these samples. Additiona lly, for sample

72200, the dilutions did not have a residual DO criteria of gre ater than 1.0 mg/L;

therefore, BOD 5 was reported as not detected for this sample. The rest of the samples had

at least one dilution with a DO depletion greater than 2.0 mg/L. As required in the

method, the final result was calculated by taking the av erage of the results for all

dilutions with a DO depletion greater than 2.0 mg/L and a final DO greater than 1.0

mg/L.

Chloride and Sulfate

MS and MSD were performed on samples 72147 and 72196. The MS/MS D recoveries

for both samples were within the method control for both chloride and sulfate; however,

the MS and MSD results for chloride exceeded the calibra tion range. Both sets of

MS/MSD results were flagged with “E” qualifiers.

COD

MS and MSD were performed on samples 72147 and 72196. The MS a nd MSD

recoveries for sample 72147 were 66% and 71%, respectively, w hich is outside the

method control criteria. These MS/MSD results were flagged with an “F” qualifier. The

MS and MSD recoveries for sample 72196 were 72% and 70%, respec tively, which is

outside the method control criteria. These MS/MSD re sults were flagged with an “F”

qualifier.

Cyanide

Because of the nature of the sample matrix, all of th e samples in this sampling episode

used a lower volume, which resulted in elevated RLs being ca lculated and reported by

TestAmerica with the sample results.4

MS and MSD were performed on samples 72147 and 72196. The MS a nd MSD

recoveries for sample 72147 were 76% and 75%, respectively. T he MS and MSD

recoveries for sample 72196 were 59% and 57%, respectively. Th e LCS/LCSD

recoveries associated with these batches were acceptabl e, which indicates the analytical

system was operating within control. Additionally, ther e is no method requirement for the

analysis of a MS/MSD and therefore, no corrective ac tion is necessary.

Nitrate/Nitrite

No MS/MSD data was reported for batch 45200 in the sample a nd QC sample report

summary. The method requires that a known amount of ana lyte be added to 10% of

samples per batch. The general chemistry worksheet indi cates that MS samples were

performed on a sample outside of these episodes, but no spiking concentrations or percent

recoveries are indicated. The MS/MSD recoveries for the other batches were within

control limits.

Phosphorus

The results for the method blanks associated with two of the batches was greater than the

MDL, but less than the RL. The blank results were flagge d with a “J” qualifier. All

associated samples were qualified with a “B” flag. No additional corrective action is

necessary.

MS and MSD were performed on sample 72001, 72147 and 72196. The percen t

recoveries for the MS and MSD for sample 72147 were 69% an d 70%, respectively,

which is outside the method control criteria. These MS /MSD results were flagged with

an “F” qualifier. The LCS/LCSD recoveries for this ba tch were acceptable and indicate

that the analytical system was operating within control . The percent recoveries for the

MS and MSD for sample 72196 were 91% and 85%, respectively. The MSD recovery is

outside the method control criteria, but within the labor atory criteria and therefore, was

not flagged. If reported, the MSD result should be flagge d with an “F” qualifier. The

LCS/LCSD recoveries for this batch were acceptable and ind icate that the analytical

system was operating within control. Additionally, the MS/MSD performed on sample

72001 was in the same batch as the MS/MSD for 72196 and the pe rcent recoveries for the

MS and MSD were 96% and 97%, respectively, with are within th e method control

criteria.

TDS

TA reports that constant weight was not achieved after 3 drying cycles for the following

samples: 72097, 72143, 72147, 72151, 71993, 72196, 72200, 71997, 72004, and 72243.

Review of the general chemistry worksheets indicates th at constant weight was achieved

for all samples. No further action was necessary.5

Because of the nature of the sample matrix, some of t he samples in this sampling episode

used a lower volume, which resulted in elevated RLs being ca lculated and reported by

TestAmerica with the sample results.

The analytical duplicate associated with sample 72143 excee ded the recovery criteria.

The duplicate result was qualified with an “F” flag. Beca use an analytical duplicate was

not required by the method, no further corrective action i s necessary.

TKN

MS and MSD were performed on samples 72147 and 72196. The MS a nd MSD

recoveries for sample 72147 were 76% and 57%, respectively. The concentration in the

original sample was greater than four times the spike a mount; therefore, the recoveries

cannot be reliably calculated and the results were flagge d with a “4” qualifier. The MS

and MSD recoveries for sample 72196 were 81% and 78%, respecti vely, which do not

meet the method control criteria, but do meet the labo ratory control criteria and therefore,

these results were not flagged by the laboratory. If r eported, the MS and MSD results

should be flagged with “F” qualifiers. The LCS/LCSD reco veries associated with these

batches were acceptable, which indicates the analytical system was operating within

control.

TSS

Because of the nature of the sample matrix, some of t he samples in this sampling episode

used a lower volume, which resulted in elevated RLs being ca lculated and reported by

TestAmerica with the sample results.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

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

Deb Bartram, ERG

TJ Finseth, ERG

From: Donna Tedder, ERG

Date: 2/9/2012

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

Month 4 and 5

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

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

Atomic Fluorescence Spectrometry (CVAFS) analysis.

Table 1 summarizes the 30 samples (excluding laboratory pre p blanks) FGS extracted

and analyzed for total mercury.

Table 1. Long-Term Monitoring Month 4 and 5 Mercury – Sample Identification

EPA

Sample # Lab Sample

ID # Sample

Matrix Sample Description Sampling

Date

71994 1101223-48 Aqueous FGD Influent, Set 4 1/17/2011

71998 1101223-53 Aqueous FGD Bioreactor Influent, Set 4 1/17/2011

72002 1101223-58 Aqueous FGD Bioreactor Effluent, Set 4 1/17/2011

72007 1101223-59 Aqueous FGD Bioreactor Influent Field Blank, Set 4 1/17/2011

72011 1101223-60 Aqueous FGD Bioreactor Effluent Field Blank, Set 4 1/17/2011

72044 1101308-01 Aqueous FGD Influent, Set 4 1/26/2011

72048 1101308-06 Aqueous FGD Effluent, Set 4 1/25/2011

72053 1101308-07 Aqueous FGD Effluent Field Blank, Set 4 1/25/2011

72094 1101223-41 Aqueous FGD Influent, Set 4 1/14/2011

72098 1101223-46 Aqueous FGD Effluent, Set 4 1/14/2011

72103 1101223-47 Aqueous FGD Effluent Field Blank, Set 4 1/13/2011

72144 1101223-21 Aqueous FGD Influent, Set 4 1/12/2011

72148 1101223-26 Aqueous FGD Bioreactor Influent, Set 4 1/12/2011

72152 1101223-31 Aqueous FGD Bioreactor Effluent, Set 4 1/12/2011

72157 1101223-32 Aqueous FGD Bioreactor Influent Field Blank, Set 4 1/12/2011

72161 1101223-33 Aqueous FGD Bioreactor Effluent Field Blank, Set 4 1/12/2011

72193 1101223-08 Aqueous FGD Influent, Set 3 1/12/2011

72197 1101223-13 Aqueous FGD SBR Influent, Set 3 1/12/2011

72201 1101223-18 Aqueous FGD SBR Effluent, Set 3 1/12/20112

Table 1. Long-Term Monitoring Month 4 and 5 Mercury – Sample Identification

EPA

Sample # Lab Sample

ID # Sample

Matrix Sample Description Sampling

Date

72206 1101223-19 Aqueous FGD SBR Influent Field Blank, Set 3 1/12/2011

72210 1101223-20 Aqueous FGD SBR Effluent Field Blank, Set 3 1/12/2011

72244 1101223-34 Aqueous FGD Influent, Set 4 1/12/2011

72248 1101223-39 Aqueous FGD Effluent, Set 4 1/13/2011

72253 1101223-40 Aqueous FGD Effluent Field Blank, Set 4 1/12/2011

72293 1101223-01 Aqueous FGD Influent, Set 3 1/12/2011

72297 1101223-06 Aqueous FGD Effluent, Set 3 1/12/2011

72302 1101223-07 Aqueous FGD Effluent, Field Blank, Set 3 1/12/2011

72294 1102108-01 Aqueous FGD Influent, Set 4 2/9/2011

72298 1102108-06 Aqueous FGD Effluent, Set 4 2/9/2011

72303 1102108-07 Aqueous FGD Effluent Field Blank, Set 4 2/9/2011

SUMMARY

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

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

dataset. The following summarizes the findings from the data review:

• The sample number for Sample 72157 was labeled incorrectly o n the traffic

report.

• The sample description for Sample 72148 was entered incorrec tly by FGS at the

time of sample receipt.

• Two laboratory duplicates were out of the method-suggested relative percent

difference (RPD) criteria.

SAMPLE RECEIPT, HANDLING, AND STORAGE ISSUES

Sample 72157 was labeled incorrectly as Sample 721557 in the tra ffic report submitted to

the laboratory. The error was identified and correct ed during the data review based on

the sample description. FGS incorrectly labeled Sampl e 72148 as the FGD Bioreactor

Effluent, Set 4, when the correct sample description is FGD Bioreactor Influent, Set 4.

This error was identified and corrected during the data review and confirmed based on

the traffic report.3

INITIAL CALIBRATION

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

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

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

criteria.

BLANKS

All the preparation blanks or laboratory reagent blanks (L RBs) and the continuing

calibration blanks (CCBs) met the method-specified crite ria. Because all of the blank

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

results.

DUPLICATES

No field duplicate samples were collected with these sa mpling episodes. Four samples

were analyzed in duplicate at the laboratory, Influent s amples 72144 and 71994 and

Effluent samples 72048 and 72298. The relative percent differenc e (RPD) for samples

72144, 71994, 72048, and 72298 were 30.6%, 7.66%, 19.4% and 43.9%, respectively.

Two of these RPDs were outside of laboratory criteria . The samples from another

sampling episode were also analyzed in duplicate with RPD s of 13.3%, 22.4%, and

3.03%. The laboratory’s RPD criteria between analytica l duplicates is 24%. Analytical

duplicates are not a method requirement; therefore, no samples were qualified based on

analytical duplicates.

LABORATORY CONTROL SAMPLES

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

and 24% RPD.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

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

sample 72144 and Effluent samples 72048 and 72298. MS/MSDs were also performed

on samples from another sampling episode. All aqueous MS /MSD recoveries were

within method specifications of 71-125%. All RPDs met metho d-specifiec criteria.

DETECTION LIMITS

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

were reported as not detected (ND).1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Total Metals by 200.8 – Episode 6572

and Episode 6566 (Set 4)

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

chromium, copper, lead, nickel, selenium, silver, thallium and vanadium) for Sample

Episode 6572 and long-term monitoring, set 4 samples for Episo de 6566. The samples

were analyzed according to EPA Method 200.8.

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

EPA Method 200.8.

Table 1. EPA Episode 6572 and 6566 (Set 4) – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

72044 FGD Influent, Set 4 280

- 11953

- 1 Aqueous 1/26/2011 1/27/2011

72048 FGD Effluent, Set 4 280

- 11953

- 2 Aqueous 1/26/2011 1/27/2011

72053 FGD Effluent Field Blank, Set 4 280

- 11953

- 3 Aqueous 1/26/2011 1/27/2011

72341 FGD Scrubber Purge, Set 1 280

- 11853

- 1 Aqueous 1/24/2011 1/25/2011

72342 FGD Scrubber Purge, Set 2 280

- 11893

- 3 Aqueous 1/25/2011 1/26/2011

72343 FGD Scrubber Purge, Set 3 280

- 11958

- 1 Aqueous 1/26/2011 1/27/2011

72344 FGD Scrubber Purge, Set 4 280

- 12014

- 2 Aqueous 1/27/2011 1/28/2011

72345 FGD Concentrator Distillate, Set 1 280

- 11893

- 1 Aqueous 1/25/2011 1/26/2011

72346 FGD Concentrator Distillate, Set 2 280

- 11958

- 3 Aqueous 1/26/2011 1/27/2011

72347 FGD Concentrator Distillate, Set 3 280

- 12014

- 1 Aqueous 1/27/2011 1/28/2011

72348 FGD Concentrator Distillate, Set 4 280

- 12078

- 1 Aqueous 1/28/2011 1/31/2011

72349 FGD Scrubber Purge Field Blank 280

- 11853

- 3 Aqueous 1/24/2011 1/25/2011

72350 FGD Concentrator Distillate Field

Blank, Set 1 280

- 11893

- 2 Aqueous 1/25/2011 1/26/2011

SUMMARY

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

ICP/MS SOP: Inductively Coupled Plasma Mass Spectrometry for Trace Elements2

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

EPA Method 200.8, by ICP/MS analysis.

Any significant findings are summarized below. No addition al data qualifiers were

required.

• One of the continuing calibration verifications (CCV) performed on 2/9/2011

failed the method criteria for chromium and vanadium.

INTERNAL STANDARDIZATION

All internal standards used by TestAmerica were within th e method criteria.

INITIAL CALIBRATION

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATION (IC V/CCV)

The initial calibration verifications (ICV) and CCV perf ormed by TestAmerica all had

recoveries within the method criteria, except for chrom ium and vanadium for the last

CCV performed on 2/9/2011. All chromium and vanadium resul ts associated with this

CCV were non-detects and therefore, no corrective actio n was taken. All chromium and

vanadium values reported that were associated with this CCV have been flagged with a

“^” qualifier. No additional qualifiers were required.

METHOD/INSTRUMENT BLANKS

All the method blanks were less than the reporting limit (RL). No additional qualifiers

were required for method blanks.

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

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

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

REPORTING LIMIT VERIFICATION STANDARD (CRI)

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

LABORATORY CONTROL SAMPLES (LCS)

All LCS samples passed the method QC limits of 85–115% recov ery.3

SYNTHETIC FGD INTERFERENCE CHECK SOLUTION

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

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

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

ICS.

All interference check sample B (ICSAB) synthetic sp ikes recovered within

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

SERIAL DILUTION

The serial dilution performed on sample 72345 passed TestAmer ica’s criteria of ±10%

difference.

FIELD DUPLICATES

No field duplicate samples were collected with these sa mpling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

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

72345 and 72346. All MS/MSD spike recoveries were within the me thod control limits

of 70–130% for all analytes. The relative percent differen ce (RPD) for the MS/MSDs

were within the FGD ICP/MS SOP control limits of ±20% f or all analytes. No additional

data qualifiers were required for MS/MSD samples.

POST DIGESTION SPIKES (PDS)

The post digestion spike (PDS) performed on sample 72345 pas sed TestAmerica’s

control limits of 85–115% recovery for all analytes. No a dditional data qualifiers were

required for the PDS sample.

DETECTION LIMITS

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

of reagent water.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Randy Mercurio, ERG

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Total Metals by 200.7 – Episode 6572

and Episode 6566 (Set 4)

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

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

titanium and zinc) for Sample Episode 6572 and long-term mo nitoring, set 4 samples for

Episode 6566. The samples were analyzed according to EPA Met hod 200.7.

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

EPA Method 200.7.

Table 1. EPA Episode 6572 Total Metals – Sample Identification

EPA

Sample # EPA Sample Description Lab Sample

ID # Sample

Matrix Sampling

Date Receipt

Date

7 2044 FGD Influent, Set 4 280

- 11953

- 1 Aqueous 1/26 /201 1 1/27 /201 1

7 2048 FGD Effluent, Set 4 280

- 11953

- 2 Aqueous 1/26 /201 1 1/27 /201 1

7 2053 FGD Ef

fluent Field Blank, Set 4 2 80

- 11953

- 3 Aqueous 1/26 /201 1 1/27 /201 1

72341 FGD Scrubber Purge, Set 1 280

- 11853

- 1 Aqueous 1/24 /201 1 1/25 /201 1

7 2342 FGD Scrubber Purge , Set 2 280

- 11893

- 3 Aqueous 1/25 /201 1 1/26 /201 1

7 2343 FGD Scrubber Purge, Set 3 280

- 11958

- 1 Aqueous 1/26 /201 1 1/27 /201 1

72344 FGD Scrubber Purge , Set 4 280

- 12014

- 2 Aqueous 1/27/2011 1/28/2011

7 2345 FGD Concentrator Distillate , Set 1 280

- 11893

- 1 Aqueous 1/25 /201 1 1/26 /201 1

7 2346 FGD Concentrator Distillate , Set 2 280

- 11958

- 3 Aqueous 1/26 /201 1 1/27 /201 1

72347 FGD Concentrator Distillate , Set 3 280

- 12014

- 1 Aqueous 1/27/2011 1/28/2011

72348 FGD Concentrator Distillate , Set 4 280

- 12078

- 1 Aqueous 1/28/2011 1/31/2011

7 2349 FGD Scrubber Purge Field Blank 280

- 11853

- 3 Aqueous 1/24 /201 1 1/25 /201 1

72 350 FGD Concentrator Distillate Field

Blank, Set 1 280

- 11893

- 2 Aqueous 1/25 /201 1 1/26 /201 12

SUMMARY

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

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

summarized below. No additional data qualifiers were require d.

• A serial dilution for boron for sample 72345 failed TestA merica’s requirements of

percent difference less than 10%.

• The post digestion spike (PDS) for barium for sample 72345 failed TestAmerica’s

control limits of 85-115% recovery.

SAMPLE RECEIPT, HANDLING AND STORAGE ISSUES

There were no sample receipt issues in this data package.

INTERNAL STANDARDIZATION

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

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

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

INITIAL CALIBRATION

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

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

INITIAL AND CONTINUING CALIBRATION VERIFICATIONS

The initial calibration verifications (ICV) and continu ing calibration verifications (CCV)

performed by TestAmerica all had recoveries within the m ethod criteria.

METHOD/INSTRUMENT BLANKS

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

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

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

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

flagged with the “J” qualifier.

REPORTING LIMIT VERIFICATION STANDARD (CRI)

All CRI samples passed TestAmerica’s SOP control limi ts of 50–150% recovery.3

LABORATORY CONTROL SAMPLES (LCS)

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

INTERFERENCE CHECK SOLUTIONS

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

data quality objectives met TestAmerica’s SOP criteria.

SERIAL DILUTION (SRD)

A serial dilution was performed on sample 72345 which had percen t differences less than

10% as required by TestAmerica’s SOP for all elements exce pt boron at 11%. This

boron result was flagged with a “V” qualifier. No additio nal data qualifiers were

required.

FIELD DUPLICATES

No field duplicate samples were collected with these sa mpling episodes.

MATRIX SPIKE AND MATIX SPIKE DUPLICATES (MS/MSD)

Matrix spikes (MS) and matrix spike duplicates (MSD) w ere performed on the total

samples of 72345 and 72346. All MS/MSD spike recoveries were w ithin the method

control criteria of 70-130% for all elements. The relati ve percent difference (RPD) for all

MS/MSDs were within TestAmerica’s ± 20% requirement.

POST DIGESTION SPIKE (PDS)

The PDS performed on sample 72345 passed TestAmerica’s contr ol limits of 85-115%

recovery for all analytes except barium. A qualifier wo uld have been required for this

barium result; however, barium was not detected in t his sample.

DETECTION LIMITS

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

of reagent water.1



### MEMORANDUM

To: Ron Jordan, Work Assignment Manager, EPA EAD

CC: Jezebele Alicea, Alternate Work Assignment Manager, EP A EAD

Deb Bartram, ERG

TJ Finseth, ERG

From: Ariel Atkinson, ERG

Date: 2/9/2012

Subject: TestAmerica Data Review Narrative for Classicals Ana lyses – Episode 6572

and Episode 6566 (Set 4)

TestAmerica Denver Laboratory generated analytical data for classical wet chemistry

analyses for Sample Episode 6572 and Episode 6566 (Set 4 sampl es). Samples were

tested for the following analytes:

• Ammonia by EPA method 350.1,

• Biochemical Oxygen Demand – 5 day (BOD 5 ) by SM 5210B,

• Chloride and Sulfate by EPA method 300.0,

• Chemical Oxygen Demand (COD) by EPA method 410.4,

• Cyanide (total) by SM 4500 CN

- E,

• Nitrate/Nitrite by EPA method 353.2,

• Phosphorus (total) by EPA method 365.1,

• Total Dissolved Solids (TDS) by SM 2540C,

• Total Kjeldahl Nitrogen (TKN) by EPA method 351.2, and

• Total Suspended Solids (TSS) by SM 2540D.

Table 1 summarizes the ten samples that TestAmerica a nalyzed for the above analytes.

Table 1. Long Term Monitoring Iatan Episode 6572 Classical Analytes

– Sample Identification

EPA

Sample # Sample

Matrix Sample Description Sampling

Date

72044 Water FGD Influent, Set 4 1/26/11

72048 Water FGD Effluent, Set 4 1/26/11

72341 Water FGD Scrubber Purge Set 1 1/24/11

72342 Water FGD Scrubber Purge, Set 2 1/25/11

72343 Water FGD Scrubber Purge, Set 3 1/26/11

72344 Water FGD Scrubber Purge, Set 4 1/27/11

72345 Water FGD Concentrator Distillate, Set 1 1/24/11; 1/25/11

72346 Water FGD Concentrator Distillate, Set 2 1/25/11; 1/26/11

72347 Water FGD Concentrator Distillate, Set 3 1/26/11; 1/27/11

72348 Water FGD Concentrator Distillate, Set 4 1/27/11; 1/28/112

SUMMARY

All samples were analyzed within the holding time specif ied in 40 CFR 136 Table II. All

samples were preserved appropriately. BOD analysis was not performed on sample

72348 because it was received after the hold time had expire d.

Field duplicate samples were not collected for these ep isodes. Depending on the method,

a laboratory duplicate was analyzed, instead. The Relati ve Percent Difference (RPD)

between the sample and its duplicate was less than 20% unl ess otherwise noted below.

If applicable, the appropriate number of standards was used to create a calibration curve.

If sample results were above the highest standard used t o create the curve, the sample was

diluted and reanalyzed, unless otherwise specified below. A ll sample results were

between the lowest and highest standards unless noted below. Additionally, unless

otherwise noted, all calibration blanks and calibration verification samples met the

criteria specified in the method.

If required by the method, the quality control sample (QC S), a secondary source standard

used to verify calibration, was always within the cont rol limits specified by the method

unless otherwise noted below.

As described below, the analyte of interest was detecte d above the method detection limit

(MDL) in some laboratory reagent blanks (LRB). However , the analyte of interest was

never detected above the reporting limit (RL) in the LRBs . If required by the method, all

laboratory fortified blanks (LFB) met the criteria spec ified in the method.

If required by the method, a matrix spike (MS) sample wa s analyzed on samples 72344,

72346, or 72348 for each analyte to check for matrix interfere nces. MS samples analyzed

met the criteria specified in the method unless described otherwise below.

DATA NOTES/ISSUES

Ammonia

A MS and matrix spike duplicate (MSD) were performed on sample 72346. The percent

recoveries were 130% and 127%, respectively, which are above the method specific

control limit of 90-110%. These MS/MSD results were flagg ed with a “4” qualifier

because the analyte present in the original sample is f our times greater than the matrix

spike concentration; therefore, the control limits a re not applicable. No further

qualification is necessary.

A MS and MSD were also performed using sample 72348. The percen t recoveries for the

MS and MSD were 120% and 113%, respectively, which is greater than the control

limits. Both the MS and MSD were flagged with “F” qualifie rs.3

BOD 5

TestAmerica analyzed five dilutions; the dilutions had d issolved oxygen (DO) depletions

greater than 2.0 mg/L for samples 72345, 72346, and 72347. As required in the method,

the final result was calculated by taking the average of the results for all dilutions with a

DO depletion greater than 2.0 mg/L and a final DO greater t han 1.0 mg/L.

Chloride and Sulfate

Samples 72345, 72346, 72347, and 72348 had results below the lowest calibra tion

standard. All of these samples had results that were gr eater than the MDL, but less than

the RL; therefore, the samples were flagged with a “J ” qualifier. No further qualification

is required.

COD

A MS and MSD were performed for sample 72344. The MSD perce nt recover was 80%,

which is outside the method criteria. The MSD result wa s flagged with an “F” qualifier.

No further qualification is necessary.

Sample 72348 had a result below the lowest calibration st andard, but this result was

greater than the MDL, but less than the RL and theref ore, was flagged with “J” qualifier.

No further qualification is necessary.

Cyanide

The calibration was performed using standards ranging from 0.00 ppb to 400.0 ppb. The

method states that the appropriate range of calibration standard concentrations for this

method is between 5 ppb and 20 ppb. All samples in which cy anide was detected had

results ≥ 20 ppb.

MS/MSDs were performed using samples 72344 and 72346. The percent re coveries for

the MS and the MSD for sample 72344 were 43% and 45%, respecti vely. The percent

recovery for both the MS and the MSD for sample 72346 was 88%. The percent

recoveries for both sets of MS/MSDs are below the c ontrol limit of 90% and as a result

the MS/MSDs were flagged with “F” qualifiers.

Nitrate/Nitrite

Samples 72345, 72346, 72347, and 72348 had results below the lowest calibra tion

standard. These results were greater than the MDL, but less than the RL and therefore,

the results were flagged with “J” qualifiers. No further qualification is necessary.

The data report narrative for nitrate/nitrite indicate s an incorrect sample ID (72493) as

requiring a dilution. No such sample is included in this ep isode.4

Phosphorus

The LRB results for both batches of samples had phospho rus concentrations greater than

the MDL at 0.0154 mg/L for batch 51117 and 0.0106 mg/L for batch 51477; how ever the

results were below than the RL. Therefore, the LRB r esults were flagged with “J”

qualifiers and all samples that contained the analyte were flagged with “B” qualifiers. All

calibration blank results were also above the MDL but le ss than the RL, and therefore,

were also flagged with “J” qualifiers.

Samples 72345, 72346, 72347, and 72348 had results that were lower than t he lowest

calibration standard. These results were greater than the MDL, but less than the RL and

therefore, were flagged with a “J” qualifier. No further qualifiers are needed.

TDS

Constant weight was not achieved after 3 drying cycles f or the samples. It should be

noted that the weight increased from the first weighing to the second weighing and/or

second weighing to third weighing for samples 72344, 72347, 72343, 72346, 72345, a nd

72342. Method 2540C warns that samples which contain high levels of calcium,

magnesium, chloride, and sulfate may be hygroscopic meaning they absorb moisture

from the air. The concentrations of all of these specie s may be high in these samples; and

so this was likely the cause for the inconsistent wei ght calculations. These samples were

not qualified, but results may be biased high.

The RPD for the laboratory duplicate from sample 72347 was 67%, which is greater than

the 10% control limit required by SM 2540C. The sample was not qualified, but the

duplicate was flagged with a “J” qualifier because the duplica te result was greater than

the MDL, but less than the RL.

TKN

The LRB results for batch 53496 had a TKN concentration gr eater than the MDL at 0.389

mg/L; however the results were below the RL. The LRB result was flagged with a “J”

qualifier and sample 72348 was flagged with a “B” qualifier. The initial calibration blank

results for both batches were also above the MDL but less than the RL at 0.375 mg/L for

batch 51337 and 0.378 mg/L for batch 53692, and therefore were also f lagged with “J”

qualifiers.

TestAmerica performed MS/MSD analyses on sample 72346. The percent recoveries for

the MS and MSD samples were 377% and 378%, respectively. Th e MS and the MSD did

not meet the method control limits of 90-110%, so they wer e flagged with “F” qualifiers.

No further qualification is necessary.

TSS

No issues were identified by data reviewer.